CPD consultation response

25 November 2019

• Introduction
• How we consulted
• Who responded
• What you said
• What we did
• What else you told us
• What happens next
• Equality impact assessment

Introduction

As the new specialist regulator for social workers in England, our purpose is to protect the public and raise standards across social work so that people receive the best possible support whenever they might need it in life.

We take over from the current regulator, the Health and Care Professions Council, on 2 December 2019. In preparation, we’re speaking with those who have an interest in our work so they can help shape the regulator we’ll become.

Following our consultation in early 2019 on our rules and standards, on 7 August 2019 we launched a 10-week public consultation on our approach to continuing professional development (CPD). The following is an overview of the consultation, including a summary of our activity, who responded and the feedback we received.

What is CPD?

CPD is the reflection and learning activity that social workers undertake throughout their career to maintain and improve their practice. By undertaking and recording CPD, social workers demonstrate to us and the public that they uphold our professional standards and continue to remain fit to practise. For social workers on our register, demonstrating that you meet our CPD standard sis a requirement of maintaining your registration with us.

Our approach

In consultation with social workers, we’ve developed an approach to CPD that puts an emphasis on reflection and the impact of learning on practice. We’re also keen to learn more about the ways social workers are learning. This will help us to inform our approach to CPD, including how we validate and how CPD can support social workers to raise standards, and will be the focus of our first year as the social work regulator.

As part of this work, we’ll talk to social workers and others interested in social work throughout 2020 to examine what we’ve learned so far and to consider our proposals for CPD from December 2020 onwards.

How we consulted

We first considered our approach to CPD as part of our rules making and standards setting work in Spring 2019. We discussed CPD at our public consultation events, sought advice from our professional experts and experts by experience groups, and analysed responses from our online surveys. We then used this feedback to develop a process that formed the basis for our CPD consultation.

People and organisations were able to provide feedback for the CPD consultation in a number of ways:

• We asked targeted questions in an online survey;
• We invited feedback via email, post and social media;
• We held workshops with professional experts and professional regulators;
• We attended events and workshops across the country;
• We consulted with our regional engagement leads.

Consultation methodology

We counted, read and analysed every response to the consultation. We received 216 responses, 20 of which were from organisations.

In the online survey we asked the extent to which people agreed with our proposals. Respondents could rank their level of agreement on a scale from 1 (strongly disagree) to 5 (strongly agree). We also asked two questions with free text boxes to capture any additional comments or information. The scale helped us to understand how much people approved of the process we proposed and the comments helped us consider areas for change and improvement.

As well as the survey, we collated and analysed feedback from workshops and events, as well as feedback we received by email and through our social media channels.

All the consultation feedback was considered and recorded and help us to review our CPD process.

Who responded

Most individual respondents described themselves as coming from an adult or children’s social care background. Most responses from organisations came from employers, educators and the third sector.

Individuals respondents by role in social work

• Adult social care - social worker: 73
• Children's social care - social worker: 44
• Other or not stated: 21
• Children's social care - other: 12
• Mental health services: 11
• Adult social care - other: 8
• Charity or non-governmental organisation: 7
• Higher education institution/academia: 7
• Local authority: 5
• Prefer not to say: 2
• Other health services: 1
• Social Work Student: 1

What you said

Here, we provide a summary of the feedback we received about our CPD proposals.

Respondents generally approved of our approach with an average approval rating of 4.0 out of 5.0. The draft proposal was largely well received, and respondents were supportive of the phased approach to CPD, supporting our commitment to ongoing review and improvement.

This view was echoed by organisations such as the British Association of Social Work (BASW) and the Professional Standards Authority who welcomed our commitment to building an evidence-based approach to future developments for CPD in social work.

Many respondents felt that it’s important for social workers demonstrate how the CPD they undertake is relevant to their role, that they describe the impact it has on their practice and describe how it has benefitted those with lived experience. Some thought that it’s important to require a variety of types of CPD a social worker records and that we recognise the importance of all types of CPD, not just formal training. Some, including BASW, believe this flexibility is essential.

