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Podiatry Assistants in the NHS

Discussion in 'United Kingdom' started by rosherville, Jul 16, 2011.

  1. rosherville

    rosherville Active Member


    Members do not see these Ads. Sign Up.
    Can some of you enlighten me ?

    Pod Assistants are now being sent out to do DOMs on 'at risk' patients. We know this is for cheapness, is this very common ?

    Presumably the Head of Chiropody is delegating cases rather than referring, to unregulated individuals. Does this conflict with any ethical code, SCP or HPC ?

    It`s hard to maintain that the assistants are 'supervised' in these circumstances.

    It seems we`re witnessing another stage in de-professionalisation !
     
  2. Catfoot

    Catfoot Well-Known Member

    Rosherville,
    I may have got hold of the wrong end of the stick here, but in my book "supervised" means having the supervisor in at least the same building as the person being supervised?

    I also thought that patients should be assessed as to their suitability for treatment by a Pod Assistant, so someone somewhere must have a set of criteria for this? I wonder who carries the can in the case of an untoward outcome?

    The cynic in me says that you shouldn't be too concerned about this, because, after a little while, they will be leaving the NHS to set up in practice as FHPs and advertise themselves as "NHS-trained". :D

    regards

    Catfoot

    PS. Can you actually call them Podiatry Assistants when "Podiatry" is a Protected Title ? :confused:
     
  3. Ian Drakard

    Ian Drakard Active Member

    Just to add that I don't think this is a new thing- can think of an example going back to at least 2005.

    Not that the length of time it's been happening is relevant to whether it should or not
     
  4. blinda

    blinda MVP

    I know of at least two trusts who trained their Pod Assistants in scalpel work and sent them out to treat all the dom patients, most of which were high risk (the patients that is, not the PA`s, although.....)

    The HPC are not interested as they do not regulate assistants. The SCP Codes of Conduct on supervision are not specific enough to state whether this is ethical or indeed `safe`. I wonder why? :rolleyes:

    Just my experience.

    Bel
     
  5. DAVOhorn

    DAVOhorn Well-Known Member

    Dear All,

    To my knowledge the person who refers inappropriately to an ancilliary grade is liable for that decision.

    The anciliary staff must refer back appropriately and is accountable for this.

    Auxilliary Nurses have been doing this for years.

    IMHO this is not desireable, and is a false economy.

    A relative will say afterwards WHAT DO YOU MEAN THEY ARE NOT A PODIATRIST????:craig:
    My relative is a Diabetic and i thought the person treating them was a Podiatrist.:butcher:

    Is there a difference between delegating work to an assisitant and referring?

    It will be in the notes that a trained member of staff had decided that the anciliary staff was appropriate to t/t that pt.

    So it will be resolved in a court

    David:drinks
     
  6. rosherville

    rosherville Active Member

    Is there a difference between delegating and referring ?

    Yes, a fundamental difference. When you delegate you retain responsibility, when you refer you are passing the responsibility over to another.

    If Chief Pods are passing the fundamental work of a Podiatrist over to an unregulated person it would seem they are undermining the professional standing of the Regulated Podiatrist and the Profession !

    Can you imagine a Dental Surgeon doing the same ? It would be illegal for a start, the fact that it is not illegal for it to occur in Podiatry does not mean that it should be done.
     
