Sue Evans Chief Executive, Social Care Wales By email June 21 2017 Dear Sue, Consultation: Review of Heath and Social Care Induction Framework Thank you for the opportunity to respond to this consultation on the proposed Induction Framework for the health and social care sector. As the independent voice and champion for older people, in 2014 I published a Review of the quality of life and care of older people living in care homes which highlighted a number of areas for improvement, including in relation to the workforce. Therefore, I am pleased to note the reviewed Induction Framework has taken account of the Requirements for Action made in my Review, A Place to Call Home? i I welcome also that Qualifications Wales are developing a new suite of health and social care qualifications and that the revised induction framework will mirror the core content of these new qualifications, ensuring that all new workers are provided with appropriate learning and support during their first period of employment which can also be used towards the achievement of the qualifications required for practice. My Review found that whilst many care staff are generally kind and committed and are trying their best to deliver high standards of care in a pressured environment with limited resources, increased pressure placed on care staff can result in less time to interact with residents as
they become more task-orientated to ensure that their essential core duties are undertaken. I called for values based training, which includes themes such as dignity and respect, attitudes and empathy and equality and human rights, to ensure that care staff not only fully understand the needs of older people living in residential care, but can also understand what it feels like to be an older person receiving such care. This is essential to be able to provide truly person-centred care and not simply follow a task-based approach. Therefore, I am pleased that this Induction Framework embeds a person-centred approach at its core. In addition to this, my Review recognised that the emotional and communication needs of older people living with dementia are often misunderstood and neglected, resulting in their care and support needs often being poorly understood. As a consequence, they are too frequently labelled as challenging or difficult, placing them at risk of unacceptable treatment and the inappropriate use of antipsychotics. I therefore welcome the section within the Induction Framework dedicated to caring for people living with dementia. Overarching commentary During my Care Home Review, evidence from Care Council for Wales estimated that only 60% of care staff had completed mandatory training, meaning that a significant number of care staff across Wales are delivering care without even the most basic of training. As such, I welcome the requirement within the Section 27 Regulations under the Regulation and Inspection of Social Care (Wales) Act 2016 (RISCA), which are currently being consulted on, for all social care workers to complete the relevant induction programme required by Social Care Wales within the defined timescale alongside any service specific areas. There is currently a statement in the Introduction Section of this Framework in relation to the benefits of a planned and well thought-out induction. However, it is important that it be made as clear as possible that adherence to this Induction Framework will be made mandatory for all social care workers through the implementation of the Section 27 2
Regulations. Additionally, given that the staff of regulated Independent Professional Advocacy services (which is yet to be defined by regulations under RISCA) are included within the definition of social care worker (also set out by RISCA), clarification will be needed on whether these staff will be required to adhere to this Induction Framework. If staff of regulated Independent Professional Advocacy services are required to complete the Induction set out by this Framework, the question must then be asked as to whether the Framework is appropriate for staff of such services. Also included within the Section 27 Regulations are a number of requirements that relate both directly and indirectly to the workforce. It is therefore vital that the Induction Framework mirrors the language and requirements set out in within these Section 27 Regulations. For example, the Regulations will require each individual to have a Personal Plan and for staff to deliver care and support in accordance with this. Therefore, the Induction Framework must reflect this within the relevant section to ensure staff are fully aware of their responsibilities. Whilst I am a strong advocate for the social care workforce to have the correct level of skills and competencies in order to deliver a high level of care and support that upholds older people s rights and entitlements, it must also be ensured that excellent staff who may not deem themselves as academic are not discouraged from working in the sector. A number of the sections within the Framework are high level so it is important for the emphasis to be placed on practice rather than detailed knowledge of complex legislation. As such, I welcome any plans to provide tools to help operationalise the learning within the Induction Framework. Investment in staff training along with workforce regulation will help raise the status of the social care workforce, helping make it a career of choice. However, it would be negligent to not recognise the increased level of skills that is being demanded of the social care workforce often without the appropriate remuneration. Whilst it is not in the remit of this consultation to consider staff terms and conditions, it must be a consideration for the sector if we are to retain and attract individuals to the profession. 3
As an advocate of better integration of health and social care systems, I welcome the intent for this Framework to be used as a joint framework across health and social care. However, I am unclear as to which healthcare workers will be subject to this Framework and how this will be monitored by Social Care Wales, given its remit for social care, and whether the service regulator for health will be including the Framework s content within its inspections. Requirements for Action As previously stated, I am pleased that many of the Requirements for Action made in my Care Home Review have been addressed by this Framework. However, there are some specific areas that could be further strengthened: Befriending and the need for staff to build positive relationships with the individuals they care for, helping staff see and know individuals and support their sense of identity; Positive mealtime experiences - whilst it is essential for staff to understand the importance of a balanced diet for the optimum health and well-being and for staff to understand food safety, it is also important for staff to understand that mealtimes should be a social and dignified experience with older people offered real choice and variety, both in respect of what they eat and when they eat; Emotional neglect and never events must be included in staff discussions on what constitutes abuse and neglect. Requirements under Section 27 Regulations As previously stated, this Framework must closely reflect the content of the Section 27 Regulations under the Regulation & Inspection of Social Care (Wales) Act. Whilst I acknowledge that these Regulations are currently under public consultation, the Framework will need to be updated following the passing of these Regulations towards the end of 2017. There are currently requirements within the draft Regulations that do not seem to be fully reflected in the Induction Framework. These include: 4
The requirement for staff to maintain good personal and professional relationships with the individuals that they support and care for (Regulation 20). The requirement for staff to be trained in the service s Behaviour Support Policy and Procedures (Regulation 25). The requirement for staff to be aware of their role in health promotion and the importance of health checks and activities related to health promotion (Regulation 32). The requirement for staff to understand the importance of maintenance of independent living aids (glasses, hearing aids etc.) (Regulations 39 & 40). Conclusion Since the publication of my Care Home Review in 2014, many changes to our health and social care services are underway, both at a strategic and local level in Wales, through legislation, modernisation programmes and collaborative approaches. Whilst this is to be welcomed, a key question that I will continue to ask is: are the changes underway sufficient to deliver the change that older people want and have a right to see? Care staff play a fundamental role in ensuring that older people living in care homes have the best quality of life and should be seen as a national asset to be invested in. Therefore, I am pleased that many of my Requirements for Action have been embedded within this draft Induction Framework. However, this must be accompanied by support from providers to ensure that staff have the skills, knowledge and competencies to deliver high quality care and support and that opportunities exist for continued professional development and career progression if we are to make good practice standard practice across Wales. Yours sincerely, 5
Sarah Rochira Older People s Commissioner for Wales i http://www.olderpeoplewales.com/en/reviews/residential_care_review/reviewreport.aspx 6