Health CommitteeWritten evidence from NHS North West (ETWP 87)

Introduction

The North West Workforce and Education Directorate of the North of England SHA Cluster welcomes the Health Select Committee (HSC) Inquiry on Education, Training and Workforce Planning and the opportunity to contribute in the form of this written submission. The inquiry is wide ranging in its examination of the Government’s plans regarding the future healthcare education arrangements.

Our comments reflect our submission to the Future Forum, following consultation with all NHS employers and key stakeholders in the North West and covers the key themes and specific issues as set out in the Committee’s terms of reference.

Key Themes

1. The right numbers of appropriately qualified and trained healthcare staff (as well as clinical academics and researchers) at national, regional and local levels

This will be addressed by strategic workforce planning, effective partnership working and use of planning models. Employers are anticipated to more directly link priorities and risks when given responsibility for workforce planning and training budgets. Providing effective learning environments (see paragraph 6) is a crucial part of this and we have developed educational governance guidance to help North West organisations meet the appropriate high standards.

2. Training curricula reflect the changing nature of healthcare delivery, including the medico-legal context

This represents a significant challenge, particularly in the current financial climate and the complexities of shifting service provision to the community, whilst maintaining current hospital infrastructures safely. It will be addressed by continuing to work in partnership with regulators, service colleagues and education providers.

3. All providers and commissioners of healthcare (both NHS and non-NHS) play an appropriate part in developing the future workforce

This will be addressed by engagement, partnership working and providers’ own desire for an effective and efficient workforce. The governance arrangements and statutory duties also play an important role as non-NHS organisations will need to sign up to training commitments in order to benefit from outputs of training and create a more level playing field.

In the North West, both the workforce and the education and training commissioning plans are tested out annually with service commissioners as well as all the employer organisations.

4. Multi-professional and multidisciplinary leadership and accountability (encompassing the full range of healthcare professions, specialties and grades) at all levels

Learning in and from teams on clinical placements is being actively promoted. The significant investment in education, training and clinical skills facilities, including those in primary care across the North West, is an example of how Multi-professional Education and Training (MPET) funding has been used to promote multi-professional training and development. This is only really successful if focused on the patient pathway and service improvement rather than professions, though it is absolutely right that specialist skills are acquired separately as appropriate and professional identity is created.

The most successful initiatives also tend to be where traditional hierarchy has been levelled and all grades of staff are encouraged to contribute to discussions about patient care and where there is the potential for it to be less than excellent. Accountability is first and foremost from the individual to their employer and, where regulated, to their profession. This requires a focus on good team management where every individual is held accountable for their contribution regardless of whether regulated and professionally qualified or not.

Patient safety is also enhanced by ensuring all staff have good levels of literacy and numeracy, accessing SFA/NAS funding where eligible, to achieve the appropriate basic skills and competence and help stimulate a learning culture across the whole workforce.

5. High and consistent standards of education and training

High and consistent standards are promoted through the use of Learning and Development Agreements (LDAs) and formal contracts with education providers. Regular reviews of these agreements take place, serving to inform regional benchmarks and create opportunities to share practices.

There is a huge amount of quality assurance that takes place through regulatory bodies, including the Qualifications and Curriculum Authority (QCA) in the case of HEIs; OFSTED in the case of colleges and other education providers funded by SFA/NAS and our two Deaneries, through their visits and reporting to the GMC on the quality of postgraduate medical education and training.

Great importance is given to feedback on the student/trainee experience and there has been a great increase in the involvement of patients and carers in devising training, taking part in training and feeding back on trainees. More consistency and portability in training has been achieved through increased standardisation of qualifications where possible, with much greater widening participation in learning to support skills development and provide better standards of care.

The Education Commissioning for Quality and draft Medical Quality Indicator frameworks recently introduced, are going some way towards even greater consolidation of quality markers across professions. The Education Outcomes Framework, whilst noting is in the early stages of development, is attempting to make a more explicit link between training provided and outcomes for patients and service delivery, utilising the domains of the general outcomes framework for NHS services.

