Consultations and briefings
Our consultations allow us to share the latest psychological evidence and support the development of well-informed policies. Our Parliamentary Briefings allow us to comment on government actions and decisions which affect our community.
Open consultations
HEIW Strategic Perinatal Workforce Plan
Deadline: 30 November 2023
HEIW are developing the Strategic Perinatal Workforce Plan, to recruit, retain, train and transform the current and future perinatal workforce in NHS Wales, for implementation by Spring 2024.
The BPS will respond to the consultation. Members views are greatly appreciated.
For more information, and if you’d like to take part in HEIW consultation events, please consult the Strategic perinatal workforce plan.
Please send your feedback to [email protected] by close on 30 November.
Office for Health Improvement and Disparities - UK clinical guidelines for alcohol treatment
Deadline: 04 December 2023
The Office for Health Improvement and Disparities, which is part of the Department of Health and Social Care (DHSC), has worked with the devolved governments in Scotland, Wales and Northern Ireland to produce the first ever UK clinical guidelines for alcohol treatment.
There is currently no equivalent for alcohol to the guidance Drug misuse and dependence: UK guidelines on clinical management (the ‘orange book’) and the UK clinical guidelines for alcohol treatment are intended to fill this gap.
The DHSC is currently consulting on these guidelines.
The BPS will be responding to this consultation and member views are greatly appreciated.
Please send your responses based on your practice or research experience to [email protected] by 9am on Monday 04 December.
Download a copy of the response form.
If you have any questions, please do not hesitate to get in touch.
Please feel free to share this call for evidence amongst your networks.
National Institute for Health and Care Excellence - Menopause: diagnosis and management
Deadline: 13 December 2023
The National Institute for Health and Care Excellence (NICE) are consulting on a guideline covering the identification and management of menopause, including in people who have premature ovarian insufficiency.
It aims to improve the consistency of support and information provided to people experiencing menopause. This will update the previous guideline, published in November 2015.
The BPS will be responding to this consultation and member views are greatly appreciated.
Please send your response using the attached response form or in bullet points, making it clear which question and section of the guidance you are responding to.
In your response, you may wish to consider:
- The areas that will have the biggest impact on practice and be challenging to implement.
- How to help users overcome challenges.
Please send your responses based on your practice or research experience to [email protected] by 9am on Wednesday 13 December.
Welsh Government: White Paper on ending homelessness in Wales
Deadline: 09 January 2024
The Welsh Government are consulting on: reform of existing core homelessness legislation; the role of the Welsh public service in preventing homelessness; targeted proposals to prevent homelessness for those disproportionately affected; and access to housing.
For more information, consult the White Paper on ending homelessness in Wales.
Members views are greatly appreciated.
Please send your feedback to [email protected] by close on 09 January.
Scottish Government: draft National Specification for the Care and Treatment of Eating Disorders in Scotland
Deadline: 10 January 2024
The Scottish Government is currently consulting on the draft National Specification for the Care and Treatment of Eating Disorders in Scotland.
To provide brief background, the National Specification for the Care and Treatment of Eating Disorders in Scotland was developed in response to the National Review of Eating Disorder Services (2021). The government aims to publish the final version of the Specification in early 2024.
The Specification will complement other ongoing work, such as the creation of the National Care Service (NCS) and the findings from the recently published Mental Health Law Review. It also sits within the context of the Core Mental Health and Wellbeing Standards and the National Specification for the Delivery of Psychological Therapies and Interventions in Scotland.
It is the government’s intention to ensure that the final version of the Specification aligns with the format and contents of these two documents. A version will also be developed for patients and their families.
- Pages 6 to 48 of the consultation document provide a copy of the draft Specification in its entirety.
- Part One of the consultation asks questions about the Specification as an entire document.
- Part Two and Three ask questions on specific outcomes, and their measurement.
- Part Three asks more detailed and technical questions to gather opinions about how the government can support services in order to implement the Specification and how it plans to measure their implementation.
Member views would be very welcome as BPS considers its response. Please send your views to [email protected].
Practice Board Consultation: Draft Supervision Guidelines
Deadline: 22 January 2024
The Practice Board’s supervision task and finish group has developed supervision guidance for practitioner members.
Member’s views are greatly appreciated. Please use the Response Form.
Please send your feedback by the close of play on 22 January 2024 to [email protected].
Why do we respond to consultations?
The Government, Parliament, regulators and third party organisations frequently open consultations to seek the views and expert insights of stakeholders to inform decision making, as well as policy and legislation design, and to ensure that the interests of affected parties are not overlooked.
Consultations allow entities to understand more about the impact of certain decisions, and can also reveal the sentiment of stakeholders towards such decisions and assist entities in identifying who those stakeholders are.
The society responds to consultations to ensure that psychology is considered as part of these processes. We seek the views of our members to ensure that we develop responses to consultations that best represent the expertise that psychology has to offer.
