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PEQF - Judicial Review Action Launched

Chief Constable of Lincolnshire Seeks Judicial Review of College of Policing scheme to require all new police officers to obtain a degree

In  an exceptional legal move,  the Chief Constable of Lincolnshire Bill Skelly, supported by Police and Crime Commissioner Marc Jones has begun the first stage action to take the national College of Policing to Judicial Review over the new degree requirement recruitment scheme being imposed on the police service.  The College of Policing is the national body which was established by the Home Office in 2012  and Mr Skelly is taking issue with its plans to implement a new officer recruitment process which requires all recruits to have an academic degree or be prepared to commit to study for one in work time.  

But he says it will mean 40 fewer officers at any one time for front line policing  - roughly 10% of his deployable strength – because the study time has been significantly increased compared to the current recruitment programme, increased turnover and failure to complete the course. In addition, there will be extra cash costs to pay for contracts with local   academic providers and a requirement for more training staff within the force.  There is no estimate for the impact across England and Wales but if it is 40 officers for Lincolnshire, it could easily be over 4,000 for the country.

“I have been raising these concerns with the College of Policing and the National Police Chiefs Council (NPCC) for more than two years since the impact of PEQF became clear,” he said.  “The College has pushed forward ignoring the growing evidence that demonstrates the impracticality of their proposals for Lincolnshire. Their most recent communication states the intention to change Police Regulations to enforce the  Police Education Qualifications Framework (PEQF) recruitment process from next year,” says Mr Skelly.

He is being fully supported by Lincolnshire’s Police and Crime Commissioner Marc Jones who is funding the court action.   “All I am asking for is a stay of implementation (to the summer of 2023) to give time for a legitimate evaluation of the new system being imposed across the country  and for the  results to be assessed and any adjustments made,” says Mr Skelly. “In the meantime we are developing an enhanced initial training package that meets the requirements of the modern police officer without creating an unaffordable impact on the police service in Lincolnshire.”

In addition to the financial costs, Mr Skelly says that no assessment has been made on such issues as the additional strain on the Police Pension Scheme or on the impact on equalities.  Mr Skelly has also questioned the future of the Special Constabulary under PEQF.  He said “The College is requiring that every new police officer to be a degree holder and have undertaken years of initial training.  At present, Special Constables have the same police powers as our regular officers but do so after a limited period of training and a lower required level of educational qualifications.  I see this as unsustainable after the introduction of PEQF”.

Lincolnshire’s Police and Crime Commissioner Marc Jones has also written to his PCC colleagues in England and Wales saying that many of them share his views on the introduction of PEQF.

“I was elected by the people of Lincolnshire to represent them and act in their best interests regarding policing and crime.  Put simply, if I did not challenge the imposition of these untested and far reaching changes that will see fewer officers on the streets of my county and the country as a whole, I would be failing in my duty.  The public did not support a council tax rise earlier this year so we could put extra cops in classrooms and to have fewer than ever fighting crime and protecting communities.  I would have expected the College to present a single business case that includes a detailed academic rationale, full financial assessments, detailed equalities assessments and a full benefits realisation plan,” said Mr Jones. “Protecting the people of Lincolnshire is our number one priority and to do that we cannot support a further loss of officer numbers to this ill thought through scheme.  We believe that losing around 40 officers from the front line without challenging the College would be unforgivable and the costs to the public both financially and in loss of service leave us with no choice.”

Key facts and implications of PEQF

The following research has been done by Lincolnshire Police which covers abstraction, failure demand, turnover, diversity and ethnic minorities, cost, rational, existing workforce and other significant issues; with a brief description of each below:

  • To begin with abstraction has been found to be one of the key issues with PEQF, as the new routes will lead to an increased level of abstraction, which will remove officers from the front line.
  • Lincolnshire Police will financially be unable to recruit additional officers to cover the level of abstraction, as PEQF will, on the whole, cost even more as a training initiative compared to IPLDP.
  • From drawing comparisons with nursing, which has a similar educational history to policing, there may be an increase in failure demand from the pre-join degree, as well as an increased turnover.
  • Another point of concern is that PEQF may have a negative impact on the diversity of forces and will disadvantage minority groups.
  • There is also the issue of the College’s rational for the introduction for PEQF, as this does not seem to be substantiated by rigorous background research or pilot studies.
  • The College have also yet to supply sufficient proposals on the special constable educational requirements and the promotion from constable to sergeant.

