economic and social impact of the UK’s exit · Bupa is an international business headquartered in the UK. In addition to Bupa UK employees, employees from two other market units

Migration Advisory Committee study on the

economic and social impact of the UK’s exit

from the EU

Response to Call for Evidence

Bupa

October 2017

Confidential – contains commercially sensitive information

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This submission sets out Bupa’s response to the questions raised by the Migration Advisory Committee (MAC) in their July 2017 call for evidence. We have not provided responses to all questions, only those where Bupa has particular comments or evidence to share. All data in this submission is correct as of the end of September 2017, the last full month for which we have the relevant data. Tables 1-8 in this response contain commercially sensitive data that should be treated as confidential and redacted before publication.

Table of Contents 1. Introduction and background

1.1 About Bupa

1.2 About Bupa in the UK

1.2.1 Bupa UK

1.2.2 Head office and Bupa Global

1.2 Overview of our UK based workforce

2. EEA migration trends

2.1 Breakdown of types of roles held by EEA migrants

2.1.1 Aged care services

2.1.2 Dental services

2.1.3 Health Services, including the Cromwell Hospital

2.2 Regional distribution of EEA migrants

2.3 Recent EEA migration trends

2.4 Impact on our business of a possible reduction in the availability of EEA migrants

2.4.1 Nurses

2.4.2 Aged care workforce

2.4.3 Dental workforce

2.4.4 Wider workforce

3. Recruitment Practices, Training and Skills

3.1 Methods of recruitment used to employ EEA migrants

3.2 Recruitment and training of UK workforce

3.3 Views on current UK migration policies including the Shortage Occupation List

4. Economic, Social and Fiscal Impacts

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1. Introduction and background

1.1 About Bupa Bupa is an international healthcare company. Our purpose is helping people live longer,

healthier, happier lives. With no shareholders, our customers are our absolute focus. We reinvest profits into providing more and better healthcare for the benefit of current and future customers.

We have 16.5m health insurance customers, provide healthcare for 10.6m people in our clinics and hospitals, and look after around 25,000 aged care residents.

We employ over 80,000 people, principally in Australia, the UK, Spain, Hong Kong, Chile, Brazil, Poland, New Zealand, Saudi Arabia, India and the USA.

1.2 About Bupa in the UK 1.2.1 Bupa UK

In the UK we see our role as contributing to a strong and sustainable health and social care system.

Bupa UK is the UK’s leading health insurer with 2.4 million insurance customers. We provide personal, corporate and small business health insurance, as well as ancillary health insurance products, such as cash plans, dental and travel insurance.

We operate around 60 wellness centres and health clinics across the UK, plus Bupa Cromwell Hospital, a complex care hospital in London providing care for insured, self-pay, NHS and international patients.

The purchase of Oasis Dental Care in 2017 makes Bupa a major dental provider in the UK with two million customers and around 450 clinics. Through our dental clinics we provide dental care to both NHS and private patients. In total, 69.3% of patients treated in our dental clinics are NHS patients.

Through our aged care business, we are also a major provider of residential care in the UK. We currently provide quality residential, nursing and dementia care across approximately 270 homes and six Richmond Villages. In August 2017 we announced that we have agreed to transfer 122 of our care homes to HC-One, a leading provider of health and social care. In October we announced the transfer of a further 22 homes to Advinia Health Care. We expect both these transfers to take at least three months to complete, subject to regulatory approvals. The data included in this submission includes the 144 homes that are being transferred.

1.2.2 Head office and Bupa Global

As an international business headquartered in the UK, our UK workforce also includes a number of people working for our Centre (head office) functions and for our international private medical insurance business, which trades as Bupa Global.

