Transforming Mental Health Services Formal Consultation Process

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1 Project Plan for the Transforming Mental Health Services Formal Consultation Process June 2017 TMHS Project Plan v NOS This document can be made available in different languages and formats on request. Please contact the Communications and Engagement Team on or by 1 P a g e

2 Contents 1. Context 2. Background 3. Scope 4. Consultation Governance and Quality Assurance 5. Pre-Engagement 6. Option Development 7. Legal Duties and Requirements 8. Assessing Impact 9. Stakeholder Mapping and Analysis 10. Development of Consultation Document 11. Communications and Engagement 12. Standards and Format of Information 13. Budget and Expenditure 14. Risk and Assurance 15. Management of Consultation Responses 16. Consultation Analysis 17. Reporting and Feedback 18. Evaluation 2 P a g e

3 List of Appendices Appendix 1: Appendix 2: Appendix 3: Appendix 4: Appendix 5: Appendix 6: Appendix 7: Consultation Scope Equality impact assessment of the consultation plan Stakeholder mapping Feedback Form Consultation Plan Risk Register Gantt Chart Timescale 3 P a g e

4 1. Context Hywel Dda University Health Board (Health Board) plans, organises, commissions and delivers local health services for the 384,000 people who live in Carmarthenshire, Ceredigion, and Pembrokeshire. We organise and pay for the care and treatment local people get in their hospitals, health centres, GPs, dentists, pharmacists, optometrists and other healthcare settings. We want the people in our area to be supported by mental health services that are on par with the best in the UK, Europe and across the world. This project plan outlines the practical steps we intend to take to ensure that we run a best practice consultation exercise for Transforming Mental Health Care and Support. It includes details on how we will manage the process, what we are consulting on and the areas of influence. The consultation will be presented at the Hywel Dda University Health Board Meeting and subject to approval will be formally launched on the 22 June The consultation period will be 12 weeks and will close on the 15 September Background The mental health needs of the people who live in Carmarthenshire, Ceredigion and Pembrokeshire have changed significantly over the last few decades. Our approach to treating those conditions has changed too. More of us understand mental health issues and many people who used to go into hospital for mental health treatment now expect treatment and support within their own homes or communities. Most people who rely on our services tell us they value the help and support in their local community from health, social care, and voluntary organisations or local charities. They understand that those services are backed up by hospital care and treatment when they need it. 4 P a g e

5 Through our engagement people have told us that the services we provide can be hard to access and don t always help as much as they could or should do. Our staff and colleagues in other agencies like social services, the police, and the ambulance trust work hard and are committed to delivering the best possible care, but our system has evolved over many years around buildings that were put in place for different purposes and this can often prevent us from delivering care in the way we would like. Our future services need to have a greater focus on the promotion of mental wellbeing, preventing the development of mental illness, reducing the stigma and discrimination associated with mental ill health, offering appropriate and easy access to care and treatment, early intervention and timely treatment when needed. Services do not always feel joined up for people with mental ill health, with communication between different parts of the service not always being as good as it should be and many people having to endure many repeat assessments before they get the right care. People should be able to expect better access to higher quality mental health services in their communities, helping people to stay well and out of hospital where possible. 3. Scope of Consultation The scope of the consultation has been informed by members of the Transforming Mental Health Programme Group and refined by the Health Board. The scope provides an outline description of the consultation process and includes; - The context of the consultation - Who we need to consult with - The fixed points (what is not open to influence) - What is open to influence - Options not put forward for consultation - How the consultation process will be managed The consultation scope has been tested by the Consultation Institute and has achieved best practice accreditation. The full consultation scope is included as Appendix 1. 5 P a g e

6 4. Consultation Governance and Quality Assurance The Health Board has responsibility for the consultation and decision making process. The consultation will be managed by the Mental Health Programme Group with support from the Communication and Engagement work-stream who will have responsibility for overseeing the consultation process on a regular basis. The work-stream will manage and oversee the development and implementation of the consultation process and related consultation dialogue activity with the public. The group will include members from the Transforming Mental Health Programme Group and include representation from: - mental health services - the engagement team - the communications team - the equality and diversity team - service users and carers - the third sector - members and officers of Hywel Dda Community Health Council (the CHC) The work-stream will meet fortnightly to discuss progress and make any specific changes to the consultation plan as a result of feedback and issues presenting throughout the consultation process. The scope of the Consultation and Engagement Workstream will include: Informing the draft project plan and associated consultation documents for presentation to the Health Board - Identification and mitigation of risk - Monitoring of all dialogue communications and engagement activity - On-going equality analysis and assurance throughout the consultation - Reviewing arrangements for targeted engagement to ensure that people from groups with protected characteristics are fully engaged in a way that is accessible 6 P a g e

