The SIA of Healthcare and then some...
Paul Steward
Founder and Managing Director of Platinum Oak. Health-Wealth Management and discreet medical provision. Experienced Leader and Innovator in global healthcare delivery.
It is always slightly tricky when addressing a situation that could challenge the status quo and gently highlight the not insignificant phrase: "...must be registered with us otherwise they commit an offence.".
Within the security industry in England, particularly executive and close protection and all that entails, there has very rightly been an evolution towards securing what we might term "Health-Wealth Management". That most important of assets, one's own health and wellbeing, should absolutely be at the forefront of consideration, planning and preparation. That progress, and it is to be lauded as progress without doubt, has potentially exposed another (unexpected/unintended) vulnerability.
IS YOUR PROTECTIVE HEALTHCARE PROVISION CQC REGISTERED?
The Security Industry Authority (SIA) is, no matter one's view on it, a familiar and known entity. They manage the regulation of security professionals as individuals and, where such organisations volunteer, of the Approved Contractor Scheme (ACS). Nobody is going to be engaging security staff who aren't registered-it's illegal.
When it comes to Healthcare provision, however, not only does a Registered Healthcare Professional (HCP) have to be registered with their appropriate body (Health Care Professions Council (HCPC) for Paramedics, Nursing and Midwifery Council (NMC) for Nurses and Midwives, and the General Medical Council (GMC) for Doctors) but there is a requirement for anyone carrying out regulated healthcare activities to be registered as well - with the Care Quality Commission (CQC). Now, that may be the individual if solo or it may be the organisation if they are being offered or deployed under the entity of a Limited Company for example.
This is where there may be an "Oh, $#!* moment..." creeping in. If you are a company (or other entity) offering a Close Protection Paramedic within your services then this is where the big scary paragraph pops up:
Take a breath...
Grab a cuppa (contents unjudged and unmonitored!) and maybe carry on reading....
WHAT IS A REGULATED ACTIVITY?
There are a fair few, so please do go and look in more depth, but the ones most likely to be relevant with Executive/Close Protection or UHNW (Ultra-High-Net-Worth) individuals could include:
Treatment of disease, disorder or injury; Diagnostic and screening procedures; Transport services, triage and medical advice provided remotely; Nursing care; and Personal care.
This is probably a good juncture to add that there are certain exemptions, such as "Medical practitioners in independent practice" HOWEVER - the big 'must know' here is that this exemption specifically does not include any treatment or assessment done outside of a consulting room, which also means they are not covered for telephone advice or video/email consultation if they are not registered with the CQC. It also precludes administering intravenous medicines even if they are in their consulting room. So, have acute pain requiring morphine in their room and they're still calling 999 for an ambulance to treat you fully.
There are also contextual exemptions, including cultural or sporting events. This is why a purely Event Medical Provider does not need to be registered to cover a football match or a carnival. They would however need to registered if they convey patients off-site in an ambulance. Confused yet? Indeed.
领英推è
SHADES OF GREY - and not the fun kind...
Where there is some slight greyness is the threshold at which a 'medic' exceeds first aid. That said, within the First Aid exception, it does state "non-healthcare professionals who are trained to deliver such treatment." So, it is my personal feeling that a reasonable approach would include a primary security professional who has been trained to say FREC3, FPOS-International or RTACC standard delivering anything within that syllabus (subject to appropriate insurances, etc., and agreement with whomever is deploying them).
Whether or not a primary 'medic' engagement of an Ambulance Technician ('Tech')/ Associate Ambulance Practitioner (AAP) would still be able to claim the 'first aid' exception is not so clearly discerned. I think certainly at the point one is making the choice to engage or offer a 'medic' then there may be some interesting perspectives on whether 'First Aid' can be claimed. It doesn't say "non-REGISTERED healthcare professionals...", in which case the boundary might easily be seen as Paramedic, Nurse, Doctor - not exempt, AAP/ECA exempt. It says (as below) "non-healthcare professionals...).
It is worth noting that the middle phrase "healthcare professionals in unexpected or potentially dangerous situations requiring immediate action" leans towards coming across a life-threatening emergency for example, or being at the site of some form of attack. This is not likely to succeed contact when intentionally employed/engaged/deployed as a planned resource. It also still only covers First Aid provided, not the whole spectrum of diagnostics and treatment, which would need registering anyway.
These issues are ones that I am being asked about more and more, which is reassuring as it means people are becoming more switched on to the potential exposure as an organisation, company or provider.
As with anything, I thought it might be helpful to offer at least a starting point once you've finished your cup of whatever saw you through....
WHAT SHOULD YOU NOT DO NEXT?
Dismiss all of your healthcare provision on the spot in a blind panic
WHAT SHOULD YOU DO NEXT?
1) Add this to your risk register so you can log that you have become aware of and are working on it.
2) Assess whether you have, or may be likely to have, any provision within your arc that falls in to this area. If you provide a Paramedic then it's a no-contest first tick in the box. If you provide a 'medic' then maybe put some time aside to properly process and assess this.
3) If you are not a provider of healthcare services at all (including a CP Paramedic - self employed or otherwise) but you engage them, your next step is to determine whether they fall in scope of requiring registration. Then ask them if they are registered.
The caveat I place with all of this is to make sure you seek out good advice, read and understand the legislation and don't reach for the bucket of sand in to which you will insert your head. The events industry is under greater scrutiny due to providers flexing the exemptions, and with Martyn's Law (The Protect Duty) in everyone's orbit there will be greater focus on wider providers of security and healthcare services. I'm sure of it.
Personal protection officer, paramedic, registered nurse, coastguard rescue officer 30 year career as a police officer, continuing 25 year career in the military reserves. Educator, IQA and assessor
2 年As always my challenge would be ‘are you a CPO who happens to be a paramedic or are you a paramedic who has a CP license as well? Material obligations to attend to patients first as a duty will obviously detract from the role of the CPO who should be providing security for the principal. Does it at that point become an ‘event’ or ‘temporary provision’ which there are then exemptions claimed. Is there a Doctor in the provision who then become the focal point and the paramedic becomes a medical first responder who will signpost (which indeed their recce will hopefully include) and so it becomes a first aid provision. Honestly think that the CQC will flip their flop and will do the same as event provision and steer away. However, with Martyn’s Law, there is this an incumbency to demand regulation of the event medical industry, and I’ve got to say rightly so. I will always go back to the original argument of ‘define ‘CP paramedic’ …… enjoy the conversation ????
Rescue and Medical, Security, Safety
2 å¹´a good read and highlights some common misconceptions and loophole usage or abuse
Paul, a well written short article, I'm sure it will produce some discussion from Close Protection providers and event security companies. Following on from the Manchester arena report recommendations, I do hope the CQC actually has the appetite to regulate the event industry.
A really informative post highlighting some key points. If it helps - the CQC clearly define a “healthcare professional†as a person registered with a specific list of bodies. As you highlight, the HCPC and NMC are included on this list. AAPs and technicians are not in this list and so fall outside of the scope of registration. I think your point around the inclusion of a paramedic within a team indicates a pre-planned need for care (emergency or not) is incredibly important. A few providers have been caught out by this recently.