SUBMITTING EVIDENCE TO A SCOTTISH PARLIAMENT COMMITTEE DATA PROTECTION FORM Name: Ruth Balmer Date: 1 August 2018 Organisatin: (if required) Tpic f submissin: BDA The Assciatin f UK Dietitians, Sctland Bard Health and Care (Staffing) (Sctland) Bill I have read and understd the privacy ntice abut submitting evidence t a Cmmittee. I am happy fr my name, r that f my rganisatin, t be n the submissin, fr it t be published n the Scttish Parliament website, mentined in any Cmmittee reprt and frm part f the public recrd. I understand I will be added t the cntact list t receive updates frm the Cmmittee n this and ther pieces f wrk. I understand I can unsubscribe at any time. Nn-standard submissins Occasinally, the Cmmittee may agree t accept submissins in a nn-standard frmat. Tick the bx belw if yu wuld like smene frm the clerking team t get in tuch with yu abut submitting annymusly r fr yur submissin t be cnsidered but nt published. It is fr the Cmmittee t take the final decisin n whether yu can submit in this way. I wuld like t request that my submissin be prcessed in a nn-standard way.
HEALTH AND SPORT COMMITTEE HEALTH AND CARE (STAFFING) (SCOTLAND) BILL SUBMISSION FROM BDA Sctland Bard The Cmmittee is seeking views n the Health and Care (Staffing) (Sctland) Bill. Specifically, the Cmmittee is seeking views n the fllwing questins: 1. D yu think the Bill will achieve its plicy bjectives? The BDA Sctland Bard welcmes the Bill s aim t prvide safe and high-quality services. Hwever, we cnsider achievement is nly pssible currently fr nursing services as the mechanism and necessary measures d nt exist fr ther services. We believe the Bill can nly be implemented fully, and in a way which will imprve the quality f care that patients receive, if there is significant investment in develping methdlgies which will allw fr imprved multidisciplinary wrkfrce planning. 2. What are the key strengths f: Part 2 f the Bill? The BDA Sctland Bard welcmes the prpsal that NHS Sctland has a legal duty t ensure apprpriate staffing. In particular, we supprt the requirement that each Health Bard has a duty t ensure at all times suitably qualified and cmpetent individuals are wrking in such numbers as are apprpriate fr health, wellbeing and safety f patients and prvisin f high quality care. The BDA Sctland Bard recgnises and applauds the requirement that Health Bards have a duty t fllw a cmmn staffing methd where the necessary tls are available. We als value the recgnitin given t necessary staff training and cnsultatin. Part 3 f the Bill? The BDA Sctland Bard welcmes the prpsal that Care Service prviders have a legal duty t ensure apprpriate staffing. We supprt the requirement fr all thse prviding a care service t ensure at all times suitably qualified and cmpetent individuals are wrking in the care service in such numbers as are apprpriate fr health, wellbeing and safety f patients and prvisin f high quality care. The BDA Sctland Bard supprts the duty that thse prviding care services have t ensure individuals wrking in the care service
are apprpriately trained and supprted in acquiring qualificatins apprpriate t their rle. We appreciate the intentin t develp staffing methds fr thse prviding care hme services fr adults and ther care services. We als appreciate the detail n the need fr this develpment t be cllabrative and the requirement fr thse prviding services t use the staffing methds. 3. What are the key weaknesses f: Part 2 f the Bill? The BDA Sctland Bard are extremely cncerned that Allied Health Prfessins (AHPs), which includes the Dietetic prfessin, are missing frm the Bill. The Bill under part 2, appears t have its sle fcus n the nursing prfessin, there is n mentin f ther prfessinal grups. The example given f evidence f link between safe staffing and delivery f high quality care is nursing. What abut the rle f AHPs including Dietitians in the delivery f quality care? Particular apprehensin relates t 121C(2) which states, includes ther persns prviding care fr patients and acting under the supervisin f, r discharging duties delegated t the persn by, the registered nurse, registered midwife r medical practitiner. Dietitians are autnmus practitiners wh d nt wrk under supervisin f nurses r medical practitiners. The cmmn staffing methd requires the use f staffing tls, therefre the methd can nly be applied where such tls exist. The BDA Sctland Bard cnsider the primary fcus f the Bill shuld nt be n specific mandatry tls which in themselves cannt deliver safe and high-quality care. Instead, we wish the key fcus t be n methdlgies t achieve the verarching aim f the right staff with the right skills in the right place at the right time. As staffing level tls are currently nly available fr the nursing prfessin, we regard listing specific tls in primary legislatin inapprpriate as it culd impede innvatin in wrkfrce