BABCP response to Scottish Government consultation on NHS Delivery – a new national delivery organisation to lead transformation across our health and social care system
The British Association for Behavioural and Cognitive Psychotherapies (BABCP) is the lead organisation for Cognitive Behavioural Therapy (CBT) in the UK and Ireland. Our mission is to support the development of CBT, and those who deliver it, to improve the mental health of people across the UK and Ireland.
As the leading organisation for CBT in the UK and Ireland with over 24,000 members, we are committed to promoting the highest standards of CBT practice, training, and supervision. We hold all of our members to the highest professional standards, which they commit to by adhering to our Standards of Conduct, Performance, and Ethics.
Our response to this consultation will therefore focus on the impact that the proposals will have to CBT psychotherapists, and other members employed by the NHS in Scotland.
Question 1
Do you agree that creating a new national organisation to drive forward digital transformation and system change – beginning with the consolidation of NES and NSS into one organisation – is the right approach to deliver the ambitions set out in Scotland’s Population Health Framework and Service Renewal Framework?
BABCP supports the principles of the Service Renewal Framework, particularly the principles of shifting to prevention, community, digitalisation, and placing people at the centre of the plan. In theory, creating a new organisation to deliver the ambitions in the plan by merging NES and NSS could reduce fragmentation and facilitate streamlining. However, it will depend on how the organisation is managed, and whether the feedback from workforce and patients is incorporated into the system.
BABCP welcomes innovation and digitalisation as a way of making processes more efficient. Digital tools offer an opportunity for widening access, however, they could also be a source of exclusion. It is therefore important to emphasise that any new organisation tasked with improving digitalisation in the NHS, ensures that this is co-created with the general population so that there is equitable access to services with non-digital alternatives available for those who may not be able to use technology. This should include the provision for education on digital technologies and the use of computer/phone/software to access mental services.
BABCP would also welcome the new organisation to facilitate more community care. However, for community support to be effective, there need to be enough resources in the community and access to evidence-based treatments as well as safe and accessible infrastructure. While some progress has made, some key barriers that remain include the long-term lack of staff and funding for mental health services so that people can afford to work in care services long term.
The move to prevention is also a very important part of the new framework. It is crucial that the Government takes action on increasing provision of BABCP Accredited Cognitive & Behavioural Psychotherapists encouraging and facilitating their training and supervision who can deliver evidence-based tailored mental health approaches to people in the community. BABCP-registration should also be encouraged or mandated for those delivering low intensity interventions or any CBT informed approaches such as EPPs. Utilising the available skills within the existing workforce so they can be used to their potential will increase workforce retention an allow a smooth transition to community and preventative care.
The training of BABCP-accredited CBT therapists is crucial to increase capacity and presence in schools to treat children and adolescents. As we know there is a growing demand for psychotherapies amongst children and adolescents so ensuring that BABCP-accredited CBT therapists have a presence in schools will ensure high-quality therapy delivered by those who have met the stringent criteria for qualifications and clinical experience.
Lastly, mental health awareness has to be embedded in every area of society from early years to older adult care. This will provide the population with an opportunity to take care of one’s mental health by building it into school curricula, social care and the workplace acting as a preventative tool allowing early identification of any challenges.
Question 2 (a)
Do you agree with the proposed strategic objectives for the new organisation (driving innovation, delivering Once for Scotland services, and streamlining structures)?
BABCP agrees with the need for innovation, streamlining and delivering Once for Scotland services.
NHS Delivery must address the challenges in system usability infrastructure and ensure effective integration between different services/ platforms. Some of the infrastructure is difficult to use, time-consuming and inequitable for people with disabilities so accessibility is key.
On driving innovation and keeping in line with the principles of the Service Renewal Framework, the Scottish Government may wish to consider a scheme similar to NHS Talking Therapies in England where the Government has been successful in increasing community care by recruiting BABCP-registered Psychological Wellbeing Practitioners (PWPs), Children’s Wellbeing Practitioners (CWPs), Education Mental Health Practitioners (EMHPs) and Mental Health and Wellbeing Practitioners (MHWPs). A psychological wellbeing practitioner (PWP) assesses and treats people with mild to moderate mental health problems, such as depression and anxiety disorders, using low-intensity cognitive behavioral therapy strategies. These professions are all accredited by BABCP, and the inclusion of these professions in the shift to community care has proved essential to its success. PWPs have similar training to EPPs the Scottish Government may wish to consider BABCP-registration of EPPs. https://digital.nhs.uk/data-and-information/publications/statistical/nhs-talking-therapies-for-anxiety-and-depression-annual-reports/2024-25/therapy-based-outcomes.
