Any proposals that reduce the stress and time for all parties involved in the fitness to practise process are definitely at the top of our regulatory reform 'to do' list. But this should not result in a reduction in public protection, fairness and transparency. The consultation puts forward a new approach for how regulators deal with concerns about their registrants: accepted outcomes. But unlike the current system where there is an in-built independent safety check on regulators' final fitness to practise decisions, and a power to appeal decisions insufficient to protect the public, there is no such proposal in the consultation. 

Our independent power to double-check fitness to practise decisions was borne out of inquiries into regulatory failings in the early 2000s. The consultation could be taking a step backwards in public protection if there is no independent oversight of decisions made using accepted outcomes. This will make the regulator the investigator, judge, jury and appeal. 

Instead of a system to independently review final decisions made using accepted outcomes, the proposal is that patients/the public will have to request a review via the regulator's registrar if they are unhappy with the result. This puts the burden of public protection on the shoulders of the people regulation is meant to serve. This system also loses all the additional benefits that our independent oversight brings to regulation, including creating case law, clarifying the process and providing a rich source of data which can help identify patterns and themes across the regulators and lead to improvements in the process.