7 - On-going analysis and identification of under-represented stakeholder groups - Targeted engagement to ensure there are opportunities to participate - Participation in the mid-point review - Providing updates to Mental Health Programme Group on progress and arising issues / mitigations to be addressed. The Community Health Council has been involved throughout the co-production process and will continue to be involved throughout the consultation process. The consultation process will go through an independent, rigorous assurance process by the Consultation Institute. The Consultation Institute has developed and deployed a tried-and-tested method for the Quality Assurance of public consultations. This quality assurance process will include testing and review of the Project Plan, Documentation, Mid-Point Review, Closing date and Final report to confirm Institute endorsement. All key documents will also be presented to the Hywel Dda University Health Board Public Board meeting on the 22 June Pre engagement In recognition of current challenges with existing models of care, and the continuing need for improvement and innovation, the Mental Health Programme Group (MHPG) was established in April The focus of the MHPG was to govern and oversee the Transforming Mental Health Services Programme. The Programme embraced the ethos of co production and was led by a multi-stakeholder group made up of professionals, service users, carers, third sector, local government, and the Community Health Council. The MHPG have worked together over the past 2 years to consider how best to meet the mental health needs of our local population across services, age groups and specialities, considering historical barriers and boundaries to providing services. 7 P a g e

8 The programme has focussed on ensuring that people have the same high quality care wherever they are and creating modern, safe and sustainable services that meet the needs of our changing population. The programme has a clear focus on supporting people to recover from mental health difficulties and be supported to live full and meaningful lives. The MHPG agreed that they wanted to develop a service with the following principles at its core: - To be accessible 24 hours a day - To have no waiting lists - To move away from hospital admission and treatment to hospitality and time out - Day time out and opportunities A formal engagement period for the programme was undertaken from the 1 st of October 2015 to the 31 st of January At over 100 engagement events we talked to a wide range of staff and stakeholders, service users, carers, the third Sector, Community Health Council and Local Authority, in order to establish what services they thought the Health Board should provide and how they thought the process of changing the services would affect them, or the people they care for. Alongside the engagement events the Health Board worked closely with West Wales Action for Mental Health (WWAMH) to ensure that an independent service user and carer perspective on alternative models of care was used to inform any service transformation. We commissioned the University of Wales Trinity St David s to analyse the feedback, which resulted in the identification of ten common themes: - Responses to Change - Accessibility to Mental Health Services - Understanding and Managing Crisis - Workforce issues - Rurality and Mental Health Services - Systems and Management - Collaboration - Values and Attitudes - Engagement, Research and Knowledge-Sharing - Desired Outcomes 8 P a g e

9 There was an overwhelmingly positive response to change There was a consensus amongst public, staff and stakeholders that the mental services model in the Hywel Dda region needs to change and reflect the distinctive needs of the Hywel Dda health economy. 6. Option Development The feedback from the engagement analysis was presented to the Hywel Dda University Health Board on the 2 nd June, 2016 and following this meeting approval was given to commence the process of developing options. Between June and November 2016 a multi-stakeholder Options Development Group was formed to distil and short list options. Representation included service users, carer representatives, Community Health Council, Police, NHS Staff, West Wales Action for Mental Health (WWAMH), Carmarthenshire, Ceredigion and Pembrokeshire County Councils. The group followed best practice advice on developing options from the Consultation Institute and was guided by the Equality Lead for Hywel Dda University Health Board. The group worked to undertake the following core tasks: - Outline current services provided across the three counties - Provide an overview of the status quo including service mapping of current provision and buildings utilised, and an overview of staffing and roles within the service. - Develop a scoring criteria and weighting for option appraisal - Develop options that take into account the themes identified from the engagement period - Develop a clinical case for change The group used what we learned from stakeholders, service users and carers in the engagement process and the engagement analysis document to draw up a list of weighted scoring criteria, which were: - Transport and location - Service responsiveness - Information and understanding 9 P a g e