The Government should also consider that video CBT and telephone CBT is a modality of CBT and should be delivered by BABCP accredited CBT therapists to ensure that the highest standards of ethics and practice are met in all Trusts.
The move to streamlining structures, training standards and supervision should help CBT therapists and the provision of mental health in Scotland, if done appropriately. In Scotland, currently, many experienced professions such as social workers, nurses and others cannot continue a career in CBT psychotherapy as the pathways are not as clear as in England and not all employers facilitate taking time off to do the relevant training and accreditation, so it is very Trust dependent.
As above, there is a need to have a consistent pathway for training and supervision of CBT Therapists which is not trust dependent. NHS Delivery should ensure that all employers facilitate those who have an interest in becoming a CBT psychotherapist to do the relevant training so that they can be deployed in the area where there may be needed most – even more so important with the shift to community care. This will help to meet ambitions of Scottish government by reducing some barriers in NHS CBT practitioner training. BABCP also has a role to play in supporting those on non-accredited courses gaining accreditation through KSA and we will be willing to work with NHS Delivery in this area.
There is also a need to ensure that the training standards are all equivalent across all Trusts. This is why we strongly suggest that the Scottish Government mandates BABCP accreditation for all NHS employed CBT therapists in Scotland. This will aid with streamlining while providing patients with the reassurance they need that they are being treated by a CBT therapist held to the highest possible standards of practice. Being an accredited CBT therapist means adhering to BABCP’s standards of conduct and if a breach of those standards takes place matters can be investigated which offers public protection.
Lastly, the new organisation should also look at streamlining access to talking therapies in Scotland. We would suggest that self-referral should be implemented across all Trusts, whereas now, it is available on some Trusts while in others, patients are dependent on referrals from their GP. It should also ensure increased access for people experiencing suicidal ideation- as the evidence suggests offering therapy promptly can make an impact; yet many services operate to exclude on the basis of risk. NHS Delivery should consider this guidance by NHS England: https://www.england.nhs.uk/long-read/staying-safe-from-suicide/#who-should-implement-this-guidance.
Question 2 (b)
Should the organisation consider additional strategic objectives?
One area that should be considered by NHS Delivery is increasing training provisions to produce BABCP-accredited CBT therapists. As explained in question one, there is currently considerable variability between training standards of CBT therapists in Scotland and we believe that mandating BABCP-accreditation across all CBT therapists working in the NHS will ensure the highest quality of therapy, public protection and safety. This will also help tackle the long waiting lists to access mental health support.
NHS Delivery should consider investing in all evidence-based psychotherapies, including CBT and using these methods in Drug & Alcohol Services, schools, and other settings.
Question 3
Are there services or functions currently delivered by other organisations (in addition to what NES and NSS already do) that should be delivered only by NHS Delivery to improve consistency and reduce duplication?
The coordination of all levels of psychological therapy in Scotland by NES is well organised and considered. The difficulty is that health boards in Scotland are at liberty to choose how psychological therapy provision happens, how or if staff are supported to access training and whether or not they wish a staff member to have done an accredited training.
A uniform approach across NHS Scotland would help to rebalance inequity in access and a uniform approach to accreditation of CBT therapists would ensure a uniform quality of care and educational standards.
Question 4
What areas of national delivery could be improved by NHS Delivery to make services more efficient or better joined-up?
Please see the response to question 2. BABCP believes that creating a scheme similar to NHS Talking Therapies employing CBT accredited psychotherapists which adhere to BABCP standards will aid with streamlining access to psychological therapies for patients. Service improvement and reduction of health inequalities has also been enhanced by consistent data collection at every session, monitoring and acting on outcome data.
It will also be important for NHS Delivery to work further with BABCP to ensure that CBT therapists working for the NHS are all BABCP-accredited, as is the case in England.
