White Paper: Services fit for the future A response from Aneurin Bevan Community Health Council 1
Contents Forward 3 Page no Chapter 1: 4 Board membership and composition 4 The role of the Board Secretary 5 Chapter 2: 6 Duty of quality 6 Duty of candour 7 Chapter 3: 8 Setting and meeting common standards 8 Joint investigations of health and social care 8-9 Complaints Chapter 4: 10 Representing the citizen in health and social care 10-15 Service change Co-producing plans and services with citizens 15-16 Inspection and regulation 16-17 CHC proposal for the new organisation Appendix 1 Aneurin Bevan CHC Operational Plan Appendix 2 Aneurin Bevan CHC Annual Plan 2016/17 Appendix 3 2
Forward It gives me great pleasure in presenting Aneurin Bevan Community Health Council s response to the white paper, Services fit for the future. Aneurin Bevan Community Health Council understands that as an organisation, changes are needed to future proof the patient s voice in Wales. We welcome many of the changes proposed within the white paper, such as bringing health and social care together in order to ensure a seamless process and in developing an organisation that will strengthen the citizen s voice in Wales. As an organisation we are concerned that the white paper is suggesting an over reliance on legislation to deliver its policy aspirations and is also looking at aspects of the Scottish Council in developing a new organisation whilst being criticised by its own parliament. Aneurin Bevan Community Health Council believes that a new organisation is needed, but feels that it is imperative that it has the appropriate key functions in order to provide the citizens of Wales with a stronger voice. Aneurin Bevan Community Health Council would welcome the opportunity to work with Welsh Government in the future on developing a new organisation. Angela Mutlow Chief Officer 3
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? NO What further issues would you want us to take into account in firming up these proposals? The White Paper s proposals claim that there are two options for the appointment of Board members 1) core membership set out in regulations for elements of consistency and elements of flexibility for the appointment of executive members and 2) Allow Boards to decide on almost all the executive members themselves, apart from one or two. Option one s conclusion states that this could be unpopular and the second option concluding that consistency across health boards would inevitably be sacrificed. From these statements it is unclear whether the proposals offer enough detail to evidence the benefit of either option for us to make an informed decision. Furthermore, the questions for these proposals do not directly ask for feedback on these options but state that Board membership should probably include some key positions and should be consistent but also allow some flexibility. These statements again do not give sufficient assurances that Board membership will be consistent as the words probably and flexibility give rise to Board s each having different variations in the Board membership in line with their differing priorities. It is therefore difficult to understand how consistency, which appears to be the ultimate goal, will be achieved through the implementation of these proposals. Whilst we agree with the ethos of the proposed 11 core principles, we have concerns 4
around how the independence of the public members will be any different from the current independent members, and how a change in their title will achieve greater perspective of the population than already exists. Until clarity is offered on the benefits of either option 1 or option 2 plus the clarity around how the public member will be any different to the existing independent members, we cannot agree to 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? NO What further issues would you want us to take into account in firming up these proposals? The Aneurin Bevan CHC holds the role of Board Secretary in the highest of regard as we believe they currently uphold the high standards of strong governance within the Aneurin Bevan University Health Board. The White Paper s proposals are unclear around whether this position would, in the future, remain an NHS appointment or a Welsh Government appointment, given that the White Paper states an independent process should be put into place to dismiss a Board Secretary, it does not state at all whether their appointment would also be subject to the same independent process. If it remains an NHS appointment, how will these proposals and potential statutory protection offer adequate assurances of independent scrutiny of the Health Board or NHS? If it is to be a Welsh Government appointment, then this avenue suggests a Welsh Government officer will be working within an NHS remit which may give rise to accusations that the NHS will not be sufficiently independent from the operational scrutiny of Welsh Government. 5
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? Yes but we require some assurances What further issues would you want us to take into account in firming up these proposals? We agree that the Duty of Quality (and Planning) should indeed be updated to reflect the proposed integrated shape of Health & Care Services and population expectations. There should be reciprocal duty placed on Health and Care Services to co-operate and work in partnership to improve quality. If agreed following the outcome of this White Paper, we require the assurance that as a measure to meet public expectation, consultation and engagement with the public will be undertaken to ensure that their perspective on quality and planning is fed directly into the updated duties placed on Health and Care organisations. This would ensure that the public are truly involved in the co-design and co-production of services and those services truly understand their realistic expectations. Also, the updated duties