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1.2 Overview of our UK-based workforce

Bupa is an international business headquartered in the UK. In addition to Bupa UK employees, employees from two other ‘market units’ are based in the UK: from our international private medical insurance business, Bupa Global, and from our Centre (head office) functions. Table 1 provides a breakdown of our UK-based employees by market unit:

Table 1 – All UK-based Bupa employees

Figures in brackets are to nearest %

Market Unit EEA Non-EEA Not recorded UK Total

Bupa UK 2933 (9%) 2677 (8%) 350 (1%) 27328 (82%) 33288 (100%)

Bupa Global 86 (11%) 36 (5%) 2 (0%) 641 (84%) 765 (100%)

Centre functions 47 (8%) 39 (7%) 21 (4%) 459 (81%) 566 (100%)

Total 3066 (9%) 2752 (8%) 373 (1%) 28428 (82%) 34619 (100%)

As you can see from Table 1, a significant proportion of our UK-based employees are non-UK citizens. In total just under 9% of our UK workforce are EEA nationals and this proportion rises to nearly 17% when non-EEA nationals are included.

It should be noted that the total figure of 3066 EEA nationals does not include approximately 500 bank staff and contractors who also work for our UK businesses.

The vast majority of our UK-based workforce works within Bupa UK. Bupa UK is organised into six ‘business units’. Table 2 provides a breakdown of our Bupa UK employees by business unit and migration status:

Table 2 – Bupa UK employees


Business Unit EEA Non-EEA Not recorded UK Total

Aged care 2111 (9%) 2369 (10%) 103 (0%) 18752 (80%) 23335 (100%)

Dental 485 (10%) 130 (3%) 64 (1%) 4299 (86%) 4987 (100%)

Health Services (inc. Cromwell Hospital)

209 (16%) 110 (8%) 24 (2%) 957 (74%) 1300 (100%)

Insurance 72 (3%) 26 (1%) 77 (3%) 2132 (92%) 2307 (100%)

UK Strategic & Support Functions

56 (4%) 42 (3%) 82 (6%) 1188 (87%) 1368 (100%)

Total 3066 (9%) 2752 (8%) 373 (1%) 28428 (82%) 34619 (100%)

As Table 2 shows, we have significant numbers of EEA and non-EEA migrants working across our UK business but they play a particularly important role in our aged care business, our dental

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business and our Health Services business, in the latter case particularly in the Cromwell Hospital.

We therefore have a strong interest in ensuring that any changes to the UK’s immigration system as we leave the EU protect the ability of social care and healthcare providers to retain the people that we need to continue to care for our residents and patients. It is also important that any changes enable providers the staff they need in future to continue delivering high quality care.

While the government will rightly be looking at the skills needs of the NHS post-Brexit, it is crucial that the skills needs of private providers of health and social care are not forgotten. Private providers make an important contribution to the UK healthcare system and in delivering critical public services. For example, around 72% of the residents in our care homes are publicly funded while over 69% of patients in our dental clinics are NHS patients.

2. EEA migration trends

2.1 Breakdown of types of roles held by EEA migrants 2.1.1 Aged care services

As Table 2 shows, we have EEA and non-EEA nationals working across our UK business, with the majority working in our aged care business and a significant number also working in our dental business and our Health Services business (including the Cromwell Hospital).

Table 3 provides a breakdown of our EEA and non-EEA employees in our aged care business by role type:

Table 3 – Aged care – EEA and non-EEA migrants by role type


Role type EEA Non-EEA Total (EEA/non-EEA)

Total (incl. UK nationals)

Care (non-nursing) 1195 (9%) 1672 (12%) 2867 (21%) 13530 (100%)

Nursing 389 (16%) 363 (15%) 752 (31%) 2444 (100%)

Clinical Management

38 (7%) 52 (10%) 90 (17%) 520 (100%)

Support 481 (8%) 269 (4%) 750 (12%) 6323 (100%)

Other roles 8 (2%) 13(3%) 21 (4%) 518 (100%)

Total 2465 (11%) 2863 (12%) 5328 (23%) 23335 (100%)

EEA and non-EEA migrants perform important functions across our business but they make a particularly significant contribution to our aged care business. In total, EEA and non-EEA migrants account for over 22% of our total aged care workforce (compared with just under 17% for our UK business as a whole).

This size of our EEA and non-EEA workforce is broadly in line with the sector as a whole. Skills for Care’s figures1 show that overall 7% of those working in the social care workforce in England had an EEA nationality and 9% had a non-EEA nationality. In our aged care business 9% of the workforce has an EEA nationality and 12% has a non-EEA nationality.

