In conjunction with our 2024 General Election Manifesto, the Council is releasing a series of blogs which explore the underlying principles and four asks in more depth.
The fourth blog in the series is by Megan Isherwood, Policy Officer, and Ed Hughes, CEO, Council of Deans of Health.
Regulation in healthcare higher education is vitally important. It protects the interests of students, staff, and the public, ensuring that healthcare programmes are delivered at a consistently high standard to prepare students to practice safely and competently when they enter the workforce. The Council strongly supports effective regulation but affirms that it should be proportionate – upholding high standards and quality, whilst embracing innovation and flexibility. Conversely, an overly bureaucratic regulatory environment can negatively impact healthcare education, restricting the autonomy of higher-education institutions (HEIs) and creating opportunity costs.
Our members across nursing, midwifery, and allied health professional (AHP) education for example, are facing increasing challenges with the regulatory burden that comes with being subject to both professional healthcare and higher education regulation. This is being exacerbated as more professional, statutory, and regulatory bodies enter the field. Our members are already answerable to multiple regulators such as the Nursing and Midwifery Council (NMC), Health and Care Professions Council (HCPC), and the Office for Students (OfS) to name a few. With the rise of healthcare apprenticeships, Ofsted is another regulator that many are likely to engage with. The devolution of education also means that different education funding and regulatory bodies oversee HEIs across the four UK nations. This translates into an increasingly complicated regulatory landscape for our members to navigate with overlapping regulators often enforcing technical, time-consuming and duplicative requirements. A recent report commissioned by Universities UK for example, revealed that universities on average have a full-time equivalent of 17.6 staff dedicated solely to regulatory compliance. Such resource intensive processes can divert attention from core priorities, impact staff experience and stifle innovation whilst also deterring new prospective education providers from entering the field.
Better join-up between the healthcare and education sectors is key to mitigate these challenges. More explicit communication with universities about how regulators will work together to avoid unnecessary requirements is important to improve transparency. Data sharing agreements between regulators could help to streamline processes and prevent duplication. Universities should be able to have confidence that if they meet the standards expected by one of their regulators they will not fall foul of the regulatory regime of another. We know that some of these conversations across regulators are starting to happen – and very much hope that the experience of our members, who are those responding to the requirements of the various regulators, will be central to thinking about how to minimise burden whilst maintaining quality and standards. At the top level, partnerships between healthcare and education governmental departments would ensure a whole-system approach to overseeing and assessing regulators and help to identify overlap and burden, as well as potential gaps.
More specifically, some aspects of the regulation of healthcare higher education are failing to keep pace with changes in pedagogy and practice. The strict hours-based requirements, combined with limited placement capacity across much of England, is a contributory factor restricting universities’ capabilities to meet rising workforce demands. The NHS England Long-term Workforce Plan has consequently advocated for the NMC to consider reducing practice hours to increase training capacity for nurses and midwives. Notably, Brexit recently opened opportunities to explore alternative regulatory approaches as standards are no longer required to comply with the EU Directive. Likewise, the COVID-19 pandemic forced regulators to adapt quickly and introduce emergency programme standards. These included new standards from the NMC, enabling students to undertake extended placements in clinical practice to support the response to Covid-19 and learn through up to 300 hours of simulation. These allowed for significantly more flexibility in programme delivery and have since been implemented permanently in the updated standards for pre-registration nursing programmes, which further expand the scope for simulated practice learning to up to 600 hours. Nevertheless, there is broader scope for the NMC to shift towards a competency-based, rather than hours-based framework. There is much we can learn from the more flexible approaches of international partners such as Australia, where the minimum number of practice hours for nursing students is 800 hours and simulation is embraced and embedded within nursing curriculums. Such flexibility in the time spent in clinical practice needs to be accompanied by a much sharper focus on making that time as beneficial as possible for students. Furthermore, we need to keep up the momentum for reform pursuing more agile regulation that can respond to future challenges and opportunities. This could include continued shifts in the needs of the healthcare workforce, patients and service users and students, the expansion of health and social care settings and digital and technological innovation.
Ahead of the upcoming General Election, the Council is sharing key policy priorities with the major political parties, and is calling for:
- A review into the regulatory responsibilities of universities that provide healthcare courses. This should aim to encourage streamlining between health and education regulators. Government should proactively work with regulators to avoid overlapping or competing demands and promote proportionality so unduly burdensome regulation is not a disincentive to institutions or staff members in expanding healthcare courses.
- The sector to embrace opportunities for more agile and outcome-focused regulation that can be updated as required so Britain more readily tailors healthcare regulation according to its needs and those of patients.
These objectives would support a move towards a more efficient and simpler regulatory landscape which could encourage more healthcare academics to enter the field and in turn create more capacity in the system to educate more students. Importantly, this cannot be fulfilled without better join-up between health and education sectors, especially the relevant government departments and local partnership structures such as Integrated Care Boards in England. Likewise, universities need to be involved at every stage of decision-making around regulatory reform.