2025-08-10 11:48:24
The Department of Health and Social Care (DHSC) has launched a consultation on proposals to regulate NHS managers https://www.gov.uk/government/consultations/leading-the-nhs-proposals-to-regulate-nhs-managers/leading-the-nhs-proposals-to-regulate-nhs-managers#policy-proposal-for-consultation
The proposals are prompted by a series of reviews into high-profile NHS scandals and failures such as Mid Staffordshire Foundation Trust which were addressed in the Francis report in 2013. A key feature of the proposals being consulted on is a requirement for NHS managers to be registered in order to strengthen accountability and regulatory oversight.
Who is a manager?
The consultation is geared to managers in the NHS, but it is not entirely clear who would be classified as a manager. The consultation paper refers to “all managers and leaders in the NHS”. This includes primary and secondary care. The consultation paper proposes that, as a minimum, the regulatory scheme should apply to:
- all board level directors in NHS organisations in England
- arm’s length body board level directors
- integrated care board members
From this, it appears that the director of a company that provides pharmaceutical services under the NHS would come within the scope of the new scheme, but the manager of an individual pharmacy may not. The consultation includes specific questions about who should be covered by the new scheme, but they are not geared to community pharmacy beyond a mention of “Managers in the independent sector delivering NHS contracts”.
The Pharmacists Defence Association has already published its view that the regulatory definition of NHS managers must include all those responsible for providing NHS services https://www.the-pda.org/regulatory-definition-of-nhs-managers-must-include-all-those-responsible-for-providing-nhs-services/ .
Dual regulation
The DHSC recognises that some managers may be healthcare professionals who are already registered, for example, in the case of pharmacists and pharmacy technicians, with the General Pharmaceutical Council. The three main options for dealing with managers who are already regulated by a healthcare regulator are:
- dual registration, where managers are required to register as a regulated manager, in addition to holding registration as a regulated healthcare professional. This would require assessment against the standards set by each of the regulators they are registered with
- broadening existing regulatory frameworks (for healthcare professionals) to include management competencies. In this scenario, managers who are already registered with a clinical regulator as part of their professional practice would not be required to register with a manager regulator, but their healthcare professional regulator would expand their existing standards to include a new set of management or leadership standards
- developing a set of mutually agreed standards between existing clinical regulators and the body responsible for regulating managers. All regulators would assess managers against those standards, while accepting that regulators are independent and have the statutory competence to set specific standards that are relevant for the professions that they regulate
There is a question in the consultation about whether individuals who are already registered with a professional regulator and who hold management and leadership positions in the NHS should be required to meet the same management and leadership standards as non-clinical managers.
What standards will be required of managers?
The DHSC’s current policy is that any standards put in place for NHS managers will cover, as a minimum, the values, behaviours and competencies that managers will be expected to demonstrate.