DfE’s taskforce on student mental health hasn’t the force and isn’t up to the task

It’s self-evident that students can’t reach their full potential if they don’t have the support they need.

The question is – what is the government doing to ensure that students get that support?

Anyone familiar with cross-sector initiatives led out of the Department for Education (and the other government departments that have looked after HE over the years) will be forgiven for casting a sceptical eye over its HE mental health implementation taskforce’s first stage report.

The department’s last go at something called a student mental health taskforce – which was focussed on transitions into higher education – was pretty much a clustershambles, taking almost four years (albeit over the Covid period) to produce little other than interminable minutes.

This isn’t quite as W1A – there’s some progress over the government’s student suicide review (including a ministerial letter to VCs urging involvement), some movement on the identification of students in need of support and an update on universities’ engagement with the University Mental Health Charter.

Another key component of our work is learning from past tragedies so we can prevent them in future. That’s why I’ve written to all HE providers to ask them to support the National Review of HE Suicides so that providers can learn from one another and better protect students. pic.twitter.com/eQPq9ruNfP

— Robert Halfon MP ➡️Working Hard for Harlow⬅️ (@halfon4harlowMP) January 31, 2024

But as well as the baseline resourcing and capacity issues, there are some significant questions about approach and focus – and major warning signs that the project may yet run into the ground.

Does one size fit small?

The bulk of the report gets into the four strands of the project – supporting the adoption of good practice, the identification of students at risk, the development of more sensitive policies and communications to students, and the national review of student suicides.

The first of those is code for cajoling the whole of the sector into taking part in Student Minds’ University Mental Health Charter programme – something that his predecessor’s predecessor Michelle Donelan called on every university to do by 2027, only for Halfon to ramp up the pressure last summer with a “sign up by September 2024 or I’ll ask OfS to regulate” threat.

There’s been moderate progress here – 83 English members of Universities UK are said to have now signed up, with the other third covered off here with concerns about its applicability to small and specialist providers. There’s no point rehearsing some of the issues with making the charter mandatory here – we looked at that back when Donelan issued her edit, suffice to say that at the time both the President of UUK and the Chair of Student Minds were also worried by the approach.

Student Minds will have worked to address some of the issues by now, and to tackle the small and specialist issue, will be undertaking a “light-touch” review of the Charter and award process over the next few months, aimed at exploring opportunities for sharing learning and insights with non-eligible providers – although it’s sticking with its view that being small shouldn’t be an excuse for hitting its standards (or, as Student Minds would put it, “principles”).

A complexity there is FE Colleges, whose own association have their own overlapping Charter (albeit without an equivalent external inspection-style review), and the (really) small and specialists who aren’t in Guild HE or UUK. There’s also students in franchised, placement, TNE and year abroad provision – none of which seems to have made it onto the agenda explicitly so far.

To cover the complexity, there’s some suggestion that both Independent HE and Guild HE fed into the taskforce to say that of course their members support adoption of the principles in the Charter (in principle), but will need to explore further “the most appropriate assessment process” for non-university members.

To get there, the taskforce has itself developed four “principles” for an alternative assessment process that would demonstrate sufficient commitment to the principles – clarity of assessment outcomes, rigour in the assessment process, assessment burden and deliverability.

There’s a bit of that that sounds a lot like some of the small and specialist part of the sector’s complaints about regulation in general. What’s not clear yet is whether Student Minds is prepared to what will look like water down the standards, and whether the realities of choosing to study somewhere small have inevitably to mean that the standards of support on offer to a student are lower than elsewhere.

And outside of much of IHE and Guild HE’s membership, the idea that anything like Student Minds’ expectations are being delivered in some of the for-profit franchised provision that UUK’s members take a cut on is almost certainly for the birds given the margins in some of the Companies House accounts.

The ambition that “every HE student in England should be studying with a HEP that is covered by appropriate charter principles with a process that verifies institutional adoption” will get a lot harder from here – even iff Student Minds finds some more capacity that it doesn’t currently have.

On notice

The second strand concerns better identification of students in need of support, and a “clear user journey” for accessing that support – a key issue in the student suicide case that we looked at on the site earlier this week.

This is all about “noticing” – ensuring that universities are more adept at identifying students at risk and in need of support, and then taking action to prevent mental health issues escalating.

Apparently last summer members of the Taskforce Project Team engaged with a variety of providers and identified three broad approaches which demonstrate evidence of positive outcomes or are otherwise deemed to be good practice – staff training and competence, mental health analytics and encouraging early disclosures.

