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Position statement on Valvira’s proposal to tighten social work substitution eligibility

The number of places for social work education is inadequate, and Valvira’s stance on substitute workers intensifies the staffing crisis in social welfare. We must not abandon our clients in their time of need.

We, the undersigned, express our concern about the availability of social workers in a situation where the National Supervisory Authority for Welfare and Health (Valvira) has tightened its interpretation of who is eligible to substitute for social workers. We call for a rapid reassessment of the guidelines and their amendment to reflect the current situation, where the wellbeing services counties are already suffering from staff shortages and financial strain.

The stricter interpretation threatens the provision of social welfare services in the wellbeing services counties. The interpretation suddenly reduces the number of people who can be counted in the strength of social services personnel in a situation where not all open positions can be filled because not enough social workers are graduating from universities. At the same time, the worker-client ratio of social work is becoming stricter, for example in child welfare services.

In accordance with the new guidelines updated on 19 July 2023, to be eligible to act as a substitute, a person must effectively be a degree student registered for the academic year who has successfully completed core and intermediate studies and practical training in social work. Social work substitutes are often persons who have completed studies at the Open University of Applied Sciences but have not been admitted to a university as degree students through the open university route.

We emphasise that the aim is always to find employees who meet the qualification requirements to serve as social workers. In practice, however, this aim is often challenging to achieve. There are too few qualified social workers available for the open positions.

Problem caused by universities’ low maximum intakes

Universities have far too few student places available in social work to meet the need for labour, with no significant increases in intakes in recent years. In 2023, there were a total of 293 student places available, of which 27 were at the University of Helsinki, 43 at Tampere University, 35 at the University of Jyväskylä, 38 at the University of Turku, 72 at the University of Eastern Finland and 48 at the University of Lapland. Swedish-language social worker training had 30 student places available. The joint application process in 2023 had 4,391 applicants for social work studies: 15 applicants per available student place.

In addition to the joint application process, universities have quotas for students taking the open university route as well as separate master’s degree programmes for applicants with a tertiary degree. The intake quotas for the open university route vary between universities as follows: University of Helsinki 1 place, University of Jyväskylä 2 places, Tampere University 5 places, University of Eastern Finland 10 places, University of Turku 12 places, Kokkola University Consortium Chydenius 5 places (+ 30 places for applicants with a tertiary degree) and University of Lapland 15 places. In total, there were 50 (+ 30) student places available.

The combined number of current available student places at universities and open university route quotas is so low that only a fraction of applicants are admitted as degree students. Those who become degree students through the open university route are also sought-after employees, as they often graduate quickly and already have practical experience. They have often previously completed a Bachelor’s Degree in Social Services, which increases their competence.

Change in interpretation only exacerbates social welfare staff shortages

Valvira’s changed interpretation considers “a person studying for the profession” to refer to a person in the process of completing a Master’s Degree in Social Services who is registered as a student for the academic year at the university at which he or she has a right to complete degree-awarding studies. This interpretation excludes a large number of social workers currently serving as substitutes from the strength of social services personnel and significantly complicates the provision of services to clients.

According to a survey conducted in our regions, approximately 55 current social welfare employees would be ineligible according to the stricter interpretation; 14 of them work at the Western Uusimaa Wellbeing Services County, 10 at the Wellbeing Services County of Vantaa and Kerava, 13 at the Wellbeing Services County of Central Uusimaa, 4 at the Wellbeing Services County East Uusimaa, 12 at the City of Helsinki and 2–4 at the Wellbeing Services County of Pirkanmaa.

The organisations are committed to developing job structures to be more versatile. In practice, however, many positions are ones that, due to legislation, can only be held by a qualified social worker.

Interpretation of substitutes’ maximum one-year work period problematic

The interpretation that a substitute could work in an organisation continuously for a maximum of one year is ambiguous and incompatible with the structures of service production in wellbeing services counties. The guidance does not take a stand on whether the entire wellbeing services county should be considered as one organisation or whether it refers to, for example, a single service area or service line.

A new employee’s induction and familiarisation with clients is a process that takes several months. If a qualified social worker cannot be hired for an open position and the contract of the substitute who has held the post cannot be renewed, it will compromise the continuity of client relationships and be detrimental to clients.

Conflicting instructions of supervisory authorities on the subject found confusing

Supervisory authorities themselves have interpreted the guidance in very different ways. The Regional State Administrative Agency of Southern Finland adopted a decision on a complaint filed by the Western Uusimaa Wellbeing Services County concerning the management of the substitution of a social worker (ESAVI/15530/2020).

The decision states as follows:

“Although legislation is unambiguous on the length of time that a temporary social worker is eligible to fill a social worker’s post, the Regional State Administrative Agency notes that, at the moment, legal interpretation is unclear in a situation where the attempts to recruit a qualified social worker have failed and the temporary social worker who previously filled the post is prepared to continue in the position. [–] In such a situation, the continuation of the temporary social worker in the position may be the solution most in the best interest of children, when the recruitment has been conducted in an open process. The Regional State Administrative Agency emphasises that the guidance of a temporary social worker must de facto take place in such a way that the qualified appointed mentor of the temporary social worker participates in assessments in person at all stages of the client process.”


Mari Ahlström
Service Area Director
Western Uusimaa Wellbeing Services County

Hanna Kaunisto
Director of Social Work
Wellbeing Services County East Uusimaa

Hanna Mikkonen
Executive Director of Children, Youth and Family Services
Wellbeing Services County of Vantaa and Kerava

Titta Pelttari
Service Line Director
Wellbeing Services County of Pirkanmaa

Suvi Salin
Acting Service Director
Wellbeing Services County of Central Uusimaa

Maarit Sulavuori
Director of Family and Social Services
City of Helsinki

Kati Villgren
Service Line Director
Western Uusimaa Wellbeing Services County