1 The state of the adult social care sector and workforce in England 2017, Skills for Care, September 2017

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2.1.2 Dental services

Table 4 provides a breakdown of EEA and non-EEA employees in our dental business by role type. Having recently significantly expanded our dental business through the acquisition of Oasis Dental Care, we are still in the process of developing a full picture of our dental workforce and do not yet have details of what specific roles all our EEA and non-EEA staff hold. Where we do not have a central record of the role held we have included as ‘Unspecified’ in Table 4:

Table 4 – Dental – EEA and non-EEA migrants by role type




Dental Nurse 280 (11%) 77 (3%) 357 (14%) 2507 (100%)

Dental Practice Manager

39 (10%) 5 (1%) 44 (11%) 400 (100%)

Clinical Management

14 (9%) 8 (5%) 22 (14%) 159 (100%)

Customer Services 0 (0%) 1 (2%) 1 (2%) 47 (100%)

Executive Management

0 (0%) 0 (0%) 0 (0%) 1 (100%)

Support Services 0 (0%) 0 (0%) 0 (0%) 11 (100%)

Unspecified 152 (8%) 39 (2%) 191 (10%) 1853 (100%)

Total 485 (10%) 130 (3%) 615 (12%) 4978 (100%)

Table 4 and the figures for our dental workforce included in Table 2 do not include dentists who work in our dental clinics as they are self-employed and therefore not captured in our payroll data. However, we do record data on the dentists who work in our clinics which is provided in Table 5.

Table 5 – Dental – EEA and non-EEA dentists




Dentists 421 (21%) 137 (7%) 558 (28%) 2015 (100%)

As Table 5 shows, in common with the wider dental sector, we have a significant number of EEA and non-EEA dentists working in our clinics. While EEA dentists account for around 17% of dentists working in the UK2 they account for 21% of the dentists in our clinics. With non-EEA dentists, they make up 28% of the total dentist population in our clinics.

We have a particularly heavy reliance on dentists from the following EEA countries: Spain, Romania, Greece, Poland, Portugal, Ireland and Bulgaria. The majority of our non-EEA dentists come from India and South Africa.

We would echo the messages and data submitted to the MAC by the Association of Dental Groups (ADG).3 As the ADG highlights in their submission, EEA dentists provide around 22% of

2 Submission from the Association of Dental Groups to the Migration Advisory Committee, Association of Dental

Groups, October 2017 3 Submission from the Association of Dental Groups to the Migration Advisory Committee, Association of Dental

Groups, October 2017

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NHS dentistry according to NHS England figures, rising to 30% of NHS dentistry in deprived parts of England and Wales such as coastal towns and rural areas.

As Table 4 shows, EEA migrants make a significant contribution to the sector in other roles such as dental nursing and practice management. Within our dental business, over 11% of our dental nurses are from the EEA as are nearly 10% of our dental practice managers and just under 9% of our clinical management staff.

2.1.3 Health Services, including the Cromwell Hospital

Table 6 provides a breakdown of our EEA and non-EEA employees in our Health Services business:

Table 6 – Health Services – EEA and non-EEA migrants by role type




Cromwell Hospital 157 (25%) 94 (15%) 251 (40%) 630 (100%)

Clinical Management

36 (9%) 12 (3%) 48 (12%) 399 (100%)

Customer Services 4 (3%) 0 (0%) 4 (3%) 133 (100%)

Support Services 12 (11%) 4 (4%) 16 (14%) 111 (100%)

Other roles 0 (0%) 0 (0%) 0 (0%) 27 (100%)

Total 209 (16%) 110 (8%) 319 (25%) 1300 (100%)

As Table 6 shows, while our Health Services workforce is relatively small in comparison to our aged care and dental businesses, EEA and non-EEA migrants play a significant role. Across our Health Services business EEA nationals account for 16% of our workforce and combined with non-EEA nationals a quarter of our workforce is from outside the UK.

EEA and non-EEA migrants play a particularly important role in the workforce at the Cromwell Hospital, a complex care hospital in London providing care for insured, self-pay, NHS and international patients, where 25% of our staff are EEA nationals and a further 15% are non-EEA nationals.