The input from members to these responses is invaluable as it supports the society in its goal of ensuring that psychology and the perspectives that psychologists have to offer is embedded within laws, guidelines, policies, and decisions.
If you wish to learn more about the consultations process, please contact [email protected].
Consultation responses
Parliamentary briefings
Imprisonment for Public Protection (IPP) Sentences
The British Psychological Society (BPS), the representative body for psychology and psychologists in the UK, is calling for the Secretary of State for Justice to adopt the recommendation[1] from the Justice Select Committee to bring forward legislation to enable a resentencing exercise in relation to Imprisonment for Public Protection (IPP) sentenced individuals.
Background
IPP sentences were indeterminate sentences given to individuals deemed to pose a significant risk of causing harm, which courts imposed between 2005 and 2012[2]. They were used far more widely than intended, with some having been issued to offenders who have committed low level crimes with tariffs as short as two years[3].
Although the IPP sentence has been abolished, there are thousands of individuals still in prison serving these sentences. As of December 2022, there were 2,892 IPP prisoners, of which 1,394 have never been released and 1,498 have been recalled to custody[4].
IPP sentences undermine the practice of forensic psychologists
The release of prisoners serving IPP sentences relies significantly on the ability of forensic psychologists to evaluate the risk an offender poses to the public. The extent of this reliance (on risk assessments) is problematic, as the unique situation people held under IPP find themselves in creates stress, uncertainty, and affects their coping strategies – all of which negatively impact on dynamic ratings of risk. Risk assessment can never be an exact science, and therefore cannot be a justification for indefinite imprisonment.
Furthermore, the role of risk assessment in IPP sentences inhibits trust between forensic psychologists and prisoners as it prevents those serving the sentences from making honest disclosure about their state of mind due to fear it will impact their prospects for release.
Serving an IPP sentence is psychologically harmful
The experience of serving an IPP sentence causes a prisoner psychological harm. Due to the nature of the prison sentence, there is a perpetual state of anxiety, and the processes involved- such as the parole hearings- contribute to a long-lasting feeling of stress[5]. This comes in addition to a sense of hopelessness, due to a feeling that their life is no longer in their own hands[6]. The extent of the negative impact of this is demonstrated by the disproportionately higher rates of self-harm among the IPP population[7].
Furthermore, the IPP sentence causes immense, long-lasting psychological distress for the families of IPP prisoners. Families have described their experience with the IPP parole process as a difficult journey between high hopes and disappointment, putting a severe strain on their mental health[8]. Many were left vulnerable to further stress related to being stuck in a cycle of parole hearings.
Conclusion
Given the negative psychological impact of IPP sentences, and the adverse impact of these sentences on the practice of forensic psychology, the BPS believes it is imperative that the Government bring forward legislation for a resentencing exercise imminently. If you wish to discuss these issues further with our experts, please contact [email protected].
References
[1] House of Commons Justice Committee (2022) IPP Sentences: Third Report of Session 2022-23.
[2] House of Lords Library (2022) Sentences of imprisonment for public protection.
[3] Ministry of Justice IPP Factsheet.
[4] Ministry of Justice (2023) Offender management statistics quarterly: July-September 2022.
[5] Harris, Edgar and Webster, (2020) The mental health implications of Imprisonment for Public Protection in the community and post-recall.
[6] Shingler (2018) Understanding the Process of Psychological Risk Assessment: Exploring the Experiences of Psychologists, Indeterminate Sentenced Prisoners and Parole Board Members.
[7] Ministry of Justice (2021) Safety in Custody Statistics.
[8] Straub and Annison (2020) The mental health impact of parole on families of indeterminate-sentenced prisoners in England and Wales.
General Debate on the future of the NHS, its funding and staffing
The British Psychological Society (BPS) - the representative body for psychology and psychologists in the UK - urges MPs to call for the following in the General Debate on the future of the NHS, its funding and staffing on Thursday 23rd February:
- Ring-fenced funding for the NHS Staff Mental Health and Wellbeing Hubs
- A comprehensive mental health workforce strategy
- Continued funding to help retain staff
- To embed psychology into primary care
Ring-fenced funding for the NHS Staff Mental Health and Wellbeing Hubs
At a time when the NHS is confronted with unprecedented levels of pressure, it is more important than ever that staff can access the support they need to be able to deliver for patients.
Therefore, it is vital that the Government commits to providing transitional ring-fenced funding for NHS Staff Mental Health and Wellbeing Hubs.
The BPS is aware that the question of whether to continue national funding for the Hubs is being considered, with an expectation that commissioning will shift to Integrated Care Boards (ICBs) in the future.
However care must be taken in the transition of funding from NHS England to ICBs as they are in varying stages of development.
Therefore, without transitional ring-fenced funding, these services will come to an abrupt halt, putting the staff members who use them, and the patients who they serve, at risk of harm.
Now more than ever, when patients are facing record waiting times, we simply cannot afford to put the mental health of NHS staff on the back burner.