6. The existing workforce can be developed and reskilled for the future (through means including post-registration training and continuing professional development)

We consider ensuring employing organisations taking on a learning organisation culture is the best way to achieve this. This is supported by a good evidence base and could be undertaken as a standard for taking on placements. This also supports better staff involvement and engagement, further supported by good evidence and as part of the NHS constitution pledges. Our most successful organisations are also those that are good at education, both at GP practice and large organisation level. We have developed education governance guidance for our organisations to help them with this.

Ensuring good CPD for the workforce is a crucial part of the work of the future provider led networks as that has been the feedback from our own Delivering the workforce programme board and stakeholder forum. We would therefore naturally be concerned about any cuts in CPD, both because of the risk this could pose to the quality and safety of patient care, as well as the wider individual and organisational benefits of on-going personal and professional development. CPD activity is importantly, increasingly a focus of regulatory and assurance monitoring processes and any reduction or withdrawal of funding would only exert further burden on what are already often pressurised budgets.

Our patient forums report the caring nature of staff with appropriate behaviours and attitudes is particularly important to them. Ensuring this culture is part of all education and training and is a task and duty for provider led networks, through placement standards and education contracts. This is important for the whole workforce not just the registered professions. It will be helpful if this focus on the NHS Constitution’s values and behaviours, is reinforced by HEE, by making it a key part of its approach to quality, in meeting the Educational Outcomes Framework.

A key emphasis for workforce modernisation is the development of support workers (AfC Bands 2–3) and Assistant Practitioners (AfC Band 4–5). Current areas of work include pharmacy technicians, ODPs, maternity support workers, higher level apprentice scientists, mental health support workers as well as those in intermediate care and primary care. Roles at this level are seen as key to improving skill mix within teams. Training for non-medical prescribing is also much in demand to enhance the patient experience and avoid delays, with very specific training and responsibilities given for certain areas and drugs.

Work is also continuing on developing Advanced Practitioners, particularly in areas where there may be vacancies in traditional roles and more innovative solutions are required. This has been particularly successful in primary care, where practice nurses take on many of the roles that were previously seen as those of GPs with clear boundaries and protocols set. There is increasing usage of paediatric and neonatal specialist nurses, trained by consultants in the workplace setting as well as having underpinning academic learning, to take on the duties that might previously have been done by junior doctors.

7. Open and equitable access to all careers in healthcare for all sections of society (by means including flexible career paths)

SHAs are focusing on widening participation initiatives ie both widening access to higher education through access/bridging/foundation courses, but also in widening participation in learning—particularly where the individual’s experience of school or personal circumstances meant that they did not gain many formal qualifications. There are now several assistant roles that can provide the stepping stones into registered training at graduate level and above, and many stories of individuals starting out with no GCSEs and ending up at PhD level study through their course of their working life within health care.

The use of flexible training routes and part time courses are often important ways of providing equitable access to career progression, with accumulation of learning credits in smaller chunks rather than one continuous qualification.

Specific Issues the Committee will Look at

8. Plans for the transition to the new system, up to April 2013

A key issue is establishing the legal entity of the provider led networks/LETBs.

SHAs are awaiting detailed guidance from the Department of Health (DH) but are establishing interim arrangements eg the North West Programme Board is overseeing the establishment of three Network Leadership Groups, as formal sub-committees of the North of England SHA Cluster Board. The Groups are chaired by a Provider Chief Executive and have strong employer representation and there is wide stakeholder involvement. The impact of uncertainty is being dealt with by strong leadership locally, staff communication and engagement and progressing the development of provider led networks/LETBs. However there are inevitable strains being put on the system in coping with all the changes.

We have concerns about the proposed social enterprise model which would put expertise and corporate memory at risk. It is unlikely to get NHS staff to transfer into the function in the future, though current staff would be protected, and it is also likely to split medical and non-medical training at a time when it is working more closely than ever.