should clearly set out processes for (the unlikely events) that the Health and Care organisations fail to work collaboratively and fail to agree on reasonable project goals. Furthermore, avenues for the public to challenge Health and Care Services during the decision making processes needs to be clear and accessible. As the White Paper stands, it is unclear how Health Boards and Local Authorities will balance national or regional priorities and needs against conflicting local views and wishes. We recognise that during times of national or regional service reconfiguration or development, difficult decisions will need to be made and those decisions will be unpopular with different areas in some way or another. At present, Community Health Councils are involved in local, regional and national processes to ensure that the public s voice and view on the quality and planning of Health Services is taken into consideration (example being the CHCs involvement in the South Wales Programme), CHCs also ensure that communication with the public on service options is clear so the public are adequately informed on the reasons for regional and national focus. We believe the proposed new Citizen s Voice body (Chapter 4) 6
should hold statutory rights to be involved with Health and Care Services to represent the public on matters around the quality and planning of Health and Care services. 2.2. 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 but assurances and clarity are required on some aspects What further issues would you want us to take into account in firming up this proposal? The White Paper rightly refers to the NHS s Putting Things Right Procedure which places a duty on the NHS in Wales to be open, transparent and honest when health incidents occur, whether they are identified through the submission of complaints or identified by members of staff when undertaking their duties. Extending this duty to social services is a clear necessity. Lessons can be drawn from the implementation of the Duties of Candour in England and Scotland to learn from good and bad experiences when attempting to encourage a culture change in multiple public service organisations. It should be clear who the responsible body will be to ensure that a culture of openness, transparency and honesty is being achieved and how it will be monitored; will it be Healthcare Inspectorate Wales, Care and Social Services Inspectorate Wales, both or neither? We recognise that culture changes are not achieved straightway and there should be one monitoring body in place to be responsible for assessing Health and Care organisation s commitments to the Duty of Candour. It s imperative that any Duty of Candour being developed (or being built upon) in Wales should itself be clear and accessible for public and staff understanding and the requirements should (as far as possible) be jargon free and be in plain language. Training days for staff should be developed to encourage the open and honest reporting of incidents. It should also be clear that a duty of candour not only covers the reporting of incidents but also encourages openness and transparency on all levels, including Executive/Board decision making. The ethos of the Duty of Candour should encourage learning and improvement to better staff and service user experiences, rather than harbour any negative connotations that are perceived to be attached to Whistle-blowing. 7
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 What further issues would you want us to take into account in firming up this proposal? We believe that the public expects clear and meaningful standards that apply wherever and whoever provides their care. Any such standard should be informed by and reflect what is important to the public. We recognise that there may be a need to address the imitations within current regulations that specify what standards must be followed. We feel it is important that any new legislation is framed in a way that allows flexibility and adaptability to meet the future expectations. 3.2. 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 but assurances are required What further issues would you want us to take into account in firming up this proposal? Joint investigations between Health and Social Care to ensure a seamless complaints investigation makes clear sense and the Aneurin Bevan CHC welcomes this proposal but we require clarification/reassurance on a few points. This proposal is in line with the Social Services & Wellbeing (Wales) Act 2014 part 10 Complaints, representations about Social Services. However, we query if the Social Care aspects of any complaint submitted would be subject to the same principles of the NHS s Putting Things Right Procedure 2011 and whether proven social care failings or breach of duties in care where harm has been caused will be subject to the same investigation/panel review for assessing whether a qualifying liability in tort exists. We believe that this level of investigation and legal responsibility should be transferred to the Local Authority complaints procedures so that complainant outcomes are not negativity impacted upon when the organisation at 8
fault (whether NHS or Local Authority) has been identified. Currently, the Community Health Councils in Wales offer a free and professional Independent Complaints Advocacy service for NHS complaints. The Aneurin Bevan University Health Board have stated that complaints where a CHC Advocate is involved, is a smoother and less stressful process for clients and staff, as the CHC Advocates assist and guide patients/relatives through the correct processes to ensure their complaint is addressed fairly and through the correct channels. If in the future, joint investigations between Health and Social Care are realised, we believe that the new Citizen s Voice body should take on the existing Complaints Advocacy Service and support it to integrate Health and Social Care complaints. This will ensure the public feel greater reassurance that the advice and support they receive will be through a truly independent, citizen focused body. 9