  7. Catfoot

    Catfoot Well-Known Member

    All,
    This paper spells it all out ,

    "Supervision, accountability and delegation of activities to support workers
    A guide for registered practitioners and support workers
    Intercollegiate information paper developed by the CSP, RCSLT, BDA and the RCN.
    This paper is a result of collaboration between different organisations and individuals. Contributions gratefully
    received from:
    RCSLT, Royal College of Speech and Language Therapists – Jenny Pigram
    BDA, British Dietetic Association – Rosemary Simpson
    RCN, Royal College of Nursing – Susan Hopkins, Jenny Brown and Helen Caulfield
    CSP, The Chartered Society of Physiotherapy – Catherine Smith and Sue Hayward Giles
    Trent RDSU University of Sheffield – Susan Nancarrow, Senior research fellow
    Supervision, accountability and delegation of activities to support workers
    A guide for registered practitioners and support workers
    Preface...............................................................................................................................2
    Introduction.......................................................................................................................4
    Understanding delegation and competence....................................................................6
    What is delegation?........................................................................................................6
    Principles of delegation..................................................................................................6
    Accountability....................................................................................................................8
    What is competence?......................................................................................................8
    Delegation and the assessment of patients/clients.......................................................9
    Deciding on delegation....................................................................................................11
    Length of service...........................................................................................................11
    Assessing competence..................................................................................................11
    Lifelong learning..........................................................................................................12
    Supervision.......................................................................................................................14
    New staff.......................................................................................................................15
    Experienced support workers.......................................................................................16
    Knowledge and Skills Framework................................................................................17
    Pay and grading............................................................................................................17
    Professional Liability Insurance....................................................................................17
    Conclusion........................................................................................................................18
    Annex 1 The national policy context driving the development of support workers..19
    Annex 2 Country specific policies driving the development of support workers........23
    Bibliography....................................................................................................................24
    References........................................................................................................................26
    SUPERVISION, ACCOUNTABILITY AND DELEGATION OF ACTIVITIES TO SUPPORT WORKERS
    JANUARY 2006
    1
    Supervision, accountability and delegation of activities to support workers
    A guide for registered practitioners and support workers
    PREFACE
    This paper has been developed by a working group of representatives from the professional bodies for the allied health professions and nursing*.
    The terminology used to describe this group of workers and their management, varies within and across professions and so for the purposes of this paper, the following terms have been used:
    Term used in this paper
    What the term covers or describes
    Support worker
    There is currently no national policy that determines a single name for this group of workers. Numerous titles exist to reflect the many and varied roles carried out and the plurality of employers.
    The titles include:
    • care assistant
    • health care assistant
    • health care support worker
    • re-ablement worker
    • rehabilitation assistant
    • rehabilitation support worker
    • rehabilitation technician
    • support worker
    * CSP, RCSLT, BDA, RCN
    SUPERVISION, ACCOUNTABILITY AND DELEGATION OF ACTIVITIES TO SUPPORT WORKERS
    JANUARY 2006
    2
    • support practitioner
    • team support worker
    • therapy assistant
    • assistant practitioner
    • assistants
    • technical instructors
    For the purposes of this paper the term ‘support worker’ describes the staff member who has a role or task delegated to them by the registered practitioner.
    Registered Practitioner
    Many terms have been used to describe the practitioner who is responsible for delegating a task. It simply means that it is a professional who is on a register for that particular profession, i.e., the Health Professions Council (HPC) or the Nursing and Midwifery Council (NMC)
    SUPERVISION, ACCOUNTABILITY AND DELEGATION OF ACTIVITIES TO SUPPORT WORKERS
    JANUARY 2006
    3
    INTRODUCTION
    The purpose of this paper is to encourage both groups of staff engaged in the delivery of healthcare to reflect collaboratively on tasks proposed for delegation, in order to ensure that clients receive safe and effective care from the most appropriate person.
    Health and Social Care in the UK is undergoing rapid change as organisations restructure the delivery of services in order to provide the most efficient and effective care to service users. A wide range of drivers has led to support worker roles growing both in terms of number and in the scope of activities being undertaken. This has prompted an increasing number of enquiries to professional bodies and trade unions about their management and support. This paper has therefore been developed to help clarify the delegation process for registered practitioners and support workers and the associated issues of accountability and supervision.
    Research and anecdotal evidence shows that support workers throughout the UK can be working at relatively simple or a very wide range of levels of practice as a result of delegation1 2. This variance is broadly explained by two associated factors:
    • the decision as to which activities are appropriate to delegate lies solely with the registered practitioner, who is responsible for delegating work to the support worker; and,
    • there is no specific guidance regarding which activities can or cannot be delegated.
    Professional bodies have collaborated to provide more comprehensive and detailed guidance in this area. The aim of this intercollegiate paper is to enable each discipline to learn from the experience of others. It prevents duplication and promotes a shared approach to support the delivery of health and social care groups from multi-disciplinary teams, rather than from uni-professional services. It aims to prevent confusion in these teams by collaboration at a national level that is driven by local practice.
    The issue of delegating tasks to support staff is increasing in significance, following the current consultation on the registration and regulation of this group.
    The paper is for:
    • individuals who manage support workers either through line management or by providing clinical support
    4
    • support workers
    • any registered practitioner or manager who delegates an activity or role
    • service managers
    • individuals who deliver services from a multi-disciplinary team that has a mix of registered and non registered workers
    • all settings where registered practitioners are called upon to delegate tasks to support workers – education, social service, NHS, independent sector etc.

