The Work of the WAA Policy Board

Employment Rights Bill: Trade Union Access Consultation Update

For the second round of the trade union access consultation, Care England submitted a formal response where the Board’s engagement, and the direct advocacy of its members, has had demonstrable impact on the shape of the emerging code. Drawing on the operational expertise and first-hand experience of Board members, Care England’s response helped secure explicit recognition that residential care homes are fundamentally different from standard workplaces, with the draft code now stating that access should take place in staff offices or meeting rooms, that private dwellings are exempt, that arrangements must respect residents’ privacy, and that off-site meetings may be required where suitable on-site space cannot be accommodated, paid for by the unions.

Our Letter to the Casey Commission: Valuing Care and the Case for Reform

In May 2026, Professor Martin Green OBE wrote directly to Baroness Casey setting out detailed evidence on commissioning practices that the Board believes the Commission must examine closely. The letter was prompted by Baroness Casey’s speech at the Nuffield Trust Summit, in which she questioned the practice of Integrated Care Boards commissioning private companies to identify savings within Continuing Healthcare expenditure, with those same companies then receiving a proportion of the savings achieved. Care England’s letter focused in particular on the role of Valuing Care, commissioned by a number of local authorities and ICBs to undertake fee modelling exercises, in several cases on a percentage-of-savings basis, a model that providers argue cannot reliably reflect the actual cost of delivering safe, sustainable care for people with complex needs.

The letter urges the Commission to examine arrangements where third parties benefit financially from reducing care fees, to consider clearer national expectations around external cost modelling, and to look at accountability and transparency in fee-setting processes more broadly. It concludes with an invitation for Baroness Casey and her team to meet directly with Care England members operating across learning disability, autism and complex care services, providers with first-hand experience of how these arrangements are operating on the ground.

Click here to read Care England’s letter to the Casey Commission.

Our Letter to the Casey Commission: Working Age Adults and the Broader Reform Agenda

Members of the Working Age Adult Policy Board have engaged directly with the Casey Commission, including through meetings with members of Baroness Casey’s team, to ensure that the distinct pressures facing providers of working-age adult services are properly understood and reflected in the Commission’s emerging thinking. That engagement has been reinforced by a formal submission presenting the united voice of Care England members on the reforms needed to place working-age adult services on a sustainable footing.

The submission addresses poor commissioning practice, the funding gap, workforce challenges and the need for greater national consistency in how services for working-age adults are planned, commissioned and resourced, making the case that these issues must be treated as priorities within the Commission’s final recommendations, not as secondary considerations to the broader social care agenda.

Click here to read the letter to the Casey Commission from the Working Age Adult Policy Board.

Oliver McGowan Mandatory Training: Our Response

Care England’s Working Age Adult Policy Board is coordinating sector-wide engagement on the implementation of the Oliver McGowan Mandatory Training on Learning Disability and Autism. Building on detailed feedback from members, the Board has written formally to both the Care Quality Commission and the Secretary of State for Health and Social Care, setting out providers’ shared concerns and proposing practical solutions that support the intent of the training while ensuring it can be implemented effectively across a diverse provider landscape. The letters call for consistent national inspection expectations, recognition of equivalent or legacy training, proportionate timelines, and co-design of a delivery framework that can operate at scale without compromising quality.

A shared appendix, developed by the Board and accompanying both letters, sets out specific proposed clarifications to the Code of Practice, covering tier definitions, evidence of equivalence for existing training, remuneration and safeguarding for lived-experience trainers, and practical considerations for large-scale delivery. Together, these documents reflect the Board’s commitment to constructive, evidence-based engagement: supporting the principles that underpin the training while insisting that implementation is practical, ethical and sustainable.

Click here to read the letter to the CQC.
Click here to read the letter to the Government.
Click here to read the shared appendix.

The Board also produced an impact assessment to understand the real costs of implementation for providers, the findings of which informed a dedicated meeting with the DHSC to discuss the sector’s concerns directly, and agree a sustainable way forward.

You can view the impact assessment here.

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