Consultation outcome

Allowing NHS ambulance services to carry out driving tests for their staff: response to consultation

Updated 11 October 2021

Executive Summary

The Department for Transport (DfT) in conjunction with the Driver and Vehicle Standards Agency (DVSA) sought views on the Department’s proposals to:

• permit NHS ambulance services to engage in delegated driver testing
• allow the emergency services and Ministry of Defence (MoD) to conduct tests for one another

The overall reaction to the proposals was very positive. Ministers have taken into consideration all the comments made.

To implement the proposals will require amendments to regulations and we will seek to do this as soon as possible.

List of questions

About you or your organisation

1. Who are you?

DVSA needs to be able to analyse responses according to who gave them. This question asks the respondent about their interest in this matter.

Delegated testing for NHS ambulance services

2. Do you agree that NHS ambulance services should be able to be authorised to conduct driving tests?

Police and fire services are already able to conduct driving tests on their own employees. However, the NHS ambulance services are not permitted to do so. This question asks about extending provisions for delegated testing to allow NHS ambulance services to conduct driving tests for people they propose to employ as drivers.

3. Do you think there is any road safety issue or risk attached to the proposal to allow NHS ambulance services to conduct delegated tests?

Road safety is a key consideration for DVSA, and we would not wish to make a change if there was evidence that safety would be compromised.

4. Do you have any general comments on the proposal to allow NHS ambulance services to conduct delegated tests?

This is an open question in order to capture any other issues or comments about this proposal. It is followed by a series of questions that are specific to the NHS ambulance services and how they might approach delegated testing.

Questions for representatives of NHS ambulance services

5. Would delegated testing benefit your organisation and would you be likely to seek approval?

DVSA wants to establish how many of the NHS ambulance services might engage with delegated testing.

6. Having gained approval to conduct practical tests would you also want to conduct theory tests?

Arrangements for theory testing are slightly different to those for conducting practical tests. Approval to conduct theory tests can only be granted once a service has a delegated practical examiner in place. DVSA would like to know how many of the NHS ambulance services might seek approval to conduct theory tests.

7. How many driving tests do you think you might conduct each year?

There are rules around the minimum number of driving tests and examiner must conduct each year. This question also helps DVSA to understand the operational impact on its own test centres.

Cross testing

8. Do you agree, or disagree, that the emergency services and Ministry of Defence should be able to test for each other?

This question relates to the second proposal and checks the level of support for the introduction of ‘cross testing’ among the emergency services and Ministry of Defence.

9. Do you agree that this proposal will assist in easing driver recruitment pressures caused by the coronavirus pandemic and provide additional resilience?

DVSA thinks that this proposal will assist in maintaining driver supply and also offer a contingency measure should the pandemic cause further issues with testing. This question checks if that is generally thought to be the case.

10. Do you see any issues with the proposal for cross-testing?

A general question before specific questions for the emergency services about how they might respond to this proposal if it is implemented.

Questions for delegated test authorities and potential NHS test authorities

11. Which other services do you think you might cross-test for? For example, services that are the same type as yours or services in the same region as yours?

DVSA would like to know how cross-testing, if permitted, might be organised.

12. Do you think that cross-testing arrangements would be fairly informal, or fixed?

DVSA wants to understand whether cross-testing arrangements might be quite permanent or temporary, ‘pop-up’, arrangements.

13. Do you think that cross-testing would result in national re-structuring of driver testing by the emergency services?

This question asks about the likely longer-term impact of this proposal.

14. Do you agree that DVSA should have to approve cross-testing arrangements?

If introduced it is intended that DVSA will approve arrangements before cross-testing can take place. This question checks if the delegated examiners are content with that part of the proposal.

15. Fee and other arrangements to be agreed between the respective parties. Do you have any comments?

DVSA intends to allow delegated examiners that engage in cross-testing to make the operational arrangements between themselves- provided that the standard of the test and key procedures are upheld. This question checks that delegated examiners are content with this part of the proposal.

Introduction

On 16 July 2021, DVSA published an online consultation on amendments to the law concerning delegated driver testing. The consultation ran until 14 August.