Table 7 below provides a breakdown of the roles held by EEA and non-EEA migrants at the Cromwell Hospital. As the table demonstrates, EEA migrants make up a significant proportion of staff at the Cromwell Hospital in a number of roles. For example, EEA migrants account for 31% of nurses, 23% of radiographers and a third of physiologists at the hospital.

Table 7 – Cromwell Hospital – EEA and non-EEA migrants by role type




Nurse 58 (31%) 32 (17%) 90 (48%) 188 (100%)

Healthcare assistant 6 (15%) 13 (33%) 19 (49%) 39 (100%)

Radiographer 6 (23%) 3 (12%) 9 (35%) 26 (100%)

Practitioner 4 (21%) 5 (26%) 9 (47%) 19 (100%)

Physiologist 3 (33%) 1 (11%) 4 (44%) 9 (100%)

Specialist 1 (33%) 0 (0%) 1 (33%) 3 (100%)

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Therapist 1 (20%) 2 (40%) 3 (60%) 5 (100%)

Principal Physicist 1 (33%) 1 (33%) 2 (66%) 3 (100%)

Physiotherapist 1 (5%) 5 (25%) 6 (30%) 20 (100%)

Pharmacist 0 (0%) 1 (33%) 1 (33%) 3 (100%)

Other roles 76 (23%) 31 (10%) 107 (33%) 315 (100%)

Total 157 (25%) 94 (15%) 251 (40%) 630 (100%)

All data in this submission is based on our payroll data and as such our Cromwell Hospital data does not include self-employed consultants who also work at the hospital. However the data in Table 7 nonetheless gives a good indication of how important EEA and non-EEA staff are in delivering care at the hospital.

2.2 Regional distribution of EEA migrants

We have a workforce spread across the UK. While we are currently unable to provide an accurate regional breakdown of our whole UK workforce we can provide a breakdown by region for those staff working in care homes (accounting for over 95% of our aged care workforce and over 64% of our total UK workforce).

Our care homes are organised into five regions. A breakdown of the EEA and non-EEA staff working in our care homes by operational region is provided in Table 8.

Table 8 – Regional breakdown of aged care EEA/non-EEA workforce


Region EEA Non-EEA Total (EEA/non-EEA)

London & East 448 (13%) 658 (19%) 1106 (32%)

Midlands 491 (11%) 500 (11%) 991 (22%)

North & Wales 254 (5%) 290 (6%) 544 (11%)

Scotland & North 167 (4%) 199 (5%) 366 (9%)

South 713 (14%) 701 (14%) 1414 (28%)

Total 2073 (9%) 2348 (11%) 4421 (20%)

As Table 8 shows, the reliance of our care homes on EEA and non-EEA staff varies significantly by region. The number of EEA and non-EEA staff is lowest in our Scotland & North operational region (9%) and highest in London & East region where non-UK staff make up almost a third of our care home workforce (32%).

The ability of social care providers to recruit UK nationals into care roles varies significantly by region. If the UK’s exit from the EU restricts the ability of social care providers to recruit the people they need, some regions will be particularly hard hit. For example, Independent Age has published research suggesting that up 3 in 5 of the care workforce in London was born abroad.4

2.3 Recent EEA migration trends

While we have recently begun tracking trends in our employment of EEA and non-EEA migrants, historically we have not done so. We can therefore only comment on our recent experience.

Of particular concern is the potential impact of Brexit on our care homes and the social care sector in general. We track our leavers, joiners and new applications and when we compare our

4 Moved to care: the impact of migration on the adult social care workforce, Independent Age, November 2015

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2016 data with 2017 data we are starting to see a significant drop in applications in some areas, particularly London and the South East.

We do not track applications by nationality so are unable to say whether the drop is primarily led by fewer applications from EEA nationals or whether the drop is directly related to Brexit as some of the effects could be seasonal or a result of the general cost of living in London and the South East. However, the scale and timing of the drop in applications suggests at least some Brexit related impact: for example, we had approximately 2100 applications for roles in our aged care business in September 2016 compared to approximately 1200 applications in September 2017.

