Welsh autonomy on student mental health will see improved consistency

In March 2023, following a detailed, thorough and thoughtful inquiry into student mental health, a parliamentary committee came forward with a thought-provoking report containing 33 recommendations for government on improving the quality and consistency of mental health support across higher education.

My colleague Michael Salmon wrote it up on the site at the time, noting that it had used student focus groups and university visits, as well as evidence from charities and campaign groups, NHS trusts, trade unions, university management, and a wide range of higher education sector bodies to inform its findings and recommendations.

It covered a wide range of issues – such as the impact of pandemic, mitigating the impact of the cost of living crisis, improved data collection, better information sharing, training and awareness raising for staff and students, and more sustainable funding which matches the level of need.

We now have the response from government – which although is partial given the relationship between the government and the regulator and the need to consider some funding implications in the round, sets out a comprehensive and impressive range of commitments to be delivered in partnership with the sector.

There will be a a strategic approach that embeds health and well-being, including mental health and suicide-safer approaches, into university policies and practices.

You’ve not heard about it? That sounds far-fetched? It’s in Wales.

How can I ever change things that I feel?

In the witness evidence session designed to inform the Westminster Petitions Committee debate over a statutory duty of care for students in higher education, an important issue raised was that of consistency.

Lee Fryatt, whose son died by suicide while at Bath Spa, drew a specific distinction between optional best practice and universal minimum practice:

The point about a statutory duty of care is to say, “Right, we’ve now got best practice”. A statutory duty of care, if you do not implement best practice, means you have some accountability as an institution to explain why you have not followed that best-practice guidance. [The question would be] Why have you not ensured that your staff have been trained in that best practice and why did you not implement it?… We say that best practice should not be voluntary in this space, and currently it is.

And Mark Shanahan, a politics lecturer at the University of Reading whose son Rory died by suicide while at the University of Sheffield, saw inconsistencies both across thre sector and within universities

Universities are communities. They are community of care, or so they should be. However, what we are finding is that, while there are many fantastic things that go on in a lot of universities for most of the time, there isn’t a consistency of practice. Students do not get the parity of approach; they do not see consistency from us, between departments or between institutions or across the academic and professional teams within universities.

The Welsh Parliament’s Children, Young People and Education Committee inquiry specifically explored the extent to which a diverse sector might work towards a consistent standard of provision.

It heard that all Welsh universities were signed up to Universities UK’s Stepchange and Suicide-Safer Universities framework, but noted that there is no set standard for mental health and wellbeing services, and that collaborative policy development work undertaken by all the main players in this area had “recommended a consistent standard of expectations for all students.”

So building on the introduction, during the passage of the Tertiary Education and Research (Wales) Bill 2022, of a specific condition of registration on the effectiveness of arrangements for supporting the welfare of students and staff within providers, the committee called on the government, through the new Commission, to prioritise:

… the development of a common framework for mental health support across the higher education sector. The Commission must ensure it engages with all key partners, but particularly students, in developing this framework. This framework should set out a baseline but be flexible enough to enable institutions to design services that takes account of their own specific contexts and the specific needs of their students. It should also reflect and complement any wider work on mental health support in the post 16-sector more broadly.”

And now the government has unconditionally accepted that recommendation:

The new registration and funding conditions will require the Commission to set out clear expectations for universities and colleges regarding the effectiveness of their policies, services, and processes for supporting and promoting student and staff well-being, welfare, and safety. We anticipate that the new registration and funding conditions will cover many of the matters raised in the Committee’s report, as well as building upon the Stepchange framework and the current expectations of higher education providers set out by HEFCW. Combined with the relevant issuing of guidance and best practice to providers, this work will effectively constitute a common framework for mental health support across the tertiary education sector, developed in partnership with key stakeholders.

There’s still a way to go here – the government also says that “costs will need to be considered by the Commission as part of budget allocations.” But the difference in approach from the government and its emerging regulator between Wales and England could not be more stark.

How can I when you won’t take it from me?

There’s lots of other recommendations here that should strengthen support and deserve praise.

A call for accurate, timely and consistent data on the extent of mental health issues within each student body (including the demographics of those reporting mental health distress) is accepted in principle – as is a push on understanding the interventions that they are putting in place and evaluation of the interventions.

For those familiar with the Access and Participation regime in England, it’s “gather the data, analyse the data, do something about it, evaluate those interventions” and does make you wonder why so few universities elsewhere in the UK can tell you if anything they’re doing on mental health is making a difference.

The committee had asked that CTER oversee providers and student representatives working together to set a base level of provision for international students, taking into account the specific needs of the different groups which make up the international student community. That was accepted. It also called on CTER to ensure that placement providers and student representatives work together on addressing mental health issues arising from placements. That was accepted too.

In fact, Health Education and Improvement Wales (HEIW) has already established wellbeing as a key theme in new education contracts for healthcare professionals – with adherence to student well-being support a part of their Performance and Quality Framework.

In the CYPE report there was a whole section that (quite rightly given the evidence) drew links between cost-of-living support and mental health. Recommendations are accepted there in principle too – as are recommendations on identifying best practice around transitions, which you may remember the Westminster government promised to do once but in the end spectacularly failed.

A new cross sector policy advisory group on mental health in tertiary education will be formed, work will be done on supporting students to disclose mental health conditions, there are in-principle commitments on mental health training for staff and students, and while specific calls for funding assessments to be carried out have been rejected, the government has agreed to move towards longer term funding for mental health support having had various one-off project pots in recent years.

The government will also start work with the NHS on the development of a shared and clearer understanding of the roles and responsibilities across healthcare and education for student mental well-being (encompassing agreement on thresholds, language and definitions), will ask CTER to take the lead in establishing effective data sharing protocols between HE providers and the health service, and accepts a recommendation that would establish a student passport enabling “away from home” students to share their healthcare information more easily.

There’s even a commitment to ensure that staff working conditions, including terms and conditions of employment, do not undermine staff in providing effective support to students.

You can call it another lonely day

Of course there are worries about funding here, and Universities Wales are likely to resist undue prescription from CTER partly over the old “One Size Fits All” problem, and partly over universities’ own ability to deliver consistency that students might want to hold those providers to legally.

As ever, things are easier when you’re holding eight universities to account rather than 415 HE providers. It’s increasingly odd that reports like the CYPE’s and the Welsh Government’s response don’t acknowledge the Welsh students studying in other parts of the UK – although maybe the politics prevent a direct confrontation. And there isn’t mention of a statutory duty of care here either – Health and Safety Law is not devolved.

But on the assumption that such a duty would be accompanied by regulation (in the same way that, say, consumer protection law is accompanied by the Quality Code/OfS B Conditions) this smart-looking package of support, partnership convening, data gathering and in-principle commitments on funding offers a glimpse of how things could be if the grown-ups in England could just stop pointing at eachother and get on with delivering the consistency that the CYPE says students need.