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Regulatory definition of NHS managers must include all those responsible for providing NHS services

The consultation response from the government on proposals to regulate NHS managers in England is welcome. However, the PDA reiterates the importance of including those responsible for all NHS services if patients are to be protected.

Thu 31st July 2025 The PDA

The government have responded to the consultation on proposals to regulate NHS managers, and they have committed to begin to do so through the Health Care Professions Council (HCPC). This is a welcome development; however, the PDA highlights that unless the definition of NHS managers includes those responsible for all NHS services, it will not improve patient safety in all areas.

The PDA represents more than 40,000 members, including pharmacists who practice in each part of the health system. While many thousands are employed by NHS employers, thousands more are employed by others, including many private businesses that provide NHS services, such as those who own multiple GP practices or multiple community pharmacies. In those businesses, very senior managers can make decisions that impact patient safety in tens, or even hundreds, of locations and therefore have consequences for many thousands of patients.

PDA members know that in all such environments, the manager’s influence can have a significant impact on how patients receive care. Such managers may control factors such as workload and resource allocation, deciding on systems and working practices, managing the organisation’s response to whistle-blowing and other concerns, setting and enforcing targets and much more.

The PDA has consistently stated that, in the interests of patient safety, some managers in each of these organisations should be included in the scope of regulation. Other regulators already ensure the safe practice of healthcare professionals wherever they are employed. However, for managers it seems that the government’s intention is to limit regulation to only those who are employed by the NHS.

The PDA believes that this is a mistake and calls on the government to ensure that the scope of such regulation is suitably broad. The PDA’s argument is very easily supported by the following example; NHS structures are constantly changing, even now in the early shaping of NHS England’s ten-year plan where the precise involvement of organisations from the private and third sectors is not yet clear. It is recognised that such changes may include some services transferring from NHS providers to other organisations. In such a scenario, the employer of those senior managers could change from being employed by an NHS employer to being employed by another.

It defies any sensible logic to claim that a manager needs to be regulated while employed by the NHS, but if their employer changes they would no longer need to be regulated, despite doing the same role. The PDA reiterates that it should be an individual’s potential impact on patients that determines if they should be regulated, not the name of the employer detailed in that person’s employment contract.

The PDA reiterates their call for the regulation of NHS managers to include any part of the health system where NHS services are delivered, regardless of the employer of those individuals.

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