Written submission from the British Dietetic Association (PBM0027)

About the BDA and Dietitians

The BDA is the only body in the UK representing the whole of the dietetic workforce. We are a trade union and professional body representing the professional, educational, public and workplace interests of our members. Founded in 1936, we are one of the oldest and most experienced dietetic organisations in the world.

Registered dietitians are qualified health professionals that assess, diagnose and treat diet and nutrition problems at an individual and wider public health level. Uniquely, dietitians use the most up-to-date public health and scientific research on food, health and disease, which they translate into practical guidance to enable people to make appropriate lifestyle and food choices. Dietitians are statutorily regulated, with a protected title and governed by an ethical code, to ensure that they always work to the highest standard.

This submission seeks only to discuss the post-Brexit immigration system as it relates to dietitians and healthcare staff wishing to come to the UK. We have deliberately not drawn any conclusions on any other aspect of immigration policy, as this is outside our area of expertise.

What should the Government’s objectives be in drawing up a post Brexit immigration system?

The BDA believes that the objective of any post-Brexit immigration system must be to allow the UK to access the skilled workers that it needs to support our health and care services, including dietitians. It is vital that any health or care staff born outside the UK feel welcome, given their enormous contribution to UK society, our healthcare system and our economy.

Currently, some 10% of the UK dietetic workforce are of non-EU nationality, with around 10% more having a non-UK EU nationality[i]. All these dietitians play an important role in our health and care services, be they in public health, the NHS, academia, the care system, food industry or private practice. Any post-Brexit immigration system must be simple, fair and proportionate, to ensure we can continue to encourage people to come to the UK.

Current salary caps for Tier 2 visas fail to take account of the generally fairly low salaries of health and care roles. The current cap of £30,000 would preclude most band 5 or 6 dietetic posts outside of London, despite those making up the majority of dietetic posts. In other areas, such as care staff, an even larger proportion of staff are likely to be under this threshold. We would therefore hope that the blunt instrument of salary caps could be dropped to ensure health and care services can hire the staff they need, regardless of the salary they are to be paid.

What are the implications of the net migration target?

The net migration target is arbitrary and based on political, rather than economic or workforce priorities. At the moment, the desire to meet this unnecessary target serves to restrict the number of skilled healthcare staff from outside of the EU that can work in the UK, to the detriment of our health and care services. If the UK requires more skilled staff to address a need, a net migration target should not be a barrier (from the EU or from outside it).

Should a post-Brexit immigration policy seek to reflect regional variations?

It will be important to consider regional variations as some regions have greater need than others for certain professions. Within dietetics for example, the North East of England has historically had greater vacancy rates than other areas of the UK, and some trusts have specifically recruited from abroad in order to fill vacancies.

That said, an effective system would not block any appropriately skilled person from coming to the UK to fill a role where they have a job waiting for them, regardless of where in the UK it is based.

What would be the advantages and disadvantages of having the same immigration arrangements for EEA and non-EEA citizens? Would it be practical to apply existing non-EEA rules to EEA citizens after Brexit?

We believe that immigration arrangements with regard to healthcare should be the same for both EEA and non-EAA citizens. As long as a dietitian from outside of the UK is appropriately qualified and well suited to the role they are coming to fill, where they originate from should not be a factor. As mentioned previously, a significant proportion of dietitians working in the UK hail from outside of the EEA, in particular from Canada, Australia and South Africa, reflective of the fact that dietetic training in those countries is of a high standard.

July 2018