On the training issue, the taskforce has “come to the view” that there are multiple issues – whether a consensus can be reached on staff responsibilities and boundaries over student wellbeing and mental health; whether it is feasible to formulate a professional development framework that can flex to all sizes and specialisms in the sector; whether there is benefit in reviewing existing training, development, and guidance materials and mapping them against required competences; and whether there is an opportunity to link this strand of work with existing activity within the sector to help reduce the burden of change.

No way forward on those is (yet) proposed – and it’s hard to read the above without fearing the worst for proper progress. As I discussed on the site over the Southampton suicide case, the complexities and need to re-visit the overall scaffolding here are huge issues, the resourcing crunch is a real problem, the relationship between mental health and teaching and pedagogy is barely mentioned here, and the issue of staff’s own mental health concerns and condition doesn’t get a mention either. Sadly, I’d be surprised if this one gets much further.

On learner analytics, there’s a boilerplate rehearsal of their benefits and a reminder of some of the projects in this space that seem to be generating results. There is, though a quite downbeat assessment of progress – the extent of providers’ current and future use of wellbeing data to underpin student support (or their planned future development) is “not yet clear”, and it “looks likely” that providers are designing and delivering local systems without benefitting fully from collaborative learning. The bigger questions of the investments required to both implement and then have the right staff support to work off the data are avoided entirely.

Meanwhile the section on encouraging early disclosures is baffling – because for all the woolly stuff in the report on UCAS forms (which in any event ignores the many thousands of students who don’t enter via UCAS), the taskforce doesn’t seem to have noticed that at least for providers who have to prepare an OfS Access and Participation plan, taking action on disclosures is now a regulatory requirement.

Providers are required to consider the risk to equality of opportunity for their students in relation to mental health – both where students have declared a mental health condition to their provider and where there is evidence that poor mental health may be impacting outcomes for particular groups of students – and encouraged to seek to understand the whole student population, including exploring barriers and challenges faced by groups of students who may be more at risk of poor mental health.

In addition a “credible intervention strategy” has to focus on groups of students may be more, or less, likely to report a mental health condition; how poor mental health or having a mental health condition may affect outcomes for specific groups of students differently; the most suitable support and pathways for particular groups of students, and include work with students to declare mental health conditions.

Maybe the OfS rep missed a meeting, but you’d have thought the taskforce might have noticed that most of its concerns on declaration (and plenty of the concerns encompassed in its wider work) should already be being worked up in APPs.

Naturally, the subsequent “student journey to access support” section is the weakest here – with some vague stuff on “a view emerging” that this will require a “redesign of student support across all of dimensions” and not just those related to mental distress. It then passes the buck on future progress to Nottingham Trent VC and government HE Student Support Champion Edward Peck, who it is said will engage in further work with the sector over his Student Needs Framework, published with Advance HE last year.

Committing to compassion

Over the past few years, concerns have been raised by bereaved families, including The LEARN Network, about the unintended harm arising from policies and procedures, and the language used to communicate them to students, over stuff like academic misconduct, fitness to study, the sharing of assessment outcomes, and broader codes of student behaviour – where insensitive wording and timing may have contributed to the exacerbation of students’ mental distress, and where opportunities for prevention of escalating mental health issues by providing relevant signposting and support have been missed.

So the “student commitment” strand of work is about the development of more “sensitive” policies, procedures, and communications that both prevent harm to students and do so without compromising appropriate academic challenge and acceptable behaviour – and notably the intention is to add some text to the Office of the Independent Adjudicator’s Good Practice Framework, whose expectations are about as close to rights and standards as we get in this space.

On this there’s been a roundtable, some work on framing, but then another set of “challenges” – including the need for a broader range of good practice exemplars, the requirement to adapt existing and emerging practice to the precise requirements of each individual provider; the role of senior leaders in setting the tone for a compassionate culture; the volume of material to be revised (“in the context of resource constraints and competing priorities”) and the balance between compassion and the need to be clear about requirements and potential consequences of non-observance.

I’m not convinced that the consultation approach adopted so far has properly picked up the myriad problems here – if, for example, it hasn’t looked in detail at the threatening emails that university finance departments put out to international students over paying fees (or getting deported), or the increasingly problematic ways in which providers are handling upticks in academic misconduct allegations, then the failure to email SUs asking for feedback will render the exercise moderately meaningless.

