White Paper: Services Fit for the Future

Transcription

1 White Paper: Services Fit for the Future Consultation response form Your name: Manel Tippett Organisation (if applicable): The Royal College of Psychiatrists in Wales Your address: RCPsych in Wales Baltic House, Mount Stuart Square Cardiff, CF10 5FH Responses should be returned by 29/09/17 to: Healthcare Quality Division Welsh Government Cathays Park Cardiff CF10 3NQ. or completed electronically and sent to: Responses to consultations are likely to be made public, on the internet or in a report. If you would prefer your response to remain anonymous, please tick here:

2 Summary of questions Chapter 1: Effective Governance 1.1. Board Membership and Composition The Welsh Government believes that the Boards of both health boards and NHS trusts should share some core key principles which are outlined including delivering in partnership to deliver person centred care and a strong governance framework to enable the Board to work effectively and meet its responsibilities. All Boards should have Vice Chairs in order to support focussed and skilled leadership. The Welsh Government also believes that Ministers should have the authority to appoint additional Board members on time limited appointments if an NHS Health Board/Trust is under performing or under escalation procedures in accordance with the NHS Wales Escalation and Intervention arrangements. The Welsh Government believes that Board Executive Officer membership for local health boards should probably include some key positions which are consistent across local health boards but also allow some flexibility to appoint based on remit and priorities. Do you agree with these proposals? We agree with all of the above proposals. The consultation document is correct in highlighting (paragraph 27) that in some Health Boards there is a loss in focus on mental health, which has resulted in not meeting the requirements of existing legislation. We have raised our concerns regarding this in a number of previous consultations and with senior figures in Welsh Government, the NHS Wales and Assembly Members. In our Manifesto for the Welsh elections in 2016, and in the Green Paper Our Health, Our Health Services we called for the creation of an Executive Director of Mental Health and Intellectual Disabilities with full voting powers in each Health Board. This would address two areas of increasing importance: parity of esteem, or the provision of equal care for those experiencing poor mental health as it does those with poor physical health; and the underlying and often undetected mental health of people with a wide variety of physical health conditions. We believe that the creation of this post would ensure proper implementation of the Mental Health (Wales) Measure 2010 so that services are designed around the needs of the patient and not of the organisation. This post could improve patient experience and service delivery and this in turn would result in a happier workforce that is currently struggling under existing pressures from increased workload and lack of resources.

3 What further issues would you want us to take into account in firming up these proposals? 1.2. Board Secretary In order to deliver on the key principles outlined the Welsh Government believes that the role of Board Secretary should be placed on a statutory basis and have statutory protection to allow the role to be independent with safeguards in place to challenge the Chief Executive of an NHS organisation or the Board more widely. Do you agree with these proposals? Yes. What further issues would you want us to take into account in firming up these proposals? The post should have a specific remit to include scrutinising and holding to account the quality of mental health and intellectual disabilities service delivery. Chapter 2: Duties to Promote Cultural Change 2.1. Duty of Quality for the Population of Wales The Welsh Government believes that the duty of quality should be updated and enhanced to better reflect our integrated system. This duty should be sufficiently wide in scope to facilitate the needs of the population of Wales to facilitate and enable collaborative, regional and all-wales solutions to service design and delivery NHS bodies should also be placed under a reciprocal duty with local authorities to co-operate and work in partnership to improve the quality of services provided. Welsh Government also believes that strengthening the existing planning duty will make sure health boards work together on the needs of the population of Wales in the planning and delivery of quality healthcare services. Do you agree with these proposals? We agree with the proposed move from individual organisations working in silos to placing a duty on organisations to collaborate in order to meet the

4 needs of the population as a whole. Collaboration between organisations results in a shared responsibility of care. It will enable better integration between primary and secondary care and between health and social care. This is in line with what already exists for local authorities under the Social Services and Wellbeing Act (2014) Wales. What further issues would you want us to take into account in firming up these proposals? The proposals would require significant amendments to the NHS (Wales) Act We would insist that any changes to existing legislation (or policy) must bring about improvements to quality, and not only to process. We would urge that lessons are learned from the drafting of the Mental Health (Wales) Measure Legislating for good clinical practice will not guarantee improvement in quality of care. The Measure has resulted in an imbalance between bureaucracy and patient care, a widening gap between primary and secondary care, and a need for health professionals/local Health Boards to meet quantifiable targets and not quality outcome measures Duty of Candour The Welsh Government believes that the development of a statutory duty of candour across health and social services in Wales would consolidate existing duties and be in the interests of a person centred system. Do you support this proposal? Yes, not least as this will keep us in line with the rest of the UK. The reporting of incidence is crucial. Errors can be corrected and used for learning and training purposes. Doctors, nurses and midwives are already required to be open and honest with patients (GMC 2013) and must report any mistakes that compromise patient safety. If the responsibility were to lie with the organisation rather than on the individual this may encourage people to report incidents. The likelihood for dismissal, disciplinary action or clinical negligence would be greatly reduced. There is a danger that patient and carer voices within vulnerable groups for example are not heard as they would be in other areas. What further issues would you want us to take into account in firming up this proposal?