10 - Expertise (level of) - Service user and carer outcomes and experience - Ability to meet current or projected demand - Statutory requirements - Evidence-based practice/guidance - Crisis management - Equality and inclusivity - Protected characteristics and additional related considerations - Affordability - Workforce - Sustainability - Delivery joint/integrated - Level of co-production/co-design The Options Development Group used feedback from the stakeholder events to: - carefully review the weighted scoring criteria it had developed to make sure it accurately reflected stakeholder views., and - score the seven shortlisted options From September to November, 2016 the seven shortlisted options were tested at stakeholder focus groups and engagement events, and at two options scoring workshops. The group considered the feedback and fully reviewed the weighting of the 17 scoring criteria and made sure the scores took into account all the stakeholder feedback. Following discussions with the Consultation Institute in December, 2016 it became clear that the extensive co-design programme approach had resulted in the development of a consensus model. Up to this point the consultation documentation had been developed around taking two options forward for formal consultation. However, it was felt that the two models identified were not sufficiently different for consultation purposes. It was agreed to take forward a single service model and consult on the implementation of this model. We wanted the consultation to be based on real influence, we took time to work with our option development and consultation and engagement group to look at 10 P a g e

11 where we could get value out of people s knowledge and ideas to inform the areas of influence within the consultation. 7. Legal Duties and Requirements 7.1 Equality Act / Public Sector Equality Duties Our duties in relation to equality and diversity are outlined in the Equality Act 2010 (Statutory Duties) (Wales) Regulations The Act aims to ensure and those carrying out a public function consider how we can positively contribute to a fairer society in our day-to-day activities through paying due regard to eliminating unlawful discrimination, advancing equality of opportunity and fostering good relations. In order to make this happen, the Regulations place specific duties on the devolved public sector, including Health Boards in Wales to carry out equality impact assessments. In the context of this work we are required to assess the impact of our proposals to ensure that, as far as is practicably possible, the opportunities for promoting equality and human rights for people with protected characteristics are maximised and any actual or potential negative impact is eliminated or minimised. 7.2 Mental Capacity Act The Mental Capacity Act is a law designed to ensure that all people, age 16 and over, are protected and empowered if they lack the capacity to make a decision about their care and treatment. 7.3 Human Rights Act The Human Rights Act 1998 (the Act or the HRA) sets out the fundamental rights and freedoms that everyone in the UK is entitled to. It requires all public bodies, including health boards, to 11 P a g e

12 respect and protect your human rights. 7.4 Welsh Language (Wales) Measure 2011 Our duties in relation to the Welsh Language are outlined in the Welsh Language (Wales) Measure The Act, the current Welsh Language Scheme and subsequent Welsh Language Standards. In line with the new Welsh Language Standards the organisation will be expected to consider, when formulating a new policy, or reviewing or revising an existing policy, what effects, if any (whether positive or adverse), the policy s formulation or decision would have on (a) opportunities for persons to use the Welsh language, and (b) treating the Welsh language no less favourably than the English language. When publishing a consultation document which relates to a policy decision, the document must consider, and seek views on, the effects (whether positive or adverse) that the policy s formulation or decision under consideration would have on (a) opportunities for persons to use the Welsh language, and (b) treating the Welsh language no less favourably than the English language 7.5 Welsh Government Guidance for Engagement and Consultation on Changes to Health Services Ministerial Guidance (issued in March 2011) makes it clear that there are certain responsibilities on the Health Board in undertaking consultations of this nature. The process for consultation requires a two stage process: - Stage 1 Pre-consultation to engage key stakeholders in exploring issues, developing options and plans - Stage 2 Formal consultation A Health Board is expected to undertake a two stage consultation process where it appears likely that formal consultation should take place. The first stage of this process is for the Health Board to undertake extensive discussions with all key stakeholders, including: - Stakeholder Reference Group 12 P a g e