Many thought examples of CPD would be helpful and we hope to provide those as we learn more about the CPD that social workers carry out and record.

Other responses, both online and via email, expressed concerns over duplication of the process with local CPD requirements, but appreciated the flexibility to record their CPD in numerous ways and formats which will allow social workers to upload CPD recorded elsewhere. BASW advised that we make it clear that the process involves uploading CPD annually, not just over the first year.

When asked about the validation process, social workers said they want a process that’s easy, transparent and quick, and does not require any additional submissions at validation. Feedback from organisations such as from the National Institute for Health and Care Excellence (NICE) and BASW asked for a validation process that’s co-produced with groups including people with lived experience, employers and social workers.

Many people asked for guidance on how to demonstrate the standards. Some respondents felt it would be necessary to consider the settings in which social workers work, where, for example, they may be the only social worker in their team. Others felt that the process should take into account the specific designated role of the social worker, such as managers or educators, where they felt it may be more difficult to demonstrate some of the CPD standards.

Social workers mainly approved of the requirement to record their CPD online, despite some concerns over security and the General Data Protection Regulation (GDPR). Many believed the new recording system would make recording CPD ‘on the go’ easier which social workers felt accommodated their busy work and time demands.

What we did

We listened carefully to all the feedback and, given the overall support for our approach, will use the first year of regulation as an opportunity to learn more about social workers and their CPD.

We’ll also talk to those with an interest in social work throughout our first year to develop our process for 2021.We’ve changed the language around the amount of CPD required after receiving concerns that ‘at least one piece of CPD’ may be misinterpreted as only having to record one piece.

Our intention is actually to encourage social workers to record a minimum of one learning activity but to regularly record their learning throughout the year. We’ll ask social workers to record their CPD on their Social Work England online account but ask those who feel they can’t use this method to contact us to discuss their concerns and potentially find an alternative. We listened to feedback requesting a flexible approach to recording CPD and designed and developed template options to suit a variety of recording methods.

We changed some of the terminology in the evaluation process, now referring to it as ‘validation’ instead of ‘evaluation’. This is a more accurate term for the process we have described. We also changed ‘determine’ whether a social worker continues to meet the professional standards, to ‘check’ that they do, and defined what that looks like as part of our validation process.

We’ll continue to select 2.5% of the register for validation and social workers responded positively to their being no additional administrative requirement as part of the process.

We’ve written guidance for all aspects of the CPD process to support social workers, including what a social worker should do if they feel they’re unable to meet the professional standards including the requirement around CPD.

What else you told us

Consultation is an important way for us to talk to people about social work, gauge their thoughts about our proposals and their hopes for our work as the new specialist regulator. This section reflects just some of the thoughts and concerns people shared with us, all of which continue to inform our approach to the regulation of social work.

Here are just some of the thoughts from people who took the time to tell us about their personal experiences.

• “Social workers are under a lot of pressure and learning through practice is the main source of learning alongside reflection and supervision.” – Social worker
• “Employers must have a responsibility for making sure that there are sufficient opportunities for CPD.” – Social worker
• “There has to be a balance between responsibility of the employer and the social worker.” – Adult social care
• “It would be useful to have dedicated time during the work hours to ensure social workers do not burn out/have a good work life balance.”– Social worker
• “We felt the CPD standards are refreshing, [we] felt listen[ed] to, it is a validation for Social Work”– Employer

As well as personal reflections, some respondents questioned the link between our professional standards and the other standards and frameworks social workers may work to.

Our professional standards are the threshold standards we expect a social worker to meet and uphold in order to register with us and maintain their registration. Beyond that, we understand there are a number of different standards and frameworks in the social work environment. We’re currently working with relevant social work organisations to make this clearer.

Support from employers

Social workers who responded to our consultation raised the issue of having the time, support and opportunity to undertake CPD. We ask employers to familiarise themselves with the regulatory CPD requirements for social workers. We also encourage them to foster a learning culture where social workers are supported to carry out their CPD activities by providing them with adequate time and opportunities to do so.

