Memorandum 11
Submission from the British Association
for Counselling and Psychotherapy
RESPONSE TO THE INNOVATION, UNIVERSITIES
AND SKILLs COMMITTEE: FUNDING FOR EQUIVALENT OR LOWER QUALIFICATIONS
(ELQs)
1. The British Association for Counselling
and Psychotherapy (BACP) welcomes the establishment of a Select
Committee to conduct an inquiry into the Government's decision
to phase out support given to institutions for students taking
second qualifications of an equivalent or lower level (ELQs) to
their first qualifications. The BACP is recognised by legislators,
national and international organisations and the public as the
leading professional body and the voice of counselling and psychotherapy
in the United Kingdom, with over 28,000 members working to the
highest professional standards.
2. We have serious concerns about the proposals
and believe that they are flawed. We feel that they have been
drawn up with minimal consultation with stakeholders and that
little consideration has been given to the consequences of the
proposals on other government policies and initiatives. For example,
the policy contradicts the Leitch Review and the idea of reskilling
the population to meet the needs of modern labour market.
3. It is also in conflict with the DH emphasis
on continuing professional development and skills acquisition
to transfer across levels in the workforce and the requirements
of the Regulatory Councils for continuing professional development
and revalidation. The proposals are also likely to affect the
strength of cpd as a workforce change tool by limiting possibilities
for essential education and training within professions; it is
important to remember that much of the education is likely to
be carried out through short and part-time courses and consideration
needs to be given to how to protect these too.
4. In a previous membership survey, we found
that 65% of the membership applying for accreditation as counsellors
or psychotherapists were already graduates in non-counselling/psychotherapy
disciplines. It is, therefore, of particular concern to the Association
that no consideration has been given to the exemptions for routes
into counselling and psychotherapy and other training courses
in psychological therapy and mental health. Counselling and psychotherapy
is a second profession for many, who enter the field already holding
high level qualifications in their first professions, such as
teaching, social work and nursing. This proposal would have a
negative impact on those individuals and would deter such people
from re-training.
5. From the wider government mental health
agenda, this is particularly significant with regard to the training
of counsellors and psychotherapists to meet the demands of the
"Improving Access to Psychological Therapies"
strategy and we urge that training in all areas of psychological
therapies be exempt from such proposals. It is important to recognise
that successful delivery of the strategy will depend upon the
retraining of a large number of professionals—by 2011, the
service will be employing some 3,500. (The use of the 2005-06
HESA report would be an inadequate basis for consideration of
training in psychological therapies as this national priority
was only recognised by government in the 2005 IAPT programme.)
6. Whilst it has been argued that the plans
will broaden access to higher education, they do so at the expense
of the institutions that focus on part-time studies and these
institutions provide the best route to widen access. In addition,
the risks to part-time education are considerable because of the
significant number of those undertaking ELQs will be doing so
part-time. This will affect the very providers, such as FE institutions,
who have done most to widen participation and reach mature students.
This will also affect certain subject areas disproportionately
and such courses may cease to be viable. For example, the change
of policy will have a devastating effect on the Relate Institute,
which has been newly established by Relate, the UK's largest provider
of relationship counselling and sex therapy. About 70% of the
students who are studying on the Relate Institute's entry level
training (called a University Advanced Diploma and equivalent
to half of a third year undergraduate degree course) would be
deemed ineligible. Not only will this have a negative impact on
the future of the Relate Institute, but it will also damage service
delivery.
7. The suggested strategy will discriminate
against older participants and those without employer support,
in addition to those who wish to choose their own learning pathways.
It is important to acknowledge that a particular level of qualification
does not always indicate its worth in employment terms and those
needing to reskill will be severely disadvantaged. This proposal
would discriminate against mature students and women and anyone
wishing to retrain while continuing to work. We would be very
interested to see the results of any Equality Impact Assessment
that has been carried out.
8. Finally, we wish to emphasise implications
for the UK economy as a whole. If businesses are unable to find
the skills that they need from the UK education system, then the
likelihood will be that the workforce is sourced from elsewhere
or that, where possible, affected activities will cease to be
located in the UK.
December 2007
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