CASEWORK NOTE: COMPLAINTS RELATING TO PLACEMENTS

Many courses involve one or more placement opportunities for students. For some this will be compulsory and there will be formal learning opportunities and expected outcomes. For others the opportunity is voluntary and doesn’t formally contribute to the student’s academic outcome. Sometimes the placement opportunity will be in a different country. In our casework we see complaints from students about placements in all these different contexts.

We tend to see more complaints from students undertaking placements as a compulsory requirement of a course leading to a professional qualification, for example teaching or nursing. Most professional, statutory and regulatory bodies (PSRBs) make fitness to practise a requirement for registration, and fitness to practise and placement issues are often interconnected in the complaints we see from students on these courses. The Fitness to practise section of the Good Practice Framework includes further guidance for providers on designing and operating fitness to practise procedures.   

Whatever the context of the placement, it’s important that students are given clear and accurate information about it. Students need to know what’s expected of them and where and how to access support while they’re on placement. It’s also important that providers have processes in place to respond when things go wrong.

In this casework note we draw out some good practice learning points informed by the general issues we see around placements across our casework and outreach work. We have published some case summaries that illustrate some of the issues we see. Many of the principles for successful placements are similar to other forms of working in partnership and providers may also find it helpful to look at the Delivering learning opportunities with others section of the Good Practice Framework.


Setting up provider-organised placements

The early stages of setting up a placement are an opportunity for providers to think through and agree clear arrangements with the placement organisation. This can reduce the likelihood of issues further down the line and set the framework for responding to any issues that do arise. It’s helpful to set out expectations about things like regular communication, information sharing, student support, record keeping and timescales for responding. If the placement is part of a course delivered under a partnership agreement between two or more providers, the agreement should be clear on which provider is responsible for managing placement arrangements.


Providing clear information

It’s important that providers make clear, accurate information about placements available to both prospective and current students, in line with Competition and Markets Authority (CMA) guidance and the requirements of consumer protection legislation. Key information about placements is likely to be material information that applicants rely on when making decisions about what and where to study.

Information to provide may include:

  • Whether the placement is optional or compulsory
  • Whether the student or the provider is responsible for arranging the placement, and where the student is responsible, what they may need to do
  • Whether the availability of placements is limited and/or subject to any application or eligibility criteria
  • What happens if a placement can’t be arranged for any reason
  • What, if any, tuition fees the student will pay during the placement, and whether there are any other costs associated with the placement (for example, for uniform, travel, equipment etc)
  • Whether the student will be paid during the placement
  • The intended learning outcomes of the placement
  • Whether, and how, the placement contributes to the student’s award, including information about any assessments
  • Whether there is a specific attendance requirement for successful completion of the placement, and what students should do in the event of illness or other circumstances affecting this
  • If the placement is within a partnership arrangement, which provider is responsible for managing the placement.

Before the placement starts

Location of the placement

Providers will sometimes need to work with placement organisations outside of the local area. It’s important to manage students’ expectations about the possible location of their placement, for example by explaining what the provider considers to be a reasonable time and/or distance to travel. For some students there will be considerations to take into account when deciding where to place them, for example accessibility needs, caring responsibilities or transport considerations that might make commuting to a placement more difficult. Providers can usefully signpost students to any sources of financial support, either at the provider or elsewhere, that may be available to help with any costs associated with the placement. Where it’s not possible to offer a placement within the expected area, the provider may want to consider whether it would be reasonable to support the student with any additional expenses they may incur as a result of being offered an out of area placement. It’s also important to tell students in good time what placement they have been allocated so that they have time to make any arrangements they may need to.

Support arrangements

It’s important that students know in advance where they can go for advice and support whilst on placement. It is good practice for providers to ensure that students have a named staff member at the provider that they can liaise with, as well as a named mentor at the placement organisation.

Some students may need additional support during the placement, for example because they are disabled or have caring responsibilities. The provider should explore in advance how those support needs might be met, and whether the provider or the placement organisation will be responsible for meeting them. Considerations are likely to include what information it is essential to share with the placement organisation to ensure that the student is properly supported and to provide a safe environment for the student, professional colleagues and where appropriate, users of the placement service. It can be helpful to set out any information which a student may choose to share in addition to this. The Good Practice Framework gives guidance on Supporting disabled students.

Overseas placements

Where the placement is in another country, the provider may want to think about what else may be helpful for students. This could include information and support to arrange accommodation, information about local customs and culture, and clear information about where to go for emergency help. International students may need access to customised advice about visa requirements. Disabled students may require additional support during placements in countries where the legal obligations of service providers may be different. It may also be relevant to provide advice to other groups of students where the law is significantly different to the UK, for example to LGBTQ+ students. It is good practice for providers to identify members of staff that the student can contact if difficulties arise during their placement overseas.

Expectations of students

It’s important that providers give clear guidance to students about what is expected of them while on the placement, especially if they need to demonstrate particular behaviours, standards or competencies in order to pass it. This includes practical expectations such as reporting absence.

If a student can’t complete a placement

Most students successfully complete their placements, but it’s important to explain what will happen if the student doesn’t complete a placement that is a necessary part of their course. For example, can the placement be extended? Will the student have an opportunity to complete another placement elsewhere? What would happen if it’s not possible to arrange another placement? What would the financial implications be for the student?