We recognise the pressures the profession faces, so it’s important to acknowledge that CPD includes a range of activities and does not just involve social workers attending training courses. While formal training, especially in statutory responsibilities, is an important aspect of CPD, we also encourage employers to support social workers to undertake a range of activities.

We will not give direction or advice on what CPD a social worker should undertake, but we do encourage social workers to think creatively about learning opportunities and the learning they’re already doing in their role.

We encourage employers to support their social workers to use critical reflection to improve their practice, to keep their knowledge up-to-date, and to learn from feedback and supervision. This will allow them to demonstrate to us they meet the standard for CPD and maintain their registration.

What we’ve learned

Consulting allows us to develop a greater understanding of the profession and the thoughts and concerns around our proposals. These lessons have been invaluable to us, and while some of the concerns raised cannot be fixed immediately or are not in our authority to fix, we’ll consider them carefully throughout our work and pass on any relevant feedback to our partners.

In particular, through this consultation we’ve learned that social workers want to undertake CPD and want to use it to the benefit of their practice. There remain concerns over employer support and the time available to social workers to undertake good, valuable CPD.

We’ll continue to work with people with lived experience of social work and social workers in developing our proposals and embedding new process. This means asking people what would make our work clearer and thinking carefully about what we offer to the profession.

We will always make sure we are led by research and intelligence and look forward to working with all those who have an interest in social work to become a responsive, fair and effective specialist regulator for social work.

What happens next

The consultation closed on 17 October 2019 but we are committed to ongoing conversation and collaboration with everyone who has an interest in social work. We’ve carefully considered the feedback we received and made changes to the CPD process. We’ve published a guidance document to support social workers through the process.

We’ll continue to work with social workers, employers, people with lived experience and others with an interest in social work to develop and refine our standards, CPD process and approach. This will allow us to make intelligence-led improvements so that CPD supports our work to raise standards of social work practice.

Equality impact assessment​

Introduction

Social Work England is the new, specialist regulator for social workers in England. Between 7 August and 17 October2019,we held a public consultation on our proposed approach to continuing professional development (CPD).This equality impact assessment sits alongside our consultation response.

It is a written record that shows how we’ve taken care to eliminate unlawful discrimination and promote equal opportunities.

Outline of our approach to CPD

CPD is the reflection and learning activity that social workers undertake throughout their career to maintain and improve their practice. By undertaking and recording CPD, social workers demonstrate to us and to the public that they uphold our professional standards and continue to remain fit to practise. Meeting the requirement for CPD is one element of maintaining registration with us.

Working with social workers, people who use social work services, employers and others with an interest in social work, we’ve developed an approach to CPD that emphasises reflection and the impact that learning has on practice. Our professional standard on CPD sets out our expectations on what social workers need to do to maintain their registration. Part of our expectation is that social workers keep an up to date record of CPD in an online account.

We’ve not specified an amount of CPD that social workers should do in the first year, but we would expect to see at least one learning activity. We encourage social workers to decide how much CPD to undertake, taking into account their personal circumstances, their learning needs and how they’re practising.

At the point of registration renewal, social workers will need to confirm that they have met the professional standard for CPD. This is part of renewing their registration. At the close of the registration renewal period, we’ll check their online account to make sure they’ve recorded CPD during the year.

At this point, they may be selected for validation. If they’re selected, we’ll look at their CPD activities in more detail. For our first year of regulation we won’t be assessing the quality of CPD. Instead, we’ll check whether the CPD shows how the activity has impacted on practice.

Consultation responses

Through our consultation, we asked respondents if they thought our proposed CPD process would have a positive, neutral or negative impact on people in different protected characteristics groups, and in what way. The responses have helped us to understand which groups respondents thought would be most impacted and consider areas for change and improvement.

What people said

Respondents mostly said there’d be a positive or neutral impact on groups with protected characteristics, often stating that all people will benefit from social workers meeting the required standard and recording their CPD.

