Health CommitteeWritten evidence from the Allied Health Professions Federation (ETWP 107)


The Allied Health Professions Federation (AHPF) is a federation of twelve Allied Health professional bodies representing over 130,000 professional members across the UK of whom 84,000 work in the NHS in England.1

The purpose of the AHPF is to promote the value of AHPs and integrated professional working. The AHPF believes that AHPs, as key specialist clinicians, are an essential part of the health and care workforce who are well placed to deliver high quality care to patients, clients and service users across the whole of the health and social care sectors. The AHPF also believes that in the emerging health and social care environment there will be a need to involve AHPs in all spheres of decision making and therefore maintaining and developing professional expertise over time will be important to ensuring the sustainability of the system.

The AHPF is uniquely placed to draw on the expertise and experience within the professional bodies in order to inform and engage with consultations, issues and opportunities impacting upon Allied Health Professionals across the health and social care sectors.

This consultation response has been put together on behalf of the whole of the AHPF by the Education Leads within the federation. It has deliberately been confined to broader comments. Individual professional bodies have submitted separate responses where a profession specific response adds value to the consultation process.


1. Our primary points can be summarised as concerns about the following:

The continued trend for student commissions for the allied health professions (AHPs) to decrease; for some professions, this has been up to 30% over recent years, with there being no assurance that cuts will be halted.

Cuts to AHP student commissions do not fit with the strong case for increasing, or at least maintaining, student numbers, based on the professions’ contribution to meeting patient and population needs and helping to address government-identified health care priorities in clinically—and cost-effective ways (eg in areas of health promotion and illness prevention, management of long-term conditions, and addressing the needs of an ageing population), and their being excellently placed to lead the integration of services across sectors and settings, deliver care closer to home, and minimise hospital re-admissions.

2. Our more detailed points relating to these concerns are outlined below, with an indication of how each relates to the Inquiry’s themes.

Appraising Workforce Needs

Forecasting future workforce needs/Role of Centre for Workforce Intelligence

3. We have particularly strong concerns about how far projections of future workforce needs are currently being based on high-quality data and how far the data that is being obtained is being subject to high-quality analysis. Both quality data and analysis are essential if an evidence-based approach to workforce planning and decision-making can be achieved. Within this, fulfilling projections of patient and population needs in clinically- and cost-effective ways must be put to the fore, with realistic forecasts made of workforce requirements predicated on evidence of need and taking account of skill mix. We lack confidence that this approach is currently being taken by the Centre for Workforce Intelligence through its contractual role with the Department of Health.

Forecasting future workforce needs/implications of more diverse provider market/requirements of NHS and non-NHS healthcare providers

4. Related to this, we have strong concerns that AHP workforce needs across the whole health care economy are not being factored into commissioning decisions, despite rapidly changing models of service delivery; as patient care is delivered increasingly outside the NHS—and with NHS-funded care set to be delivered by increasingly diverse providers under enactment of the “any qualified provider” (AQP) policy—there is increasing risk that only partial account will be taken of workforce needs, exacerbating a shortfall in supply.

UK context/requirements of NHS and non-NHS healthcare providers/public health workforce

5. There is an on-going risk that student commissioning arrangements and decisions do not take account of the AHP professions being a national (UK-wide) workforce, having important roles that extend beyond the purely clinical (including leadership and management, education and research roles) and having a significant and vital role to play across sectors and broad policy areas in meeting population needs and addressing government priorities (including public health, social services, education, criminal justice and industry).

Forecasting future workforce needs/implications of more diverse provider market/requirements of NHS and non-NHS healthcare providers

6. Current financial pressures are impacting negatively on staffing trends and hiding workforce needs and scope for workforce development: as senior posts are downgraded and frozen, this is eroding services’ capacity to take on newly-qualified AHPs and AHP students on placement; in turn, this is impeding the development of sustainable staffing and service models focused on delivering high-quality patient care and with strong clinical leadership. This is likely to have a direct and adverse effect on the quality of patient outcomes and experience and on productivity (including in relation patient waiting times and admission and re-admission rates).

Forecasting future workforce needs/international context

7. Insufficient account is being taken of the international context of workforce planning relating to AHPs (and health professionals more broadly). Projected shortfalls in some countries and within the European Union need to be factored in, so that a full understanding can be gained of how these labour markets will affect supply and demand and migration patterns in ways that will impact on how the UK is able to meet its workforce needs (recognising the traditionally strong reliance upon overseas-qualified health professionals to fulfil staff needs in the NHS).

Education to Meet Workforce Needs: Quality and Sufficiency


8. There is a strong risk that current health care and higher education reform in England will combine to have a significant and destabilising effect on the commissioning process and the on-going development and delivery of AHP education. We are particularly concerned that the level of uncertainty and volatility created (including by fragmented decision-making regarding commissions, and the pursual of an “open market” approach to competition within higher education) will erode the quality, sustainability and sufficiency of AHP education provision and lead to achievements over recent years unravelling (including the development of strong arrangements for inter-professional education as a platform for future practice, and mutually-beneficial links between AHP education and research and between higher education and clinical services in support of education, research, continuing professional development [CPD] and service evaluation and innovation).