Introduction

The Policing Education Qualifications Framework (PEQF) represents a substantial change from the status quo in policing, with significant potential to impact upon the Statutory Duties and Obligations of the Service in general and of PCCs & Chief Officers in particular. These range from the Chief Constable’s duty to avoid discrimination in employment and other areas, through to those relating to the maintenance of business continuity and interoperability.

Abstractions

Definition of Abstraction: For the purpose of this report we define abstraction to be the withdrawal of a police officer from operational duties for the purposes of learning and assessment.

  • The abstraction impact is very high, particularly around the PCDA, due to a compulsory 20% of time spent “off the job” in order to cover the required knowledge.
  • The predicted abstraction of the student officer for the PCDA route is around 40% for year one, 20% in year two and 20% in year three. Currently, the abstraction level through IPLDP is 40% in year one and 6.4% for year two. Therefore, if a force recruits 5% of their total strength each year, then the abstraction of total force strength would rise from the current level of 2.5% to 6% of total constable strength.
  • The predicted abstraction of the student officer for the DHEP route is around 40% for year one and 20% in year two.
  • The predicted abstraction of the student officer for the Pre-Join route is around 7% for year one and year two.

Failure Demand

  • No consideration appears to have been given by the College in its modelling to the impact of either the failure of student officers to complete their qualification course, or their resignation from the Service before their normal retirement date, i.e. the use of the PCDA primarily as a means to acquire a degree qualification without incurring student debt.
  • All degree level courses have a non-completion rate and there does exist vocational degree qualifications, such as Nursing Degrees to which ready comparisons can be made. In 2015/2016 the average dropout rate across all degree programmes was 10.5% (Higher Education Statistical Association, 2018); whilst in nursing the average attrition rate is 25%(The Royal College of Nursing, 2018).
  • The nursing degree programme has the closest parallel to the PEQF pre-join programme, in that it is a programme designed for a specific career outcome. The pre-join degree will have the additional pressure on failure demand.

Turnover

  • The percentage range of turn over for PEQF is predicted from turnover rates in similar professions such as teaching and nursing, whose turnover rates are between 10%-16% (Department for Education, 2017; Royal College of Nursing, 2018) this would double the current average police turnover of 6% (Home Office, 2017).

Diversity and Ethnic Minorities

  • Ethnic minorities are well-represented in traditionally academic and high-earning degrees such as law (33.7%), medicine and dentistry (33.6%), business and administrative studies (30.7%). They are much less represented in public sector degrees such as education (15.1%).
  • Additional evidence for this conclusion can be gathered from the NHS, as similar requirements are in place for nursing, yet the organisation still faces challenges with diversity and attrition.
  • There is the concern that the introduction of the entry requirements of pre-join, degree-holder and apprenticeship will deter mature applicants. The numbers interested in becoming police officers who are under 25 is 51.4%, compared to those aged 26 and over, which is 48.5%. Thus, there are a substantial proportion of those individuals over the age of 26 who want to pursue a career in policing.
  • One of the larger issues for mature applicants is that the pre-join degree option would not be a suitable path for a lot of applicants, due to financial and timing constraints. For example, in consultations it has been raised that working as a Special Constable would reduce the opportunity for applicants to take part in paid work to supplement their income.
  • The longer probationary periods may be off-putting for mature applicants. By extending the probationary period, apprentices would be paid an apprenticeship wage for 3 years. It is likely that this would appeal more to younger rather than mature applicants. This is further evidenced as mature applicants, targeted for recruitment, find even the current appointment rates of pay problematic.
  • By introducing higher entry requirements, such as a pre-join degree, which are academic in nature, the College may be affecting the public-sector Equality duty. There needs to be clarity around how the College will ensure that chief constables are upholding their Equality duty, specifically when it comes to students who have a disability that would impact on their learning.
  • There are particular protected characteristics, which it is against the law to discriminate against. In both of the College’s equality impact analyses they have provided very limited information on some of these characteristics (e.g. gender reassignment, marriage and civil partnership), and how PEQF could affect them.
  • An estimated 25.6% of pupils who were in receipt of Free School Meals (FSM) aged 15 in 2012/13 entered Higher Education by age 19 by 2016/17. This compares to 43.3% of non-FSM pupils. The gap in progression rates between FSM and non-FSM pupils has remained at 17.7 percentage points over the past three years. The gap has varied between 16.8 and 19.2 percentage points since 2005/06 (Department of Education, 2018). Therefore adding a degree to the entry criteria for police officer could be a potential barrier to those from a disadvantaged socio-economic background. Meaning the force would not be representative of the people we serve.

