Memorandum 63
Submission from the British Psychological
Society
The British Psychological Society (the Society)
welcomes the opportunity to contribute to the Committee's inquiry
into Funding for Equivalent or Lower Qualifications (ELQs).
The Society is the learned and professional
body, incorporated by Royal Charter, for psychologists in the
United Kingdom, has a total membership of over 45,000 and is a
registered charity. The key Charter object of the Society is "to
promote the advancement and diffusion of the knowledge of psychology
pure and applied and especially to promote the efficiency and
usefulness of members by setting up a high standard of professional
education and knowledge".
The Society is authorised under its Royal Charter
to maintain the Register of Chartered Psychologists. It has a
code of conduct and investigatory and disciplinary systems in
place to consider complaints of professional misconduct relating
to its members. The Society is an examining body granting certificates
and diplomas in specialist areas of professional applied psychology.
It also has in place quality assurance programmes for accrediting
both undergraduate and postgraduate university degree courses.
INTRODUCTION
The Society is strongly opposed to the general
principle underlying the proposal to withdraw funding from ELQs.
The opportunity to undertake retraining is an essential component
of the concept of lifelong learning. Removing it would make the
labour market inflexible and much less able to respond to the
changing demands of the economy. This weakness in the proposals
is partially recognised by the acceptance that there will have
to be exemptions to the general removal of funding for ELQs.
THE NEED
FOR ADDITIONAL
EXEMPTIONS
If the proposals are persisted with, then the
Society is greatly concerned by the failure to consider exemptions
for routes into careers in practising professional psychology.
There are currently seven main areas of practising psychology:
clinical psychology, counselling psychology, educational psychology,
forensic psychology, health psychology, occupational psychology,
or sport and exercise psychology. The largest of these routes
is for clinical psychology, and other NHS-related psychology/mental
health training. For the sake of brevity, we have concentrated
on this particular route; however, similar cases could be made
for the training routes into the other important areas of applied
psychology. It is worth noting that all the above mentioned areas
benefit substantially from the input of people who have had experience
in other careers before coming into psychology, just the group
who would be hardest hit by the removal of ELQ funding. The Society
is therefore also particularly concerned about the lack of clarity
in the proposals around the status of conversion awards, an important
route for mature students into professional psychology, in relation
to exemption. Finally, we raise briefly the need for a fully funded
route for retraining those teaching psychology in schools with
degrees in other areas.
1. Clinical Psychology and Other NHS-related
Psychology Training
A strong case for additional exemption exists
in relation to clinical and mental health training pathways; this
would allow continuation of recruitment to such awards for students
who have previously undertaken equivalent level qualifications,
prior to embarking on psychology-related mental health training.
Many health professionals with existing degrees
(eg in nursing) go on to study psychology at degree level in order
to access postgraduate training in applied psychology. Frequently,
entrants to Clinical Psychology doctoral programmes, some of which
attract elements of HEFCE funding, already possess research doctorates;
in addition, trained clinical psychologists must receive further
training at equivalent level in order to qualify in Clinical Neuropsychology.
Given Department of Health developments around
New Ways of Working and Continuous Professional Development, and
its support for lateral transfer and re-skilling of the NHS working
force in relation to mental health issues, there needs to be clarity
that new courses designed to meet these needs (eg Graduate/Primary
Mental Health Worker Certificates/Psychology Assistant and Associate
Certificates and Diplomas/Certificates in Cognitive Behavioural
Therapy) are exempt from ELQ withdrawal of funding, in order to
encourage HEIs to take this forward. For example, the Minister
of State for Health, the Rt Hon Alan Johnson announced in the
Commons in October additional investment (£178 million) for
Improving Access to Psychological Therapies which see the training
of an additional 3,600 new psychological therapists. If the current
proposals are implemented we believe they would seriously jeopardise
the implementation of new, innovative and highly desirable initiative
from the Department of Health.
We have interpreted the exemptions noted in
Annex B, 2a of the proposals as not applying to the types of student
referred to in the last paragraph, but suggest that consideration
of recent NHS workforce training priorities must better inform
policy exemptions in this area, for example by extending the exemption
to students who are already healthcare professionals, as well
as those studying on courses providing the primary training for
healthcare professionals. Similarly we understand that these student
categories do not fit current interpretations of an SIVS, despite
the significant emphasis given to the teaching of quantitative
research methods in psychology. With this in mind, we urge the
reconsideration of SIVS priorities hinted at in Point 33 of the
proposals.