Anecdotally, Home Managers within our aged care business are also beginning to report concern amongst their EEA nurses and other staff about the implications of the referendum vote for them and several have told their managers they are considering repatriating to their home country. If these concerns grow and staff begin to leave the UK it will make the already concerning vacancy rate, particularly amongst nurses, even worse. Currently, Skills for Care’s figures show the sector has a vacancy rate of 6.6%, equivalent to 90,000 vacancies at any one time.5

Similarly, while it is too soon to identify a clear trend, we did experience some difficulties in recruiting EEA dentists in the immediate aftermath of the referendum and anecdotally the Brexit process does appear to be creating uncertainty that is leading to fewer candidates from overseas for dentist positions.

Since the referendum we have experienced an approximately 50% decline in overseas interviews. We have also seen a significant fall in the volumes of new overseas dentists who have attended our induction programme (a compulsory programme for dentists who have qualified overseas and not worked for the NHS): from 67 attendees in 2015 to just 26 in 2017.

2.4 Impact on our business of a possible reduction in the availability of EEA migrants

As the data provided in this submission demonstrates, EEA nationals perform critical functions at a range of different skill levels across our business and in delivering care for our customers and residents.

While a reduction in the availability of EEA migrants would have an impact in a number of areas, the problems caused would be most acute in our aged care, dental and Health Services businesses.

2.4.1 Nurses

The UK has a well documented shortage of nurses in both the NHS and the social care system, as recognised by the inclusion of nursing on the shortage occupation list. Given the shortfall in the number of UK nurses, providers have increasingly had to look overseas to recruit the skilled staff we need. This includes recruitment from both EEA and non-EEA countries.


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Figures published by the Nursing and Midwifery Council in July 20176 show that more people are now leaving the professional register than joining, suggesting the existing shortage is likely to get worse.

A reduction in the availability of EEA migrants following the UK’s departure from the EU therefore has the potential to greatly exacerbate the existing nursing shortage with a direct impact on the quality and amount of care that can be provided through both the health and social care systems.

While both the health and social care systems have already begun to take steps to mitigate the shortage of nurses, mainly through up-skilling of other roles, there are many tasks in, for example, a care or nursing home setting which can only be undertaken by a registered nurse.

A substantial decrease in the availability of EEA nurses post-Brexit would therefore have a direct impact on the ability of the aged care sector to deliver care to the UK’s ageing population.

While EEA migrants account for just under 9% of our total UK workforce, they account for nearly 16% of our aged care nursing workforce. Similarly, while non-EEA migrants account for approximately 8% of our total UK workforce they make up nearly 15% of our aged care nursing workforce.

While the overall numbers are smaller, EEA and non-EEA workers make up an even higher proportion of our nursing workforce at the Cromwell Hospital – 31% and 17% respectively.

The decision to include nursing on the shortage occupation list to date is welcome but we are concerned, as the UK leaves the EU, about the ability of the social care sector to recruit and retain the skilled workers it needs for the future. The government must ensure that in any future decisions they make about recruitment of nurses from overseas, the needs of private providers of public services, in social care, dental care or health care, are properly accounted for alongside the needs of the NHS.

2.4.2 Aged care workforce

We also, in common with the wider social care sector, employ significant numbers of both EEA and non-EEA migrants in non-nursing roles within our care homes, whether as care assistants, in clinical management roles, or in support roles such as catering and maintenance. EEA migrants make up 9% of non-nursing care roles and nearly 8% of support roles in our homes.

In the social care sector therefore, a reduction in the availability of EEA migrants is also likely to impact other important caring roles. Skills for Care’s figures show that the vacancy rate in the sector is already 6.6%, amounting to approximately 90,000 vacancies at any one time, even before any reduction in the availability of EEA migrants.7 Again, any reduction is therefore likely to have a direct impact on the ability to deliver aged care.

While these roles are sometimes described as being ‘low skilled’ they require significant ‘soft skills’ with factors such as empathy and attitudes to older people being crucially important when hiring staff. In some areas we struggle to find sufficient numbers of staff in the UK who have these ‘soft skills’.

