The Royal College of Speech and Language Therapists consultation response to the Department of Health consultation: Changing how healthcare education is funded Question 1: After reading the list of impacted undergraduate and postgraduate courses, are there further courses which you think should be included in the scope of the reforms? If yes, what are these courses and why would the current funding and delivery models require their inclusion? N/A Question two: Do you have any views or responses that might help inform the government s proposed work with stakeholders to identify the full set of postgraduate healthcare courses which would not be eligible for a postgraduate masters loan and to consider the potential support or solutions available? The RCSLT believes that it essential to maintain and support the diversity of pre-registration postgraduate course provision and is disappointed that students studying for healthcare preregistration postgraduate diplomas will not be eligible for postgraduate loans. The Department of Health s (DH) proposals have already begun to affect the design of future pre-registration postgraduate course provision. Due to concerns that the planned funding changes may affect funding for pre-registration postgraduate diplomas, several universities are developing plans to convert their speech and language therapy pre-registration postgraduate diploma courses into masters. Whilst this may be an unintended consequence, we are concerned that this will narrow the pre-registration postgraduate offer for speech and language therapy courses. We would welcome the opportunity to further discuss with the Department for Health which courses are eligible for pre-registration postgraduate masters loans and funding arrangements regarding pre-registration postgraduate study more widely. For course providers we consider that: There is an urgent need to provide clarity regarding funding arrangements for universities, including the additional teaching grant administered via HEFCE, and for the DH to address the shortfall between the tuition fees paid by students and the actual costs to train students to qualify as a speech and language therapist (SLT) on a pre-qualification programme. 1
The maximum loan amount that pre-registration postgraduate masters students are able to access (up to 10,000) needs to be reviewed as it will be insufficient to cover even one year s tuition fees for a speech and language therapy masters course which are on average two years and go beyond the length of the normal academic year. More broadly we are concerned about the assumptions used to benchmark fees and overall costs for healthcare and non-health care courses. Healthcare courses are generally more intensive and involve clinical placements which mean that students are unable to take on part-time work and earn extra money which can help to support their studies, unlike the majority of students on non-healthcare courses. For potential students we are concerned that: The repayment arrangements for pre-registration postgraduate loans, which will be made concurrently alongside repayments of any outstanding undergraduate loan unlike students who take on a second undergraduate loan, are likely to serve as an additional deterrent to pre-registration postgraduate study. Due to high levels of debt aversion amongst mature students and students from disadvantaged backgrounds, without effective measures to address barriers to participation in higher education, there is a high likelihood that the move to a loans system will lead to a decline in applications by students from these groups. Question 3: We think that operating the exemption will support the objectives for encouraging second degree students to undertake nursing, midwifery and allied health courses. Are there any other options, which do not include an NHS bursary that could be considered? We welcome the introduction of an exemption which will allow students who are planning to undertake nursing, midwifery and allied health professional subjects as a second degree to access the standard support system. However, we would welcome clarification from the DH as to why pre-registration postgraduate loan repayments will be made concurrently alongside repayment of any outstanding undergraduate student loan, whilst students who take on a second undergraduate loan will only be required to make repayments on the second loan once the balance of the first loan has been repaid. We urge the DH to revise financial support arrangements for postgraduate pre-registration courses to bring student support for these courses in line with those undertaking second undergraduate degrees in these subjects. Question 4: Are there circumstances, as set out above or otherwise, in which the standard student support system which would be available for nursing, midwifery and allied health students would be inadequate or limit participation? Why is this? We are specifically interested in cases where an individual s circumstances mean that they would not fully benefit from the increase in living cost support or to the same extent as other students. 2