planning and lead t inequality f pprtunity. The BDA Sctland Bard recgnises the Bill des permit the creatin f new tls where necessary and sets a mechanism t develp new tls. Hwever, we are cncerned there is n cmmitment t develp such tls fr AHPs including the Dietetic prfessin and als a cmplete lack f timescales fr develpment and implementatin. The BDA Sctland Bard asks fr acknwledgement that the develpment f staffing tls t cver all necessary NHS staffing grups will take significant time and financial cmmitments. We want cmmitment t be given fr develpment f tls fr all prfessinal grups alng with apprpriate and dedicated timescales. We request the establishment f a statutry duty n an apprpriate agency such as Healthcare Imprvement Sctland t scrutinise
and advance the cmmn staffing methd, including tls, t reflect develping evidence n the staffing mix and levels which are prven t deliver the best (statutry) utcmes. Part 3 f the Bill? The BDA Sctland Bard are apprehensive the Bill des nt take accunt f multi-disciplinary and multi-agency wrking, particularly in relatin t staffing in and fr care services. The wider multidisciplinary team needs t be accunted fr including thse nt emplyed directly by the care prvider, e.g. AHPs including Dietitians prvide an invaluable rle t the assessment and care prvisin in nursing and residential hmes, day centres etc. Multidisciplinary staffing methdlgies and tls need t be develped. Prfessinal leaders fr this task need t be multi-prfessinal nt just nursing. 4. What differences, nt cvered abve, might the Bill make? (fr example: will the Bill have any unintended cnsequences, will it ensure that staffing levels are safe, des the Bill take accunt f health and scial care integratin, hw are 'safe and high-quality' assured/guaranteed by the Bill?) The BDA Sctland Bard are cncerned there may be a number f unintended cnsequences f the Bill. Namely, cncerns the Bill may result in a multi-tiered system if a whle systems apprach is nt taken. There are risks f resurces being drawn frm ne service t anther. This risk has been identified in previus cnsultatin respnses, hwever the Bill needs t clearly identify hw this risk will be actively managed. Nursing tls have been develped ver a number f years with investment f cnsiderable time and resurce will the same effrt and investment be available / recgnised fr ther grups? Cmmitment t the develpment f ther tls is required with all health and care settings cvered. Key persnnel in each sectr f health and care need training n the develpment f tls. Accurate and realistic timescales fr the develpment and implementatin f such tls is crucial. There is a risk f the Bill lking at individual staff grups in sils and missing ut n the value f multidisciplinary team wrking. Determinatin f staffing must cnsider as well as the mix f prfessins needed, the skill mix within each prfessin. The Bill culd well result in uneasiness and affect staff mrale staff will need t be prperly supprted and their wellbeing taken int accunt. The BDA Sctland Bard acknwledge the Bill des nt actually use the wrding safe staffing, instead the guiding principles describe safe and high-quality services. The supplementary papers t the Bill d use the wrding safe staffing, therefre it wuld be helpful if all dcuments including the Bill were cnsistent n the use f terminlgy. There is a need fr the Bill t place emphasis n measurable utcmes as there is a risk f the Bill becming s prcess fcussed that is incnsistent with
the aim t imprve utcmes in relatin t safe and high-quality services. Currently there are high csts assciated with emplyment f lcum cnsultants. If the lcum situatin was addressed it wuld release significant funds t emply a wide range and mix f staff t achieve safe and quality services. There is a very real and serius risk f AHPs including Dietetics nt being given equal standing within the Bill. The nly mentin f AHPs is in the Bill memrandum under pint 93, which states general staffing duty will apply t AHPs. It is very disappinting this appears t be the sle reference t AHPs. The Bill memrandum describes the legislatin supprting lcal decisin making, flexibility and the ability t redesign and innvate acrss multidisciplinary and multiagency setting. The current tls d nt take cunt f multidisciplinary and multiagency wrking. The BDA Sctland Bard cncern is that if the fundatin is nt in place fr AHPs nce the legislatin cmes int peratin, AHP services in prviding safe and effective care, will get left behind in terms f service delivery, redesign and innvatin. The prfessin is cmmitted t wrking twards the develpment and applicatin f the necessary staffing tls and measures, hwever, this needs t be matched by adequate recgnitin f AHPs including the Dietetic prfessin within the Bill, alng with identificatin f adequate investment and a cmmitment t timescales fr delivery.