20 June 2012

Student fitness to practise: Finding a proportionate way forward

In recent months, we have been examining the most appropriate mechanism for assuring the fitness to practise of students during their education and training. We have undertaken this work because the General Social Care Council (GSCC), the current regulator of social workers in England, holds a register of social work students, as do the other Social Work Regulators in Scotland, Wales and Northern Ireland. In contrast, we do not hold a student register. Instead, we assure the fitness to practise of students through our standards of education and training and the approval of education and training programmes.

We consulted between November 2011 and March 2012 on whether or not a register for student social workers in England should be held by HPC, and whether or not a student register should exist for the 15 professions we currently regulate. We also commissioned an independent literature review.

It was clear from the literature review that student registers are the exception, rather than the norm in professional regulation, both in the UK and elsewhere. Other mechanisms, such as robust standards for educators and placement supervisors, well executed student fitness to practise processes, and holding students to account through standards and guidance on conduct are more commonly used. The review also highlighted the need to educate students about their responsibilities as professionals in training.

In the consultation the majority of those who responded from the social work community thought that registration of social work students should continue. Registration was seen as helpful in providing a ‘safety net ‘ which ensured that consistent decisions were made about the suitability and conduct of students. This was often considered useful in providing additional reassurance to employers accepting students on practice placements.

However, we also heard concerns from social work employers and other stakeholders about some of the current supervision arrangements for social work students on practice placements and in particular, about social work students’ unsupervised contact with vulnerable service users whilst on placement. In contrast, the majority of professions currently regulated by HPC did not think a student register was appropriate, considering that these issues were best managed by education providers in accordance with our standards, assured through our programme approval arrangements.

It seems clear from the consultation that whatever stakeholders’ views on registration, we all want to achieve the same outcome – students who understand the professional responsibilities expected of them and who are fit to practise and equipped to work with service users when they complete their training.

We recently looked at the results of the consultation and the evidence from the review and decided that there should be no new register for the 15 professions we currently regulate. We also agreed that, in the longer term, the most effective and proportionate means of quality assuring the fitness to practise of student social workers in England would be through the HPC’s existing mechanisms. (To read my Guardian article on this click here)

After the register of social workers in England opens in August 2012 education providers will have to meet our standards of education and training. At this time, all the programmes approved by the GSCC will be treated on a transitional basis as if they were approved by us and we will begin scrutinising those programmes to ensure that our standards are met.

These standards will ensure that social work education providers retain overall responsibility for their programmes, including owning and managing the potential risks associated with the character and conduct of students. For example, education providers are required to have arrangements in place for dealing with concerns about students on placements; and have arrangements in place for managing and monitoring practice placements effectively, including ensuring that students receive appropriate supervision and that there is effective partnership working with employers. They also ensure that students understand their obligations under our standards of conduct, performance and ethics.

Many education providers are likely to already meet these requirements. However, we know that the Social Work Task Force  has previously reported continuing concerns about some social work practice placements, so some providers may well find the new requirements challenging to meet.

In our discussions, we were mindful of the potential impact that not registering social work students and applying our standards might have on social work education providers and employers. The Council therefore decided that it would be preferable to introduce interim arrangements over the next two to three years whilst the approval of programmes takes place.

At our meeting on 19 June 2012, we agreed to implement a new process for dealing with concerns about student fitness to practise - a social work student suitability scheme. The key features of this scheme are:

  • There is no HCPC register of all social work students
  • There is a mechanism for referral to us where,
    • in exceptional circumstances, an education provider requires an opinion on whether an applicant is of suitable character to be admitted to a programme.
    • a student has been removed from a programme or has withdrawn from a programme following a complaint
    • an education provider has not dealt with a credible complaint appropriately.
  • Students who have complaints upheld via the scheme may be placed on a list which would prevent them from being admitted to, or participating in, a social work programme.

 The scheme has several benefits. It provides a transitional ‘safety net’ of a kind that social work stakeholders have suggested is necessary. It will allow educators, employers, colleagues and members of the public, to refer their concerns to the regulator during the transition to HCPC standards. It is proportionate, in that it only affects those students and prospective students who are a cause for concern. It will send a clear message to educators that they are responsible for ensuring that student fitness to practise is managed and quality assured according to HCPC standards.

We have listened to the concerns expressed by social work stakeholders, and we are conscious of the huge changes that are underway in the social work profession. Our aim is to work with the social work community to drive up standards. HPC has a good track record in quality assuring education and training programmes through its standards of education and training and approvals process. Ultimately, these standards will apply across all social work programmes. But this will not happen overnight. The suitability scheme does not compromise the role or purpose of HPC’s standards, but does provide a proportionate mechanism to mitigate risk and allow time for change.

 Anna van der Gaag