The comparison of current student support rates outlined in the consultation document indicates that increased living cost support will be made available to students under the proposed student loans system. However, it is important for the DH to consider wider issues that may limit students participation in higher education more broadly, for example: - Mature students and students from disadvantaged backgrounds tend to be more debt averse and may be deterred from applying for healthcare courses due to the prospect of having to make large loan repayments. One in five of RCSLT members who responded to our student survey on reforms to healthcare education funding provided qualitative feedback expressing that they would have been unable to afford their studies without the NHS bursary and/or would be reluctant to do their course had a loans system been in place. - The low levels of financial support proposed for postgraduate students may lead to a decrease in the number of mature students and students from disadvantaged backgrounds who apply to pre-registration postgraduate speech and language therapy courses. We urge the DH to revise financial support arrangements for postgraduate pre-registration courses to bring student support for these courses in line with those undertaking second undergraduate degrees in these subjects. - The level of financial support available to students with dependents will also act as a barrier to mature students participation in higher education. We are disappointed that paragraph 3.33 of the consultation document lists a number of cases where students may receive lower allowances under the standard student support system at current rates. We urge the DH to cover informal living costs associated with raising children (such as food, accommodation and clothing) as well formal childcare costs as part of dependents allowances and welcome clarification as to whether pre-registration postgraduates will be able to access these allowances. Question 5: Do you agree that increasing the available support for living costs typically by around 25% or more, and enabling these students to apply for additional funding through the allowances on offer from the Student Loans Company, would ensure that we continue to have a diverse population of students? Whilst the support of living costs is helpful, we do not think that it will ensure a diverse population of students. It is important for the DH to acknowledge that regardless of the increased living cost support available to students while they are studying, some students may be deterred from studying due to the prospect of having to repay large loans following graduation. RCSLT s student members have directly raised concerns about incurring large debts and reported that they would not have applied for their course under the loans system: The NHS funding was crucial in enabling me to undertake my studies. Especially as a mature student with children. I would not have wanted to take on a large student loan. RCSLT student survey respondent 3
Factors that may result in a decline in applications from students from diverse backgrounds and could threaten the diversity and quality of the SLT student population and the future SLT workforce include: Debt aversion amongst mature and disadvantaged students Reduced access to financial support for students with child dependents (the consultation document notes a number of specific cases where the BIS allowance is not higher, or at the same level than that available under the NHS Bursary Scheme). The prospect that students will have to make a substantial contribution towards the costs of travelling to placements and placement accommodation costs are not covered in the Government s proposals. It is essential that the DH designs effective mechanisms to mitigate risks of a decline in applications by these students and support their participation. Question 6: Are there specific factors relating to healthcare students which you consider we need to take account of in relation to the discretionary maternity support provided by the student support system? N/A Question 7: Are there any other measures which could be considered to support our principles of fair access? We encourage the DH to consider barriers to higher education faced by mature students, students from disadvantaged backgrounds and students with dependents. In addition to our responses to questions above, we would like to reinforce the need for the DH to review the level of financial support available to students during clinical placements. We object to the proposal that students should contribute an excess of around 300 towards their placement travel costs before costs are reimbursed this is unfeasible for students from disadvantaged backgrounds and reflects a lack of understanding of how placements operate. We urge the Government to urgently reconsider this proposal. We ask the DH to provide clarification on whether accommodation costs that students incur during placements will be covered as part of the proposals. Under the NHS bursary scheme, students who have to stay in temporary accommodation in order to attend their placement are able to apply for a reimbursement of their accommodation expenses. Placements both in and outside of university regions can require a large amount of travel and overnight stay, for example, for students at the University of St Mark and St John in Plymouth a placement within the region can necessitate a two to three hour journey each way and the use of overnight accommodation. We recommend that the DH continues to provide financial support towards the costs of accommodation, as block placements can be extremely expensive. The prospect that students will have to pay for temporary accommodation, whilst continuing to pay for their 4