Additionally, NHS delivery could lead on scaling up and clear service provision for Trauma Informed Disaster planning – e.g. Covid, Terrorist attack, natural disasters, issuing clear guidelines for skilled staff.
Question 5
Are there any existing services, programmes, or functions currently delivered by NES or NSS that you believe could be stopped, scaled back, or redesigned (or handed over to another organisation) to better align with current priorities and system-wide impact?
Currently, NES provides health workers with education, training, workforce development needed. There should also be a review of NES services and programs along with NSS. This should include effectiveness, cohesiveness and cost of training and supervision pathways; to ensure it aligns with BABCP standards.
There should also be consultation with those delivering services regarding what training is required, and what challenges are being faced so that training is appropriate and tailored to the needs of those delivering the services.
Question 6
Do you agree that NHS Delivery should lead the development of national digital capabilities (e.g. Electronic Health Records, digital inclusion, data architecture) for Scotland’s health and social care system?
BABCP believes that if NHS Delivery is the organisation tasked with driving innovation, it will make sense for the organisation to lead on the development of national digital capabilities.
While there are considerable benefits to digitalisation, it is crucial that NHS Delivery ensures that there are efficient and effective processes for those working with any newly introduced IT systems. They must include appropriate training of staff, accessibility issues and ensure regular updates; as well as education and support for patients using the new systems. This should include the possibility of contacting a person in real time for any troubleshooting and support for those who choose not to or cannot access the system.
NHS Delivery should also pay attention to the introduction of AI and digital models as this will have an impact on workforce modelling replacing some of the administrative tasks such as managing online appointments, rescheduling, reducing the need for some of the administrative professionals. The deployment of AI and digital models will also require employing different professionals such as project managers to be able to deal with the challenges from integrating services, infrastructure or system usability as well as other professionals that are able to offer adequate training to staff using these tools to build staff confidence.
Question 7
Should NHS Delivery be tasked with improving data sharing, data access and interoperability across health and social care?
NHS Delivery could be tasked with improving data sharing, access and interoperability. It is crucial that as part of that exercise, “one policy for NHS Scotland” on sharing of audio and video recording for staff in training is developed. This would help to ensure quality of training and uniformity of approach.
Administration staff are also crucial to well-run services, so; while management is important, it is also crucial to continue investing in personnel at all levels that can deliver frontline services.
Question 8
Do you believe NHS Delivery should be tasked with the lead national support role in innovation development & adoption, service redesign, change management, improvement, and commissioning?
Yes, it could be if an NHS Talking Therapies approach was considered, or an alternative Scotland-wide cohesive approach to quality and consistency of CBT training, including BABCP accreditation and standards.
It is crucial that any development is made in conjunction with staff involved in delivering frontline services rather than removed from these functions.
Question 9
As NHS Delivery evolves in the longer term, what additional capabilities, functions or bodies should be considered for integration into a single national delivery capability that supports the aspirations of the Service Renewal Framework?
NHS Delivery should consider implementing any lessons learned from NHS Talking Therapies deployed in England, so this can be incorporated into any future schemes in Scotland.
NHS Delivery should also consider developing whistleblowing services, give more power to Guardian Service and consulting with expert trauma informed services and serviced organisations as well as trade unions.
Question 10
What principles should guide decisions about future expansion of NHS Delivery’s remit and structure?
NHS Delivery should be guided by the principles of Transparency, Accountability and Compassion; as well as by listening to those with live experience and their carers.
Any expansion should also be guided, considering the importance of having an NHS organisation that focuses on education and training being carried out within the NHS and acknowledging the need for good quality education programmes with appropriate quality assurance, that increase knowledges and skills within the workforce. Decisions should also be guided by acknowledging the role education plays in ensuring patient safety and outcomes.
Question 11
What mechanisms should be put in place to review and adapt NHS Delivery’s remit and performance post-launch?
It is crucial for the Government to invest in people who are delivering health and care services. Some of the interventions which will be welcomed include training and providing career pathways, reasonable income and providing support to increase staff wellbeing and retention.
Any review should also take into account the voices of lived experience and carers.
There should also be independent reviews, staff feedback and consultations, and trade unions should be able to represent the workforce.
