My Lords, like the noble Lord, Lord Davies, I am also new to this House—in fact, I am even newer than the noble Lord. Like him, I support my noble friend Lady Noakes’ points on Amendment 32, but I actually wish to speak to Amendment 32A in the names of the noble Baronesses, Lady Randerson and Lady Garden.
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I absolutely support wider consultation. I made that clear in discussions on the earlier groups where, despite being the only person to support the Government, I think I was the only one not to receive any letter from the Minister at five o’clock or any other time this weekend. I trust that that will be sorted out for the future.
As I say, I absolutely support wider consultation, but I am not sure that this is the right context for including it. Many regulators already regularly consult higher education institutions, training providers and professional bodies. In some cases, this includes programme approval and monitoring, and in others it is about promoting and discussing latest practice developments. Certainly in healthcare, each of the professions regulated has at least one professional body or association, and these organisations are often closer to the ground in understanding emerging issues or delivering post-registration training or CPD. I would prefer an emphasis on consultation with these professional bodies compared with listing higher education institutions at the top. As I have said, I accept that there is a role for regulators in consulting all appropriate bodies, but I am not sure why it should be specifically inserted only here.
I want to sound a note of caution regarding what actual use the information from any consultation would achieve in practice. To give a specific example, occupational therapists have highlighted to me an issue with American and Canadian students accessing our pre-registration
master’s programmes, which I understand are rather lucrative for the universities involved. Our various services then offer practical placements to these students. Once completed, they return home, so there is no benefit to the local services that have supported these courses and students.
The Royal College of Speech and Language Therapists has also highlighted that much workforce modelling for this profession, particularly in England, tends to focus only on healthcare settings employed by the NHS, whereas many of the professionals in this sector are employed in non-health settings—such as education, justice and social care—or are employed by voluntary and community organisations or in independent practice. The risk of not taking into account these wider workplaces in any consultation is that there could potentially not be enough professionals to cover all the areas they work in, therefore exacerbating and not relieving the vacancy issues within the NHS.
Additionally, regulators will regularly review standards to ensure that they are keeping pace with the realities of services. For example, in my area of health and social care, Covid-19 has been an absolute catalyst for significant innovation, such as the rapid adoption of digital provision or the development of multidisciplinary teams and advanced practice roles. These are examples of the ever-changing landscape and of looking at what will be required into the future. Therefore, I remain wary of insisting that regulators, or anybody else, do something or publish information based on today’s consultations, which many are doing already. I cannot see that it will produce the desired practical results.