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 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? NO Can you see any practical difficulties with these suggestions? Aneurin Bevan Community Health Council supports the development of a new Citizen s Voice body. However we feel that the White Paper s proposals do not give sufficient detail or information on the plans, expectations or role for the new Citizen s Voice body which is intended to replace Community Health Councils and have concerns that the proposals set out in the white paper have the potential to significantly weaken the citizen s voice rather than strengthen it. We believe that the White Paper lacks assurances around the ability of a new Citizen s Voice to be able to represent the public with any form of legal strength that would ensure services are held to account and service standards are kept under review from the public s point of view. We set out our concerns below: 1. The White Paper states that currently CHCs are limited in cross-boundary working due to their attachment to a particular geographical area and population and this presents challenges. The White Paper therefore wishes to strengthen the voice of people in the way that health and social care is planned and delivered by setting up a new arrangement which will have national and local focus. We feel the first statement is inaccurate and can evidence a number of cross-boundary working initiatives to address local, regional and national issues, the principles of which should underpin the new Citizen s Voice body: The Consultation for the South Wales Programme 2013 this looked at options for the future of consultant-led Maternity Services, Neonatal Care, Inpatient Children's Service and Emergency Medicine (A&E) at hospitals in South Wales. It spanned the regional areas of Abertawe Bro Morgannwg, Aneurin Bevan, Cardiff and Vale, Cwm Taf and Powys also working with the 10
Welsh Ambulance Service to create safe and sustainable hospital services for people living in South Wales and South Powys. All CHC s across South Wales and the South of Powys were involved in this consultation event between May July 2013 and worked with the Health Board s to gather the public s view and wishes for the future of these Services across South Wales. Each event was represented or chaired by paid CHC officers or volunteer members to assist in the public engagement. http://www.wales.nhs.uk/sitesplus/documents/1077/swp%20update%2034% 2015-04-14.pdf Welsh Government s Planned Care Board The Aneurin Bevan CHC was approached in 2015 by the Clinical Lead for the WG s Planned Care Board and asked to develop a national patient survey that would be used to gather the patient experience through the whole for a clinical pathway from referral to follow-up treatment for Ophthalmology, ENT, Urology, Radiology and Orthopaedics. Aneurin Bevan CHC developed and piloted the whole patient pathway survey in Aneurin Bevan University Health Board s Ophthalmology Service. The surveys referred to as PREMS (Patient Recorded Experience Measures) were designed to ask patients the same questions across Wales at certain trigger points throughout their care and treatment. These standard surveys were developed by the Aneurin Bevan CHC for the Planned Care Programme Board and piloted for national use in order to measure patient experiences across the whole of Wales. This project was set up and directly worked towards the principles of the Prudent Healthcare Programme to move services toward patient centred care and involvement in the co-production and co-design of service improvement. The Board of CHCs then set, as part of their annual plan, 5 national projects for 2016/2017 for each of the 7 CHCs to participate in: Ophthalmology Patient Experience Review, Care of the Elderly, Dementia, Child and Adolescent Mental Health Services and Adult Mental Health Services. The Aneurin Bevan CHC led on the national Ophthalmology Patient Experience Review. The Wales-wide survey (using the PREMS surveys) was conducted by all CHCs in Wales, and gathered national feedback. The report then fed directly into HIW s National Ophthalmology Thematic Review, whilst they looked at clinical experiences and standards, the CHC s patient experience review informed their review at Stage 1 to offer patient-led guidance for their stage 2 review going forward. Not only does this demonstrate national scope but also collaborative working with HIW. 2. The Citizen s Voice should be independent in order to gain the trust of the public and to ensure that the public are able to voice their concerns regarding Health and Social Care services. The White Paper proposes an independent body, however, it then states the body will work alongside Healthcare Inspectorate Wales and Care and Social Services Inspectorate Wales and the Care and Social Services Inspectorate Wales and work closely with them. We want these bodies to be organised in such a fashion that they can take a unified approach when required, for example, through joint planning or advisory structures, but similarly can continue to operate independently of each other when necessary. This proposal is a contradiction to the White 11
