Immigration and Social Security Co-ordination (EU Withdrawal) Bill

Written evidence submitted by the Cavendish Coalition (ISSB29)

The Cavendish Coalition is a UK-wide coalition of 36 organisations across social care and health, bringing together employers and unions from the complete spectrum of state, charitable and private providers. The Immigration Bill gives the Government sweeping powers to construct a new immigration system post EU-exit. The coalition is deeply concerned about the effect current Government proposals for this system as set out in the Immigration White paper will have for health and social care provision in the UK and we welcome the opportunity to make a written submission outlining these concerns. We believe a crisis already brewing in the social care sector could be worsened with knock on effects for the NHS and for vulnerable service users and their families.

Executive Summary

§ EEA citizens are a hugely valued and appreciated part of the workforce caring for service users and patients and should be treated as such. It is vital that the government provide reassurance, support and build confidence in the settled status scheme as we leave the EU.

§ Clause 4 of the Immigration Bill, ‘Consequential etc provision’ gives the government Henry VIII powers to repeal or change primary legislation. The Cavendish Coalition is concerned that government intentions for a new system as set out in the Immigration Bill White Paper will worsen current recruitment and retention problems across the social care and healthcare sector.

§ Proposals to lift the monthly cap on doctors and nurses are welcome, but this will not end recruitment issues or shortages. They also do not address concerns for the social care workforce, physiotherapists, paramedics and other allied health professionals.

· Health and social care are already dealing with serious workforce gaps and demand continues to outstrip the supply of staff at an unprecedented rate – despite the workforce having grown.

§ It is expected that the NHS in England alone will need an additional 190,000 workers. Social care has a current vacancy rate of 12.3% and is heavily reliant on EEA workers. Any impact on EEA workers will have a destabilising effect across the health and social care sector.

§ The Cavendish Coalition is also deeply concerned about the proposed £30,000 p.a salary threshold and the impact this would have on recruitment. Many social care and health jobs do not fulfil the requirements for the minimum skills or salary levels of the current non-EEA immigration – it is vital that the £30,000 threshold be reviewed and replaced with criteria that allow our sector to recruit and retain the workers needed to fill gaps in the UK workforce. A future immigration system should use public service value as a key factor in assessing skill levels and setting entry requirements and should not use salary as a proxy for skill.

§ Immigration is not the primary nor the most sustainable solution to resolving workforce gaps – however it would be irresponsible for the government to bring the shutters down overnight on those performing vital services for the public. We want international recruitment to form part of a costed and holistic workforce strategy and are worried that the snap implementation of a new policy could have a destabilising effect on our workforce.

§ It is vital for the health and social care sector that immigration policy supports the delivery of high quality public services – allowing us to remain world-leaders and to meet the needs and expectations of service users across the UK.

Settled status/ EU citizens

1. The coalition have serious concerns over EEA staff finding the UK less attractive to work. In a GMC survey in 2017, 61 per cent of doctors from the EEA were considering leaving the UK. Of these, 91 per cent said Brexit played a part and 45 per cent were considering leaving in the next two years [1] .

2. The Cavendish Coalition are therefore concerned that vital and valued EEA nationals working in the sector are retained. This includes the registration process for settled status to be as easy and smooth as possible, with additional support and reassurance and support for those encountering technical difficulties.

3. We believe more guidance might be needed on the additional documentation required for people awarded pre-settled status and seeking to prove eligibility for settled status.

4. Some NHS staff have reported hesitancy to take part in the settled status pilot due to wider uncertainty with the government and Brexit, and anxiety as to whether they are welcome in the UK.

5. The lack of clarity from the Home Office on reimbursement (both when and how) has been a barrier to continued applications and caused some processing issues for NHS trusts.

6. We want to continue to work with the Department for Health and Social Care and the Home Office to ensure the rollout of the scheme is successful when the scheme is opened to all EEA nationals in March 2019. We are concerned that more needs to be done to raise awareness of the settled status scheme – A BMA survey conducted in November 2018 of over 1,500 EU doctors working in the UK found 37 per cent of EU doctors are not aware of the Government’s 'settled status' scheme for EU nationals. If the scheme is to be a success, the Home Office must significantly increase its communications to EU nationals.

