Ten notes of caution on making the mental health charter mandatory

Ministers are demanding that universities take part in a previously voluntary scheme on student mental health. Jim Dickinson is worried

Jim is an Associate Editor at Wonkhe

The Department for Education (DfE) Education Hub has published a whole blogpost called “How we’re supporting students with their mental health.”

Now don’t get too excited. It turns out that this “support” mainly appears to consist of a three line whip on vice chancellors to sign up to Student Minds’ University Mental Health Charter programme within the next five years, which will take us to eight years after her predecessor’s predecessor took credit for its launch.

No rush or anything.

In her circular to VCs of 13 December, Donelan says she is “pleased to see mental health and wellbeing established as a long-term strategic priority by many providers” – but (and you know what’s coming here) said she thought they “could and should do more”:

Protecting mental health has always been a personal priority of mine, and I remain committed to ensuring students get the support they need during this exceptionally challenging time… The Universities Mental Health Charter programme will help to improve mental health and wellbeing on campuses across the country, and I expect all universities to sign up as soon as possible.

So is it voluntary, or an expectation? Back in November, Universities UK President Steve West warned against making the charter mandatory:

I worry – I suspect Student Minds worry – that, to mollify ministers, what is currently a voluntary charter, based on strong improvement methodology, may end up being used as a quasi-regulatory lever by the English sector regulator.

As a reminder, the charter requires that institutions take “a whole-university approach” to mental health. It requires “both adequately resourced, effective and accessible mental health services and proactive interventions” and “an environment and culture that reduces poor mental health, as well as supporting good mental health.” Universities start by conducting a self-assessment of their activity, and programme members work towards a Charter Award, which recognises universities that promote good mental health and demonstrate excellent practice:

As an integral part of the framework, universities who voluntarily sign up for the charter award will undertake [a] rigorous and systematic evaluation of their services, interventions, culture, and practice that informs decision-making and continuous improvement.

Now I’m not someone that believes that regulation is automatically bad – and my spidey senses always tingle in a bad way when Universities UK cautions against being required to do a thing. It’s always felt odd to me that we put mental health provision in a university in the “a feature that universities should compete over” box rather than a “universal expectation across the sector” box.

I should also add that I generally take the view that Student Minds is a significant force for good and that the University Mental Health Charter is a great piece of work.

But. A shift by ministers to de facto requiring university participation in that scheme – with, doubtless, some pressure on the Office for Students to make it a default way to demonstrate compliance with some aspect of the regulatory framework – should cause us to stop and think.

If nothing else, I feel like it’s important to at least raise some concerns.

1. Problems and solutions

First of all, I think there’s a danger that the Donelan move obscures failings in the NHS and public health teams. It further shifts the line towards student mental health being the “problem” of VCs, and the “solution” funded by tuition fees.

As Steve West said back in November:

Where, for example, is the overarching cross-governmental approach to 0-25yrs? Where is the sustained collaboration between education and health on young adult mental health?

2. Feel assured

As I said, I think Student Minds is a great organisation. But I honestly don’t know whether the University Mental Health Charter model is up to an assessment that might “quality assure” a university on this stuff.

Donelan frames it in the same way that OfS frames its regulatory requirements:

Signing up to the programme means students can feel assured that if their university is signed up to the Charter programme then they receive consistent and effective mental health and wellbeing support, that is driven by the latest shared best practice.

But all the dangers and complexities of making judgements – which some will say “assured” them when a failing is found, and others will say condemned a provider when exemplary effort was put in, are really hard things for QAA, Advance HE and OfS to do, all with decades of experience of doing so – let alone Student Minds.

3. Prove it

I’m not calling for a league table, but outcomes and value for money do matter – especially if we’re playing with student fee income. We need to know if student mental health is getting better or worse (both generally and within student participation types, subject areas and by student characteristics) and to know what of that decline or improvement we can causally attribute to the behaviours and practises of universities.

See also OfS and outcomes! I’m not (yet) convinced the UMHC is really there on all that, and that will be a problem in the medium term.

4. Pick pocket

It seems to me that a lot of “quality model” approaches across HE (and in related sectors) are poor at getting at “pockets”, and the problem is that in (very) large universities a proportionally small pocket of bad practice can be a massive issue impacting thousands of students. See also OfS regulation and/or the TEF!

I’m just not convinced that the UMHC has that issue nailed – and it certainly feels like a department that doesn’t take any of this seriously could be missed by an assessment.