It is important that current SHA responsibilities are transferred safely to the provider led networks/LETBs. These include:

(a)Workforce strategy and planning.

(b)Education commissioning and workforce development.

(c)Postgraduate medical and dental education.

(d)HR Strategy.

(e)Leadership and organisational development.

Ensuring there is clarity on the future of the electronic staff record (ESR) from 2014 onwards is also important as this is a key source of workforce information.

9. The future of postgraduate deaneries

Postgraduate Medical and Dental Deaneries are a critical element of provider led networks/LETBs, and they are a core part of SHAs. The Postgraduate Deans are key members of their respective Network Leadership Groups in the North West. The size of these Groups and robust governance arrangements means that no single healthcare organisation has the ability to dominate. This combined with the requirement to meet the standards set by the professional regulatory bodies (GMC for medicine) and robust contractual arrangements, will mitigate concerns about conflict of interest, which is one of the issues raised during the consultation period. Whilst SHAs and in future provider led networks/LETBs, are bound by national plans in some areas such as junior doctor training numbers, there is the necessary flexibility to reflect local priorities. Strides have been made in recent years with healthcare employers in considering skill mix more fully and looking to ensure that specialist skills are used for more of the time, with general support provided where it makes sense and a blurring of boundaries around tasks.

It is critical that the whole workforce can be considered in one place, (as now in SHAs), as there are very strong messages from service managers that they are happy to plan on patient pathways to consider the most appropriate workforce and that the focus should be around the patient, drawing on general caring and more specialist skills as appropriate. SHAs have very much been the conduit to positive work between professions and also between service and education colleagues in meeting needs through devising suitable training that provides appropriate qualifications (though not necessarily regulation) to reflect skills required, including leadership and management skills. The new arrangements will enable this approach to continue but with the benefit of greater employer involvement and accountability.

The MPET SLA (see paragraph 21) sets out the key elements of the Service Level Agreement between the DH and SHAs for the utilisation of MPET funding. It also sets out how key NHS Operating Framework requirements eg Health Visitor numbers will be met.

The Learning and Development Agreement (LDA) is critical for holding employers to account for the delivery of training and development and its quality across the board, complementing contracts with education providers so that both academic and placement quality is maintained, and also complementing professional regulator activity. This helps to ensure consistency and portability of qualifications to help with patient safety, avoidance of repeating elements of learning and, therefore, maintenance of staff morale and maximum value for money from training.

There needs to be some flexibility in any national planning to allow for regional variation and particular priorities at any one time. Employers are also less likely to engage in training if they do not perceive that there is some recognition of local issues and local involvement. This represents a major challenge in planning the future medical workforce requirements given the long lead in time for training doctors across a wide range of medical specialties. It will need to be managed effectively between HEE and the provider led networks/LETBs.

10. The future of Health Innovation and Education Clusters

Health Innovation Education Clusters (HIECs) were established in 2010 with two years pump priming monies. Their primary purpose is to bring together all partner organisations in an area, with the aim of securing adoption and diffusion of best practice, innovation, research and development through education and training. In the North West the three HIECs, which are coterminous with the three Network Leadership Groups, have initiated a range of projects and facilitated effective partnership working between NHS Organisations, the HEIs and other partner organisations in the localities. It will be for the new provider led networks/LETBs to find funding to support HIECs if it is considered that they have been effective—the decision will focus on the share and spread of existing innovation and developments rather than trying to create other things.

11. The role of the Secretary of State for Health in the new system

It will be important for the Secretary of State to have overall accountability and to ensure that MPET funding is appropriately protected in the new system.