    5
    UNDERSTANDING DELEGATION AND COMPETENCE
    What is delegation?
    In this context delegation is the process by which a registered practitioner can allocate work to a support worker who is deemed competent to undertake that task. This worker then carries the responsibility for that task.
    There is a distinction between delegation, and assignment. In the former case the support worker is responsible while the registered practitioner retains accountability. The latter case both the responsibility and accountability for an activity passes from one individual to the other3.
    Choosing tasks or roles to be undertaken by support staff is actually a complex professional activity; it depends on the registered practitioner’s professional opinion. For any particular task, there are no general rules. Additionally it is important to consider the competence of the support worker in relation to the activity to be delegated.
    Principles of delegation
    The registered practitioner must ensure that delegation is appropriate. The following principles should apply:
    • the primary motivation for delegation is to serve the interests of the patient/client
    • the registered practitioner undertakes appropriate assessment, planning, implementation and evaluation of the delegated role
    • the person to whom the task is delegated must have the appropriate role, level of experience and competence to carry it out
    • registered practitioners must not delegate tasks and responsibilities to colleagues that are beyond their level of skill and experience
    • the support worker should undertake training to ensure competency in carrying out any tasks required. This training should be provided by the employer
    • the task to be delegated is discussed and if both the practitioner and support worker feel confident, the support worker can then carry out the delegated work/task
    • the level of supervision and feedback provided is appropriate to the task being delegated. This will be based on the recorded knowledge and competence of the

    6
    support worker, the needs of the patient/client, the service setting and the tasks assigned
    • regular supervision time is agreed and adhered to
    • in multi-professional settings, supervision arrangements will vary and depend on the number of disciplines in the team and the line management structures of the registered practitioners
    • the organisational structure has well defined lines of accountability and support workers are clear about their own accountability
    • the support worker shares responsibility for raising any issues in supervision and may initiate discussion or request additional information and/or support
    • the support worker will be expected to make decisions within the context of a set of goals /care plan which have been negotiated with the patient/client and the health care team
    • the support worker must be aware of the extent of his/her expertise at all times and seek support from available sources, when appropriate
    • documentation is completed by the appropriate person and within employers’ protocols and professional standards4.
    SUPERVISION, ACCOUNTABILITY AND DELEGATION OF ACTIVITIES TO SUPPORT WORKERS
    JANUARY 2006
    7
    ACCOUNTABILITY
    Like other public bodies, the health service providers are accountable to both the criminal and civil courts to ensure that their activities conform to legal requirements. In addition, employees are accountable to their employer to follow their contract of duty. Registered practitioners are also accountable to regulatory and professional bodies in terms of standards of practice and patient care. At present, support workers are not subject to professional registration5 6.
    When delegating work to others, registered practitioners have a legal responsibility to have determined the knowledge and skill level required to perform the delegated task. The registered practitioner is accountable for delegating the task and the support worker is accountable for accepting the delegated task, as well as being responsible for his/her actions in carrying it out. This is true if the support worker has the skills, knowledge and judgement to perform the delegation, and that the delegation of task falls within the guidelines and protocols of the workplace, and the level of supervision and feedback is appropriate7.
    What is competence?
    There are two key questions to be answered when considering delegation
    of activities.
    1. Does the registered practitioner view the support worker competent to carry out the tasks?
    2. Does the support worker feel competent to perform the activity?
    Competence is an individual’s ability to effectively apply knowledge, understanding, skills and values within a designated scope of practice. It is evidenced in practice by the effective performance of the specific role and its related responsibilities. Competence also involves individuals in critical reflection about, and modification of, their practice. Capability is a step further than competence and relates to the individual’s full range of potential and may go beyond their current scope of practice.
    The following summary may help to clarify related terms and their meanings:
    Term
    Basic meaning
    Competence
    General, overall capacity; holistic; rests on consensus view of what forms good practice