The consultation set out the Government’s proposals to change rules around delegated driver testing. Delegated testing is where organisations are allowed to conduct the driving test for their own employees. It is used to ensure that these organisations can maintain a good supply of drivers and can organise their test programmes in line with the training that new recruits undertake.

Police and fire services can already be approved to appoint delegated examiners. However, delegated testing is not available to the NHS ambulance services. This consultation sought views on including the NHS ambulance services in the arrangements for delegated examining.

Currently the regulations around conducting delegated tests are quite rigid. Each approved service can only conduct tests for their own employees and people who will become drivers for them when they pass the test. DVSA sought views on lifting this restriction for the emergency services. Such ‘cross-testing’ will allow the various services to co-operate in their approach towards testing. It could add resilience and provide contingency solutions in the face of issues such as the Coronavirus pandemic.

Finally, the Ministry of Defence (MoD) conduct their own driving tests on military personnel. They have expressed an interest in being included in provisions for ‘cross-testing’, as described above.

General observations

78 responses were received via the online consultation, and one by e-mail.

This consultation was of limited interest to the general public, with only 8 responses from people who classified themselves as such. It was aimed at key stakeholders in the emergency services. The following table shows how respondents classified themselves.

Occupation	Responses
Member of the public	8
Trainer of examiner at a delegated authority	12
Representative of an NHS ambulance service	45
Representative of an police or fire service	9
Other	4

Among the representative organisations that provided comments were those from several NHS ambulance services, including heads of driver training and recruitment teams, and from police and fire services.

In particular the Chairperson for the Driver Training Advisory Group (DTAG) for UK ambulance services said that each Trust was ‘fully supportive’ of both proposals. He explained that delegated testing would give Trusts the ability to plan and programme their driver recruitment knowing that timely testing could be arranged, without the influence of external factors. He suggested that the proposal for cross-testing would:

‘provide a level of resilience never before seen in the emergency services providing an additional layer of assurance to the public that services are being actively protected.’

Chairperson for the Driver Training Advisory Group (DTAG) for UK ambulance services

We wouldn’t expect the MoD to respond to a public consultation, but we know from our contacts with them that they support this proposal.

Ministers would like to thank everyone who contributed to this consultation.

Disclosure of information

As part of the consultation, DVSA said that, unless the respondents made clear that their responses were to be treated as confidential, at the end of the consultation period, it would publish some of the responses.

This report quotes comments only from respondents who have not requested confidentiality. However, the statistical analysis takes account of all the on-line replies.

Allowing NHS ambulance services to carry out driving tests for their staff

Question 2. Do you agree that NHS ambulance services should be able to be authorised to conduct driving tests?

Under this proposal the NHS ambulance services who employ drivers of ambulances and paramedics, will be able to apply to conduct driving tests for such staff.

This will mean that they can arrange test appointments internally and in line with when the candidate completes their training.

94% of respondents agreed with this proposal. 6% disagreed. None ‘neither agreed nor disagreed’. The overwhelming support for this proposal was underlined with comments such as:

‘… allowing the NHS Ambulance Services to conduct delegated driving tests will greatly improve our success rate and recruitment process’

Representative of an ambulance service

‘This would massively help our paramedics’

Representative of an ambulance service

‘If the NHS were allowed to do delegated driving tests, it would save them money and give greater control over the progress of each learner’

Driver trainer at an ambulance service

‘At a time like this it is crucial we are able to process these applicants in a timely manor therefore this would be really beneficial’

Representative of an ambulance service

‘.. one of my roles is to organise C1 tests during our onboarding process. One of the main issues we are currently seeing is a delay in Theory and Hazard Perception tests and with the practical training and test. If we were able to undertake these tests in house this would enable us to omit the delays we are currently seeing. This would also be cheaper to the Trust, meaning funds would be able to be spent elsewhere’

Works in recruitment at an ambulance service

There were only 5 people who disagreed with the proposal. One disagreed because they think that delegated testing is subject to commercial pressures. However, we do not believe that this is likely to be the case with the emergency services.

Another said that they felt that the rules should be the same across all the emergency services. Yet bringing the NHS ambulances services into delegated testing will mean that they are treated the same as Police and Fire Services.