Age and disability were the characteristics most frequently selected as being positively affected. Reasons included that having an online recording system may make it easier for disabled people to use assistive software to record their CPD and in a flexible format.

Some respondents thought the non-prescriptive approach to CPD activities would make it easier for people on extended periods of absence to maintain their registration, whilst others felt that those on maternity leave could struggle to demonstrate that they’ve met the CPD standard.

A few respondents voiced concerns relating to age, suggesting some social workers may need more support to use the new online account. However, others suggested that this should not be an issue in a profession that requires its workers to be able to use a computer effectively for their role.

Equality impact assessment

We’re committed to monitoring and promoting equality across our organisation.

We’ve reflected on the feedback from our consultation to assess both the positive and negative impacts that may arise as a result of our proposals. As part of the equality impact assessment we found that social workers from some protected characteristic groups could be impacted negatively. These impacts related to:

The effect that maternity and disability may have on a social worker’s ability to demonstrate that they meet the CPD standard and the potential effect this has on registration renewal.

The potential barriers to using our online account recording system for some groups. These areas are set out below, along with the action we will take.

Registration renewal

Social workers with protected characteristics relating to maternity, pregnancy or disability may feel that they are negatively affected during registration renewal by having to demonstrate that they meet our requirement to undertake and record CPD.

Our approach to CPD is not prescriptive. We don’t give guidance on what or how much CPD social workers should do. Instead, we ask social workers to demonstrate the professional standard relating to CPD (standard 4)in a way that suits them, their practice and their learning needs.

We do expect to see how social workers have reflected on any learning they’ve undertaken and describe to us the impact this has had on their practice. Our guidance on CPD makes clear that if a social worker thinks that over the course of the registration year, they won’t be able to meet the CPD requirement, they should contact us so we can discuss their circumstances and options.

As part of the discussion, we may ask the social worker to provide evidence of their personal circumstances. We’ll review the information provided, let them know the outcome, and tell them what, if anything, they need to do.

At the close of the registration period, we will provide 21 additional days for CPD records to be updated. We extended this period from 7 days as a result of consultation feedback. Where no CPD has been recorded at the end of the 21 day period, we’ll contact the social worker to understand why this might be the case.

While conditions on practice and removal from the register are available to us as the regulator, these would only apply as a last resort option when the social worker has not sufficiently explained why they have not met the CPD standard or an agreed condition relating to meeting the CPD standard.

If a social worker’s personal circumstances mean they’ll be away from practice for a significant period of time, meaning that they may not be able to demonstrate the CPD standard, they may want to consider voluntarily removing themselves from the register.

When they are ready to come back onto the register, they can contact us to discuss their circumstances and we may choose to waive the restoration fee in accordance with our rules.

Online recording system

Social workers with protected characteristics relating to age or disability may feel that they are negatively affected by having to record their CPD in our online account to demonstrate that they meet our requirement to undertake and record CPD.

Our registration rules set out that social workers must maintain an up to date record of their CPD to demonstrate that they’re eligible to renew their registration each year. This should be recorded in our online account, which we believe is the easiest way for social workers to ensure that they can demonstrate that they meet the CPD standard.

We are committed to making our website accessible in accordance with our obligations (Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018).

We want to improve the accessibility of our website and have already included many features to support access. We continue to look at making the website text as simple as possible to understand and we’re working to optimise the accessibility of our website. If anyone needs information in alternative formats, we encourage them to get in touch.

Our guidance on CPD provides details on how to use the online account and makes it clear that if a social worker feels they are unable to record their CPD in this way, they should contact us as soon as possible to discuss their concerns.

Sign off

This equality impact assessment has been undertaken and signed off in accordance with Social Work England’s responsibilities under the Public Sector Equality Duty, as set out in the Equality Act 2010.

• Name: Sarah Blackmore
• Title: Executive Director, Strategy, Policy and Engagement
• Date approved: 16 January 2020