Impact on the health sector

7. Health and social care are already dealing with serious workforce gaps and shortages and demand is increasing. Health Education England predicts that by 2027 the NHS in England alone will need an additional 190,000 workers while current supply would only add 72,000. This will result in a real gap of 118,000 workers in the next 9 years. This means we need an extra 13,100 workers every year. Any impact on EEA workers will have a destabilising effect across the health and social care sector.

8. New research [2] for the Cavendish Coalition by NIESR has exposed the size of the challenge that confronts us:

· in the UK, a little over 5% of the regulated nursing profession, around 9% of doctors, 16% of dentists and 5% of allied health professionals were from inside the EEA

· in 2016, EEA nationals made up 5.4% of the workforce, though in absolute terms their number grew by 68 per cent, or 30,600 individuals, since 2011

· EEA nationals are more likely to work in specialties and locations with weak domestic supply. EEA doctors are well-represented in shortage specialties and there are regional differences in the reliance on EU nationals.

· 67% of EU nationals are working in clinical roles compared to only 50% of the UK staff in the same category. This figure is also 66% for non-EEA overseas staff.

9. The number of EEA nurse joiners to the NHS in England fell by 17.6% in the 12 months following the referendum and the number of leavers rose by 15.3%. The number of EEA doctors has declined from 22,967 in 2012 to 21,609 in 2017 – a decrease of 5.9%. [3] North central London, East of England, South London and Kent, Surrey and Sussex have the highest proportions of EEA nationals both in numbers and share of the workforce [4] .

Impact on the social care sector

10. Social care is particularly vulnerable because it is increasingly reliant on EEA nationals with a 68% increase between 2011 and 2016 – this amounts to 30,600 people. It could not survive without workers from the EU. The sector is already under considerable strain with a vacancy rate of 12.3%.

11. Moving a future EEA workforce to the Tier 2 route will have a massive impact on the sector, with large numbers of highly valued social care colleagues cut off by the proposed salary threshold. IPPR modelled the impact on EEA nationals currently living in the UK and working in social care and found that four in five (79%) of EEA employees working full-time in social care would have been ineligible to work in the UK under the skills and salary thresholds proposed by MAC [1] .

 

12. A one-year visa scheme system to recruit into the social care sector would be highly unsuitable in a sector that is already suffering from high levels of workforce turnover. It would affect the future sustainability of services and see the loss of valuable training and experience. It also undermines the continuity of care, so important for vulnerable service users.

 

13. The sector has been waiting on the Government to publish a long delayed social care green paper for England – a chance to make much needed changes to a sector already struggling to recruit and retain workers before the new rules come in.

Salary Thresholds

14. The current proposal of a £30,000 p.a threshold for ‘skilled’ workers and the one-year only proposal for workers crucial to our sector who earn less than this could have a potentially destabilising effect on our sector. Many social care and health jobs do not fulfil the requirements for the minimum skills or salary levels of the current non-EEA immigration – it is vital that the £30,000 threshold be reviewed and replaced with criteria that allow our sector to recruit and retain the workers needed to fill gaps in the UK workforce. A future immigration system should use public service value as a key factor in assessing skill levels and setting entry requirements and should not use salary as a proxy for skill.

15. We therefore call on government to adjust skills and salary levels to ensure that health and social care provision can be properly staffed by the skilled care staff it needs. The proposal for a short term one year visa for those earning less than £30,000 is extremely disappointing and is likely to lead to additional burdens arising from a high turnover of staff and a waste of investment and training.

16. An important part of responding to the social care crisis is to ensure that funding is available to enable social care to improve their pay offer if they are to be competitive within the social care and health sector – and the wider economy. There is predicted to be a shortfall in funding in social care of £3.5 billion by 2025 although the sector is already consuming 40% of local authority budgets. [2]

February 2019