A third asked what would prevent a lowering of test standards in order to recruit staff.

The answer to this is that delegated examiners complete the same training as DVSA examiners and are subject to supervisory checks and professional development.

DVSA regards NHS driver training staff as being extremely professional and has full confidence in them. We have no reason to think that this professionalism wouldn’t be applied to any testing arrangements.

Ambulance drivers and paramedics go on to receive enhanced driver training and are placed in charge of valuable equipment and perform a vital public service. It is therefore very unlikely that the standard of the licence acquisition test will be undermined by this proposal.

Question 3. Do you think there is any road safety issue or risk attached to the proposal to allow NHS ambulance services to conduct delegated tests?

85% of respondents felt that there would be no road safety issue with this proposal. A further 9% indicated that they weren’t sure. 6% (5 respondents) said that they thought that there would be an issue with road safety.

The people who had disagreed with the proposal were largely the same ones who said that there would be a road safety issue. Three gave no comment here, another mentioned commercial pressures and another suggested that supervisory checks should be more frequent.

Those who said that they didn’t think that there would be a road safety issue talked about the quality of training for ‘blue light’ drivers. Comments included:

‘Our NHS ambulance trust already conducts high speed emergency response assessments as part of a dedicated driver training unit, so this is relatively less risk’

Representative of an ambulance service

‘The Emergency services have well trained and qualified individuals who deliver emergency driver training at a high level. Their expertise should ensure that only suitably competent drivers are passed to drive C1 vehicles on the road’

Representative of an ambulance service

Question 4. Do you have any general comments on the proposal to allow NHS ambulance services to conduct delegated tests?

The next question simply asked for other comments. The responses underlined the support for this proposal with comments such as:

‘As a Fire Service, we would benefit from working with our neighbouring ambulance service to save money and for resilience purposes. Throughout the pandemic we could have provided better collaboration, in addition to Theory/Hazard Perception Testing, resulting in improved efficiency and service to the public. As a service we look to work smarter and more efficiently and this proposal would undoubtedly support this approach’.

Representative of a police or fire delegated testing service

‘COVID has severely impacted on testing availability for C1 vehicles which in turn has caused recruitment and operational issues, inhouse testing will alleviate a lot of those problems’

Representative of ambulance service

‘It has been demonstrated through the national pandemic that the resilience of C1 training provision can be critically compromised and adding this to an approach will add a level of critical infrastructure should future compromises occur in this way…’

Representative of an ambulance service

‘The proposal would decrease strain on government resources whilst allowing frontline services to more quickly fill the essential roles which continue to support the health and well-being of the entire community’.

Person with vested interest in delegated testing

Question 5. For NHS ambulance services – would delegated testing benefit your organisation and would you be likely to seek approval?

DVSA wanted to understand a little more about how many of the 13 NHS ambulance services might take up delegated testing. So, we asked a series of questions along those lines.

We were looking for responses only from representatives of NHS ambulance services. However, 57 people answered this question. Of those 41 respondents said that they represent an ambulance service and that they would engage with delegated driver testing.

The responses here indicate the NHS ambulance services have a strong intent to apply for delegated testing. However, it seems likely that decisions on whether to apply for delegated testing would be taken at Board level and so we cannot say how many NHS ambulance services will actually apply.

Only 5 respondents indicated that they would not, or not be likely to, apply for delegated testing. Analysis of those responses show that they were not input by representatives of ambulance services.

Question 6. For NHS ambulance services - having gained approval to conduct practical tests would you also want to conduct theory tests?

The next question asked whether those representatives of NHS ambulance services felt that they would take up delegated practical testing also felt that they would conduct theory tests. Theory testing is done electronically and requires the organisation to set up a test room where a candidate can concentrate whilst they complete their test.

Test rooms can be set up so that they accommodate more than one candidate. For example, many DVSA test centres can test 10 candidates, or more, at a time. This means that theory test waiting times are not usually an issue. Therefore, the gain to an organisation from conducting delegated theory tests is generally less than from delivering its own practical tests.

The results of this question are again slightly masked by the number of people that completed the question who aren’t representatives of the NHS ambulance services. However, analysis shows that all the people who said that they represent an NHS ambulance service said that they would want to conduct theory tests.