13 - Health Professions Forum - Partnership Forum - Community Health Council - Local Service Boards - Staff and their representative bodies - Other key partners as appropriate The purpose of these discussions is to explore all the issues, to refine the options and to decide and agree on which questions will be set out in the consultation. Only when the Health Board is satisfied that the first stage has been properly conducted should it proceed to formal consultation. Following the first stage, a formal consultation period of a minimum of 6 weeks should be sufficient in most cases if the issues have already been fully explored during the first stage and if the CHC agrees. The consultation document must take into account the specific information on what should be included in a consultation document. It is important to include a clear explanation as to how the views expressed will be considered as part of the decision making process. It is best practice to provide an indicative timeline for the decision making process and identify how results will be fed back to those who have been involved in the process. 7.6 Gunning Principles Any consultation should be able to demonstrate that it has taken into account the Gunning principles i.e.: i. consultation must take place when the proposal is still at a formative stage; ii. sufficient reasons must be put forward for the proposal to allow for intelligent consideration and response; iii. adequate time must be given for consideration and response; and iv. the product of consultation must be conscientiously taken into account. 13 P a g e

14 7.7 National Health Services (Wales) Act 2006 Section 183 of the National Health Services (Wales) Act 2006 requires LHBs, with regard to services they provide or procure, to involve and consult citizens in: planning to provide services for which they are responsible developing and considering proposals for changes in the way those services are provided; and making decisions that affect how those services operate. Section 242 of the National Health Service Act 2006 extends this requirement to NHS Trusts. 7.8 Wellbeing of Future Generations Act The Well-being of Future Generations (Wales) Act 2015 (the Act) is new legislation which has at it s heart the well-being of future generations, through the establishment of seven national wellbeing goals and five ways of working: A prosperous Wales where everyone has jobs and there is no poverty A resilient Wales where we re prepared for things like floods A healthier Wales where everyone is healthier and are able to see the doctor when they need to A more equal Wales where everyone has an equal chance whatever their background A Wales of cohesive Communities where Communities can live happily together A Wales of vibrant culture and thriving Welsh language where we have lots of opportunities to do different things and where lots of people can speak Welsh 14 P a g e

15 A globally responsible Wales where we look after the Environment and think about other people around the World. Five Ways of Working 7.8 Social Services and Wellbeing (Wales) Act 2014 The Social Services and Well-being (Wales) Act 2014 imposes duties on local authorities, health boards and Welsh Ministers that require them to work to promote the well-being of those who need care and support, or carers who need support. The West Wales Care Partnership (WWCP) has been established under Part 9 of the Social Services and Wellbeing (Wales) Act 2014 with specific duties to promote the integration of community care and support services. Whilst statutory partners comprise Hywel Dda University Health Board, Pembrokeshire County Council, Carmarthenshire County Council, and Ceredigion County Council, membership of the Regional Partnership Board (RPB) also includes user and carer representation as well as third and independent sectors. Under the legislation the RPB is required to prioritise the integration of services for older people, including dementia; people with learning disabilities; Carers; Family Support Services; and children with complex needs due to disability or illness. The WWCP has prioritised five priorities based around key enablers for building on these foundations and progressing the integration agenda in the region. These are: 15 P a g e

16 Integrated Commissioning Service integration/ pooled funds, including establishing pooled fund arrangements for care homes Information Advice Assistance Implementation of the Welsh Community Care Information System Transformation of MH and LD 7.9 Convention on the Rights of the child (UNCRC) In November 1989, the United Nations General Assembly unanimously adopted the Convention on the Rights of the child (UNCRC). In December 1991, the United Kingdom government signed up to ( ratified ) the Convention. In line with this the Welsh Assembly Government has made a commitment to promote and support children and young people s participation and to implementing children and young people s rights to participate as stated in Article 12. Article 12 of the convention states that: Children and young people have a right to participate in the decision making processes that are relevant their lives and a right to influence the decisions made in their regard within the family, the school or the community. 8. Assessing Impact In line with S.149 of the Equality Act 2010 (Statutory Duties) (Wales) Regulations 2011 the Health Board must have due regard to the need to: - Eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act - Advance equality of opportunity between people who share a protected characteristic 1 and those who do not - Foster good relations between people who share a protected characteristic and those who do not 1 Protected characteristics are Age, Disability, Gender Reassignment, Marriage and Civil Partnership, Pregnancy and Maternity, Race, Religion and Belief ( including no belief) Sex, Sexual Orientation 16 P a g e