6 The NMC Register 2012/13 – 2016/17, Nursing and Midwifery Council, July 2017


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Unlike nurses, workers in non-nursing roles are not included on the shortage occupation list as, despite the crucial role they play in delivering care, they are not eligible for Tier 2 visas under current rules. This means social care providers face even higher barriers to recruiting the people they need to deliver essential care. As the government considers changes to the UK’s immigration system following the vote to leave the EU, they need to ensure that the social care sector can continue to access workers for these other care roles, as well as nurses, to ensure it can continue to provide high quality aged care services.

It should also be noted that many of the non-nursing roles held by EEA migrants within the aged care sector, while sometime referred to as ‘low skilled’, require significant amounts of training in order to ensure staff can deliver high quality care. These roles play a crucial part in the care ecosystem. An inability to recruit a sufficient number of appropriately skilled people who are also the right cultural fit for aged care, due to reductions in the number of EEA migrants, will have a direct impact on the ability of the sector to deliver quality care. This is particularly true at a time of high employment in the UK, restricting the ability of providers to fill roles from within the UK workforce.

A reduction in EEA migration is therefore likely to have an adverse effect on the capacity of the sector to deliver high quality care. The impact is likely to be particularly severe in certain regions, particularly if any reduction in EEA migrants is also accompanied by further restrictions on non-EEA migrants. In London, for example, Skills for Care figures show that 62% of the adult social care workforce is from outside the UK.

2.4.3 Dental workforce

We support the arguments put forward by the Association of Dental Groups (ADG) about the impact of a reduction in the availability of EEA migrants on the dental sector.

As the ADG’s evidence to the MAC consultation makes clear, NHS dentistry is particularly dependent on the supply of dentists from other EEA countries with 17% of dentists in the UK coming from the EEA.8

Our own data (see Table 5) shows that 21% of dentists working in our dental clinics and 10% of our wider dental workforce are from other EEA countries.

Our overseas dentists are often engaged to work in areas of the UK where we struggle to recruit UK dentists, often more deprived areas such as rural areas and coastal towns.

This is a skilled workforce and in many cases EEA workers are filling skills gaps that we struggle to fill in many areas from amongst the UK population. Any restriction in the availability of EEA migrants to the dental workforce is therefore likely to have a direct impact on patient care.

69.3% of patients treated in our dental clinics are NHS patients. The government must ensure that in any post-Brexit immigration system, the staff needs of private providers are recognised otherwise the delivery of crucial public services will be placed at risk.

While the sector may be able to offset some reduction in availability of EEA migrants in the short to medium term by hiring dental staff from outside the EEA in order to fill skills gaps, one of the

8 Submission from the Association of Dental Groups to the Migration Advisory Committee, Association of Dental

Groups, October 2017

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reasons we and the wider dental sector have hired significant numbers of EEA dentists to date is due to the alignment and mutual recognition of qualifications across the EEA that is not easily replicated outside the EEA.

Any restriction in access to EEA dentists is likely to have a particularly severe impact on patient care in the short to medium term as it takes six years to produce a fully qualified dentist. This means that even with significant additional investment in training the capacity to fill any skills gaps will not exist within the UK for the foreseeable future.

The importance of dental nurses from the EEA must also be noted. Currently, 11% of our dental nurses are from the EEA. Given that dentists in the UK are not able to practice without being accompanied by a dental nurse, any restriction in the ability to recruit EEA nurses where skills shortages exist poses a significant risk to the provision of dental services. Dental nurses are currently not included on the shortage occupation list and we would urge the MAC and the government to consider adding them to the list to ensure services are not put at risk.

2.4.4 Wider workforce

As noted above, our UK workforce includes 765 people working for our international private medical insurance business, Bupa Global, 11% of who are EEA nationals.

Approximately 13% of the 350 people working in operations are EEA nationals and within specific roles such as claims management consultants and customer service consultants, the proportion of EEA nationals is 18% and 17% respectively.

The need for multilingual skills forms an important part of our recruitment criteria so that we can best serve our international customers in their own language. We recruit locally for multilingual employees and seek to employ people of any nationality who fit our criteria and who have the right to work in the UK. A reduction in the availability of EEA migrants may make recruitment for our multilingual services team more difficult.

