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

NHSE Consultation – Service for Children and Young People with Gender Incongruence: Referral Pathway consultation guide

Deadline: 26 February 2024

As part of a series of consultations relating to gender services, NHSE is consulting on its referral pathway guidance for children and young people with gender incongruence.

Find all the information and consult the documents relating to this consultation on the NHSE website.

If you wish to respond to this consultation, please complete the attached form and send it to [email protected] by 26 February.

Department for Education Consultation – Gender questioning children: draft schools and colleges guidance

Deadline: 26 February 2024

The DfE is seeking views on the content of its guidance relating to gender questioning children and whether it will help to support schools and colleges, teachers and leaders to make considered and lawful decisions in relation to children who are questioning their gender and the wider school and college community.

Find out more information and consult the documents regarding the consultation on the DfE website.

If you wish to respond to this consultation, please complete the attached form and send it to [email protected] by 26 February 2024.

Call for evidence - A world-class education system: The Advanced British Standard consultation 

Deadline: 05 March 2024

Over the next decade, the Department for Education is seeking to introduce the Advanced British Standard (ABS), a new Baccalaureate-style qualification framework for 16- to 19-year-olds, which will increase teaching time, require the study of maths and English to 18 and ensure students study a greater breadth of subjects.

The consultation document sets out proposals on the way the ABS could work.

The BPS will be responding to this consultation and member views are greatly appreciated to help the DfE continue developing their approach for the ABS and how it is delivered.

Please send your response using the attached comments form or in bullet points, making it clear which question and section of the guidance you are responding to.   

Download a copy of the response form.

Please send your responses based on your practice or research experience to [email protected] by 9am on 05 March 2024.

If you have any questions, please do not hesitate to get in touch.

Welsh Parliament inquiry into children and young people on the margins

Deadline: 13 March 2024

The Senedd’s Children, Young People and Education Committee are holding an inquiry into children and young people on the margins who are likely to go missing or become victims of criminal exploitation.

The inquiry focuses on the nature and scale of the problem, specific concerns about at-risk groups, data collection and information sharing, the effectiveness of policy, and how well devolved and non-devolved services (such as criminal and youth justice) are working together.

Read the inquiry Terms of Reference.

Members views are greatly appreciated as they inform our response.

Please send your feedback to [email protected] by close on 13 March.

Welsh Parliament consultation on the Development of the Mental Health Standards of Care (Wales) Bill

Deadline: 22 March 2024

The purpose of the Mental Health Standards of Care (Wales) Bill is to:

  • replace outdated mental health legislation
  • improve the delivery of mental health plans for Child and Adolescent Mental Health Services and adult services in Wales
  • improve the accountability of Welsh public sector organisations
  • help establish parity between the treatment of physical and mental health
  • help reduce mental health stigma in Wales

Find out more about this consultation.

Member views are greatly appreciated as they inform our response.

Please send your feedback to [email protected] by close on 22 March.

Scottish Government consultation: Learning Disability, Autism and Neurodivergence (LDAN) Bill

Deadline: 29 March 2024

The government has published its public consultation on the Bill, related news release and short guide.

The Bill is part of the rights-based Programme the Scottish Government is currently progressing, including work on incorporating four UN human rights treaties into Scots law within the limits of devolved competence through the Human Rights Bill (recently consulted upon), the United Nations Convention on the Rights of the Child (UNCRC) (Incorporation) (Scotland) Bill, the establishment of a National Care Service, the Mental Health and Capacity Law Reform Programme, and the Public Sector Equality Duty Review.

To inform the BPS response to the consultation on the LDAN Bill, please send your views to [email protected] by 29 March 2024.

Consultation on the Professional Standards Authority’s good practice guidance documents in support of regulatory reform

Deadline: 01 April 2024

The Professional Standards Authority has launched two consultations on guidance they have produced.

Further details, including the consultation documents, can be found on the PSA’s website.

1. Accepted Outcomes

This is new process for handling Fitness to Practise cases. 

PSA’s guidance on the use of Accepted Outcomes in Fitness to Practise identifies key factors for regulators to consider when developing their own guidance on the use of accepted outcomes.

The guidance includes factors to consider when deciding whether a case is best resolved by an accepted outcome or a fitness to practise panel (the disposal route) as well as factors for regulators to consider to ensure the accepted outcomes process is fair and transparent, and to promote effective decision-making.

2. Rule Making (allowing regulators to make and amend their operational rules)

PSA’s guidance on Rulemaking aims to help regulators make effective use of their new rulemaking powers in a way which prioritises public protection.

It includes some principles to guide what good rules should aim to do or be, and the rulemaking process.

How to respond

These are really important changes to the regulation of health and social care professionals.

If you would like to contribute to the society’s response - please complete the response form and send it to [email protected] no later than 1 April 2024.

Welsh Government: children missing education database

Deadline: 10 April 2024

The Welsh government are consulting on draft regulations that will place a requirement on local authorities to develop a database of children in their areas who are potentially missing education (CME) and place a requirement on local health boards to share basic information about children with the relevant local authority, so that they can establish the database.

Find out more about this consultation.

Member views are greatly appreciated as they inform our response.

Please send your feedback to [email protected] by close on 10 April.

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].

Woman writing on post-it notes

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].

Westminster

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