17 - Equality Impact Assessment requires us to consider how our proposals on transforming mental health services may affect a range of people in different ways and will help us answer the following questions:- Do different groups have different needs, experiences, issues and priorities in relation to the proposed service changes? Is there potential, or evidence that the proposed changes will promote equality? Is there potential for, or evidence that the proposed changes will affect different groups differently? Is there evidence of negative impact on any groups of people? If there is evidence of negative impact, what alternatives are available? What changes are possible? How will we monitor impact following implementation? The involvement of people from protected groups will be monitored to ensure that views from a range of groups is represented as defined within the Equality Act 2010 (Statutory Duties) (Wales) Regulations The Health Board is undertaking an Integrated Impact Assessment as part of the review of proposed model, underpinned Equality Impact Assessment which will be further informed by findings from our consultation. The equality analysis has to date considered potential impacts that any change to mental health services may have on people from groups with protected characteristics. As part of the consultation process, we will test the potential impacts on people. This will include asking about the perception of how any change to service might have a positive or negative impact on them. The equalities analysis will be reviewed throughout the consultation process by the Communication and Engagement Work-stream and additional engagement will be conducted around this as required To ensure that the Health Board fully meets its duty an equality impact assessment has been conducted on project plan and will 17 P a g e

18 be further reviewed as part of the consultation process. The equality impact assessment can be viewed as Appendix 2 9. Stakeholder Mapping A detailed stakeholder mapping analysis exercise has been undertaken to ensure that the relevant stakeholders are aware of and have the opportunity to participate in the consultation. A formal consultation will commence following approval by Board and will be delivered in accordance with the guidance for engagement and consultation on changes to health services. Throughout the consultation process we will need to ensure due regard is given to the general and specific equality duties for public sector organisations in Wales, and the requirement to engage with representatives of protected groups in assessing the potential impact of proposals on these groups. We will also take account of the best practice guidance for involving service users in mental health services. We need to understand the views of the following groups on the proposals: - People who use mental health services, their carers and advocates - Reference Groups such as carers, service users, People s First and Veterans. - Health Board staff - Each county (Carmarthenshire, Ceredigion and Pembrokeshire) will have a specific interest in our proposals due to historical legacy positions - Community Health Council - NHS organisations including WAST and statutory organisations e.g. Police - Local community organisations, community representatives, third sector, voluntary sector - Local Authorities (Carmarthenshire, Pembrokeshire, Ceredigion ) councillors, officers - Professional Bodies - Media 18 P a g e

19 - Staff with protected characteristics and/or who may be carers We need to understand the views of particular groups in relation to Transforming Mental Health service proposals in more depth: Service users, their families and carers with particular emphasis on service users. Service users, their families and carers with particular emphasis on service users with protected characteristics. Community and interest groups representing service users, carers, their families and advocates. Community and interest groups representing service users, carers, their families and advocates with protected characteristics. Primary care contractors Professional bodies concerned particularly with the delivery of these services. We need to understand views on proposals for change in these services so that the Board can decide on the best way to deliver a service that: Is accessible 24 hours a day Has no waiting lists Moves away from hospital admission and treatment to hospitality and time out Improves day time out and opportunities Stakeholder mapping will include a focus on disadvantaged, marginalised and minority groups and communities via local community and voluntary sector groups and networks to make sure that those who may not always have the opportunity to have their say in decisions that affect them. See Appendix 3 for stakeholder mapping document. 10. Development of the Consultation Document A full consultation document has been developed which details: - The background to the consultation and vision for change - The need to change - Our proposals for change - Rationale for the proposed model and areas of influence 19 P a g e

20 - How people can participate in the consultation and give their views We will provide the consultation document in different languages including audio, easy read, Polish and Welsh. Information will be provided in additional formats as required to ensure participants have enough information to give informed consideration to the areas of influence. This will also ensure that the consultation meets the standards set out in the Gunning Principles described in legal duties and requirements section of this document. The feedback and materials will be reviewed as part of the Communications and Engagement Work-stream. 11. Communication and Engagement The consultation objectives are: To describe and explain the model for future mental health services in Hywel Dda - To understand the impacts that have been identified and identify any other impacts of our proposals that have not been identified - To seek people s views on the model, including the range of services/ activities and contact methods of services as set out in the proposals - To inform and provide opportunities for a diverse range of people (inclusive of staff, service users, carers, our partners, stakeholders and the general public) to share their views about how the model has been developed and generate specific discourse on elements of our implementation to help influence the final direction. - To identify additional ideas to develop the core model and manage the implementation of proposals - To ensure that the consultation process maximises community engagement and complies with legal requirements and duties A variety of communication and engagement activities will be used to ensure that the consultation is fully accessible to the population 20 P a g e