12. The proposed role, structure, governance and status of Health Education England (including how it will take on the roles of Medical Education England and the Professional Advisory Boards), and its relationship to professional regulators and to the other parts of the new NHS system architecture

The multi-professional nature of HEE will provide important opportunities to address the changing nature of healthcare and the requirements of workforce development. It is recognised that clear accountability arrangements between LETBs and HEE are essential but that HEE must acknowledge and respect the need for appropriate local determination. A key enabler will be the ability to utilise some funding to meet training needs around patients and service needs in addition to meeting a specific training number in regulated professions in undergraduate or post-graduate medical/dental. Also to be able to utilise unused funding within traditionally allocated numbers across different professions to support more skill mixing and, therefore, appropriate use of skills and expertise for more of the time.

This is possible as, despite national numbers, trainees do not opt to distribute themselves according to theoretical geographical allocations, resulting in some shortages (often in rural areas) whilst popular cities and locations have a wide choice of employees.

13. The proposed role, structure, status, size and composition of local Provider Skills Networks/Local Education and Training Boards, including how plans for their authorisation by Health Education England will address issues relating to governance, accountability and potential or perceived conflicts of interest, and how the Boards will relate to Clinical Commissioning Groups and the Commissioning Board

We believe that the right balance between HEE and Provider led Networks is to ensure functions are done as locally as possible unless they need to be done a level up. We think that most good education and training needs to be undertaken at organisation level. At provider led network, we would expect only those things that are best organised at a regional level, such as contract management, doctors in training coordination and overall workforce needs assessment. We believe that HEE needs to provide a strategic framework for provider led networks to work within but should not commission or organise education and training directly. It should commission the networks to undertake this including lead commissioning on behalf of other networks for smaller professions.

We think that it is vital that the provider led networks are part of the NHS either as new NHS statutory bodies or through hosting by Foundation trusts. We do not consider the social partnership approach will enable us to keep sufficient staff to carry out the planned responsibilities at provider led network level. The authorisation framework will define the relationships, roles and responsibilities for providers as members of the networks. We would emphasise the statutory duties on providers to provide workforce plans and to participate in the networks. We believe that each provider led network as part of its authorisation should have an overarching workforce and education and education commissioning strategy for its area which would ensure a complete portfolio of education and training for the workforce in its area.

Conflicts of interest will be dealt with by all board decisions being based on principles rather than application to specific organisations. Members will be representative of their constituencies rather than organisation and board members will withdraw if a decision is specific to their organisation. The key issue is having strong and effective governance arrangements with effective stakeholder arrangements. In the North West HEIs and other key partners are involved with the provider led networks. HEE will have to have appropriate links to the NHS Commissioning Board to ensure triangulation of service, finance and workforce plans with appropriate links to CQC and monitor. Clinical Commissioning Groups will need to have appropriate local links to LETBs.

14. How professional regulators, healthcare providers and commissioners, universities and other education providers, and researchers will all participate in the formulation and development of curricula

As they do now but with even greater involvement of providers. Examples: HEI partnership boards for placements, NMC consultations on curricula and GMC for approving learning environments.

In the North West we believe we have had a strong focus on partnership working which has been invaluable in achieving our aims. This has included research through our alliances with Universities and promotion of our AHSC, other research and innovation activities and strategy and maintaining a regional R&D team to support local R&D alliances. The three HIECs in the North West have full HEI membership as well as all NHS organisations in each of the localities and therefore capture all stakeholders including the AHSC.

Our partnership working has been based on our values, shared with stakeholders; clear and transparent communications on a regular basis with all stakeholders; long term trust relationships using many forums, meetings, shared membership and face to face individual work; clarity of roles and a thrust towards promoting collaboration between our stakeholders not just between us and them. This can be evidenced by national feedback from our local Council of Deans and regional staff partnership forum as well as the willingness of our providers to become engaged in these changes at executive director level. Our emphasis has been on partnership and collaboration rather than competition. This has meant our provider organisations and universities explicitly setting aside their competition aims for specific collaborative work.

