Memorandum 47
Submission from the Tavistock and Portman
NHS Foundation Trust
1. INTRODUCTION
AND PRELIMINARY
COMMENTS ON
THE GOVERNMENT'S
DECISION TO
PHASE OUT
SUPPORT FOR
STUDENTS STUDYING
FOR ELQS
1.1 The Tavistock and Portman NHS Foundation
Trust is a multidisciplinary mental health clinical, training
and research institution which collaborates with three academic
partners to deliver university-validated courses.
1.2 Its students are mainly already employed
in health, social care, education or the forensic sector. They
are largely public and voluntary sector employees, mature learners
and mainly women.
1.3 The organisation is known for the high
quality of its training and for its commitment to raising standards
in training and professional development across the sector, in
line with the government's own workforce development agenda.
1.4 The Trust is concerned at the government's
decision to phase out support for student studying ELQs. The decision
seems likely to affect 50% of the students on validated programmes
-approximately 800 to 1000 students per annum, many of whom are
not offered clinical or practice based supervision or support
in their workplace. Others, on our professional training programmes
are seeking to make a mid-life career change and will be penalised
unless they seek a higher level of qualification, at a time when
the government is expressly seeking to improve the skills and
competencies of the great majority of workers in mental health
in particular, and is seeking to improve access to the psychological
therapies with an appropriate foundation level training for many
in the mental health workforce. In many cases, these students
are not funded by their current employer, but pay their own fees
funding in order to develop their skills and move on in their
careers.
1.5 The government's decision is likely,
inadvertently, to penalise workers who have already studied for
ELQs in their original training or to penalise those who have
worked for a quite a number of years since obtaining their first
qualification.
1.6 The government should take account of
the number of people who are seeking further training or new professional
qualifications, particularly women, members of minority ethnic
groups and late learners who are frequently in the lower income
groups who could not pay significantly increased fees for their
education, and whose employers are unlikely to be able to provide
adequate financial support.
2. TIMING OF
THE DECISION
AND THE
IMPLEMENTATION
2.1 Overall this Trust feels that consultation
on the proposal was sought late on in the development process.
2.2 There is insufficient time to be able
to plan for implementation in 2008 without serious difficulty
for specialised institutions, such as the Tavistock and Portman
NHS Foundation Trust, as well as universities (such as Birkbeck
College, University of London, and the Open University) which
specialise in part-time training for mature learners.
3. EXEMPTIONS
FROM THE
WITHDRAWAL OF
FUNDING PROPOSED
BY HEFCE
3.1 It is essential that if this withdrawal
of funding is approved, the number of public sector-related exemptions
is increased to include:
3.1.1 Preparatory courses for mental health
professional qualifying programmes (at doctoral level requiring
Master's level for entry).
3.1.2 All social care and health practitioner
qualifying programmes.
3.1.3 All Continuing Professional Development
programmes for public sector employees.
3.1.4 Students returning to study an ELQ
related to work more than five years qualification at the same
level after undertaking the first.
4. IMPACT UPON
STUDENTS AND
WHETHER THERE
IS A
DISPROPORTIONATE IMPACT
FOR SOME
GROUPS
The Trust believes there will be a disproportionate
impact on:
4.1 Women, including those who have taken
time out to have children since taking their first qualification.
4.2 People making career changes and seeking
continuing professional development or skill changes in line with
workforce development priorities.
4.3 Low paid workers seeking higher education
with possible disproportionate impact on members of black, Asian
and other ethnic minority groups.
5. CONTRADICTIONS
WITH PUBLIC
SECTOR WORKFORCE
PRIORITIES
5.1 It is evident from the consultation
documentation that some public sector career programmes are exempt,
but it is not clear quite to what extent. Nurse qualifying courses
are specified, however continuing professional development programmes
for all mental-health professionals—including post-registration
nurses—are not referred to.
5.2 Employers do pay for CPD to some extent,
but funding for education and training in the NHS has been cut
significantly over the past two years, funding to cover programmes
in full is simply not available within NHS training budgets. We
are very concerned that this change in the funding structure contradicts
other workforce development priorities (such as the NHS Knowledge
and Skills Framework and General Social Care Council (GSCC) registration
and CPD).
5.3 There is a clear government agenda to
increase people's skills and competencies through continuing education,
and a vast amount of this work is taking place through health/higher-education
partnerships. Removing HEFCE funding for these programmes contradicts
the overall strategy for Continuing Professional Development in
health and social care. The current HEFCE funding helps significantly
to encourage individuals to undertake the further education needed
to fulfill these strategies.
6. IMPACT UPON
SPECIALISED INSTITUTIONS
SUCH AS
THE TAVISTOCK
AND PORTMAN
NHS FOUNDATION TRUST
6.1 The Tavistock and Portman NHS Foundation
Trust as a public sector (NHS) organisation delivering training
programmes to all mental health professionals. Its specialised
nature means it is an institution sought out by education commissioners,
because it so clearly understands and is embedded in the NHS and
public and voluntary sector professional development. It has a
high proportion of ELQ students since they are often seeking different
kinds of courses to further their own professional and career
development. Most of these workers have access to relatively small
amounts of funding for their training and they, and this institution
will be jeopardised if there is no exemption for NHS and public
sector workforce and continuing professional development courses
at ELQ.
6.2 As the learning provider we receive
the HEFCE funding to provide teaching for students through the
accrediting University. Since all of our students (except a small
number of nurses on one advanced diploma course) are studying
at a post-graduate level this withdrawal of funding will affect
us disproportionately and will have serious financial implications
for our training delivery. Initial analysis suggests that this
withdrawal of funding will affect 50% of our University accredited
student places, which equates to a projected loss of approximately
£200,000 per academic year. This is surely an unintended
consequence of the proposal.
6.3 In addition to this financial threat
there is a further concern about the future of this Trust's collaborative
partnerships with universities. This funding change will influence
their strategic planning, and while we all support the concept
of increasing access to foundation-level programmes, many professions
across the public sector rely on existing collaborative programmes
for the quality-assured career development of their workforce
in health, social care and education.
7. RECOMMENDATIONS
(a) The Government should re-think the exemptions
and increase them as detailed in section 3 of this submission.
(b) Redefinition of ELQs is needed to separate
the levels of PG Cert, PG Diploma and Master's level (currently
a student with a Postgraduate Certificate would not qualify for
further "M" level HEFCE funding such as for Postgraduate
Diploma or Master's level study).
(c) A longer implementation period is needed
to allow for essential strategic planning.
(d) An audit of the impact of the plan on
women, low paid workers, and black and ethnic minority students
is necessary to ensure the policy is equitable.
(e) A further audit across government departments
is necessary to analyse the impact of this policy on the development
of new competencies and skills across the public sector workforce.
January 2008
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