Nevertheless, if there’s any HE sector body that can cut through that “yes but would it work for our entirely different and bespoke students” bluster, it’s the OIA – and so fingers crossed that its close association with this strand will yield some results. A further consultation and a national event are at least promised.

Learning from student suicide

Strand four is the National Review of Student Suicides. I’ve covered the various “significant shortcomings” surrounding this project on the site before – on this evidence, it remains difficult to believe that the review as designed or as it is being implemented will avoid the predictable pitfalls.

The progress bit is that in November 2023, DfE appointed the University of Manchester’s National Confidential Inquiry into Suicide and Safety in Mental Health (NCISH) to conduct the national review – and there are some decent names involved, including Louis Appleby, who chairs the National Suicide Prevention Strategy Advisory Group (NSPSAG) for England.

The problem is almost certainly the design of the exercise. In initial scope are only suicides (including those “suspected” or “attempted”) which have occurred since September 2023, and the idea is that providers will be encouraged (though not required) to submit serious incident reviews. There’s stuff in the report on assuaging concerns and engaging with providers, and a nod to taking into account reports and details of historic cases – but the central problem of providers not being too keen to admit failings (either to themselves or to this review) feels particularly underexplored here.

There’s also an odd note on addressing “perceived” concerns around the accuracy and availability of data on student suicide – in November 2023, a part of the Department of Health and Social Care (DHSC) launched a new suicide surveillance system for England, which uses near to real-time suicide data and will report on suspected suicides in the wider population across England.

It uses standardised reporting from individual Police forces, who submit their data on a monthly basis – and while it is “possible” for a victim to be identified as an HE student, it is “challenging” to collect this information consistently across individual Police forces – and so they’re not going to try. That leaves the ONS dataset for suicides among HE students in England and Wales as “the most accurate and authoritative” – despite not covering “suspected” or “attempted” at all.

Absolute beginners

There’s an appendix to note briefly that looks at potential work on the relationship between HE and the NHS (that seems not to have clocked that DfE funded OfS to run projects in that area a couple of years ago), and “case management approaches” to coordinated support – although no firms plans are described.

Finally, given it’s a DfE document and that the taskforce was likely created off the back of the minister needing something to say at the Westminster Hall debate on duty of care that wasn’t “yes OK then”, it’s worth reflecting on the political foreword.

It’s all very well for universities minister Robert Halfon to say that mental health is an “absolute priority” for the government, and that “this is not just about individual success but a matter of social justice” – but anyone that’s been near the almost wholesale collapse of children’s mental health and special educational needs services in large parts of the country will find those central messages hard to swallow.

For students, these problems feed through into higher education, and the dissonant boasting of the foreword threads through into this taskforce’s “three pillars” that put the taskforce at “the centre of the government’s plan for student mental health”.

The first is “funding vital services and innovative projects via the Office for Students”, where Halfon uses his intro to remind readers that the £10m one-off pot announced alongside his 2.5 per cent increase to student maintenance has to cover both additional student hardship needs and mental health. Even added to the core £15m allocated before this year, it’s a pot that is expected to stretch to far too many purposes, and to far too many students.

The second is “spreading and implementing best practice consistently across HE providers” – nothing wrong with that, of course, but as well as any “good practice” needing to be scalable and deliverable in what feels like a funding crisis (for both students and universities), it raises the spectre of the “best practice” exercise that so spectacularly failed last time DfE ran a taskforce on the issue. (Does “one size fit all”, rinse, repeat, etc)

The third is then “clear responsibilities for providers and protection for students” – which will rightly rankle with the families calling for a statutory duty of care – because that’s exactly what they mean by the phrase. Halfon’s stated resistance to OfS regulation in this area (surely provider responsibilities and student protection are what a regulator is for) simply isn’t an approach that seems to match the ambition.

In many ways, it’s ambition that is the running theme for me here. I know that it’s a very different country with a very different approach to taxation, but having just returned from Finland – where there’s a national student health service, a national student health and wellbeing survey, and a debate about how to (not whether to) implement a “therapy guarantee” that will secure rapid access to mental health services for students in conjunction with universities – it’s hard to view even the ambitions that are set out here as anything will scratch the surface, and that’s if they’re realised.

And the failure to underpin here with any real exploration of context or cause – as well as the failure to join up with other parts of the state – is profoundly upsetting.

Even on HE terms, any sector initiative of this sort requires enforced universal minimums, helpful enhancement work beyond the minimums, and the money and capacity to make both so. I really hope I’m wrong, but for now all three sides of that triangle feel doomed.