3. Recruitment Practices, Training and Skills

3.1 Methods of recruitment used to employ EEA migrants

If, as is most often the case, EEA migrants are already working in the UK then they are recruited through the same process as UK workers. Any EEA migrants need to fulfil the same requirements as UK workers, for example NMC registration if applying for a nursing position.

In certain circumstances, such as a severe shortage of nurses in a particular region, where normal recruitment processes in the UK fail to produce the required staff, we do on occasion proactively recruit staff in country.

Where we are proactively seeking to recruit staff from other EEA nations the process is far lengthier and more expensive as, in the case of nurses, recruits might need to complete their IELTS and then go on to complete their objective structured clinical exam (OSCE) before they can be employed in the UK. Given the expense of recruitment projects of this sort we would only undertake them in exceptional circumstances.

The difficulties and cost involved in actively trying to recruit EEA migrants who are not already living and working in the UK means this is a costly and complicated option for us to take and we

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only take this approach where we have been unable to fulfil skill shortages through our normal UK recruitment procedures.

3.2 Recruitment and training of UK workforce

As set out above, proactively trying to recruit from overseas often incurs significant additional cost and time. We therefore put a great deal of focus into recruiting and training within the UK workforce.

As Table 2 shows, over 67% of our Bupa UK workforce are employed in aged care. For all roles in aged care we advertise via local Job Centres and members of our HR function work closely with local Job Centres to ensure these roles are actively pushed out. Roles are also advertised on a range of nationwide job boards and at a local level via local advertising and posters in key locations. We also work actively with recruitment agencies across the UK to identify potential joiners and attend careers fairs and other events across the country to promote social care as a profession.

‘Soft skills’, including factors such as empathy and attitudes to older people, are crucially important when hiring staff in order to ensure all staff can deliver high quality care. In some areas we struggle to find sufficient numbers of staff in the UK who have these ‘soft skills’.

To try and boost the number of UK workers coming in to the sector we work with a range of programmes such as ‘Movement to Work’ to offer young people the opportunity to volunteer in our homes with the possibility of a contract at the end.

Both to train new employees and upskill existing members of staff within our aged care business we invest in a range of apprenticeships. Since the Apprenticeship Levy came into force in April 2017 we have placed 141 employees on apprenticeship programmes.

We also invest significantly in recruiting and training nurses for our dental business via apprenticeships. We recruit and train in the region of 160 dental nurse apprentices every year.

In recognition of the shortage of trained dentists in the UK, we have also recently launched a Dental Bursary Scheme at Manchester University. The scheme, in addition to a £5,000 donation to the Student Hardship Fund, which any dental student can apply for, will pay three final-year students £3,000 this year and another three students the same amount next year. Students will be offered the chance of a mentor from within Bupa, the chance to meet senior clinicians, and meetings with senior management. There is no obligation for recipients of the bursaries to join Bupa but it is hoped that suitable vacancies may be available after the successful completion of their Foundation Training.

While the investment we make in training, particularly through apprenticeships, helps us to fill skills gaps over the medium to long term, we still face significant difficulties in filling roles in the short term from within the UK.

For example, we often have difficulty recruiting sufficient numbers of dentists, particularly in ‘hard to fill’ locations. At time of writing, we have 136 live vacancies for dentists, of which 44 have been live for more than 90 days. 50 of these vacancies are in ‘hard to fill’ locations. 47 are currently ‘empty chairs’ i.e. they are not being covered by an existing dentist at the same location or by a locum dentist.

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The aged care sector also faces significant vacancy rates, reflecting the difficulties that all providers have in recruiting and training sufficient numbers of staff. Skills for Care estimate that 6.6% of roles in adult social care are vacant, equivalent to approximately 90,000 vacancies at any one time.9

3.3 Views on current UK migration policies including the Shortage Occupation List

As indicated by the data in Table 2, we employ a significant number of non-EEA migrants across our business, some of whom, particularly in nursing roles, have been recruited pro-actively from abroad to fill skills shortages we are unable to fill from the UK. As such we have a very good understanding of current UK migration policies.

