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FIH Federal Approach

For a multi therapy approach to VSR

 

RRWG letter to PFIH

October 2007

 

20 October 2007
[By email and by mail]

Kim Lavely
Chief Executive PFIH
Professor Dame Joan Higgins
Chair FWG
The Prince's Foundation for Integrated Health
33-41 Dallington Street
London EC1V 0BB

Dear Kim and Joan

Following an emergency meeting of the Reiki Regulatory Working Group (RRWG), I am writing to you to inform you of our position following this meeting. At the meeting The Reiki Regulatory Working Group confirmed it is united in its response, which is detailed below.

Having reviewed the Federal Working Group Progress Report of October 2007 [PDF, 60kb] the Reiki Regulatory Working Group has a number of concerns which we would very much welcome discussing and exploring further. We do feel that consultative engagement on these points could ensure a positive outcome. The organisations of the RRWG would welcome the opportunity to return to the Federal Working Group (FWG) to enable the Reiki profession to participate in the remaining planned meetings. This is a result that we trust is achievable.

In the interests of achieving an effective and efficient “light touch” and appropriate model for voluntary self regulation of the CAM professions within a Federal structure, we have detailed our concerns below.

The role of the Regulator

  • We believe the Regulator should have an overriding duty to regulate the practitioners, but not the practices or therapies themselves, e.g. such as the teaching of Reiki in its many diverse forms
  • We believe it is vital, as stated in the October Report, that the “Standing Orders will make it clear that the Regulator cannot make unilateral changes to standards of practice, education and training, and must consult the professions when any changes are envisaged”. We would therefore like to see a regulatory structure that supports this

The role of the Professional Advisory Panel (PAP)

  • We believe that there should be an obligation for the Federal Regulatory Council (FRC) to respond to and take action following the advice of the Professional Advisory Panel (PAP). Therefore, to safeguard professional integrity, the PAP should be a part of the regulatory structure and not, as suggested, be funded by professional forums.
  • We propose that the dotted line between the FRC and PAP on the diagram of the organizational structure becomes a solid two-way line
  • We uphold the following examples of effective governance models currently in existence: The Financial Services Practitioner Panel, The Food Standards Agency Consumer Panel (the Board has responsibility to publicly respond to the Panel’s advice and concerns) and the Ofcom consumer panel.

Education

  • We believe the licensing of teachers or schools should not reside with the Regulator but with each profession
  • We believe the accreditation of Reiki courses should not reside with the Regulator and propose the Profession Specific Boards (PSB) have a duty to advise the Council on Reiki Practitioner courses that meet the practitioner curriculum that is currently being developed by the RRWG and the National Occupational Standards (NOS) for Reiki.
  • We would like to seek further clarification on the role and remit of the Education, Training, QA and Standards Board Standing Committee

Registration and Validation of Evidence

  • We believe that there should be a Standing Committee for the Registration and Validation of Evidence Board to support the Registrar

Recruitment of staff and Council members

  • We welcome the original commitment to an independent recruitment process to be made by an external appointments board as discussed at Meeting 4 on 25 April 2007
  • We believe that current PFIH-appointed lay chairs and members would not be the best people for this job but would instead propose a new Appointment Council nominated in line with Nolan principles and regulation by the Office of the Commissioner for Public Appointments

Governance

  • We fully support the various White Papers and recommendation of a robust regulatory system from the Better Regulation Commission support the principle of 50:50 lay:professional membership on the Regulatory Body. Though robust, this model reduces unnecessary regulatory and administrative burdens, ensuring that regulation and its enforcement are proportionate to the risk, accountable, consistent and transparent. “Success will be achieved if the proposed measures deliver a net reduction in administrative costs and a real tangible decrease in regulatory burdens . . . allowing voluntary organisations to thrive without bureaucracy”. The RRWG asks for this recommendation to be reflected in all levels of the federal governance structure. Better Regulation Commission, http://www.brc.gov.uk; Royal Pharmaceutical Society of Great Britain, Regulation White Paper, February 2007; Regulation of Non Medical Healthcare Professions DH Review: Trust, Assurance and Safety – The Regulation of Health Professionals in the 21st Century.

Transparency of decision-making

  • We would welcome clarification on the Executive and Management decision-making process. We would see it an example of best practice to demonstrate accountability and build confidence with stakeholders involved in this process

Administration

  • We would welcome clarification of the role and structure of the Registrar’s Office, including where this role will appear in the regulatory structure.

We ask in particular that the following view is considered. The current professional forums are lead bodies with all the profession-specific expertise within them. Therefore, the RRWG is of the view that these lead bodies should carry the regulatory responsibility and become part of the regulatory body, ie the PSBs. When the regulator needs profession-specific advice for its registrants, it should be required to come to the group that has guardianship of that therapeutic and/or spiritual practice. For example the Reiki Regulatory Working Group would become the PSB for Reiki. Once the professional forum became the PSB, it is accepted that to differentiate between representation and regulation, it should not be sponsored by professional associations.

In order that the RRWG may demonstrate its continued commitment to develop a voluntary self regulation model which is appropriate to all professions, we look forward to maintaining a positive and constructive contribution through our elected representatives in this important debate. In this respect, the RRWG looks forward to your positive response prior to the next Federal Working Group meeting on 30 October in order that our representative may attend.

Please note that this letter replaces the RRWG’s response to the feedback to the FWG Progress Report.

Yours sincerely

Anthony Perry
Chair, Reiki Regulatory Working Group


For more details visit the Reiki Regulatory Working Group web site

Bristol - South West Gloucestershire - U.K.

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