As things currently stand, anxiety; stress; depression and other psychiatric illnesses are consistently the most reported reason for sickness absence in the NHS, accounting for over 521,600 full time equivalent days lost and 25.5 per cent of all sickness absence in August 2022.
This has increased since July 2022 (20.9 per cent) (NHS Digital. (2023). NHS Sickness Absence Rates, August 2022) .
A comprehensive mental health workforce strategy
We do not believe that the announcement of a Major Conditions Strategy to replace the 10 Mental Health Strategy allows for the level of specification and investment required for the sector.
The BPS urges the Government to implement a comprehensive mental health workforce strategy.
The BPS stresses that, as a bare minimum, this Government must invest more to implement the existing workforce plan.
The workforce shortages have reached a state of crisis and the impact of this on public health has been enormous.
As of July 2022, over 1.6 million people were in contact with mental health services, an increase from 1.2 million in April 2016 (NHS Digital. (2022). Mental health services monthly statistics), and services are struggling to keep up with increased demand.
Those seeking mental health support can experience long waiting times – at the end of 2021, NHS England estimated there were at least 1.4 million who had been accepted for mental health care but were yet to receive it (NHS England and NHS Improvement. (2021). NHS England and NHS Improvement Board Meetings in Common: Item 5: Update on mental health services).
Further, waiting times and staff shortages are having an impact on levels of patient satisfaction with the NHS; in 2021 the proportion of patients who we satisfied with the NHS fell to 36 per cent, an unprecedented 17 per cent decrease on 2020 and the lowest level recorded since 1997.
The main reasons given for dissatisfaction were waiting times for GP and hospital appointments (65 per cent) followed by staff shortages (46 per cent) [Wellings, D. et al. (2022). Public satisfaction with the NHS and social care in 2021: Results from the
British Social Attitudes Survey. The King’s Fund. P.5].
Continued funding to help retain staff
We have heard from our members that a lack of career opportunities and a downgrading of Agenda for Change bands for posts are driving staff out of the NHS into other sectors.
Furthermore, additional investment is needed to create more funded pathways for individuals entering sectors within psychology.
For example, there are little to no Government funded placements for the majority of Practitioner Psychologist training routes-including in areas such as counselling or health psychology.
It is important that the Treasury take steps to change this to facilitate closure of workforce gaps, and to create equal opportunities for groups consistently under-represented in the psychology workforce.
To embed psychology into primary care
The BPS urges this Government to make investments to adopt our recommendation to embed psychology into primary care (British Psychological Society (2022). Clinical Psychology in Primary Care- how can we afford to be without it? Guidance for Clinical Commissioners and Integrated Care Systems).
We know from both research and existing schemes that psychologists working closely with GPs can be incredibly powerful and effective in reducing demands on primary care and empowering general practice clinicians to manage the psychological component of presentations that are increasingly prevalent in general practice.
Psychologists not only assist with mental health outcomes and improving health behaviours, they reduce overall demand by helping with long term complex conditions.
Following one trial in Hackney, GPs reported improved capacity to manage patients with complex needs and reduced workload and 75 per cent of all patients showed improvements in their mental health, wellbeing and functioning (British Psychological Society (2022). Clinical Psychology in Primary Care- how can we afford to be without it? Guidance for Clinical Commissioners and Integrated Care Systems).
- The Public Affairs Team
For more information on these issues, please contact [email protected].
Westminster Hall Debate: specialist workforce for children with special educational needs and disabilities
Introduction
The British Psychological Society (BPS), the representative body for psychology and psychologists in the UK, urges MPs to highlight the need for better investment in Educational Psychologists during the Westminster Hall Debate on the specialist workforce for children with special educational needs and disabilities on Wednesday 22 March.
The need for National Government Funding
The BPS is encouraged by the promise of a nationally consistent standard in the Government’s response to the SEND Review.
SEND support across England has reached a point that reflects stark inequalities between local authorities.
However, as we mentioned in our submission (BPS Consultation on the SEND Review, 2022), the national Government must assign local authorities with ring-fenced funding in order for this to be deliverable.
More investment is needed to close the workforce gap
The announcement of £21 million for 400 more Educational Psychologists is a step in the direction (Department for Education (2022) How we are improving support for children with SEND), but does not go far enough to close the workforce gap.
Data published by the Government in 2019 showed that in 2017 there were c. 3000 Educational Psychologists working in England, which is equivalent to, on average, one Educational Psychologist for every 3,500 children and young people aged 5-19 in England and one for every 5,000 aged 0-25 (Department for Education (2019) Research on the Educational Psychologist Workforce).
Many of our members report that a consequence of the escalating demand has led to a lack of opportunities for early intervention.
Given that Educational Psychologists play such a crucial role in supporting children with SEND, there must be a greater increase in the number of Educational Psychologists in order to meet demand.
For more information on these issues, please contact [email protected].
All Party Parliamentary Group on Psychology
Founded in 2017, the All Party Parliamentary Group (APPG) on Psychology is a cross-party group of members of parliament from both