5. Two ticks

There are always tensions between models that require minimums (tick box exercises) and models that drive enhancement. As I say, I am not someone that always believes that regulation automatically drives folk towards cynically ticking boxes – but there clearly is a danger, and sometimes that danger comes externally to a quality effort rather than within it.

Crucially, if a scheme has been designed as requiring enthusiastic and voluntary consent, it almost certainly will need adaptation if chunks of participation in it switches to begrudging participation. Given the Donelan letter pushes us towards the latter rather than the former, what’s the plan?

6. Teaching and learning

As I’ve said on here before, I still think there’s more work to do on the academic/teaching and learning experience and what we think a “normal” or “acceptable” level of (dis)stress should look/feel like – especially in relation to assessment and regulations that surround it.

For me there’s too little consensus on all that, it feels to me that the UMHC fudges that quite a bit, and until I can see a clear link between (for example) the charter and the UK Professional Standards Framework (PSF) or standardised practice around mitigating circumstances there will remain concerns.

7. Call of duty

Again as I’ve raised before, we lack across our sector (and indeed within most universities) a decent and shared understanding of what a university’s duty of care *means* for its students. International aid charities will tell us that as long as there’s wild disagreement over what DoC means for adult beneficiaries, there will be big issues of gaps and overlaps – or a problematic mix of infantilisation and negligence.

It really does feel like that overarching issue needs clearing up before we move on here.

8. Staff

This isn’t Student Minds’ fault given its title – but do think the charter is fairly surface level on staff mental health, and I’m not sure it’s possible to address student mental health without addressing staff mental health. As Steve West himself put it in November:

Workplace mental health and wellbeing is cultural as well as structural – it’s about purpose as well as pay and pensions and workloads… We should not forget that under the fractured relations between sector leaders and trades unions, and not underestimating the challenge of staff mental health, surveys consistently suggest that this is a great sector to work within: transformative, changing lives, and life-changing.

9. Eggs is eggs

Above all, I think putting all (or at least a lot) of our eggs into this basket may be unwise. Ultimately, if lots of the practice in the charter should be considered core, and if we’re going beyond a focus on “student support services” and getting into the culture of a university or the teaching, learning and research activity, it ought to be in(tegrated into) the Quality Code or the OfS regulatory framework.

And I’m never comfortable with stuff that’s universally expected but not actually mandatory.

10. And finally

There’s other bits and bobs. I wish we knew more about what universities do that make student (and staff) mental health better or worse. The UMHC framework document is in many ways a great and well referenced compilation of what we do know. But it still feels like we don’t know enough.

I worry a lot about franchise provision, or year abroad work, or TNE, where the idea that your average partnerships manager is able to realistically assess the mental health culture and provision in a partner college is probably for the birds.

I fret about partners. All the evidence suggests that this stuff requires partnership work in a region, both with other universities, the voluntary sector and the NHS. But this is like assessed group work – what if the others don’t (or can’t) pull their weight?

What about student housing and accommodation, where there’s lots of evidence of the impact on pricing and design and quality on mental health, growing evidence of the (positive and negative) impact on students of living arrangements and issues with peers, and some providers offering extra mental health services – where many are not.

But overall, on the assumption that government policy (both directly in the HE space and generally in wider spaces impacting unis and students) can have an impact here, can we have a way for Student Minds to feel bolder in calling out bad stuff that it identifies as emanating from government? Isn’t the danger that an endorsement of this sort means it feels it can’t?

2 responses to “Ten notes of caution on making the mental health charter mandatory

  1. I am also in total agreement and would add an additional caveat.

    When moving forward from the Student Minds approach and the UMHC framework document to a more formal and possibly mandatory scenario, there is a danger that this “cut and paste” response may not be the best solution for all Universities. There may be issues of intellectual property involved and the possibility of a conflict of interest for Student Minds between their core activities and possibly being paid money for providing some form of accreditation to Universities to indicate competence / compliance with mandatory standards.

    In recent months we have seen organisations in the Diversity and Inclusion sector being challenged on their definitions / interpretations of important terminology.

    It may be better to introduce more options rather than rely on a monopoly supplier. Perhaps this is a service than needs a clear statement from Ofs as to what is required and then have contracts put out to tender. If we need a new body to develop new standards and then monitor and assess compliance we need Government to be clear on policy and not to fudge responsibilities.

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