When things go wrong

Students need to know how they can raise any concerns or complaints about their placement, and who they can speak to if they need further information or support with the process. Some students on placements that are part of a professional qualification, for example in schools or the NHS, may be members of a professional organisation or union that may also be able to support or advise them.  

In some cases, the placement organisation will have its own internal process that the student can follow. Even when a placement organisation has its own procedures in place, providers retain ultimate responsibility for decisions that relate to an individual’s status as a student, and to decisions about its academic awards. It’s normally proportionate for the placement organisation to resolve concerns about day-to-day issues or services it is directly responsible for providing. But students shouldn’t be expected to use the placement organisation’s procedures to raise concerns about something the placement organisation has done or not done that has affected their studies. Students should be able to raise these complaints directly with the provider, and where necessary the provider should liaise with the placement organisation to explore the issues.

Sometimes issues related to a placement will need to be considered under separate, but interconnected, procedures. For example, a student may complain that they were bullied while on placement when appealing against a decision that they haven’t passed the placement. It’s important that providers carefully consider which process is best placed to consider the issues raised and make a case-by-case assessment of the best way to handle complex or interconnected cases. Everyone involved needs to understand which process is being used to consider which issues and why. More information on deciding which process to use and managing more than one process can be found in the Handling complaints and academic appeals section of the Good Practice Framework.     

It is good practice to coordinate the use of these procedures in a proportionate way and to avoid duplication wherever possible to reduce the burden on students of pursuing or responding to two different sets of processes. Where possible, it is helpful to consider a single route for gathering information, and to have information-sharing protocols in place, even where the decision-making focus is different. The provider itself will not normally have a remit to investigate complaints about employees of the placement organisation, but it will need to consider whether any of the issues raised had an impact on the student’s studies or ability to meet expected learning outcomes. 

In some complaints we have seen, the students were reluctant to raise concerns about things that happened during the placement while it was ongoing. We also hear in our outreach work that students are sometimes put off making a complaint because they are worried that they may be subject to fitness to practise or disciplinary proceedings if the complaint isn’t upheld, or that they’ll be treated differently because they raised concerns. It’s important to assure students that they will not be penalised for raising a complaint about something they are genuinely concerned about, even if those concerns turn out to be misplaced. 

There may be different processes a provider could use to respond to concerns about a student’s own conduct on placement or to support them if they are at risk of not meeting expected standards. For example, cause for concern, fitness for study, disciplinary, or fitness to practise procedures could be relevant. The most appropriate procedure to use will depend on the nature and severity of the concerns. Issues with procedural fairness are a common feature of the complaints related to placement that we uphold. Providers will often need to respond promptly to any concerns raised by the placement organisation, especially if they are serious and immediate action needs to be taken. But in doing so it’s important that the provider is still mindful of the need to follow a fair process and the principles of good practice. The provider should clearly explain to the student which procedure is being used, and why, and be clear about the roles of each party in the process.  

Terminating or suspending a placement

A placement may be terminated or suspended for reasons directly related to the student, for example, due to concerns about professional conduct, reasons connected to the student’s health or ability to engage with the course, or the student not achieving required elements in other parts of their course. Providers will usually have specific processes in place to decide whether and how a student should be given a further placement opportunity. 

But placements may break down for other reasons, for example, the unanticipated long-term absence of the employee who was qualified to act as a placement supervisor. If a placement breaks down for reasons outside the student’s control, the provider should work with the student to find an alternative arrangement that allows them to successfully complete the course.

Providers may be constrained by the availability of placements, and it may be difficult to arrange alternative placements at short notice or in the middle of a term. If the student needs to complete the placement to meet any course or PSRB requirements, it may be possible for them to continue with the academic components of their course while the provider makes alternative arrangements for their placement or considers the circumstances that led to the placement being suspended. It’s important to make sure that students are fully aware of any potential funding implications, for example where this may extend the overall duration of their programme or where any bursary payments depend on the student attending the placement. If the placement has broken down for reasons outside of the student’s control, the provider will need to think carefully about what steps it would be reasonable to take to mitigate the impact on the student. 


If the student is employed by the placement organisation

Some placements can only operate when a student is also employed by the placement organisation. It is good practice for providers to consider what options, if any, would be available for students to continue their studies if their employment is terminated, and to explain this to students. In some circumstances it may be appropriate for the provider to facilitate a transfer to an alternative route for study. It’s also important to direct students towards sources of personal support and advice.

Where the student is employed by the placement organisation they will also have rights as an employee. This will be the same in an apprenticeship arrangement and therefore some of these principles will apply in those relationships. This situation may have an impact on how some matters are addressed which directly affect the employer-employee relationship, for example, concerns about the student’s conduct whilst on placement, or a complaint about another member of placement staff. Placements may be affected by other factors in the wider employment relationship that are not specific to a particular placement opportunity, for example, disputes over terms and conditions. Where an issue arises that is solely an employment matter, the provider will not usually be responsible for investigating or reaching decisions. But it may need to provide information to the investigator at the placement organisation, for example details of what learning outcomes the placement was intended to cover or a statement about the student’s previous experience.