Disabled students are stuck playing reasonable-adjustment ping-pong on professional courses

We don’t live in an ideal world, which is why the Equality Act 2010 exists.

A university can agree that a disabled student needs a reasonable adjustment and still be unable to deliver it. That can happen when professional education involves more than the relationship between a student and their university. An external professional body may determine the requirements for entry into a profession, while the university remains responsible for supporting the student through the course.If the adjustment a disabled student needs conflicts with one of those external requirements, the question of who can actually remove the barrier becomes surprisingly difficult.

I encountered this through professional counselling training. But counselling is only where I happened to meet the problem – what it’s really about is what happens when responsibility for a disabled student and control over the barrier they face sit in different organisations.

And that should matter across professional higher education.

Responsibility travelling in circles

A powered-wheelchair user on a postgraduate counselling and psychotherapy course at an English university contacted the British Association for Counselling and Psychotherapy (BACP). They were struggling with a requirement that most of their supervised placement hours be undertaken face-to-face, and asked what reasonable adjustments were available.

BACP told them that the placement had to remain predominantly face-to-face and that it couldn’t accept qualifications that failed to maintain the minimum requirement. But it also said that their course and placement providers should be able to make reasonable adjustments, and directed the student back to them.

The university then faced the other side of the problem.

In contemporaneous correspondence shared with me, the student’s course representative said that BACP appeared to allow no flexibility in the requirement, and expressed concern that changing it at university level without BACP approval could have detrimental consequences for the student’s subsequent professional membership.

Far from simply saying no, the university was trying to reconcile its responsibilities towards its disabled student with a professional requirement it understood it couldn’t safely disregard.

I’ve come to think of this as reasonable-adjustment ping-pong.

The professional body points towards the education provider’s responsibility to make adjustments. The university points towards a professional requirement it believes it can’t change. Both may be able to explain the boundaries of their own responsibilities perfectly reasonably.

The disabled student is still left with the barrier, and this creates a higher education problem.

Counselling provides one example, but the underlying structure is familiar across professional education.

Universities educate students for professions in which external organisations may set standards for accreditation, registration, placement, professional competence, or entry to practice. Universities therefore don’t always have complete control over the conditions their students must satisfy.

That creates a potential blind spot in our understanding of reasonable adjustments. We tend to ask whether the university has made an adjustment. On professionally aligned courses, we may also need to ask whether the whole pathway into the profession is capable of accommodating one.

A university can adjust what it controls. But what happens when it considers an adjustment educationally appropriate while an external requirement restricts its ability to implement it? And who is responsible for resolving the problem when neither organisation can solve it alone?

Those questions matter well beyond one profession.

Competence or method

Professional bodies have a legitimate interest in maintaining standards, protecting the public, and ensuring that people entering professions are competent. Reasonable adjustment can’t mean removing an essential professional competence.

But there’s a distinction worth examining between the competence itself and a prescribed method of demonstrating it.

That distinction has a legal counterpart. In Abrahart v University of Bristol, the High Court drew a distinction between a competence standard and the method used to assess whether a student meets it. The standard itself may be protected from the reasonable adjustment duty, but methods of assessing that standard are, in principle, capable of adjustment. For professional education, that makes the question of what the standard actually is particularly important – is the requirement the competence that must be demonstrated, or one particular way of demonstrating it?

In counselling, BACP requires at least 100 supervised client-placement hours, with the majority undertaken face-to-face. For a 100-hour placement, that means at least 51 face-to-face hours.

The National Counselling and Psychotherapy Society (NCPS) also requires a minimum of 100 supervised clinical hours with clients within a relevant organisation or agency.

If competence to work safely with somebody in the same physical room is the objective, that’s a legitimate professional concern.

But why 51?

That apparently simple question exposes a much larger one for higher education. What evidence demonstrates that a particular numerical threshold is necessary to establish the competence concerned? And, where disability creates a substantial barrier to meeting it in the prescribed way, could that same competence ever be demonstrated robustly by another route?

