Winter handicapping

My course has a Blue course measured for Winter, i.e. from different tees. Most of the Winter play is off mats in all areas other than true rough. There are a variable number of main greens from all main to all temporary. Players who are scoring above their handicap regularly or winning competitions have their handicap reduced, and usually this remains at the lower level into the main golf season. I wonder if other clubs are doing this? I feel this may not be what England Golf recommend but I can't find anything on the issue. Any thoughts?
If the comps meet the criteria to be qualifiers then there should be no issue, however, the use of mats in the way you describe seems wrong for it to be a qualifying course.

Our course is set up exactly as you describe yours except we only use it as qualifying when the mats are in use on fairways and closely mown to fairway height. (There is a correct local rule for using mats).

When the course was too wet for greenkeepers to define fairways, our use of mats was extended throughout the course and comps were non-qualifying.
 
At ours we have compulsory mats on fairways and semi-rough in bounce games. If you decide that you are putting in a hcp score, or playing in a medal, you must not use your mat in the semi.
 
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