While the current migration system, via the shortage occupation list, can be used to help address shortages in certain skilled occupations (for example, nursing) it makes it very difficult to recruit into occupations classified as ‘low-skilled’, regardless of the needs of the UK economy and the ability of the existing UK workforce to fill vacancies in a particular occupation.

Assuming free movement ends when the UK leaves the EU, we would argue strongly that a more flexible approach to identifying skills shortages and allowing business to recruit from overseas is needed through an expansion in the remit of the shortage occupation list to cover occupations that have traditionally been viewed as ‘low-skilled’, but where evidence shows there are clear skills gaps. We would echo the case made by the Cavendish Coalition that in future the immigration system should use public service value in assessing skill levels and setting entry requirements.10

For example, care assistants working in the social care sector, under current rules, are classed as ‘low-skilled’ for the purposes of the shortage occupation list. We prefer to talk about roles as being ‘soft skilled’ rather than ‘low-skilled’ – our care assistants do a very difficult job and one that requires substantial amounts of training.

Other roles where we have significant numbers of EEA migrants in our homes include a range of support roles such as catering managers. Again, like care assistants, these roles are not currently eligible for consideration for the shortage occupation list as they are classed as ‘low-skilled’ despite them often requiring substantial amounts of training. All these roles are essential parts of the care ecosystem and play a critical role in delivering high quality aged care services.

As the UK leaves the EU, we would urge the government and the MAC to look at extending the scope of the shortage occupation list to include roles such as care assistants in which significant numbers of EEA migrants currently work and which cannot be easily filled from the UK labour market, particularly at a time of high employment.

We would also urge the government and the MAC to look at extending the shortage occupation list to include dental nurses. As outlined above, dental nurses are critical in being able to deliver dental care in the UK.

The impact of other policies, including the Immigration Skills Charge, should also be factored in when making future decisions about which roles should be covered by the shortage occupation


10 Letter to Secretaries of State for the Home Office, Exiting the European Union and Health, Cavendish

Coalition, August 2017

14

list. The introduction of the Immigration Skills Charge was an unhelpful step and is likely to exacerbate skill shortages, particularly in sectors such as social care that are relatively low paid.

4. Economic, Social and Fiscal Impacts

We work alongside and in support of vital public services in the UK. In our aged care and dental businesses we are often directly delivering important public services. In our care homes 72% of residents are publicly funded while in our dental clinics over 69% of patients are NHS patients.

As the data in this response makes clear, EEA migrants perform a range of critical functions across our business. Many of the roles held by EEA migrants are crucial in the delivery of important public services, such as aged care through our care homes and NHS dentistry through our dental clinics, and it is important that the government and the MAC recognise that delivery of publicly funded health and social care services is not restricted to the NHS or public sector workforce.

The public services that our workforce helps to deliver, from aged care to NHS dentistry, are already under significant pressure, both in terms of funding and in relation to workforce shortages. A restriction in EEA migration will add considerably to those pressures, particularly as current high levels of employment in the UK make it difficult to fill skills gaps from within the UK.

Some of the roles held by EEA migrants within our business are defined as skilled for the purposes of the shortage occupation list and existing migration rules. However, many are lower skilled or ‘soft skilled’ roles, such as care assistants, that we would struggle to recruit from outside the EEA under current migration rules, despite the important role they play in delivering high quality care and in many cases in delivering public services.

Given the nature of our business and the need to ensure quality of care is maintained, if restrictions in access to EEA migrants mean we are unable to fill key vacancies we may face little choice but to close facilities, whether care homes, dental clinics or health clinics. This will directly impact the delivery of critical public services.

It is important that questions relating to the overseas workforce in the UK, particularly the EEA workforce, are addressed at pace. Despite being over a year on from the referendum result and over six months since the beginning of the Article 50 negotiation process, EEA citizens working in the UK and other EEA citizens looking to work in the UK in future do not yet have any certainty on their rights post-Brexit. This is already having an impact on the ability of UK businesses to recruit the staff needed to fill skills gaps.

Documents

economic and social impact of the UK’s exit · Bupa is an international business headquartered in the UK. In addition to Bupa UK employees, employees from two other market units