Response to Department for Education Child and Family Social Worker Workforce consultation

11 May 2023

Dear Sir or Madam,

As the regulator for social work, we welcome the opportunity to comment on the Department for Education’s (‘the Department’s’) proposals to reform children’s social care and the child and family social worker workforce.

I hope the Department finds this feedback helpful.

Yours sincerely,

Colum Conway
Chief Executive

Consultation feedback

We are not providing answers to the consultation questions provided by the Department. Instead, we provide feedback on some areas of the consultation. These are the areas that may intersect with, or impact on, our role and work as a regulator.

We have submitted separate responses to the consultations on:

• the children’s social care strategy: Stable Homes, Built on Love
• the National Social Care Framework

National rules

We recognise that introducing a set of national rules would improve the stability of the social work workforce. In turn, this should lead to more consistent support for those accessing social work services.

We would welcome the Department extending this proposal to the whole social work workforce (not just children and families). Without a whole profession approach, consideration should be given to the potential impact of implementing rules for only half of the profession. This could affect the profession as a whole.

We see the need for agency staff, and recognise the important contribution they make in supporting the profession and people with lived experience. However, agency work is costly for employers. Plus, the high turnover of staff can disrupt the support that people receive. This in turn creates potential risk to the public.

Social workers can frequently move between agency roles. This also makes it more challenging to identify and address practice issues. There are examples of such situations within our fitness to practise caseload. As such, we support the introduction of rules.

Price caps

We support the Department’s proposals around price caps. These proposals suggest that greater consistency in pay is likely to contribute to a more stable workforce, with less costs than the current system.

Savings made may mean employers could allocate funds to other resources that support children and families. We welcome clarity on who will have oversight of these proposals. This will ensure compliance and consistency.

Post-qualifying experience

The Department has proposed a requirement for qualifying for an agency appointment. This requirement is that social workers must demonstrate a minimum of 5 years post-qualified experience. We support this proposal.

The first years of practice are crucial to a social worker’s development. All newly qualified social workers (NQSWs) should receive additional support from their manager and employers during that time.

If this is to become a requirement for NQSWs graduating in England then it is reasonable to suggest the same should apply for international NQSWs. International recruits also need support with the challenges of joining the workforce (as well as relocating).

There is some concern that if this rule only applies to children and families social workers. then NQSWs may choose to work in another area of social work (adults services for example). They may do this to avoid waiting 5 years to work as an agency social worker.

Project teams

We acknowledge the risks of fragmenting or outsourcing aspects of the social worker role. This can lead to:

• unclear accountability and decision making
• reduced quality assurance

These have the potential to create risks to the public. We therefore support the Department’s proposal to no longer engage project teams in child and family social work.

Data and monitoring

We support increased data collection. This would provide useful insight into areas of children and families social work that are currently unclear.

Collecting and sharing this data will allow for the effective monitoring of some of the national rules laid out above. For example, consistency of pay rates and use of the market.

The creation of the National Framework and Dashboard will bring greater insight and clarity. It will also ensure greater consistency in data across local authorities.

General comments

As the regulator for all social workers in England it is appropriate to note that the proposed national rules only cover children and families social workers.

Other employers of social workers (such as CAFCASS) engage agency staff, as do Adults services.. We advocate for national rules that apply to all employers of social workers. This will create a consistent and effective solution to the issues caused by the agency market.

Limiting the national rules to one section of the profession could lead social workers to move into other areas of social work that do not have to adhere to a set of rules. This presents a potential risk to effectively addressing the vacancy issues in children and families social work.

There is a further risk that introducing national rules will lead to more social workers leaving frontline child and families roles (and potentially the register). In particular the rules around price caps. Coupled with the rising cost of living, price caps may mean that agency social workers decide to leave for higher paid roles in other sectors.

Through our engagement, we’ve heard that outdated recruitment practices may also influence a social worker’s decision to move to an agency role. We think this should also be addressed in parallel to this work.

We are already engaged with the Department on aspects of the implementation strategy. We welcome the opportunity for further discussions and to provide further feedback on the proposals.