Question 7. For NHS ambulance services how many driving tests do you think you might conduct each year?

The final question in this section asked how many candidates NHS ambulance services might expect to test in a year. Responses from people who said that they represent NHS ambulance services gave the following information:

Tests a year	Responses
up to 40	2
40 - 80	7
80 - 120	3
120 - 160	8
Over 160	21

With far more responses than there are NHS ambulance services there is obviously some duplication happening here. However, the answers given to this question suggests that most NHS ambulance services will conduct a significant number of tests.

Allowing emergency services and the Ministry of Defence to carry out driving tests for each other

Question 8. Do you agree, or disagree, that the emergency services and Ministry of Defence should be able to test for each other?

84% of respondents said that they agreed with the proposal to allow the emergency services and MoD to cross-test for one another. A further 9% were undecided.

The people who said that they disagreed with the proposal questioned whether it would help in the response to Coronavirus. They also questioned whether tests would be conducted consistently or to the correct standard. Others said:

‘Cross testing should be available for all services which would help make better use of delegated examiners and reduce pressure off the DVSA’.

Representative of a Police or Fire delegated test service

‘We already work closely and share resources so this seems an obvious next step’.

Representative of a Police or Fire delegated test service

‘Having experience within the Fire Service and joint training with the Police. It would have been beneficial to cross test to cover for leave/illness etc. Some areas are large and to have cover from another NHS Ambulance trust may mean long travel distances for the examiner. Allowed various examiners from the Fire Service/ Police would be beneficial and potentially cost saving.’

Representative of NHS ambulance service

‘Peak demand for emergency services can vary between services. E.g., the NHS may experience high demand during the period of winter pressures when the fire service may experience lower demand. Being able to utilise fire service delegate testing at this time would free up NHS resource to be available to meet the winter pressures demand’.

Someone who has a vested interest in delegated testing

Question 9. Do you agree that this proposal will assist in easing driver recruitment pressures caused by the coronavirus pandemic and provide additional resilience?

91% of respondents indicated that they thought that this proposal would help to ease driver recruitment pressures at the NHS ambulance services.

A typical comment was:

‘Absolutely, we currently have over 150 staff waiting to join us that is held up by the demand in theory and practical tests. These staff may not be able to join us and on average, we lose approximately 20 staff per month on courses due to them not achieving their C1 in time. This would be a huge help and support to the future of the Ambulance Service and would allow us to fill our courses to provide more operational ambulances to our public when they need us’.

Representative of an NHS ambulance service

Question 10. Do you see any issues with the proposal for cross-testing?

The next question asked if respondents had any concerns. 77% said that they didn’t, 17% of respondents said they could see some issues.

These included the pressure to pass candidates when the test is not entirely impartial. However, cross-testing means that the candidate is less likely to know the person who is testing them.

Other issues raised included:

• Whether tests would be conducted to a consistent standard and how good the Quality Assurance process would be;
• the difficulty getting on examiner training courses, which DVSA provides, could lead to the poaching of examiners; and,
• whether there could be a knock-on affect in the availability of instructors – who are the most likely group to be trained to be examiners.

Cross-testing would help reduce the need for examiners to be ‘poached’, although each service will have to agree what arrangements to put in place for the use of the resource. It will also reduce the pressure on new entrant training courses, as at least a short-term option for NHS ambulance services until they recruit their own examiners.

Delivering delegated testing

Questions 11 to 15 asked about what the effects of introducing the flexibility to cross test for each other might have on the way that delegated testing is delivered. Also, about the arrangements that might be needed to oversee it.

Currently the scope for organisations that are approved for cross testing to test for one another is very limited. In fact, if an examiner works for two different services then each must pay the £950 annual registration fee.

This proposal will remove the need to pay more than one fee; but it is planned that any arrangements for cross-testing would need to be approved by DVSA. The exact detail of how that will be done is not yet decided. It could simply be that emergency services ask DVSA for approval, or it could be that we require details of certain aspects of the arrangements. For example, to confirm what arrangements there are for identifying candidates, or for recording tests, or even what arrangements are in place to recover costs.

Question 11. which other services do you think you might cross-test for?