2. Conversion awards
Communication with HE departments of psychology
suggests there is considerable confusion about the status of conversion
awards in psychology in relation to these proposals. We understand
that Graduate Diplomas in Psychology are categorised as PGT by
HESA, on the basis that students normally require a first degree
on admission, regardless of the fact that many such awards are
offered at the same level ie the defining as PGT is not determined
by the level of the modules studied. This needs to be made explicit
within the ELQ policy guidelines to institutions, but does not
entirely resolve difficulties created by the proposals in this
area, as presumably Masters degrees might then be classed as ELQs
for those who had taken a conversion award? A general and related
point to emerge here is the observation that the current system
for recording entry qualifications for those with postgraduate
qualifications (eg in HESA returns) is very crude by comparison
with other levels of qualification, leading to an inability to
reflect the growing differentiation of levels of PG award in the
sector.
On this basis, we offer the argument below to
support the case for treating conversion awards as an additional
exemption:
Successful achievement of a conversion award,
most typically a Graduate Diploma in Psychology, but also the
Society's own Qualifying Examination, is a route to obtaining
the Graduate Basis for Registration (GBR) which is followed by
significant numbers of students each yearstudents who have
a first degree in a different discipline, but who require GBR
in order to pursue a career in professional psychology via postgraduate
training. The award's popularity is attested to by the fact that
41 such programmes are currently accredited by the Society, with
at least a further seven planned for 2007-08. The award's "efficiency"
is reflected in its "fast-track" nature (typically one
year's full-time study for those with the equivalent of half a
year's study of psychology at degree level). Its vocational relevance
is its primary raison d'etre. It attracts highly competent
and motivated students, who already make large personal sacrifices
in terms of time and finance because they anticipate a more fulfilling
career following graduation. Typically conversion award graduates
achieve high retention rates and grades, continue into professional
training, and make significant contributions to society and the
UK economy.
A reduction in this category of student would
be a great loss to the practice and profession of psychology,
particularly at a time when other Government initiatives are supporting
the expansion of trained mental health therapists (see above).
Referring specifically to Point 22 of the proposals, we would
argue that exempting students on conversion awards would be in
line with the general approach proposed to exemptions, in that
it is consistent with "the Government's intention to prioritise
students progressing to a higher qualification"such
students would be debarred from progressing to a higher qualification
if they could not complete a conversion award. There is also little
doubt that fees for such awards would have to increase significantly,
if they were to remain viable without HEFCE funding, leading to
other discriminatory influences with respect to those who would
be able to afford to attend.
3. Retraining those teaching psychology in
schools with degrees in other areas
Psychology is now the third most popular A level
subject in Britain, and the most popular science A level. It is
a particularly important route into science for girls who, unusually
for science, make up a substantial majority of the students. This
rapid expansion has meant that it is commonly taught by staff
with degrees in other areas, often in non-science disciplines.
There is therefore an important need for facilitating the retraining
of staff particularly through part-time degrees. The removal of
ELQ would hit this group particularly hard.
PART-TIME
STUDENTS
The Society agrees with the view accepted in
the proposals that there is likely to be a differentially-marked
impact (we believe this will be a discriminatory impact) on the
withdrawal of funding for ELQ's for part-time students. We agree
this needs to be addressed, but we are less certain that the supplement
proposed will be adequate compensation.
We are concerned that a policy which creates
a negative differential impact on part-time students in psychology
also creates a negative differential impact on women and mature
students since psychology is a very strong recruiter of these
two groups. Psychology is also particularly vulnerable in terms
of absolute numbers of students penalised, because of its large
student body. It is a subject that many turn to later in life
after pursuing other careers; again this trend increases the likelihood
that the policy will impact differentially on psychology students.
The long term impact of individuals remaining in employment which
does not satisfy them is likely to be a workforce with lower motivation,
effectiveness and efficiency.
It is ironic that the principle target of this
initiative is the part-time sector, on which the Government is
relying for return to work schemes, widening participation and
employer engagement.
SUMMARY
In this submission the Society has expressed
its serious concerns regarding the proposed withdrawal of funding
outlined by Government, presenting clear case scenarios of how
such a measure could impact on the professional future of those
individuals pursuing a career in psychology. The Society firmly
believes that psychology and the other science subjects should
be exempted from such proposals, enabling those individuals wishing
to change direction and to become psychologists, especially through
conversion courses and postgraduate courses, to do so. This approach
would support current widespread flexible work force notions,
and truly reflect the nature of our modern world.
January 2008
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