Response to Department for Education Implementation Strategy consultation - Stable Homes, Built on Love

11 May 2023

Dear Sir or Madam,

As the specialist 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 in the children’s social care strategy (Stable Homes: Built on Love).

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 are offering comments on some areas of the strategy. These are the areas that may intersect with, or impact on, our role and work as a regulator.

This feedback is provides an overview of our areas of interest within the strategy. It also starts to explore areas for further discussion with the Department. We look forward to playing an active role in both the development of the strategy, and its implementation.

We have submitted separate responses to the consultations on:

• the child and family social worker workforce
• the National Social Care Framework

Chapter 2: family help

Family help workers

We are in support of social workers spending more time working directly with children and families. However, we welcome further clarity about who will lead on case holding and risk assessment.

Social workers are the only regulated professional identified. As such, we would recommend that greater clarity is provided on:

• the functions, roles, responsibilities and accountability within family help teams
• how best teams can function well together and understand each other's roles
• how children and families would contact multiple case holders
• if there is to be a single point of contact

Knowledge and Skills Statement for family help workers

We recommend that Social Work England plays an active role in the creation of a Knowledge and Skills Statement (KSS). This is to ensure it aligns with our professional standards for social workers.

It would be beneficial to identify the knowledge and skills of other family help workers (that are not social workers) and how case holding professionals will work together to tailor the support they provide.

We also remain mindful of the crowded landscape of frameworks and standards, which we have publicly committed to simplifying and streamlining through our work.

Chapter 3: Child protection and multi-agency arrangements

National multi-agency child protection standards

We are keen to play an active role in the development of this work. This is to ensure that the principles set out in the National Multi-Agency Child Protection Standards align with our professional standards for social workers.

We would like to ensure that the use of the term ‘standards’ does not cause confusion. This is because we also set standards and requirements as the professional regulator.

As above, we also remain mindful of the crowded landscape of frameworks and standards. We have publicly committed to simplifying and streamlining these through our work.

Child protection lead practitioner role

We note that the child protection lead practitioner will work with family help teams. We would welcome further clarity on whether this would be an additional role within the family help team. Or, whether there would be an expectation that all social workers within family help teams would be child protection lead practitioners.

We would also welcome further clarity on:

• the functions, roles, responsibilities and accountability of child protection lead practitioners
• how teams of child protection lead practitioners and family help workers can function well together and understand each other's roles

We understand the need to strike a balance between national guidance and local implementation. However, the national guidance should provide some level of prescription for clarity in functions and roles. Perhaps this can be developed further through the pathfinders.

Chapter 5: The care experience

Professional registration of the residential childcare workforce

We support the proposal for the registration of this workforce. We would welcome further discussion with the Department on the development of these proposals, and our potential role in this area. We would encourage an exploration of a range of possible innovative models to achieve this.

Strengthen and extend corporate parenting responsibilities

We are interested to learn if the Department intends for this to include further and higher level education providers. For example, colleges and universities. This could intersect with our education and training standards for social work which include requirements for student support.

Chapter 6: Workforce

Apprenticeship places

We welcome the proposal to provide additional funding and support for social work degree apprenticeships. The strategy commits to providing funding for an additional 500 children and families apprenticeship places over 2 years. We would welcome further clarity around this number, and the expected delivery of the funding., This is so that we can be adequately prepared to consider new course approvals, or course changes for apprenticeships via our course monitoring and approval processes. We are currently preparing for the introduction of level 7 (postgraduate) degree apprenticeships. We are monitoring the demand that this could create for new course approvals.

We see a positive opportunity for joint working between the Department and the Department for Health and Social Care on social work apprenticeship provision. This could help to ensure consistency in funding for important aspects of course delivery. For example, practice education and arrangements for practice based learning, such as the provision of contrasting placement experiences.

Apprenticeship programmes offer social work employers and education providers new ways of working in partnership. We look forward to learning more about these programmes as our reapproval cycle progresses.

Practice educators

We have commissioned research into the role of the practice educator in social work, models of practice education across England, and the perceptions of social workers who undertake this role This research will shape and inform our approach to developing a closer relationship with practice educators through regulation.

We are also engaged in external conversations and research about the future of practice education. These are funded by the Department, but delivered by a network of teaching partnerships. We would therefore welcome further discussion with the Department about:

• our development of regulatory standards for practice educators
• our intent to annotate the register for those who choose to take on this important role
• where it intersects with wider ambitions in relation to developing an Early Career Framework

Early Career Framework

We will continue to work closely with the Department on developing an Early Career Framework (ECF).

We will provide expertise, advice and guidance to help ensure that the ECF aligns with our professional standards for social workers. We also want it to build upon our wider work. For example, the development of new guidance on readiness for professional practice. This new guidance will help ensure that all social work students across England graduate with a consistent foundation of knowledge, skills and behaviours. This will support their transition into newly qualified practice. It will also ensure they are prepared to meet our professional standards.

Our engagement and research shows that newly qualified social workers need additional support and supervision. We see this as an important public protection interest in these early professional years.

Implementing an ECF and replacing the assisted and supported year in employment (ASYE) has the potential to create a specialist pathway for children and family social workers. We look forward to exploring further opportunities for enhanced early career support across the profession with the Department of Health and Social Care.

Time in direct practice

We welcome and support the Department’s recommendation that social workers should not have a condition on their registration to spend 100 hours in direct practice. As the strategy outlines, this could cause disruption for children and families and take managers away from important work, such as supervision. We also recognise the important role that social workers play in non-frontline roles.

We will consider how best to collect data on direct practice. This includes considering whether continuing professional development (CPD) is an appropriate way to explore how social workers are using direct practice to support their professional development.

As this is not a mandatory requirement, we will have to consider whether it is proportionate to ask social workers about the time they spend in direct practice, and what our purpose would be in collecting this information.

International recruitment of social workers

We have started to analyse the international recruitment picture in the sector and will continue to develop this in line with: our strategic objectives, and in line with our role as the professional regulator.

National rules for the use of agency social workers

We will continue to engage with the Department (and wider stakeholders) to address social work recruitment and retention issues.

We have provided more detailed feedback on this in our response to the ‘Child and Family Social Worker Workforce’ consultation.

Chapter 7: System enablers

Children’s Social Care National Framework and Children’s Social Care Dashboard

We support the development of the National Framework and dashboard on outcomes for children. We see it as positive step towards understanding what works for children. We also see this as an opportunity to support the consistent application of good practice and effective models of intervention across all local authorities.

We see the National Framework as an important support for the ongoing development of professional standards. We support the approach, which identifies the leadership and practice behaviours that are fundamental to the framework. We also welcome the proposal to make the framework statutory guidance for local authorities as a key aspect of its consistent application.

We welcome our involvement in the National Practice Group. We look forward to sharing our learning, insight and unique perspective. We would welcome representation on the new Social Care Data and Digital Expert Forum, as we are keen to understand which data the Dashboard will collect, and if we could use this to inform our regulation.