permanent accommodation at home (and pay towards travel costs) will be impractical for many students, particularly for those who are from disadvantaged backgrounds or who are mature students. Question 8: Do you think that the potential options for those new part-time students commencing courses in 2017/18 will support students in continuing to undertake these courses in this transitional period? YES NB: YES/NO response only Question 9: Do you think that moving all new part-time students onto the Department for Business, Innovation & Skills (BIS) student support system for both tuition and living cost support through the Student Loans Company from 2018/19 will continue to encourage part-time students to undertake these healthcare courses on a part-time basis? If no please set out details of further supporting action you consider may be necessary by the government for students commencing courses from 2018/19 onwards. (Any options including the ongoing use of an NHS bursary or changes to the student support system will not be considered) Yes, we welcome plans to extend financial support to part-time students. Question 10: Do you have any general comments on the content of Chapter 2 (the case for health education reform) that you think the government should consider? We are concerned that chapter two, and the consultation document more generally, is nursecentric. It is important for the DH to note that many of the benefits outlined in the case for health education reform do not apply to allied health professionals. For example, SLTs are not on the NHS staff shortage list and the use of overseas staff is not a significant concern for our profession. We urge the DH to recognise the unique characteristics of, and different challenges affecting, pre-registration education courses across the allied health professions and to publish data and modelling of how the reforms will affect speech and language therapy students. We challenge the DH s statement that the reforms will improve access to a greater supply of domestically trained health professionals as at present we are concerned that the Department s draft proposals will adversely affect the diversity of applicants for SLT courses and the future SLT workforce. The low level of financial support that is currently proposed for pre-registration postgraduate students is likely to a cause a dip in pre-registration postgraduate student numbers which could be detrimental to the short-term supply of SLTs in the NHS and the delivery of Government priorities such as a shift of care into community 5
based settings as outlined in the NHS Five Year Forward View and the healthcare leadership agenda more widely. Question 11: We would welcome respondents views on how, in delivering these reforms, we look at the widest possible solutions to ensuring high quality clinical placements. These views will actively inform further stakeholder engagement prior to the government response. We are pleased that HEE plans to consult with the RCSLT and other professional bodies on arrangements for clinical placements and how extra clinical placement capacity can be created. As part of the formulation of these proposals we encourage HEE to take account of: Placement quality and diversity: Quality assurance and ensuring that all students have access to good quality practice placements is key. Within the speech and language therapy profession, the diversity of placements available to students is also integral to the quality of placement provided. The RCSLT s Guidelines for Preregistration Programmes require course providers to include sessions with paediatric and adult client groups and universities organise a range of placements so that students gain experience of working in a variety in both acute and community settings. The non-nhs workforce: HEE s workforce planning process assumes a primarily NHS-based workforce; however, there is a need to take account of the non-nhs workforce and placements in non-nhs settings. A potential conflict may arise if the number of placements assessed as required by HEE is lower than the actual number of placements required to meet the needs of the students and professional body requirements. This poses a risk for HEIs, as the funding arrangements for placements remain very opaque, particularly in the case of a discrepancy in assessed need. Possible unintended consequences of the new system: HEIs have expressed concern that the need to increase the number of student placements in the future may create competition and tensions between current education providers, as they may have to compete with one another for limited placement capacity and new providers as they emerge. University staff have suggested that this could pose a risk to placement quality and patient safety if (due to external pressures) providers begin to consider using placements which are not fit for purpose. We encourage HEE to consider how it might govern such a matter, and respond to wider concerns of HEIs such as worries regarding how the logistics of payment to placement providers might work under the new clinical placements system. We urge the DH to review its proposal that students should contribute an excess of around 300 towards their placement travel costs before costs are reimbursed and recommend that 6
the DH continues to provide financial support towards the costs of accommodation during clinical placements. The prospect that students will have to pay for temporary accommodation, whilst continuing to pay for their permanent accommodation at home (and pay towards travel costs) will be impractical for many students, particularly for those who are from disadvantaged backgrounds or who are mature students. Question 12: What more needs to be done to ensure small and specialist subject provision continues to be adequately provided? N/A Question 13: Do you have any general comments on the content of Chapter 4 (social work) which you think the government should consider? N/A Question 14: Do you have any further comments on this consultation which you think the government should consider? The Royal College of Speech and Language Therapists (RCSLT) is aware that to date the funding settlement for universities and students has been insufficient and there is a need to develop a more sustainable system which offers improved financial support. However, the DH s decision not to involve speech and language therapy course providers and the RCSLT in the development of its proposals prior to the publication of the consultation, has meant that many of the plans outlined in the consultation document 'reforming healthcare education funding do not reflect the reality of speech and language therapy course provision and/or address key challenges