The Department of Health’s wide-ranging consultation on the Care Act’s draft regulations and guidance has closed. Here are five key areas concerning social work’s role that are raised in the consultation responses from The College of Social Work and the British Association of Social Workers.
1. Greater clarity on the role of registered social workers
The TCSW and BASW responses both say that more clarity is needed on how registered social workers should be deployed in the assessment and support planning processes under the Act.
The Care Act guidance does say that registered social workers and occupational therapists are “key professions in adult care and support”. However, it also says that assessments can be carried out by a range of professionals and commonly refers to ‘care and support workers’ more broadly.
In its response, TCSW argues that the guidance “should be more precise” about social workers’ role. It says that social workers “are uniquely placed” to support complexity and argues that, when it comes to support planning, “there are instances where social workers should be used specifically.” TCSW also calls for greater clarity on the social work function with regards to advocacy.
BASW’s response also states that “clarification is required as to when the assessor must be a registered social worker”. It also recommends that the guidance is revised to include a specific section on the role of the social worker.
2. Social work input into screening and prevention processes
Linked to the above, is the question of social workers’ roles in early intervention and screening services. Both BASW’s and TCSW’s responses argue that teams involved in the early stages of care should have some social work input.
BASW’s response ‘strongly recommends’ that social workers are employed to support non-social work qualified staff who are working in access and assessment teams. Meanwhile, TCSW argues that, while councils need to utilise a wide range of skills and expertise in preventative services, social workers could take “a leadership role” and advise teams in a front-end capacity.
“There were fears that without some social work presence early on, situations could emerge whereby social workers would have to ‘pick up the pieces’ further down the line. It was felt that social workers are better able to understand complexity and long term needs and plan accordingly,” TCSW’s response says.
“This could involve some form of supervision role, with social workers supporting and training non-qualified staff, thereby equipping the wider work force with a set of skills.”
3. A greater focus on the person, not the process
TCSW’s response raises a number of concerns over the guidance on personalisation, particularly on whether it can support health and social care integration. TCSW argues that the guidance “does not adequately address” how the differences between health and social care systems (for example, the NHS is a free service while social care is chargeable) can be reconciled in practice.
Another concern is the guidance’s tool for promoting multi-discplinary working – namely a single, detailed support plan for each person that is coordinated by a ‘lead agency’. TCSW argues that this approach is flawed and “could have the unintended consequence of generating burdensome additional paperwork and bureaucracy.”
TCSW argues that the guidance’s implication that someone’s needs would remain relatively stable after a detailed support plan is agreed, does not fit with reality.
“At any point the revision of their support plan may involve or require input from a district or specialist nurse, speech and language therapists, a psychologist and might require a personal budget used to pay for personal assistants, or a new housing need. This raises the question of the appropriateness of the ‘lead’ organisation and how the paperwork – in this instance detailed information regarding the amount in a personal budget and charging rates – would be allocated,” the response states.
“It is therefore the view that though the guidance should focus on joined up working, the extent of the focus on the joint support plan detracts from a personalised, individual approach. The person should be at the heart of how services are co-ordinated, not the process.”
4. Stronger oversight of third-party social work providers
The Care Act provides a legal right for the very first time for councils to contract out adult social work functions related to assessment, resource allocation and care planning.
TCSW says that the provision raises questions around how strong professional standards and social work supervision will be maintained when services are contracted out. The College says that delegated arrangements must be “person proof” to ensure they are not easily disrupted by management changes.
It recommends that the guidance should require councils to identify a principal or lead social worker who will be responsible for ensuring employer standards are implemented and put in place arrangements for third-party providers to undergo an annual ‘health check’ on whether practice conditions are “safe, effective, caring, responsive and well-led”.
BASW’s response says that there is a “potential tension” in the Act between the drive to integrate services and the new delegation powers.
“Increasing fragmentation of services could make the task of social workers and other professionals in coordinating services more complex and hinder the development of more effective preventive services. We would like to suggest that the guidance alerts local authorities to consider carefully how social work services are commissioned to reduce the risk of fragmentation if social work is outsourced,” the BASW response states.
5. A stronger recognition of social factors
Both BASW and TCSW’s responses highlight parts of the guidance where they feel the social elements of someone’s care needs are not given enough consideration.
TCSW’s response says that the guidance on assessments needs to recognise that ‘complexity’ is not just about the extent and severity of need, but also how difficult it is to involve the person, the severity of risk and potential for conflict.
The response states: “Furthermore, complexity does not relate only to the degree of someone’s impairment, but also to social situations and therefore the guidance should refer to housing, finances, family relationships, disputes, community participation and social isolation, and stress on family carers among other factors. TCSW believes this should be better reflected in the guidance.”
BASW’s response points to the fact the guidance on needs assessments and carer’s assessments talks about assessors needing to know about someone’s “conditions”. This, they say, could lead to narrow interpretations focusing on physical causes and manifestations of conditions. BASW recommends that it would be more appropriate to say assessors need to know “about the condition and the physical, psychological and social consequences of it.”