The term ‘Independent Practitioner’ encompasses all members of the Society of Radiographers (SoR) who are healthcare practitioners (whether registered with a regulatory body or not) and who are not directly classed as employees. Some members may combine work as both an independent practitioner and as an employee of, for example, an NHS trust.
Recent years have seen major changes to the organisation of the health service in England with services being commissioned from a range of providers, not just NHS trusts. For some of our members the commissioning changes may provide opportunities to establish an independent business and/or work as an independent practitioner. This was recognised in a motion to the 2013 Annual Delegates Conference (ADC) calling on the SoR to publish guidance helping members 'to develop appropriate business models to become successful service providers.'
The full text of the motion was: “The new world of GP commissioning in England brings challenges and possible new opportunities for individual radiographers who may wish to maximise these business changes. As services move away from traditional NHS providers, members will need support to develop the skills required to maximise potential opportunities.
"Members should be supported to develop appropriate business models to become successful service providers. Our members will require new skills and access to information to enable them to take up these opportunities or someone else will leap in to the market gap.
"Conference calls upon UK Council to investigate and publish guidance on maximising opportunities for radiographers within GP commissioning and service provision, and support members in identifying how to plan for their futures, including access to information and support on the impact on their NHS pension.”
The following provides members with the additional information they need to consider when setting up their own businesses. It includes guidance on professional matters, employment matters (including pensions), legal and insurance matters and will provide links to various websites that may help them in the business decision making process.
In December 2014 the Royal College of Radiologists published a document jointly with the SCoR entitled Standards for the Provision of an Ultrasound Service. The document contains information relevant to independent practitioners.
The SCoR also publishes jointly with the British Medical Ultrasound Society Guidelines for Professional Ultrasound Practice for sonographer members. This is updated each December. There is a section (2.16) on independent practice. The great majority of independent practitioners are sonographers, although the information within section 2.16 will be of relevance to those independent members providing services in other modalities. There is also much other information within the document; for example advice on clinical governance, obtaining consent and image storage timescales.
NHS Business Partners
If you are a healthcare provider from the independent or third sectors and would like advice and support from the NHS Business Partners programme on integrating with the NHS systems and applications, please click here.
Care Quality Commission (CQC), England
Since 1 October 2010, all independent providers in England are potentially required to register with the Care Quality Commission. This is a legal requirement, although there are some exemptions. Independent sonographers and radiographers are advised to visit the Care Quality Commission website.
The most recent edition of The Scope of Registration (March 2015) can also be downloaded from the CQC website. Registration does not apply to employees, only to the legal entity (whether this is an individual, partnership or organisation) that provides the service.
Please note that CQC registration applies to England only. There are equivalent bodies to the CQC in Scotland, Wales and Northern Ireland and members in the above categories are advised to make enquiries with them as to whether there are plans to register diagnostic, therapy or screening services as in England. There may be cross border issues if practising in Scotland or Wales but also providing independent diagnostic, screening or therapy services in England, and advice should be sought from the CQC if you believe you fall into this category. If you are in any doubt the SoR advice is to contact the CQC, as the onus is on the provider of services to register.
There is, however, a very wide variety of ways in which services are delivered by providers; the CQC may not be able to advise in advance as to whether registration is required in every case and may request that the application form is completed so that a full assessment can then be made.
Scotland, Wales, Northern Ireland
Web links to the regulators in the other UK countries are indicated below. Members are advised to make enquiries with them as to whether there are plans to register independent diagnostic, therapy or screening services as with the CQC in England.
Scotland: Healthcare Improvement Scotland and Care Inspectorate.
Scotland has published legal requirements on the registration of independent clinics. The wording is very specific. This SoR news story explains.
Wales: Health Inspectorate Wales
Northern Ireland: Regulatory and Quality Improvement Authority
3D/4D 'souvenir’ scanning in obstetrics (England)
he Care Quality Commission in 2012 stated that 3D/4D ‘souvenir’ scans in obstetrics for non-clinical reasons were included in the Scope of Registration. This was re-confirmed in 2016.
NHS Mobile Working Knowledge Centre
The potential benefits for mobile working in healthcare are considerable and well-publicised. Significant challenges exist, however, in developing the right strategies and delivering successful programmes to achieve the return on investment. This Knowledge Centre brings together good practice, tools and experience to provide support and guidance for those initiating and implementing mobile working programmes and projects.
Any Qualified Provider (AQP) (England)
From March 2014 onwards, the decision to extend choice of providers and establish services as ‘AQP’, along with the qualifications of providers to do so, has rested entirely with Clinical Commissioning Groups. All such services will be posted by commissioners on the new contracts finder website, type ‘AQP’ into the search function box. For example, there are AQP contracts advertised from time to time for non-obstetric ultrasound or MRI services.
Independent providers will need to meet the complex requirements of AQP commissioned services. Competition is based on quality and not price; all providers will be paid the same for a particular service. There are fee enhancements for Market Forces Factors as well as for quality and innovation. The full commissioning documents will need to be consulted for context. Further details of fees payable to AQP providers can be found within the NHSE National Tariff.
See also NHS Standard Contract 2017/18 and 2018/19 Technical Guidance.
There are some essential qualification criteria to which providers must abide:
- Agree to terms of NHS Standard Contract
- Be NHS e-referral service compliant (see below)
- Have an NHS Provider (Monitor) licence if required (see below)
- Be accepted as meeting the requirements to apply to be an AQP Provider
- Be CQC registered
NHS e-referral service
Previously known as ‘Choose and Book’, the NHS e-referral service (e-RS) combines electronic booking with a choice of place, date and time for first hospital or clinic appointments. Patients can choose their initial hospital or clinic appointment, book it in the GP surgery, or later at home on the phone or on-line. Independent providers may need to link into the e-referral service.
NHS Provider Licence
Independent providers of NHS services are advised that there may be a requirement to hold an NHS Provider (Monitor) licence.
Providers are exempt if their annual applicable turnover from the provision of NHS services is less than £10 million but there can be other factors affecting this such as if services are specifically designated by commissioners to require an NHS Provider licence to be held. Providers are advised to make their own enquiries with clinical commissioning groups with which they hold contracts as the rules are complex. These regulations apply in England.
Professional Indemnity Insurance
Click for details of the Society's PII.
The Health and Care Professions Council have PLI advice for independent practitioners.
The Quality Standard for Imaging (QSI) - (formerly ISAS)
All providers of ultrasound services are encouraged to align their services to the Quality Standard for Imaging, (jointly owned and developed by the Royal College of Radiologists and the College of Radiographers) and to have their services independently assessed by the United Kingdom Accreditation Service (UKAS) against that standard.
QSI accreditation provides strong and independent confirmation that high quality services are being delivered. Details on the Quality Standard and how to apply to apply for accreditation can be found on the RCR and SCoR websites.
QSI is recognised by the Care Quality Commission and has been approved for use within CQC hospital inspection methodology.
UKAS are regularly recruit assessors from all areas of imaging. Please make contact if you are interested.
For further information on aspects of independent practice go to the document downloads below.
If more Health and Safety information is required in addition to the download below, go to the Health and Safety Executive website.