In the North West we have a strong tradition of partnership and collaborative working, not just in education. Our Leadership Academy, Quality Observatory: AQuA and HIECs are good examples of this approach. We feel these approaches should be embedded in the authorisation criteria and model governance frameworks produced by HEE for provider led networks.

15. The implications of a more diverse provider market within the NHS

There has always been a diverse provider market eg Nursing Homes, independent healthcare providers. It is acknowledged that that there have been difficulties with engaging with the independent sector, particularly as social care does not have an equivalent of SHAs. Networks will need to involve wider partners to ensure there is maximum collaboration, eg training of care home staff in End of Life Care—a joint programme to meet patient needs driven by SHA, service partners (inc. care home managers) and skills for care. The focus is likely to be on training to prevent unnecessary emergency admissions at end of life by increasing confidence in staff and creating sustainable training programmes given high staff turnover prevalent in this sector. A risk that will need to be carefully managed will be medical training, if the service in acute Trusts remains dependent on medical trainees for delivery and a range of alternative providers deliver elective care.

Equally, the terms and conditions under which clinical placements are facilitated/managed should be consistent across all Providers (NHS and non) to maximise both flexibility of use and breadth of student experience and avoid the any risk of disadvantage.

16. How the workforce requirements of providers of NHS and non-NHS healthcare will be balanced

By effective workforce strategy and planning for NHS commissioned care rather than specific providers. There are particular challenges when looking at social care requirements.

17. The role and content of the proposed National Education and Training Outcomes Framework

The draft education outcomes framework provides good high level domains which can provide the necessary granularity to improve both the quality of education and transparency of information about that quality. This now needs further development on the detail so appropriate metrics and/or indicators are developed that allow linkage to patient outcomes. There is already a lot of evidence and data to support the training process, but less analysis of its effective application. ROI type methodology is useful here so employers are clear about why staff are undergoing training, what expected product or outcomes will be and how these will be applied in practice.

We believe quality of education and training will be driven by education governance in each provider organisation. We are happy to send you our guidance on education governance if the Committee would find this helpful. By ensuring board level activity in education, we think publication of standards will follow. Transparency about CPD provision, take-up and outcomes will ensure quality improvement. We think there are currently many means of achieving good feedback on quality including student experience, trainee surveys and PROMs but that these should be bound together by some HEE development work to provide consistency nationally.

There may be a role for the Centre for Workforce Intelligence in collecting and comparing education outcomes framework information of specific provision such as education providers either for placements or within University programmes.

18. The role of the Centre for Workforce Intelligence

To provide high quality workforce intelligence data, as reflected in their contract with DH and their business planning process.

19. The roles of Skills for Health and Skills for Care

Both sector skills councils should continue. There is a view that they should not be merged as the workforces are distinct though it is possible for some joint working.

20. The role of NHS Employers

NHS Employers should play a key role in pay and conditions national negotiation. It also has an important role as an independent body for providers, supporting HR strategy as well as joint activities with SHAs across England.

21. How funding will be protected and distributed in the new system

By funding going to HEE and LETBs, HEE can build in control and accountability to LETBs for use of funding through the authorisation process and formal contract. However, this cannot be overly prescriptive as needs will differ locally but usage should be transparent with clear accountabilities.

Multi Professional Education and Training (MPET) Service Level Agreement (SLA)

An SLA exists between the Department of Health and the Strategic Health Authorities (SHAs) for the utilisation of the Multi-Professional Education and Training (MPET) Budget. This SLA sets out the Department of Health’s main expectations for the use of this funding. The document details the expectations and key performance indicators for MPET under the five headings of:

1.Undergraduate medical and dental education placement funding;

2.Postgraduate medical and dental education funding;

3.Nursing, Midwifery, Allied Health Professions and Healthcare Scientists education funding;

4.Student Bursaries; and

5.Wider workforce.

MPET investment planning and decisions of SHAs should also take into account the NHS Operating Framework for 2011–12. MPET allocations are negotiated nationally as part of the CSR process and are managed by Executive, commissioning and finance staff employed in SHAs and postgraduate deaneries, in consultation with NHS service providers and non NHS providers of education and training.

