Under the provisions of the Health and Social Care Professionals Act 2005, the Health and Social care Professionals Council (the Council) is an independent statutory body and is responsible for setting the level of fees.
The Council has set the following fee structure:
- A registration fee of €295 for existing practitioners and a fee of €100 for new graduates who have obtained recognised professional qualifications within two years of applying for registration;
- An annual retention fee of €295 for registrants, including those who paid the lower rate on graduation, is payable on the annual renewal date. There is a two-year transitional period from the date on which the register of the members of that profession is established, during which existing practitioners may apply for registration.
I am conscious that these fees are a new cost to health and social care professionals who have already seen reductions in their incomes. However, health regulators are self funding by way of annual fee income with operational costs being determined by the complexity and breadth of statutory functions specified in its legislation. The greater the registrant base the lower the annual fee charged. Given the enormous registrant base in teaching and nursing, for example, the annual fee charged amounts to less than €100 per annum. In general, health regulators are single profession regulators whereas the Council is charged with regulating twelve disparate professions, which can add significantly to operating costs. The twelve designated professions to be registered by the Council range in number from under 50 Clinical Biochemists to 5,550 Social Care Workers, amounting to about 20,000 registrants in total across all professions. This is an extremely low registrant base when compared to a registrant base of well in excess of 60,000 for nurses.
The Council has extensive statutory functions under the 2005 Act, and considers the annual fee of €295 the minimum required to enable it to operate. The fee charged by the Council, which takes account of the requirement to become self funding as soon as possible, is on a par with that charged by other health regulators and less than some in certain cases. The State is currently part-funding the Council in its establishment phase (€1.5 million in 2012) to offset the current shortfall in income from registration fees and will continue to do so for the next 3 years.
In response to concerns about the level of fees, the Council has reviewed the regulatory structure to establish what scope exists for controlling registration fees and operational costs and has adopted the following measures:
- Where existing practitioners with the necessary experience and recognised professional qualifications, or equivalent, pay the application fee of €295 and are granted registration during the transitional period, the application fee will cover them for the remainder of the transitional period and one full year of retention of registration after expiration of the two year period. This concession will apply only to existing practitioners availing of the transitional provisions set out in the Act,
- The Council has entered into discussions with the HSE in regard to the feasibility of arrangements for deduction of the registration fee from monthly salary, thereby spreading the cost throughout the year,
- Finally, the Council has proposed significant restructuring of the way in which the designated professions will be registered and regulated to provide a more cost effective operating system and to keep costs to a minimum. This will require the enactment of primary legislation in due course.
