The General Regulatory
Council for Complementary Therapies
Business and Operational
Plan
Prepared by: Barry ‘BJ’ Tanner
Project Manager
Date: October 2007
CONTENTS
Section 1 Introduction
Section 2 Vision
Section 3
Section 4 Values
Section 5 Context of the GRCCT
Section 6 Structure of the GRCCT
Section 7 Registration Fees
Section 8 Stakeholders
Section 9 Legal structure of GRCCT
Section 10 Staffing the GRCCT
Section 11 Office Accommodation
Section 12 Communication
Section 13 Financial Management
Section 14 Taxation
Section 15 IT Hardware and Software
Section 16 Databases
Section 17 Risk Assessment and Review
Section 18 Public
& Profession Awareness
Section 19 Equality
and Diversity
Section 20 Operational
Projections Year 1
Appendix A Office Operational Cost
Projections – 01.10.07 to
01.10.08
Appendix B Council Operational Cost
Projections – 01.10.07 to
01.10.08
1. Introduction
This Business and Operational Plan has been
developed from the original Business Plan of the General Regulatory Council for
Complementary Therapists (GRCCT) to give a more comprehensive overview of the
current and proposed operations and strategies of the GRCCT
2. Vision
The regulation of complementary
therapists in the
3.
The GRCCT continues to deliver a robust and functional
form of regulation that is sufficiently strong in concept as to be effective,
whist remaining sufficiently flexible as to be responsive to the needs of the
public and the professions.
4. Values
i. Professionalism,
credibility, transparency and accountability
ii. Respect
for equality and diversity
iii. Commitment
to delivering services of the highest quality
iv. Responsiveness
to stakeholders
5. Context of
the GRCCT
The concept of a federal regulator for
complementary therapies was originally muted in 1987. The structure at that
time was represented as a pyramid with therapists feeding into associations,
associations into boards and the boards contributing to an overarching
regulatory board. It was quickly
determined that although the concept was sound the individual professions were
not at that time sufficiently developed in terms of agreed standards for
education and practice for any form of voluntary regulation to operate regulation
effectively.
Thirteen years later in 2000 and largely due to the
involvement of The Prince of Wales Foundation for Integrated Medicine (FIM),
now called the Prince’s Foundation for Integrated Health (PFIH), the
professions were again invited to come together in therapy groups and form a
Lead Body for each therapy. These Lead
Bodies had the enormous task of developing the documents, procedures and
practices necessary to be recognised as a single therapy Voluntary Self
Regulator (VSR).
Over the next six years the major professions such
as Aromatherapy, Massage, Reiki and Reflexology, Homeopathy, Nutrition and
others, achieved the tasks appropriate to becoming a single VSR for their
individual professions. During this time the horrendous actions perpetrated by
Dr Harold Shipman served to focus government attention on the regulation of healthcare
professionals; both those regulated by statute such as Doctors and Nurses and
those to be voluntarily regulated such as complementary therapists.
In 2005, the Prince’s Foundation for Integrated
Health commissioned Julie Stone to write a report on the best way forward for
regulation of complementary therapies. It looked at the pros and cons of
statutory regulation versus voluntary self-regulation and again the concept of
a federal system of regulation was mentioned. Following this, a consultation with
the profession took place over 3 month period in 2006 and the Foundation’s
independent analyst decided it had a mandate to investigate a federal regulator
further. The White Paper “Trust, Assurance and Safety – The Regulation of
Health Professionals in the 21st Century”, published in February 2007 outlined
the governments thoughts on how regulation should be structured.
With the provision of £900,000 of Department of
Health grant funding in August 2005, the Prince’s Foundation for Integrated Health
began inviting therapy groups to consider how a federal regulatory structure
might operate through a federal working group (FWG). This work started in
January 2007 and was due to be complete by September 2007, with a launch date
for a federal regulator for March 2008.
Despite warnings from some of the larger therapy
groups that the time-scale was too short; the number of profession
representatives too small, and that some therapy groups were not sufficiently
mature in their development, the FWG was established with a remit to make universally
supported proposals for the voluntary regulation of complementary healthcare
professions. By August 2007 the process
had become largely unfit for purpose with refusals by the FWG Independent Lay
Chair to consider models for regulation supported by very large sections of the
industry. There were also concerns over the administration of the process. The expression of these concerns resulted in three
of the major therapy groups being excluded from the FWG. This caused an outcry
from those professions at not being heard or having the chance for a fair
hearing.
As a result of this action by the FWG and with the
support of major sections of the
6. Structure
of the GRCCT
7. Registration Fees
The fees paid by registrants for admission to the
National Register are the GRCCT’s primary income source. It relies entirely on
this income to function. From each registration fee £3 is allocated to support
the Front Line Regulator for each of the therapies in which the registrant is
admitted. This fee will help pay for travelling costs of the board members for
that profession on the GRCCT and their daily allowance fees.
The Registration Fee is £30 for admission of a
single therapy listing on the National Register with a further payment of £5
per additional therapy. This reflects the
GRCCT premise that regulation should be affordable to the practitioner whilst
at the same time maintain the financial integrity required to be sustainable.