5 Welsh Government must take into account that some clinical errors are the result of individual practice but many are at least in part the responsibility of wider organisational processes. The duty of candour should be seen as an organisational, as well as an individual requirement. This should address the potential for creating a blame culture. The Andrew s report and the Ockenden report attest to this. It is important to address the culture of complacency which is often found in services treating frail elderly people with mental health conditions. Chapter 3: Person-Centred Health and Care 3.1. Setting and Meeting Common Standards The Welsh Government believes there should be a common set of high level standards applied to health and social care and that the standards should apply regardless of the location of care. Do you support this proposal? Yes, enabling positive outcomes for patients with mental health and/or learning disability is a fundamental principle of the Royal College of Psychiatrists and the College s Standards and Accreditation Programmes are designed to achieve this in a range of mental health care settings, whether in hospital, in prisons, or in the community. It is important that regardless of where a person receives support, they are treated with dignity and respect. People s needs are often complex, particularly in the elderly, making it important for organisations to work together to help individuals recover, thrive, or die with dignity. High level standards of care must be consistently embedded across the public sector bodies providing care and treatment. What further issues would you want us to take into account in firming up this proposal? We would recommend that Welsh Government observe existing standards that have been set by professional bodies, including RCPsych. We would also recommend highlighting to health boards the value of signing up to the College s service quality and accreditation projects, which ensure that mental health services are supported through learning and benchmarking by a process of peer review and the provision of detailed reports. The consultation document states that the standards of care should be focused on meeting the person s needs and helping the person to achieve

6 the outcome they desire. It is important to be mindful that some people may lack capacity or an ability to understand what is in their best interest. Not everyone has the ability to make a choice or indeed make the correct choice. This is correctly raised in paragraph 66. We believe that for these people, their needs must be collectively agreed and communicated to everyone involved in their care Joint Investigation of Health and Social Care Complaints The Welsh Government believes that requiring different organisations to work together to investigate complaints will make it easier for people to complain when their complaint is about both health and social services. We also believe it will encourage organisations to learn lessons to improve their services. Do you support this proposal? Yes because in community mental health teams (CMHTs) health and social care staff already work alongside each other. Where complaints are raised they are investigated jointly by health and social services teams. This could be held up as examples of good practice. What further issues would you want us to take into account in firming up this proposal? When working in a multidisciplinary team there must be one person accountable for the conduct, outcome and lessons learned. We would recommend viewing what is already being done in community mental health teams. It is also noted that a vast amount of organisational effort is expended in the investigation process and not enough learning activity takes place to support the organisational learning process. It would be useful for the HEIW to be linked into the process to provide guidance on educational follow-up to learn from investigation findings. Chapter 4: Effective Citizen Voice, Co-production and Clear Inspection 4.1. Representing the Citizen in Health and Social Care The Welsh Government believes that local health and social care organisations should be working with the public to co-design and co-create services and that the way they do this needs to be independently monitored. We propose replacing the

7 current statutory CHCs and their functions with a new national arrangement to represent the citizen voice in health and social care, to advise and provide independent assurance. The new body will work alongside Healthcare Inspectorate Wales and Care and Social Services Inspectorate Wales and have autonomy to decide how it will operate at local level. Do you support this proposal? Can you see any practical difficulties with these suggestions? It could be argued that the abolition of CHC led to a dilution of the citizen voice in health and social care. With any reorganisation the importance of the citizen s voice must be a key priority. It would be important to emphasize the arms length relationship of the new body and include a link to the HEIW (Health Education Improvement Wales) Co-producing Plans and Services with Citizens The Welsh Government believes that introducing an independent mechanism to provide clinical advice on substantial service change decisions, with advice from the proposed new citizen voice body, will encourage continuous engagement and increase the pace of strategic change through enabling a more evidence-based, transparent process and a more directive and guiding role on the part of Welsh Government. Do you agree with this proposal? Yes, we agree with this proposal. Service change should be designed by a collective group comprising both service users and service providers and it must be evidence-based. Mental health services have changed significantly in recent years, possibly more so than any other health service. A lot can be learnt from these changes with the closure of large-scale asylums to community-based care. Some of these changes have resulted in fragmentation of patient journeys and continuity of care. There is fragmentation in physical and mental health, substance misuse and mental health, community teams and crisis teams, emergency departments and crisis teams, primary and secondary care mental health services, hospitals and social care. Fragmented services are often poorly coordinated and communication is compromised. Mental health services are very hard to navigate for both the providers and the patients. The College believes that there are still opportunities for further improvements. Although there have been vast improvements to patient care, mental health and learning disability services are still designed to enable good clinical outcomes but has resulted in fragmentation and fails to take

8 the patient s experience in account. There must be a voice in the Local Health Boards from mental health and intellectual disability. What further issues would you want us to take into account in firming up this proposal? 4.3. Inspection and Regulation and single body The Welsh Government believes that ensuring a clearer underpinning legislative framework for HIW will help to foster closer integration and joint working with CSSIW and at the very least this should be taken forward. What do you think of this proposal? Are there any specific issues you would want us to take into account in developing these proposals further? Joint working of health and social services in mental health is already established. This is sensible. Linking up the role of HIW with the HEIW would provide a mechanism for more systematic dissemination and implementation of learning identified by the work of HIW and CSSIW. However we also believe there could be merit in considering a new body for example, a Welsh Government Sponsored Body to provide more independence in regulation and inspection and citizen voice. Would you support such an idea? What issues should we take into account if this idea were to be developed further? Health and social care cultural values are different and these need to be addressed. We would ask, how would the interaction between the multiple independent bodies, proposed to be set up, be coherently coordinated?