Paper s intention to develop an independent body, as an independent body should work in collaboration with other organisations, not work alongside them. Furthermore, the independence of the Citizen s Voice body should not be set up under the premise of a Welsh Government Sponsored Body as this too diminishes the Body s integrity and credibility as this proposal also infers a lack of independence. 3. The White Paper states that CHCs currently "duplicate" the work of Healthcare Inspectorate Wales (HIW) and therefore the CHCs statutory right to enter and inspect should be removed when developing the new Citizen s Voice. We believe the public and the NHS in Gwent feel reassured that the Community Health Council can enter NHS areas to visit not inspect services to ensure that the patient voice is heard and acted upon. HIW as the regulators inspect NHS services from a clinical perspective, when they inspect a ward they look at patient notes, ensure that risk assessments, fluid charts, medication charts are all in order and complete to their fullest. They look at clinical adherence to national and local policies and also look at staffing resources and pressures etc. For example, recent GP inspections, HIW may only survey around 8-10 patients on the day of the visit as clinical focus is their priority. However, when the CHCs conduct GP visits, they send the surveys out two weeks prior to visiting day (approx. 100+ surveys) and surveys on the day to enable a greater snapshot of the patient experience, which is the CHC s primary focus. Last year HIW undertook 32 inspections within the Gwent area, Aneurin Bevan CHC undertook 119 visits, all the reports of which generated an in-depth reply or action plan from the Health Board (whom welcome our reports) to improve the patient experience. These reports and action plans are all shared with HIW inspection manager at the time for intelligence sharing and for the specific purpose of not duplicating work on specific topics. In the current model of Community Health Councils, we do visit the same hospital wards as HIW (not on the same day) but again from a holistic and patient experience point of view. Currently, CHCs looks at the environment in which the patient resides, support at mealtimes, linen availability to ensure there are appropriate levels of towels, gowns, bedding and blankets etc. Staff attitudes towards patients and the level of communication offered to patients to be able to understand their conditions, treatment plans and ability to ask questions. This is a person centred visit. Some tangible examples of Aneurin Bevan CHC s interventions includes: The movement of the GP Alternative Treatment Centre (ATC) for excluded Primary Care patients based previously in Maindee Police Station in Newport, to a dedicated clinical room within St Woolos Hospital Newport, whilst still maintaining a police chaperone. The previous room provided at Maindee Police Station was simply equipped with a desk and two chairs, there was no clinical examination couch or hand wash basin in the room. Should a patient require further medical review they would simply be referred to the hospital and face waits and delays for medical attention. The clinic there ran every Friday throughout the day and had poor attendance levels. Following the 12
Aneurin Bevan CHC s visit to the site (coverage given in the South Wales Argus) the clinic was moved to St Woolos Hospital to improve both the patient experience and clinician experience. Since its movement, attendance and use of the service has increased because patients no longer feel criminalised by the need to attend a police station for medical attention. This demonstrates that; when undertaking our statutory duties, the Community Health Council fought for a fair service to people who had been excluded, despite patients' negative behaviours, everyone deserves and is entitled to medical services that are delivered in an environment that is fit for purpose. HIW do not represent the patients' interests to this extent. If the new Citizen s Voice body is unable to visit sites and look at these issues, their purpose will quickly diminish and little faith will be placed in them to be able to fight for equitable services. On wards the Aneurin Bevan CHC s impact can be demonstrated further via the outcomes they achieved on Annwylfan Ward in Ysbyty Ystrad Fawr. This ward is a dedicated Dementia unit. When it first opened, little consideration had been made around it being a Dementia Friendly Environment (DFE) e.g. The day room floor was blue with white speckled stripes. The patients therefore believed that the floor was wet and avoided using the day room, some patients had been witnessed attempting to dry the floor with tissues. There were no hand rail supports in corridors for patients to hold on to should they be at risk of falling. These are just two examples of many issues we highlighted on this ward. Because the CHC were able to mobilise their volunteer membership quickly, and visit so frequently the Health Board produced a comprehensive action plan to address all issues we had raised and then consulted with dementia experts to improve the environment, like colour coding doors to differentiate between toilets and bedrooms etc. Levelling off the garden area to remove any trip hazards. HIW do not look at these aspects and do not follow up on visits as frequently as the CHC does to monitor progress. HIW and CHCs may visit the same wards/gp sites, but they focus on completely different aspects of care. The White Paper wishes to strengthen the "citizen's voice" by removing the Citizen s Voice statutory power to visit patient and public services. This will only weaken their position and ability to represent the citizens of Wales. Therefore, there is no duplication of work, simply a different focus, which both Bodies conduct well, one as the Welsh Government s regulator and one as the independent patient voice. This separation instils the much required credibility that patients seek from a Body set up to represent their needs and should be adopted into the new Citizen s voice. It is paramount that the Citizen s voice retains this statutory function as we believe that statutory powers and rights will give the future model the strong citizen s voice that is required to hold NHS and Social Care services to account. 4. The White Paper has proposed to make the new Citizen s Voice an "advisory body" with regards to service changes and base them in some respects around the Scottish Health Council (SHC) model. During research the CHC has found that the SHC does not have any statutory powers to protect the 13