21 of Carmarthenshire, Ceredigion and Pembrokeshire. This activity is detailed in the consultation plan in appendix 4. We will look to make good use of our website, with the various formats of the consultation document, technical documents as well as additional supporting materials including frequently asked questions, press releases etc. Feedback will be received in a variety of different formats, respondents will be able to: - complete surveys electronically or in hard copy - telephone and leave their views - write a letter - send an - participate in a Facebook event - attend a drop in session - share their views as part of an existing group / meeting When gathering feedback from meetings, or one-to-one discussions, the representative from the MHPG will be asked to complete a feedback form and this will be recorded with other submissions on the submission database. An example of the feedback form is included as Appendix Standards and Formats of Information All information produced as part of the consultation will be written in a language that can be understood by members of the public. Technical phrases and acronyms will be avoided and information will be produced in other formats as required to reflect the needs of the diverse population of Hywel Dda. 13. Budget and expenditure The Health Board has committed significant resources to the consultation process. This has included: Activity Expert advice from the Consultation Institute to ensure the consultation process meets best practice standards Estimated Cost 12, P a g e

22 External analysis of consultation responses 19,000 Design costs 2,500 Printing of main document 2,500 Printing of executive summary 500 Printing of survey 2,000 Translation (Welsh) 1,000 Translation (audio) 50 Translation (Polish) 300 Easy Read version 500 Cost of drop in events 5,000 Staff time to support delivery of consultation plan 100,000 TOTAL 145, Risk and Mitigation Risk and risk mitigation will be managed by the Mental Health Programme Group and risks relating to the consultation project plan will be identified and regularly reviewed as part of the Communication and Engagement Workstream meetings. The current risk register is included as appendix Management of Consultation Responses Consultation responses will come into the organisation in many forms and through various different routes. A database will be set up by the Public and Patient Engagement Team to log responses and feedback gathered from meetings. The database will be updated by the administrative team within mental health with support from the Public and Patient Engagement Team. Electronic versions will be saved as evidence and paper copies will be scanned so we have an electronic record of all responses received. We will share these regularly with Hwylus, a company we have commissioned to undertake the independent analysis of consultation responses. Electronic questionnaires will be completed by individual respondents online and any paper questionnaires received will be input onto the electronic survey system. 22 P a g e

23 Hwylus will undertake a quantitative analysis of the survey to provide demographics and preferences of options in addition to qualitative analysis of the open ended questions. Workshops will provide an opportunity to develop in-depth qualitative analysis of why people hold certain views on proposals. Written responses, feedback from meetings etc will be reviewed as part of the qualitative analysis. Analysis of the responses on social media campaign will be included and considered as part of the qualitative and quantitative analysis process. 16. Consultation Analysis The consultation activity will result in quantitative and qualitative feedback and data. It is essential that the data and feedback is subject to robust, in-depth analysis. This will inform the decisionmaking of the Health Board around the potential changes to mental health services. To ensure an open and transparent method of analysis an external provider, with expertise in this area, Hwylus has been commissioned to undertake the data analysis and provide a report for consideration by the Health Board. 17. Reporting and Feedback A full feedback report will be produced. This will contain an overview of the consultation, along with the data analysis, feedback on the proposed model and areas of influence and conclusions and recommendations for consideration by the Health Board as part of its decision-making process. The report will be shared with the Community Health Council for consideration as part of their role in reviewing and formulating an official response to the consultation. Following a period of consideration, the Health Board will then make a decision on any changes to mental health services. This decision will also then be published and communicated to stakeholders, along with the rationale for making that decision The feedback report will be available and widely distributed to enable stakeholders for information. 23 P a g e

24 18. Evaluation Evaluation will be on-going throughout the consultation period, led and overseen by the Communication and Engagement workstream. Once the consultation has closed, a further, full evaluation of the consultation, including development and implementation, will be conducted. The results of the evaluation will be shared with the MHPG, CHC and the wider health board to ensure lessons learned will be taken forward to inform future projects. 24 P a g e

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