    8
    Competency
    Specific ability that makes up competence
    Competencies
    Abilities to undertake specific tasks that relate to specific ability.
    Capability
    Potential competence
    Performance
    Competence in action
    (Taken from the Physiotherapy Competence & Capability resource pack 2005)8
    Continuing professional development underpins delegation and competence. Individuals and employing organisations need to consider both immediate needs (related to current responsibilities and competence) and longer-term needs (related to future responsibilities and capability) when considering staff development needs.
    Delegation and the assessment of patients/clients
    The initial assessment is likely to be diagnostic (relies on clinical reasoning) requiring the assessor (registered practitioner), to determine a programme of treatment or care. It is expected therefore; that it will be a registered practitioner who makes the clinical diagnosis, analyses and interprets assessment results, and generates possible therapeutic options in discussion with the patient/client.
    The support worker will, however, be expected to make decisions within the context of designated work with a patient/client, whilst working towards the aims set by the registered practitioner. This may mean that support staff working at more advanced levels (e.g. assistant practitioner) are able to plan and implement a therapy/ treatment programme or care plan within the scope of their skills and training – reporting to the registered practitioner for re-direction and advice, as necessary.
    The assessment process should be a continuing element of the overall therapy programme/treatment plan. Support workers may therefore be able to judge the patient/client progress and make some treatment decisions based on that judgement, assess and re-assess the patient/client’s progress. It is expected that a support worker who is delegated a task will be competent to continually monitor and evaluate changes in the patient/client’s responses and to feedback relevant information to the registered practitioner(s).
    In some instances, where a clear protocol has been produced or a specific client group in a particular environment, the support worker may have delegated discretion,

    9
    alongside limited and defined autonomy for some elements of continual assessment. It is essential that the role and specific activities of the support worker are made explicit, in the design of such protocols.
    REMEMBER Any support worker to whom a task has been delegated should be appropriately trained and supported to ensure that the activity can be undertaken competently.

    10
    DECIDING ON DELEGATION
    The question of who should carry out which activity depends on a number of factors. The three central elements involve:
    • the individual’s skills, competence, attitudes and experience of the health care provider(s)
    • the requirements of the patient/client group; and
    • the nature of the task in the specific circumstance.
    The latter point also encompasses the particular setting e.g. hospital, community and so on.
    Delegation of activity is determined in the context of the relationship that exists between the person who delegates and the person to whom some aspect of practice is delegated. A number of factors have been identified that are significant for those who delegate tasks when deciding on whether to pass a duty on to a support worker.
    Length of service
    A support worker with a long service might reasonably be assumed to have developed substantial understanding of practice through their day-to-day experience. On the basis of this assumed relationship they could be argued to be better able to take on delegated activities in a competent fashion. Previous work experience in other roles can be equally relevant.
    Long service does not, however, necessarily lead to the development of competence. Similarly, simply undertaking a programme of education cannot be seen as indicative of competence. Conversely some individuals can become extremely competent after working for only a short time in a particular area of practice. These issues are the same whether the individual is a registered practitioner or a support worker. It is important, therefore, to assess the competence of individuals within the specific workplace setting. Consequently it is essential for registered practitioners to have the necessary skills to effectively carry out thee assessments.
    Assessing competence
    When assessing competence, the registered practitioner should have an awareness and knowledge of the education, training and qualifications the support has undertaken. It is important to know whether the support worker has competently performed particular tasks in the past. The practitioner also needs to be confident

    11
    that the tasks will be performed competently in the future. If, however, the support worker has not carried out the specific activities before, this indicates that there is a training need prior to delegation taking place.
    One of the many ways in which competence is assessed in the health and social care sector (and in other occupational areas) is through the award of National/Scottish Vocational Qualifications (N/SVQ).∗ N/SVQ’s are national awards that acknowledge an individual’s work-based skills. They are based upon National Occupational Standards (NOS), which describe practical performance in the workplace. They allow individuals to demonstrate their competence by applying knowledge, understanding and skills to perform to the standards required in employment. The formalised structure of the N/SVQ may therefore provide useful support when considering the issues of competence and delegation. The advantages of these qualifications are as follows:
    • encouragement of close working relationships between registered and support staff
    • a formal assessment of practical competence across the whole range of support activity undertaken in the workplace
    • Encouragement for support workers to develop knowledge that underpins the practical aspects of their work, and
    • Development of transferable and recognisable knowledge and skills.
    If the support worker does not have access to an N/SVQ, competence can be assessed using NOS. These standards (some of which are used to form the basis of an NVQ) are stand-alone competencies that can be used for various purposes by anyone from a consultant physician to a support worker. Potential uses include:
    • to define job roles and write job descriptions
    • to design training programmes
    • in annual staff appraisals to identify progress towards development goals
    • to assess competence against a given standard.
    Lifelong learning
    In the delivery of any patient/client service, it is essential that those who are in the front line should be adequately prepared to carry out the tasks expected of them. Users have the right to expect that those who deliver the service are competent to do so. In the field of health and social care, the government is working to ensure that
    ∗ This is one example of the many learning and development opportunities now available for support workers.