8.
Stakeholders
Applications for Stakeholder status will be
considered against a criterion defined by the Regulatory Council at a meeting to
be held in February 2008. It is envisaged that applications for Stakeholder
status will be invited from:
Therapy groups not yet
regulated by the GRCCT
Healthcare providers e.g.
Doctors, Nurses, Specialists, Specialist Units
Public representative
bodies e.g. Patient groups
Private Healthcare
providers e.g. BUPA, AXA/PPP Healthcare, Pru Health
Regulators in related
fields
9. Legal
structure of the GRCCT
The
General Regulatory Council for Complementary Therapies is to be constituted as
a ‘Company Limited by Guarantee’. The
Council is a non-profit making organisation.
The
word ‘council’ is considered in the registration of companies to be ‘sensitive’
and as such the GRCCT has made application to seek approval for use of the word
in the company title. This process will be concluded before the inaugural
meeting in December 2007 at which point the Federal Regulatory Council will
formally consider additions or changes to the Memorandum or Articles of the
company.
10. Staffing
the GRCCT
In accordance with The Phase 1 Operations Plan the
GRCCT is currently staffed by a Project Manager and two temporary members of
staff supplier by Reid Employment. This structure provides the financial
flexibility required during the initial phase.
It is envisaged that the staffing will move to two
permanent staff in Phase 2. However the number of staff and the areas of
responsibility will be decided by the GRCCT Board with the advantage of hours
and costs data from Phase 1
11. Office Accommodations
The GRCCT is registered at an accommodation address
in Hampshire. The service provider is licensed by Royal Mail and carries
appropriate insurance. Mail is forwarded under secure cover and there are no
limitations of size or volume. The use of an accommodation address provides
continuity for the Register and means that the office address remains constant
as the GRCCT expands and changes physical operational location.
The physical location of operation is currently a
single serviced office in London EC1. This location has been chosen because is
it easily accessible by the project manager. All systems and operational
practices are electronic and designed to be easily transportable.
12. Communication
The GRCCT communication structure uses
state-of-the-art technology to provide a highly effective and heavily logged
communication system.
Telephone
Telephone calls to the
GRCCT use a National Rate number thus not discriminating on a cost basis
against individuals calling from different parts of the country. The system
automatically logs a range of details on each received call including, date,
time, duration, number called from (if available). This logged information can be tagged to the
Registrants file. Similar data is recorded for outgoing calls with the Project
Manager (in Phase 1) receiving automatic email notification of calls made or
received from specific numbers or calls over a specified duration.
Fax
Fax reception is via a
National Rate number thus not discriminating on a cost basis against
individuals calling from different parts of the country. Similar data to that
of telephone conversations is automatically logged with the addition of an
electronic copy of the received or transmitted fax being stored with the other
data.
Email
In Phase 1 of operation,
the GRCCT has limited its email addresses to departmental rather than person
specific. This permits easier
assimilation of ongoing operational data in regard to volume and nature of
communication. The system has the facility to facilitate and log communication
on up to 1000 individual email addresses.
Post
Incoming post is logged in
and then scanned onto the system. It is physically destroyed after three backup
cycles. Incoming and outgoing correspondence can be tagged to an individual
registrants file.
From a compliance perspective this system provides
a strong audit trail. The integrated nature of the system also serves as a
solid evidence platform when dealing with complaints.
13. Financial management
Daily financial management in the conduct of GRCCT
business is the responsibility in Phase 1 of the Project Manager and in Phase 2
of the Registrar. In both cases the
process is audited and overseen by the registered bookkeepers, Kerwick &
Co. Ltd. Should the company turnover exceed £5.8m there will be a requirement
for additional external audit. This will be undertaken by the retained
accountancy firm Baker Tilly
14. Taxation
Income Tax (PAYE)
The GRCCT will need to
register for income tax (PAYE) needed to make payments of income tax (paid to
employees and designated Board members) and employer’s and employees’ National
Insurance contributions. This action will take place in advance of Phase 2
Value Added Tax (VAT)
This is a very complex
area. The GRCCT has been advised that on the basis of our current status as a
non-profit company operating in the field of regulation it may not be a
requirement to undertake registration for Value Added Tax. This advice is
currently under investigation and the operational projection has been structured
with a provision for VAT in place.
15. IT Hardware and Software
The GRCCT operates a bespoke integrated software
package. This software links communication (email, fax, telephone and written),
registration and payment into a single audit trail. The system is run on a virtual server which
means that data is available in real-time but is not stored on laptops, office
PCs or physical servers. The inherent risks of physical theft are thus removed.
The remote access is via a high-end firewall and anti-virus software.
This system uses many of the same baseline
protocols and is similar in infrastructure to the highly successful system used
by Transport for
System access controls are separately logged and a
report produced for the system administrator on a daily basis. Set access
ceilings are in place with automatic shut-down.
If there is a sudden or unexpected increase in the number or frequency
of access attempts the system shuts down until reactivated by input of the
correct administrator code.