Question 11 asked whether people felt that cross testing might be set up between services within the same ‘sector’ (i.e., fire services only), or between local services in different ‘sectors’ (such as between local police and fire services). It also asked about whether the changes might be just local, regional, or even at national level. In the latter case there could be quite significant re-structuring of test provision.

The chart below shows how respondents answered this question.

Sector	Responses
Within the police force only	1
Within the fire service only	1
Within the NHS only	9
Within a range of local emergency services	20
Within a range of regional emergency services	28
Within a range of national emergency services	40

Respondents saw the benefits of cross-testing. For example:

• ‘This will enable the main three services in my area to develop a joined-up training strategy which will ultimately benefit all the organisations as well as the public at large in saving tax payers money’. (representative of a police or fire delegated test service)
• ‘Nationally across all emergency services would provide the greatest flexibility and minimise wait times. A central database of available test locations and times could be maintained to ensure earliest possible test dates for candidates’. (representative of an NHS ambulance service)

It is clear that most respondents think that this proposal will lead to quite significant changes in the way that delegated driver testing is organised and that it could save some costs.

Question 12. For the delegated examiners - do you think that cross-testing arrangements would be fairly informal, or fixed?

In contrast the answers provided to Question 12 might suggest that arrangements will be quite informal, which tends to contradict the findings from Question 11.

Here 15% of people said that they thought that arrangements for cross-testing would be informal; and perhaps used to cover the absences of an examiner at another service. 8% said that they thought that arrangements would be quite firmly established, but most said that they thought that there would be a mixture of informal and formal arrangements. That is useful to know because it suggests that a flexible approach to approval needs to be taken.

Question 13. For the delegated examiners – do you think that cross-testing would result in national re-structuring of driver testing by the emergency services?

Question 13 tends to support the findings of question 11 in that a significant number of the people who responded to this consultation (32%) thought that this proposal could lead to a national re-structuring of driver testing amongst the emergency services. 51% said that they weren’t sure and 17% said that it would not.

Some people felt that the driver training teams within each NHS ambulance service would not need to look outside for delegated examiners, others said it was too early to tell and others that such arrangements would only be needed to cover short term absences.

So, there’s not really a strong conclusion to draw from this question. Much will depend on cost evaluations, and other considerations, made by the services after this proposal is implemented. But there is a clear feeling that this proposal opens the door to significant levels of co-operation between the services.

Question 14. For the delegated examiners – do you agree that DVSA should have to approve cross-testing arrangements?

51% of respondents agreed that DVSA should approve any arrangements for cross-testing. 26% said that DVSA should not approve arrangements and 23% weren’t sure either way.

Question 15. For the delegated examiners – fee and other arrangements to be agreed between the respective parties. Do you have any comments?

The last question asked about internal arrangements between services. DVSA does not expect to set any standards or expectations for these and will be content provided that the standard of testing is maintained.

78% of respondents left no comment on this, but 13 did.

Most of the comments related to the payment for tests beyond the payment of the £950 annual registration fee to DVSA. For example:

‘I think this is the most pragmatic way to deal with this situation. There is no need for the DVSA to be involved once the annual registration fee has been paid’.

A representative of a police or fire delegated test service

‘If the £950(per Examiner) is for each examiner to test for the agreed services then it makes sense that the cost of that and any CPD training is born equally by the services involved’.

someone who has a vested interest in delegated examining

Several respondents said that there should be a fixed fee for delegated cross-testing. They said that this would represent a fair approach and prevent charges from becoming commercial or from rising above cost-effective levels.

DVSA is reluctant to make any legislative provisions that would require treasury approval, or to introduce legislation where it might not be required. Especially as any legislative provisions on fees would also require careful and regular review, with cross-charges potentially being subject to inflationary adjustment or other change.

So, it’s not an area that we want to get into, but the legislation will have provision for the Secretary of State’s approval for cross-testing to be granted with specified conditions, so DVSA will have to carefully consider whether to include this in the approval process.

The decision

After taking all views into account the government has decided to introduce this proposal. This will mean that, when the law is changed, delegated testing will be open to NHS ambulance services as will the facility for the emergency services and MoD to engage in cross-testing.