CET exceptions policy

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Closes 8 Jul 2021

Proposed updates to the policy

In this section we outline the proposed updates to the policy.

Shift in focus from registrant circumstances to public protection

We have updated the policy to shift the focus from the registrant’s circumstances to the GOC’s overriding objective of public protection so that it more clearly demonstrates our focus on public protection. This is because there may be circumstances where the registrant’s circumstances are truly exceptional in nature, but their CET shortfall is so significant that it would not be in the public interest to retain them on the register, and we wanted to be clearer about this. The amendments include:

  • a change of name to ‘CET exceptions policy’ to focus attention to the exception to CET rather than the exceptionality of the circumstances of the registrant;
  • revised introductory paragraphs to emphasise public protection; and
  • removing the list of exceptional circumstances, instead giving examples of case studies based on actual cases (see section 5).

Transparency in decision-making process

We have also updated the list of factors to be taken into account by the Registrar, which we think will increase transparency around our decision-making process (see section 4.2). We have expanded the application form to cover these factors, which will make it easier for potential applicants to provide us with all the information that will be considered by the Registrar and for us to process applications (see the annex).

Maternity, paternity and adoption leave

Since the current policy was introduced, we have taken account of the number of applications that involved maternity, paternity and adoption leave, and have addressed this in more detail (see section 4.3), setting out our minimum expectations in this area (e.g. the equivalent of at least one point per month that they have been on the register during the cycle and not on maternity, paternity or adoption leave). We consider that these expectations balance fairness to the registrant against public protection.

Restrictions around ability to practise

The current policy restricted consideration of exceptional circumstances to those which had resulted in the registrant being unable to practise. We consider that this aspect of the policy was unnecessarily restrictive and instead of it being an absolute requirement, the fact of whether or not a registrant could work during the exceptional circumstances is now one of the factors to be considered, rather than the focus. Part of the reason for this is that it could be argued that a registrant who is working is more likely to be maintaining their skills and keeping up to date by virtue of them practising, even if they are not completing CET at the same time. We consider that this amendment is fairer to the registrant while maintaining focus on public protection.

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