9. There is a particular trend currently for part-time and flexible study AHP routes to be de-commissioned. This works against the fulfilment of the agenda—which AHPs strongly support—of widening participation in higher education and broadening entry to the professions.

Implications of more diverse provider market/requirements of NHS and non-NHS healthcare providers/quality/funding protection and distribution

10. There is the strong risk that opportunities for practice-based education—a crucial element of AHP students’ preparation for safe professional practice—will become increasingly limited as service provision becomes more fragmented. There is the related risk that students’ practice-based learning opportunities will fail to reflect future practice contexts, especially if contractual requirements for AQP do not oblige all service providers to contribute to educating the future workforce. It is therefore essential that criteria and contracts for AQP define this contribution to educating the future workforce (through provision of practice-based learning opportunities and/or payment of a levy). If not done, there is a strong risk that the overall quality and sufficiency of practice education will be significantly compromised.

Quality/funding protection and distribution

11. There is an increasing risk that opportunities for high-quality CPD for qualified and support staff will be compromised by planned commissioning arrangements and the proposal simply to leave support for CPD to employers. Again, this will impact negatively on the quality of patient care and outcomes and services’ long-term productivity and sustainability.

Future healthcare workforce needs/overseas-educated staff

12. There is a growing trend for individual HEIs to recruit increasing numbers of self-funding international students onto AHP qualifying programmes as a way of shoring up student numbers and programme viability. However, this is unlikely to contribute to meeting future workforce needs in England (or the UK), thereby exacerbating further shortages in meeting workforce needs (please also see our point 8 above).

Governance and Structural Issues

Transition arrangements/HEE/LETBs/funding protection and distribution

13. While we recognise that the full detail of new structures and processes are yet to be fully worked out, we have strong concerns about governance and lines of accountability in what has so far been put in place. In particular, we are uncertain about how the role of Health Education England will be enacted to ensure that the local education and training boards (LETBs) are duly accountable for the workforce commissioning decisions that they make (and, as part of this, have a clear and common status). Our concerns on this front are fuelled by the apparent disjuncture between the HEE’s planned policy remit (all levels of education, for the whole workforce) and the much more limited oversight it will have in terms of how funds are used (only in relation to entry of qualified personnel to the workforce).

Transition/quality/development of curricula/outcomes framework

14. We welcome the strong emphasis on ensuring quality in health care education, and its development and relevance to meeting changing patient and service delivery needs. However, we are unsure from developments to date how the quality of education will be enhanced and assured (particularly when so many factors of reform are set to erode quality through the volatility and uncertainty that they are creating). Related to this, we are concerned that the central role that professional bodies have to play in enhancing and assuring the quality of health care education, including through providing strong leadership in curriculum development, is being ignored. At the same time, we are concerned that the proposed National Education & Training Outcomes Framework yet has a cohesive approach, and are uncertain about what its implementation will achieve, without modification, in strengthening quality.


15. We are also strongly concerned that the voice of AHPs will not be sufficiently heard within the new workforce planning and commissioning arrangements (including HEE and the LETBs) in ways that will impact negatively on the completeness and quality of decision-making.


16. There is a risk of increasing uncertainty and volatility in workforce planning as established (SHA) arrangements unravel before new arrangements are fully defined and implemented. This risks disjointed, partially-informed commissioning decisions being made that will compromise the quality and cost-effectiveness of patient care.

Roles/quality/funding protection and distribution

17. We recognise that different models for education for different professions have developed over time, with inevitable variations arising for a host of historical reasons. However, we see a strong value in achieving greater parity and equity in how professions, including the AHPs, are supported and funded, with this approach being extended to include the smaller health professions (eg the arts therapies) that are not currently funded through Multi-Professional Education & Training (MPET) monies, but that have established roles in many services. The new arrangements—which apparently have the principles of patient need, quality and “level playing field” at their centre—provide a prime opportunity to seek to achieve equity and parity.

December 2011


The Allied Health Professions Federation (AHPF) member organisations are:

The Society of Chiropodists and Podiatrists (SCP).

The Society and College of Radiography (SCoR).

The Royal College of Speech and Language Therapists (RCSLT).

The College of Paramedics (COP).

The Chartered Society of Physiotherapy (CSP).

The British Association of Occupational Therapists/College of Occupational Therapists (BAOT, COT).

The British and Irish Orthoptic Society (BIOS).

The British Association of Prosthetists and Orthotists (BAPO).

The British Dietetic Association (BDA).

The British Association of Drama Therapists (BADT).

The British Association of Art Therapists (BAAT).

The Association of Professional Music Therapists (APMT).

1 See Appendix for full list of member organisations

Prepared 22nd May 2012