    12
    this is the case, through its encouragement of continuing professional development (CPD) and lifelong learning (LLL). This can be supported by the following strategies:
    • appropriate induction and training are for working in a multidisciplinary setting, including information about relevant policies
    • planned orientation, induction and support programme for newly employed support workers
    • system of monitoring support worker ability through performance review, appraisal and personal development planning
    • systematic approach to the training and development of support workers
    • support worker should have access to continuing development opportunities (e.g. N/SVQ, BTEC, local in-service training programmes, foundation degrees and others relevant to the job)
    • where specialist skills are required, training is provided and updated
    • the service should be able to demonstrate that support workers keep clinically up-to-date (e.g. participation in personal development planning and monitoring, membership of Special Interest Groups, clinical supervision).

    13
    SUPERVISION
    The registered practitioner is responsible for designing a supervision system that protects the patient/client and maintains the highest possible standards of care. On-going supervision is used to assess the support worker’s ability to perform the delegated task and capability to take on additional roles and responsibilities. It is normally expected that a named supervisor is provided.
    The following should apply:
    • there should be a system in place for support workers to access supervision and clinical advice as required
    • regular supervision time is agreed between the registered practitioner and the support worker and a record is made of each session
    • the registered practitioner must have the necessary skills to support and assess the supervisee
    • the support worker shares responsibility for raising issues in supervision and may initiate discussion or request additional information/support
    • when the registered practitioner is absent from a setting where the support worker is working, there is an identified contact in case of query or emergency.
    Supervision can vary in terms of what it covers. It may incorporate elements of direction, guidance, observation, joint working, discussion, exchange of ideas and co-ordination of activities. It may be direct or indirect, according to the nature of the work being delegated. The decision concerning the amount and type of supervision required by a support worker is based on the registered practitioner’s judgement and is determined by the recorded knowledge and competence of the support worker, the needs of the patient/client, the service setting, and the delegated tasks. Factors to be considered by the registered practitioner therefore include:
    • the level of experience and understanding of the support worker relevant to the task being delegated
    • assessment of the support worker’s competence relevant to the delegated task
    • the complexity of the delegated tasks (i.e. whether the delegated task is a routine activity with predictable outcomes)
    • the stability and predictability of the patient/client’s health status