National/Regional MPET Allocations

The national MPET allocation for 2011–12 was £4.8 billion and is split between its three sub levies as follows: SIFT (Undergraduate training) £923 million; MADEL (Medical and Dental) £1.8 million; and NMET (Non Medical Training) £2.1 million. The allocation for NHSNW is £688 million in 2011–12 which reflected a cost pressure of c3% given the allocation was a flat cash settlement, with the requirement to fund a number of new in year cost pressures such as Health Visitors, IAPT, BMP price inflation and GP expansion in line with DH targets.

Any under spending of previous years has been carried forward and not lost to the local MPET levy. This reflects good business sense as contingency funds are always required, especially in a complex environment involving funding for training from MPET, HEFCE, SFA/NAS, employers themselves and other sources—most of which are in the process of major change and review and involve many variables.

It is critical that robust governance arrangements are in place to manage these material allocations and ensure public money is used cost effectively with training and education not being prioritised for cuts above other areas. Such actions would potentially compromise the ability to train the workforce of the future with all its associated consequences.

Future MPET allocations policy should address the disproportionately lower resources available to SHAs/LETBs outside of London. Part of this will be introduced with the standard education placement tariff for medical students, which will redress the 40% funding currently in London.

Secondly, the distribution of doctors in training posts needs to be addressed, recognising the service implications of moving junior doctor posts. The North West remains under doctored, especially for GPs and needs more training numbers, which are more likely to then work within the North West. The North West has the highest retention rate after training in England, of doctors in training at 90%.

Potential Future Reductions in MPET Funds

As previously advised the allocations have been rolled forward from 2010–11 and this is again anticipated for 2012–13. Pressures such as training more health visitors, contractual Bench Mark Price (BMP) increases with Universities and improving access to psychological therapies (IAPT) have been funded from within these monies.

The cost pressure will be the sum of:

(a)cost shifts from other budgets to MPET—some transfers expected;

(b)M price inflation on University contracts (approx 2%);

(c)price inflation on NHS contracts where salary support provided—medical pay freeze should limit this but also applies to other professions, eg scientists;

(d)volume reductions—some MMC posts are due to fall off this year;

(e)volume increases we are committed to—undergraduate placements, GP expansion, Health visitors, IAPT, increased numbers of students already in training(due to improved retention/reduced attrition rates); and

(f)other—eg cost of extended GP training due to increase failure rate, transfer of funding to BIS to fund additional student loans under new bursary scheme, payment of £9k tuition fees for medical/dental students in final years of training.

The options to manage the pressure are:

(a)reduce training volumes—especially Non-Medical CPD type spend as produces a saving in a shorter time frame (NB this applies to 91% of the health workforce);

(b)reduce rates paid to the NHS for salary support of placements;

(c)reduce management and administration costs;

(d)reduce or remove additional support funding to students in training for travel to placement, etc; and

(e)cease any developmental activity or innovation other than that delivering core training, eg clinical skills facilities and co-ordination to maximise usage, apprenticeship support, pilots to develop new learning models, eg making every contact count for public health awareness, leadership development and change management, return on investment training.

As identified the management of these issues requires robust governance arrangements utilising qualified, well trained and dedicated workforce and education staff into the future who can work with HEE to deliver national objectives in local areas liaising closely with service providers who ultimately benefit by recruiting the right numbers of well trained staff.

Implementation of a training tariff

Proposals for the introduction of a full training tariff are now in an advanced stage. This has been in response to the fact that there is evidence of wide variances in the placement rates paid for undergraduate medical students in NHS organisations and there are no placement payments for other trainees or students. The salary contribution rates offered to medical and dental trainees are also in need of review due to inconsistencies.