The GRCCT has in place 24/7/365 support contracts
with website hosts and software providers.
The GRCCT Security Policy for IT Use and the Health
and Safety Policy are on display in our office and are given to each member of
staff on their first day of employment or on commencement of contract.
16. Databases
Data Security
·
The GRCCT uses a ‘bunkered’ data backup system which is widely
acknowledged as the most secure commercially available service. The system
features include:
·
Fully automated.
·
Onsite encryption ensures that no data is transmitted from the source in
an unencrypted state.
·
Capable of performing a full system restore (‘Bare Metal’ Back up).
·
After initial Data is securely in place, only incremental changes are
stored thereafter.
·
Data stored in one of the most secure locations in the Western World, an
ex-NATO Bunker 100ft underground
·
Mirrored 7 times using RAID 5 technology
·
£1m non-restoration guarantee
Compliance
The GRCCT Privacy Policy is
displayed on the website. GRCCT must comply with the Data Protection Act 1998,
and has applied for registration.
17. Risk
Assessment and Review
The GRCCT Risk Assessment table is detailed below.
This risk assessment is subject to review and comparison against the
achievement indicators defined by the GRCCT Board
|
Risk |
Impact |
Likeli- hood |
Mitigation |
Residual risk |
|
Too few practitioners apply for admission to the
National Register |
High |
Med-Low |
Good communication with Professional
Associations. Pro-active awareness campaign |
Med |
|
GRCCT ‘brand’ is not well known or lacks
credibility |
High |
Med |
Credibility of supporting PA’s is high. Good
media relationship. Public awareness using Hampton Response Technique |
High-Med |
|
GRCCT staff may leave during first year of
operation |
Med |
Low |
Operations system is highly automated and clearly
documented. Procedures Manual reviewed monthly |
Med-Low |
|
Small staff team means that GRCCT falls behind
with essential business administration duties |
Med |
Low |
Level of system automation, simplicity of
structure and proven administrative capabilities of those involved. |
Med-Low |
|
Competitive models promoted to public |
Med |
Med |
GRCCT already in existence and already receiving
industry support. FWG model has many areas of weakness which can be
highlighted in a media campaign. Practitioners will choose their preferred
model. The most effective and affordable
system will survive |
Med |
|
Loss of IT hardware/data |
Critical |
Low |
Bunkered and encrypted data backup. Virtual
server, anti-virus protection, hardware firewall. |
Low |
|
Changes in governmental requirements for
regulation in the voluntary sector |
High |
Low |
Communication with applicable government
departments. Contextual awareness and promotion of applicable
European Law |
Low |
18. Public and
Profession Awareness
The existing GRCCT Public Awareness and
Communications strategy is based on the premise that the professional
associations are the best vehicle through which to communicate with individual
practitioners. Most practitioners act on
advice and recommendation provided by their professional association. It is to be remembered that this is a process
of public and professional awareness, NOT a product marketing campaign.
The strategy operates under two objective
statements:
1.
The practitioner needs to receive well-researched, valid and up-to-date
information on the subject of regulation to enable them to make an informed
decision as to how appropriate regulation may meet their needs and the needs of
their profession.
2.
Professional associations are historically the guardians of the
therapies; as such it is appropriate that where possible, public awareness
announcements and media statements acknowledge the contribution of these
associations in the development of The General Regulatory Council for
Complementary Therapies.
The Public Awareness Campaign, to be conducted
through various media including TV, Radio, Newspaper, Magazine and Internet; is
awaiting approval of the GRRCT Board meeting in December 2007. Subject to
approval this campaign will commence in January 2008 with the broadcast of an
interview already recorded.
19. Equality
and Diversity
As one of the corner stones in any transparent
process, the GRCCT takes full account of legislative direction and
recommendation in the field of Equality and Diversity. The GRCCT Equality and Diversity Policy and
Procedures Manual is a reference tool for good practise for both the management
and staff. It is the responsibility of
the Registrar to ensure that this manual is annually reviewed.
20. Financial
projections
Set-up and year one costs for the GRCCT were
projected at £138,844 (see Appendix A). Regulatory Council operational costs
are £13,500 (see Appendix B). These calculations are based on the regulation of
appropriately six mature therapy groups (already committed or considering
commitment).
Month one figures for income and expenditure are in
line with the operational projection.
Operational Cost Projections – 01.10.07 to 01.10.08
Office Costs
Appendix A
|
Office costs
(Year 1): |
|
|
|
|
|
|
Staff Costs: |
|
|
|
|
|
|
|
Registrar (part-time) |
|
£5,000 |
|
|
|
|
Support staff
(two FT) |
£48,500 |
|
|
|
|
|
|
|
£54,000 |
|
|
|
|
NI/pension/staff
benefits |
|
£10,900 |
|
£64,900 |
|
|
|
|
|
|
|
|
Serviced and
Virtual Offices |
|
£8,000 |
|
|
|
|
Telephone |
|
£2,000 |
|
|
|
|
Printing |
|
£2,700 |
|
|
|
|
Postage |
|
||||