    JANUARY 2006
    14
    • the environment or setting in which the delegated task is to be performed and the support infrastructure available (e.g. whether working in a community, acute or school setting)
    • availability of and access to support from an appropriate registered professional
    • periodic review of the patient/client’s outcomes
    • an identified process for periodic review and evaluation of the support worker’s performance
    • an identified process for recording and reporting.
    Supervision and appraisal have a key role to play in:
    • supporting the development of individuals in line with personal need and service requirements
    • ensuring consistency and quality in the delivery of services
    • ensuring the ongoing development of the profession
    • helping individuals to meet statutory obligations
    • ensuring clarity about roles and expectations e.g. delegating tasks to support workers.
    Appraisal in the workplace, particularly where this process is linked to assessing personal development needs, provides a useful means by which both manager and individual members of staff can identify training needs, define learning outcomes, and decide on what sort of learning activity is the most appropriate. In terms of general guidance, however, the following observations apply:
    New staff
    There should be a planned orientation, induction and support programme for newly employed support workers. They will need to be introduced to both the generalities of care provision (for example the need to ensure that quality and equality is central to practice) and the specifics of the work they will be asked to do.
    The following are some routes (taken from the National Support Worker Framework)9
    Formally – the N/SVQ Level II in Clinical Support might be appropriate. The newly developed Foundation Degree might also be an appropriate formal programme of education for these workers.
    15
    In-house programme – needs to be designed to address both the tasks being delegated and to encourage an awareness of the environment in which the staff work.
    Informal learning – i.e. observation, when adequately assessed and accurately recorded in an individual’s portfolio, can be used in induction, although a defined programme of input, observation and supervised practice represents the best combination at this stage.
    Examples:
    Formally – the N/SVQ Level III Allied Health Professions Support might be appropriate. Similarly, the BTEC/EdExcel Professional Development Qualification operates at the same level, but is a more classroom-based programme.
    In-house programme – needs to equip staff with, the essential knowledge and practical skills required to undertake duties safely and effectively. Wherever possible, services should work with their local education provider to develop an educationally sound programme that can attract accreditation.
    Informal learning – needs to be carefully managed. Measurable learning outcomes need to be agreed, and the activities (such as work shadowing or self-supported learning) need to be carefully planned.
    Experienced support workers
    Experienced support workers need to have their lifelong learning needs assessed and met in the same way as registered practitioners need their continuing professional development needs assessed.
    Keeping support workers up to date, in terms of the activity that they undertake, is important for both those staff, the professional staff that delegate activity to them, and to the clients with whom they work.
    Examples:
    Formally – suitably targeted short courses.
    In-house programme – wherever possible, two types of in-service training should be offered: departmental, where all staff are involved; and specific, where training is designed solely for those working as support workers.
    16
    Informal learning – is very important but it should be structured. Moreover, it must be recorded, so staff need to be equipped with the skills required to maintain an effective portfolio.
    Knowledge and Skills Framework
    In the NHS, the Knowledge and Skills Framework (KSF) represents the staff development element of Agenda for Change (AfC)10. It is concerned with identifying the relevant competency levels required for job roles with the NHS.
    The KSF is used, as a tool for individual review and development. This is an ongoing cycle of review, planning, development and evaluation, similar to appraisal, and is linked to organisational and individual development needs. In order for this cycle to take place, a KSF post outline needs to be developed for every post using the KSF dimensions that apply to and which identifies the level at which the post holder is required to work. Each support worker working within the NHS will have a post outline that shows where they are at in terms of meeting the requirements of the full post outline for their post. This will provide evidence to the delegating practitioner of the skills and knowledge that the support worker is applying competently within their current role.
    Pay and grading
    This paper recognises that many support workers across the UK are working at quite sophisticated levels of practice, and acknowledges the contribution that this staff group makes to the delivery of service.
    It is important to remember that employers have an obligation to ensure that all posts are appropriately banded.
    Professional Liability Insurance
    It is highly likely that the employer provides this insurance through vicarious liability. All insurance related issues should be clarified before the support worker starts working.

    17
    CONCLUSION
    A great deal of hands-on care is now being delivered by support workers. It is essential, therefore, to bear in mind that, while support workers are not registered staff, they must be trained and preferably qualified to a national standard. The connection between staff development and quality of service is now at the centre of the government’s view of the new NHS.
    Importantly, patients/clients have the right to know who is treating them and expect that those who provide their care are knowledgeable and competent; support workers need to feel confident of their abilities in this new and changing environment; and registered practitioners need to feel confident in delegating activities to their support workers.
    January 2006
    SUPERVISION, ACCOUNTABILITY AND DELEGATION OF ACTIVITIES TO SUPPORT WORKERS
    JANUARY 2006"


    regards Catfoot
     
  8. davidh

    davidh Podiatry Arena Veteran

    Unfortunately, the doc contains a "get out of jail free" card, in the shape of the wording which describes the doc as a guide.
     
  9. dgroberts

    dgroberts Active Member

    You can be "At Risk" or even "High Risk" and still only require the very simplest of nail care.

    As a Podiatrist would you be happy doing 15 dom visits in a day and just cutting non pathological nails, never once reaching for your scalpel?

    It depends on your referring criteria and robustness of your policy/procedures as to how "safe" that is.
     
  10. This remains an area which will damage Footcare Assistants, because if they refuse to treat someone who has been referred to them because they are High Risk, they will face heavy criticism from Management for not fulfilling their work-quota. On the other hand, if they complete a treatment which then causes dissatisfaction and complaint, they are likewise in trouble for that. For their own well-being Footcare Assistants need to stick rigidly to the rules prescribed to them, and refuse those patients wrongly assigned. They are too vulnerable to cost-cutting exercises, and too valuable to be taken advantage of.
     
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