Cost

  • We determine that by 2024 Lincolnshire Police would be expending £1,152,000 p.a. on PCDA training. Only circa £400,000 of this would be met by Force Apprenticeship Levy contributions, with a further £115,200 having to be drawn from Force funds as a contribution to Government co-investment. This represents a significant increase in the budget currently set aside for the direct costs associated with the training of new recruits (circa £100,000).
  • With the adoption of DHEP the overall cost of training would fall by circa £113,000. This ‘saving’ is in fact a cost to the Force, as external funding for this training is not available as it is for apprenticeship training. We anticipate that funds recouped from provision of apprenticeship training might be deployed to fund other PEQF qualification routes, but this simply places the eligible costs of apprenticeship training as a cost to the Force, so no real saving is achieved.

Rationale

  • The College continues to present the unsupported claim that development of a higher skilled workforce will result in better policing outcomes(The College of Policing, 2018, p. 8). Yet, the latest academic examination of the evidence of the impact of graduate education upon policing concludes that, “research is unable to confirm unambiguously that values associated with higher levels of education may bring improved policing outcomes,” and critically, that, “it seems policing or criminal justice degrees confers no particular advantage” (Brown, 2018).
  • The College has presented the role of police officer at a level 6, whereas it currently is set at a level 3. The College has attempted to relay their rationale for this decision in a number of documents (e.g. Case Study 1 – Why has the new police constable curriculum been set at level 6?). Yet, it stills remains arguable and also subjective as to what level the role of PC should be at.
  • In 2007 Denmark introduced their bachelor’s degree programme in policing. There were many issues with this introduction and it gradually met its demise due to the systematic decoupling of the educational reform from its strategic objectives (Diderichsen, 2017). There can be parallels drawn from this introduction to that of PEQF.

Existing Workforce

  • The College has released limited information on the educational requirements and training of special constables, in relation to PEQF. They mention in their transition guidance document (June 2019) that in the future they will be developing proposals for specials that accommodate the service’s needs.
  • There is also limited information that has been released on a constable’s promotion to sergeant and what the requirements are for this under PEQF. At the time of the writing on the transition guidance document (June 2019) the PEQF requirements for the rank of sergeant and above have still yet to be confirmed.

Other Significant Issues

  • The current National Police Promotions Framework (NPPF) was developed and trialled over several years before then being implemented over an additional three-year timeframe. The PEQF is expected to be simultaneously developed and implemented across all Home Office Forces by January 2020, with very few or no trials. It seems that the College will provide support, yet worryingly has supplied limited opportunity to pilot different delivery models, which would be very insightful for effective implementation of PEQF.
  • The College have attempted to consult with various people, such as Chief Constables and PCCs. These results were presented in their December 2016 report in which they failed to address key concerns or make any changes to their plans (e.g. Individual respondents had mixed views on whether the level 6 description is relevant to the role of constable).

References

Brown, J., 2018. Do Graduate Police Officers Make a Difference to Policing? Results of an Integrative Literature Review. Policing: A Journal of Policy and Practice, 15th November.pp. 1-22.

Department for Education. (2017). School Workforce in England: November 2016. Retrieved from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/620825/SFR25_2017_MainText.pdf

Department of Education. (2018). Widening Participation in Higher Education, England, 2016/17 age cohort – Official Statistics. Retrieved from: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/757897/WP2018-MainText.pdf

Diderichsen, A. (2017). Renewal and Retraditionalisation: The Short and Not Very Glorious History of Danish Bachelor's Degree in Policing. Nordisk Olitiforskning, 4, 149-169.

Higher Education Statistical Association, 2018. What are HE students' progression rates and qualifications?. [Online]
Available at: https://www.hesa.ac.uk/data-and-analysis/students/outcomes
[Accessed 6th December 2018].

Home Office. (2017). Police Workforce, England and Wales, 31 March 2017. Retrieved from:  https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/630471/hosb1017-police-workforce.pdf 

The Royal College of Nursing. (2018). Fund our Future Nurses. Retrieved from: https://scadmin.rcn.org.uk/professional-development/publications/pub-007348

The Royal College of Nursing, 2018. Nursing student dropout rates. [Online]
Available at: https://www.rcn.org.uk/news-and-events/news/student-attrition-rates
[Accessed 5th December 2018].

Reference: PEQF - JudJudicial Review Action Launchedhed

16 Jul 19 9:47 AM

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