Three years after ministers promised Welsh students a baseline of mental health support wherever they study, Medr has published a framework.
How on earth a regulator literally running a learner engagement code manages to run its steering group for it without a student on it is beyond me.
It also sets no minimum, creates no requirements, and arrived too late for the regulatory process it was supposed to strengthen.
Back in 2023 I hoped that Welsh autonomy on student mental health would see improved consistency. A Senedd committee had spent a year on the issue, the government had accepted its call for a common framework without conditions, and the contrast with England looked like a lesson for the rest of the UK.
The Common Mental Health and Wellbeing Framework appeared in August, and having gone back through what was promised along the way, the reality now looks pretty pitiful.
The committee’s 2023 report said the Commission must engage with all key partners in developing the framework, “but particularly students”.
Medr’s blog on the drafting thanks a 16-strong working group made up of staff from universities, colleges, training providers, adult learning and a student mental health partnership programme, and officials from Universities Wales, ColegauCymru, Learning and Work and NHS Wales – and not one student, sabbatical officer, SU or NUS Cymru representative.
Two members came from the same training company and two from the same college, and the group found room for an adviser from the University of Salford, which is in England. It didn’t find room for anyone elected by students in Wales.
The framework says its evidence from university students came from Medr’s analysis of free-text comments in the 2025 NSS, and the direct testing it describes was with apprentices, college students and adult learners. The students the Senedd inquiry was actually about were, in other words, consulted by spreadsheet.
This is a regulator whose ministers told it in 2024 to make sure that “learner voice plays a central role in the work of the Commission”, which runs a liaison group with NUS Cymru, funds NUS to support learner representation, and has just written a Learner Engagement Code.
Its framework even tells providers that their explanations of support must be “developed, tested and kept under review with learners, in line with the Learner Engagement Code” – which is more than Medr managed itself.
Nor can the other organisations round the table have been unaware that students had a stake. The call for a consistent standard of support started life in a 2022 set of post-16 mental health policy recommendations written jointly by NUS Wales, Universities Wales, ColegauCymru and AMOSSHE.
The government’s own advisory group in 2023 had the NUS Wales president on it. Three of those four organisations then sat on Medr’s group, and nothing Medr has published suggests anyone asked where the fourth had gone.
When the Senedd debated the report in June 2023, education minister Jeremy Miles said the new arrangements would create a framework “making it clear to students the baseline that they can expect from providers in this area”.
The 2024 statement of strategic priorities then told Medr that learners should be “clear on the minimum that they can expect from their providers”.
The framework quotes that priority in its first paragraph and spends the rest of the document explaining why it won’t set one. It is “proportionate”, it accepts that “not all providers will offer the same level or type of provision”, it won’t prescribe delivery models or staffing, and its example Support Map offers counselling only “where available”.
What students get instead is a common format for describing whatever their own provider happens to offer, and the nearest thing to a promise is that if something doesn’t feel right, “someone will listen”. A student can find out what their university does, but not what any university in Wales has to.
The teeth went the same way. In 2023 the government told the committee that registration and funding conditions plus guidance “will effectively constitute a common framework”, and Medr’s strategic plan promised welfare conditions “strengthened by a common framework”.
The framework now says it “does not introduce new regulatory requirements”, and the welfare condition it is meant to strengthen doesn’t mention it once.
Even the sequencing is off. The framework says it will help providers with the self-evaluation that goes with the welfare condition, but universities had to confirm they had finished that self-evaluation by 31 July – a fortnight before the framework was published.
The NHS link was supposed to be the hard part. Ministers asked Medr to improve “the coordination of service provision with healthcare services”, and in 2023 the government accepted in principle a Wales-wide roll-out of Cardiff and Vale’s university mental health liaison service.
In January 2025 the then further and higher education minister Vikki Howells told the committee that an extra £2 million for Medr would help, adding “we are looking to see if that can be rolled out across Wales”.
By July this year Lynne Neagle, who had met Medr monthly about it while in government, was telling the Senedd that progress was “still, as far as I’m concerned, too slow”, and a written answer that month confirmed the new cabinet minister hadn’t yet met Medr about it.
In September she told the education committee that “only Cardiff and south-east Wales” had the service, and when an official said Medr was still reflecting on data sharing, replied “They’ve been reflecting a long time”. The framework mentions none of it.
I mean for goodness sake. The government accepted in 2023 that data on how many students are struggling, who they are and whether interventions work “should be an expectation of all institutions” – the framework asks providers whether data “is used to provide insight”.
It accepted a “clear minimum of support” for international students and another for health and social care students on placement, and the framework mentions neither group. Miles promised better processes for students disclosing a mental health condition, and there aren’t any.
The framework was also due in April under Medr’s first operational plan, still calls itself a “draft” in its second paragraph, and has lost the physical health from the “common framework for health, mental health and well-being” that Medr and the government’s mental health delivery plan had both promised.
Part of the reason it has drifted this far is that nobody has been checking. The government promised the committee annual updates, but the only annual report it sent was about schools, and the last letter on the 2023 report arrived in June 2024.
No ministerial statement has mentioned the framework since, and it didn’t come up in any of Medr’s three scrutiny sessions with the committee. The new committee said in September that it would write asking about the mental health programme in higher education – it might start by asking who was in the room.
Medr’s own equality impact assessment concedes that the main risk is “variability of offer and provider capacity”, which is a precise description of the problem a common framework was meant to solve.
Giving evidence at Westminster in 2023, Lee Fryatt, whose son died while studying at Bath Spa, said best practice “should not be voluntary in this space, and currently it is”. In Wales, three years and a new regulator later, it still is – and this time students weren’t even asked to help write it.