faced by students and university staff. We ask the Department to consider the RCSLT s immediate issues of concern as summarised below: The overall content of the consultation: We are concerned about the lack of specific financial modelling and information regarding the impact of the reforms on allied health professionals. The proposals emphasise an increase in the number of student places but do not appear to recognise the constraints created by placement capacity and the importance of quality and values based recruitment. More broadly, we urge the DH to further consider the non-nhs workforce as part of workforce planning and the wider implications of the healthcare funding reforms for the supply of speech and language therapists (SLTs) in other sectors. As highlighted by the National Audit Office s recent review of the supply of NHS clinical staff, it is important to acknowledge the importance of the non-nhs workforce. Due to government policy regarding the provision of services by a plurality of providers, a growing number of SLTs are employed within schools, justice, private practice and the voluntary sector. Pre-registration postgraduate courses: The chapter on postgraduate study in the consultation document does not reflect the reality of course provision (most preregistration postgraduate courses are two years rather than one year). The level of financial support the DH proposes to make available to pre-registration postgraduate students (up to 10,000) will be insufficient to meet students tuition fees and living 7
costs, and there is a real risk that the viability of pre-registration postgraduate programmes will be threatened due to a shortfall between university funding and course costs and therefore become less attractive for institutions to offer. The combination of limited financial support, high levels of debt aversion amongst mature and disadvantaged students and a repayment arrangement whereby postgraduates will have to concurrently repay postgraduate loans alongside repayments of any outstanding undergraduate student loan (unlike students undertaking a second undergraduate degree) are all factors that will make preregistration postgraduate study less desirable. The overall consequence is likely to be detrimental to the supply and diversity of postgraduate students and could result in pre-registration postgraduate routes only being accessible to students from wealthy backgrounds. Clinical placements: The proposal that students should contribute an excess of around 300 towards their placement travel costs before costs are reimbursed are inappropriate and impractical for students from disadvantaged backgrounds. We are also disappointed that the consultation document does not reflect accommodation costs for placements which are outside of the university region or reference the importance of maintaining the quality and range of placements on offer to secure the relevant experience and skills required by the SLT profession. The prospect that students will have to pay for temporary accommodation during their placements, whilst continuing to pay for their permanent accommodation at home (and pay towards travel costs) will be impractical for many students. Access and affordability: We are concerned about access to and the affordability of speech and language therapy courses under the proposed changes to healthcare student funding. Debt aversion amongst mature and disadvantaged students, reduced access to financial support for students with child dependents and the prospect that students will have to make a substantial contribution towards the costs of travelling to placements are factors that may result in a decline in applications from these groups and could threaten the diversity and quality of the SLT student population and the future SLT workforce. It is essential that the DH designs effective measures to mitigate risks of a decline in applications by these students and support their participation. System architecture: We are disappointed with the lack of detail in the consultation document regarding the system architecture that will underpin the higher education reforms. Whilst we are aware that controls on student numbers will be removed under the new system, it is unclear how pre-registration education will be linked to workforce planning in the future and if, or how, the DH might address a future imbalance in the supply of health students in relation to patient demand. Whilst the move from bursaries to loans will bring undergraduate healthcare students funding arrangements in line with their peers studying other subjects, it is important for the DH to recognise the distinction between healthcare professionals and other professions and their role in securing NHS England s vision of high quality care for all in future generations. The timings of the consultation and implementation: We are concerned that the current timescales for implementation of the reforms, as they are unrealistic and place university courses providers in an untenable position. The current lack of information regarding funding arrangements is hindering speech and language therapy course providers ability to plan and provide clear information to prospective students, which could cause a dip in applications. Furthermore, uncertainty regarding funding 8
allocations could mean that courses considered at risk of a funding shortfall may be temporarily suspended, or rested for a year, whilst funding arrangements are resolved. Whilst we recognise that universities need clarity regarding funding arrangements as soon as possible, we believe that the DH s ambition to publish the Government s consultation response before the parliamentary recess provides insufficient time for proper consideration of submissions made by key stakeholders, such as students, universities and professional bodies to support its implementation. 9