Monthly Archives: May 2020

Where are we now with regulation?

In December 2018 I made a prediction (see my blog ‘What it is to be regulated’) that failed to come to fruition due to the Brexit debacle. Up until the Covid-19 crisis took hold things were slowly getting back on track at the end of 2019 after being severely delayed by the impact Brexit had on the RCVS, now the whole process is back ‘on ice’ while higher socio-economic problems take priority. Very few trainers and behaviourists have any work at all at the moment and I doubt that all will survive the shutdown unscathed, whatever emerges in the future will also take a while to re-establish as a thriving industry. There will however, still be people with pets and still a need for training and behaviour work and some would suggest the need for trainers and behaviourists will be greater. It is predicted that we will experience more cases of anxiety issues once owners start getting back to work and there will be many puppies that have not been able to experience the breadth of socialisation they would have done in different circumstances. Couple an increased need with the forecasted levels of unemployment and subsequent lack of ability to pay for such services, self-employed trainers and behaviourists competing for the business under the spectre of potential reappearance of the virus and it doesn’t take much imagination to picture an industry in turmoil for a while. Regulated services will be more important than ever.

As we are all stuck at home with our internet devices for company some of the ABTC scheduled meetings and decision making are continuing and constructive work continues. Social media has helped keep people’s social interactions going and provides a positive outlet in many instances but inevitably its less constructive characteristic is there too. Rumours and fake news spread quickly at all levels. Some of the old myths about ABTC are doing the rounds again and no doubt being accepted as gospel by many, here are two examples:

Myth 1: You cannot be an ABTC behaviourist without a degree. Absolutely not so. In many cases a degree will only cover some of the academic requirements and further study may be required anyway but the important phrase is ‘degree level of study’. There is a growing number of privately delivered programmes at the correct level but be aware that they do not all qualify in terms of covering all the topics required or being of sufficient length (100 credits at level 5 and 120 credits at level 6). For the less academically inclined there is even a process of APEL (accreditation for prior experiential learning).

Myth 2: You have to go through ASAB assessment for CCAB to become an ABTC behaviourist. This has never been the case, for sure it is an option that some choose and one organisation uses it for their membership process. But any organisation can create a process of assessment that demonstrates that all their full members have their skills properly assessed and have the required knowledge and understanding to be equipped to competently carry out the work.

So what is happening about regulation right now? A number of schemes have been attempted to provide alternatives to ABTC over the last ten years and another is about to launch shortly but most largely avoid the qualification issue choosing to place their emphasis on ethical methods instead. This is fine as far as it goes and is no different to ABTC in that respect but they miss the point of regulation. The latest scheme is no different and is claiming that ‘for the first time the dog training industry will have a clear, unified voice’ and ‘Most importantly everything will be supported by an independent oversight structure – the first time this has been put in place within the industry’, this is, of course, far from the case. I lose count but it must be the fifth or sixth such scheme and as with all the others it does not do everything that ABTC has been doing for the past ten years.

There are five crucial elements to any regulatory framework and any organisation that does not meet them all falls short of the mark, they are:

  1. Governance must be independently accountable and transparent
  2. Defined technical competence based on a standard body of knowledge (academic requirements).
  3. Defined technical competence based on a standard of performance criteria (assessment of skills)
  4. Complaints and disciplinary procedure must be in place.
  5. Standards of ethical personal and business practice including customer service, financial probity and advertising must be adhered to.

ABTC is the only organisation that meets all these requirements and remains poised to go through the RCVS accreditation process when circumstances permit. This will be the single most important step so far in the industry’s development, it is not just important, it is essential because it is an absolute requirement of formal Defra recognition that any such regulatory body is independently accredited. Nothing short of this will be accepted. Any scheme that does not meet these requirements, no matter how well intentioned, is simply misleading people and creating more confusion in an industry that is crying out for clarity.

The course accreditation minefield (continued)

Compass was one of the first course providers in the Animal Care Industry to go down the route of having its courses accredited by a regulated awarding body over 20 years ago. Since then much has changed in the academic world of accreditation. The questions we have been asked over the years have also changed as students have become more aware that an advertised course may not be exactly all it is presented as.

The process of achieving accreditation has become steadily more involved over the years with more and more hoops to jump through and corresponding additional cost. Costs have to be passed on to the students and a growing number of course providers have decided that the benefits do not justify the cost and effort involved and have abandoned formal accreditation, some have turned to unregulated accreditation bodies which confuses potential students even more (see my last blog) but others have simply given up altogether in favour of keeping costs and burdensome administration down.

Those course providers who remain with an Ofqual regulated Awarding Body have two choices for accreditation, they can adopt Customised Qualification status for their courses or Regulated Qualification status. Already I can hear the majority of readers losing the will to carry on with this blog but if you are interested in the subject the difference is important.

Both types of qualification go through essentially the exact same process of checks to ensure they meet the high level of quality required by Ofqual in terms of content and delivery. They must reach the level of study claimed which indicates the difficulty and depth of the course and they are allocated a Total Qualification Time (TQT) figure to indicate the length of the course. TQT is often quoted in ‘credits’ with one credit equalling 10 hours so, to give you a benchmark, the TQT of a GCSE is usually around 120 hours or 12 credits while each year of a three year degree is typically 1200 hours or 120 credits.

So far there is absolutely nothing to distinguish between Customised and Regulated qualifications but there is one crucial difference. When an organisation submits a qualification for Regulated status through their awarding body it relinquishes its intellectual property rights, in other words it no longer owns the course. Customised qualifications remain the property of the course provider who produced it. In giving up ownership the now regulated course is given an identifying number and appears on a register of regulated courses published by Ofqual, customised qualifications do not have such a number and do not appear on the register. The process of appearing on this register does not alter the value or purpose of the course in any way.

A question I am constantly asked is ‘is your course a recognised qualification?’ and my answer is to ask ‘recognised by whom?’. For qualifications to reach their potential they must attract industry recognition to be of any real value other than just for personal interest. It is possible to have a regulated qualification (registered by Ofqual) that is not recognised by industry. In this case Ofqual is saying that the course meets educational requirements but industry says it falls short of their requirements. Equally, a customised qualification that does not appear on the Ofqual register may be recognised by industry as fulfilling all the requirements of industry. The reasons that industry might reject a regulated qualification range from incorrect content (not covering required topics) to inadequate level or too low a TQT value (the course is too short). Courses that are produced by industry tend to meet their requirements exactly because they are written to satisfy their own requirements whether they are regulated or customised qualifications.

For further reading see: https://ofqual.blog.gov.uk/2016/06/14/when-size-does-matter/