Tariffs are a good lever for improving quality (for undergraduate medical students) and ensuring a consistent benchmark for delivery against a set price for training in practice. Discussions are continuing for postgraduate trainees, who form an essential part of the delivery workforce, to assess the appropriateness of the tariff. The aim should be equal reward for taking students/trainees with a standard tariff and money following the student/trainee.

A tariff system does currently operate for tuition payments to Universities covering non-medical education commissions and is negotiated nationally as a benchmark price. Clear benefits have been apparent since this was implemented, which have resulted in transparency of contractual details, reduced administration and improvements in planning capability.

Whilst tariffs would allow funding to follow trainees it may also result in perverse incentives to just invest in medical training (due to higher tariffs proposed) and opt outs of training for other professions. They are currently reliant on good will, professional responsibility and subsidised funding from other areas within service provider organisations.

There are real benefits to be obtained from the introduction of a tariff which is a key part of the Workforce and Education proposals which will assist in the creation of a package of training to encourage the development of NHS staff across the whole range of professions. Ensuring successful implementation will require strong leadership and decision making over a transitional period led by the new Workforce and Education organisational structure bearing in mind the interests of local provider bodies.

How funding will be protected and distributed in the new system

By funding going to HEE who will allocate resources to LETBs, HEE can build in control and accountability to ensure LETBs meet national objectives whilst also having the local flexibility to manage local issues.

22. How future healthcare workforce needs are being forecast

Good strategic workforce planning—will require a strengthened approach within employers to co-ordinate all workforce needs. This has not been strong in the past as the responsibility for education and training budgets largely rested with SHAs, so the new system should strengthen interest and understanding. A five year workforce planning horizon is required to allow for the time between education commissioning and the production of new graduates for non-medical courses. Foundation Trusts (FTs) work on five year planning, but there is uncertainty about funding in the next CSR round.

The delay between commissioning undergraduate medical education and achievement of CCT is significantly longer (five years undergraduate plus two years foundation followed by three to eight years specialty training to certificate of completion of training (CCT). There are pitfalls with long term planning due to service changes as evidenced for example, by a significant number of cardiac procedures now being carried out by interventional radiologists as opposed to cardio-thoracic surgeons.

There are considerable concerns about the high numbers of doctors in training currently and completing over the next three years, when there are limited numbers of service posts becoming available. Work to address this material problem is being taken forward nationally with MEE, DH, CfWI and the Royal Colleges.

Having local partnership groups and various networks does help to raise awareness of this and it is critical that these remain and that there is even greater strategic focus on longer term workforce planning with mechanisms to be fleet of foot when necessary.

23. The impact of people retiring from, or otherwise leaving, healthcare professions

This is taken into account by effective workforce planning and modelling to align with education commissioning.

24. The place of overseas educated healthcare staff within the workforce

This is very limited now due to immigration controls. It is important to enforce regulator standards of language fluency, credentialing of qualifications—the NHS is experienced in doing this. Potential risk of greater recruitment of overseas students by HEIs onto health courses in future to help compensate for reduced commissions and other financial changes in HE. This may pose some difficulty in that overseas students may be willing to pay more to participate in placements, which would disadvantage MPET funded students and apply more pressure to this already difficult aspect of training to organise in ensuring sufficient placements. Whilst non-EU students may have to return to their country of origin, EU students will be in the market, but there will be limited information about them to take account of in workforce planning and education commissioning.

25. How the new system will relate to healthcare, education, training and workforce planning in the other countries of the UK

It will be the role of HEE to link with the other countries of the UK and sector skills councils which cover the UK. Links already exist between UK countries in education commissioning and workforce planning networks, which should be continued.

26. How the public health workforce will be affected by the proposals

This will be part of what the provider led networks/LETBs will do, linking with local authorities. The Public Health workforce is as important as other parts of workforce and will be treated the same. It is important that both specialist and non-specialist public health training is taken into account as non-specialist roles (indeed, the whole healthcare workforce) still have a health promotion responsibility.

December 2011

Prepared 22nd May 2012