Since the development of the First Contact Practitioner (FCP) role in 2014, when they were primarily Musculoskeletal (MSK) FCPs, the FCP role has evolved significantly. Within general practice, there are paramedics, physiotherapists, dietitians, podiatrists and occupational therapists all working in FCP roles, some of which are funded through the Additional Roles Reimbursement Scheme (ARRS). So new roles, and new ways of working.

Of course, part of the Long Term Plan (LTP) for primary care was to develop a team with diverse skills to work PCN wide. But with that comes responsibility. FCPs can work across the PCN and, as the soul singer Lisa McClendon once sang, “need some accountability”. The question that’s often been asked is ‘who is accountable for the FCPs; is it the PCN as the employer or the practice where they’re working?’ Who has accountability?

Maybe, in fact, there’s more than one question that needs to be asked; perhaps there are three! Firstly, ‘who is the employer?’, secondly, ‘who is accountable for the FCPs?’, and thirdly, ‘who provides assurance that only fit and proper persons are employed?’. Is it just me or is anyone else now thinking of The Who’s song, ‘Who are You’? Just me… OK, I’ll move on…

So, let’s start with the employer; you’d think that would be simple, wouldn’t you? Surely, if the FCP is employed by the PCN, then they are the employer. Well, yes, technically they are; however, life is never that simple. Cue the Health and Social Care Act 2008 (Regulated Activities) 2014 Regulations. Not only does ‘employed’ mean staff who have a contract of employment, but it also means anyone working for ‘a provider’, under their direction and control. Confused? You’re not alone! Simply put, if a FCP is employed by the PCN and they work at all member practices, then each individual member practice will be employing that FCP for the time they work at the individual member practice.

Now bearing this in mind, each member practice (or provider) will be accountable for the FCP whilst they’re providing a service on behalf of that provider, irrespective of the fact that the FCP is employed by the PCN. But could it be argued that accountability should be joint, between the PCN and the provider – surely, that’s a logical conclusion? In my humble opinion, it’s certainly feasible. Sadly, though, it isn’t that straightforward. With accountability comes the need for assurance as opposed to assumption (you know what they say about assumption, right?).

It’s down to each individual provider to seek assurance that the FCP has had the prerequisite recruitment checks. You can’t assume that as the FCP is employed by another organisation, be it a PCN or another practice, that the necessary checks have been completed. Why? Well, if something goes wrong, would you suddenly become George Ezra and start singing ‘Blame it on me’. No, me neither! Remember, you must be fully assured that the FCP is ‘fit and proper’ and you must be able to answer the ‘Who are You?’ question with ease.

Already it seems as if there’s a lot to do and I haven’t yet explained how you seek the necessary assurances, what you need to do from a supervisory perspective, or about the training pathways for FCPs in primary care. Fear not, this is covered in ‘A guide to employing first contact practitioners’, which includes a service level agreement template for recruitment checks.

But perhaps what is crucial is understanding how we can satisfy the CQC. We all know the answer, don’t we? Evidence is key, if we’re to satisfy the CQC! The CQC will want to see evidence (or assurance) that FCPs have completed Stage 1 of the Roadmap to Practice, with a plan for completing Stage 2 if not already completed. Furthermore, as stated in GP mythbuster 106: Primary care first contact practitioners (FCPs), the CQC will want to see:

• That staff are recruited appropriately
• That staff are operating within the limits of their scope of practice
• That staff have the necessary information to carry out their role effectively
• That staff receive ongoing supervision
• Evidence that the provider has assurance of safe recruitment practice

As Albert Einstein once said, “Assumptions are made, and most assumptions are wrong.” It’s down to you, as the provider, to ensure that only fit and proper persons are ‘employed’, and you need assurance to do that. That assurance comes in the form of, but is not limited to, professional registration, DBS checks, references and qualifications. Never assume these checks have been completed. FCPs need some accountability.