Professional training already assesses competence through mechanisms beyond the accumulation of placement hours. BACP’s own guidance states that students should be individually assessed for their readiness before beginning client work, and that courses should assess competence for both face-to-face and remote practice.

At the University of Leeds, that principle can be seen in practice. Students undertake recorded counselling-skills work before placement, with the module explicitly requiring them to demonstrate “readiness to begin practice as a counsellor/psychotherapist”. Their practical skills are formally assessed through a recorded session using a counselling adherence scale.

Oxford University’s Department for Continuing Education provides another example through its postgraduate diploma in psychodynamic practice, where supervised clinical placement sits alongside clinical supervision, clinical seminars, case studies, placement-log assessment, reflective work, and tutor and supervisor reports.

Placement hours therefore form part of the architecture through which competence is developed and demonstrated. These examples don’t establish that hours are unnecessary, or how every professional course should assess competence. But they do demonstrate that hours sit alongside other mechanisms for assessing whether somebody can practise safely and effectively.

That matters when disability prevents a student from satisfying one prescribed element in the usual way. The relevant question isn’t simply whether the requirement can be removed, but what competence it’s intended to establish and whether that competence could be demonstrated robustly in another way.

Knowing where the boundary is

Universities need to know where the boundary actually is.

There may also be a legal question about where responsibility sits outside the university. Sections 53 and 54 of the Equality Act 2010 impose reasonable adjustment duties on “qualifications bodies”, with competence standards treated differently. The Act defines a relevant qualification broadly, including recognition, registration, approval or certification that’s needed for, or facilitates engagement in, a profession. Whether BACP’s role in accrediting training and conferring professional membership brings it within that definition isn’t straightforward, particularly in a profession without statutory registration. But the possibility matters – responsibility for removing a barrier may not necessarily stop at the university door.

This suggests a practical problem for universities offering professionally accredited or recognised courses.

It isn’t enough to discover the limits of an adjustment only when a disabled student reaches placement and somebody asks whether the rules can be changed.

Universities need clarity much earlier about which external requirements genuinely constitute essential professional competence standards, which prescribe a particular means of demonstrating competence, what evidence supports them, and who has authority to consider an alternative where disability creates a substantial disadvantage. Otherwise the student can become the person responsible for finding a way through institutional boundaries they didn’t create.

There’s a related problem with offering additional time as the solution. In the correspondence, BACP suggested that the student discuss an extension with their training provider. An extension may sometimes help, but giving somebody longer to overcome a disability-related barrier isn’t necessarily the same thing as adjusting the barrier itself. It may address the delay without addressing its cause.

That distinction should matter to universities when evaluating whether an adjustment has actually been effective.

Surviving the whole journey

My own experience of this issue began in further education. My training provider ultimately accepted a fully remote placement route, while the professional requirements governing progression remained the obstacle. I subsequently began gathering accounts and documentary evidence from other disabled counselling trainees, alongside a petition calling for BACP’s placement-hours policy to accommodate disabled students.

That work led me back into higher education and to the correspondence described above. It also changed the question I was asking.

I began by asking whether a particular professional requirement could reasonably be adjusted. I now think the more important question is what happens when responsibility for making an adjustment is fragmented across several organisations and no single organisation takes responsibility for whether the adjustment is actually achievable.

For universities, that should prompt scrutiny of every professionally aligned course where an external organisation influences progression.

Before a disabled student encounters a barrier, institutions should know the answers to some basic questions. What’s the competence that must be demonstrated? Which elements genuinely can’t be adjusted? Who decided that? What evidence supports the prescribed method? What alternatives can be considered? And who makes the decision when the university and professional body disagree?

Professional standards and disability inclusion are compatible objectives – the challenge is to design professional education capable of delivering both.

Because if every organisation can correctly explain why the decision belongs somewhere else, we can end up with a system in which everybody has fulfilled their own responsibility, except nobody has removed the barrier.

This blog is part of our series on meeting expectations on disability inclusion.