citizen's voice with regards to NHS service changes and it is currently under review by the Scottish Government as it is deemed "unfit for purpose". During the Consultation Institute s conference in Cardiff, which focused on the proposals set out within this White Paper, the Chief Executive of the Scottish Health Council gave a presentation on their role and remit to give a better understanding of what their structure and purpose could mean for the public in Wales. The Chief Executive explained that they do not currently speak for (or protect) the patients or public in Scotland with regards to Healthcare service change proposals, their purpose is to quality assure the [consultation] process as it develops, they do not voice or consider the feedback received from the public on any proposed changes. The SHC does not hold a view or opinion on the proposed changes or the decisions made but simply ensures the NHS follow a specific service change consultation pathway. Community Health Councils in Wales also do this, but we also focus very heavily on the patient/public voice and the potential impact on them and their wishes. The Scottish Health Council monitor processes for adherence only and do not follow-up on agreed service changes to ensure that what was proposed and agreed, is eventually delivered for the benefit of patients, which Community Health Councils in Wales do via their Scrutiny Committees and annual visiting schedules. The Chief Executive of the SHC stated that he believes their inability to represent the patients voice is a gap in their process and they want more of a role in expressing what the public think. The SHC therefore holds more of a governance role in service change proposals and don t speak for patients. In conclusion to this point, we are deeply concerned by Welsh Government s intentions to strengthen the voice of the people by shaping some aspects of the Citizen s Voice body for Wales on the model currently in place in Scotland, who themselves have stated, they do not currently represent the interests of the public in health or social care. The White Paper is proposing that the NHS itself will determine whether a service change is "substantial" or not and therefore will be able to set its own course of action to implement a service change. Whilst approaching the newly developed Citizen s Voice body afterwards and deciding, without any obligation, whether or not to take the Citizen s Voice body s advice into consideration. Again this will only weaken the Citizen s Voice body s position and ability to protect the public voice and ensure it is heard and listened to. 5. Scrutiny of Services Currently, Aneurin Bevan CHC analyse daily NHS performance data from Ambulance response times, A&E handover times, A&E waits and delayed transfers of care and referral to treatment times. At the moment the NHS is obligated under the CHCs statutory powers to answer and address any concerns brought to their attention about patient waits. For example: On a daily basis the Aneurin Bevan CHC's senior management team receive and review Stroke patient waits in the Royal Gwent Hospital and Nevill Hall Hospital A&E depts. to ensure timely transfer and medical intervention (within 15 minutes). The Aneurin Bevan CHC challenges the Health Board on any 14
long waits or trends/peaks in delayed waiting times. This data also feeds directly into any complaint trends dealt with via the CHC Advocacy Service and will highlight areas of concern via this route also. This again demonstrates the need for the new Citizen s voice body to retain remit over the scrutiny of services and the Citizen s Complaints Advocacy Service. We are concerned that the White Paper does not cover or explain this aspect of the CHC's current work but describes it as a new function of the Board Secretary who is based within the Executive Team of the Health Board itself. This proposal therefore takes independent analysis of patient waits away from the Citizen and intends to place it within the remit of an NHS employee. We believe that when developing the new model for the Citizen s Voice, this analysis and statutory remit must be done by an independent citizen focused body. If this is removed, it will again weaken the Citizen s Body s ability to challenge the NHS and Social Care services on the citizen's behalf. We hope that any proposals going forward take deep note of our response set out above and protect the strength of the citizen's voice in Wales and ensure that the new Citizen s Voice body has statutory powers and rights. If statutory functions are not placed within the new citizen s voice body, there will be no obligation on any Health or Social Care body to engage with the new organisation on any meaningful level and will only weaken their position in the Community that they serve. The public will also feel that the Citizen s body lacks the "clout" to be able to represent them and hold the service providers to account if they are simply an advisory body. 4.2. 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? NO What further issues would you want us to take into account in firming up this proposal? The White Paper s proposals to create an independent mechanism to provide clinical advice on substantial service decisions, with advice from the proposed new citizen s voice body suggests that the public will no longer have a statutory right to be consulted with on NHS service changes as set out in the NHS (Wales) Act 2006 section 183, which states that; the public or their representatives have the right to be involved in; the planning of provisions, the development of proposals and the decisions being made around service changes. 15
The White Paper suggests that the new citizen s voice body will be approached for advice after substantial service change decisions have already been made. The White Paper does not explicitly state whether an amendment to the NHS (Wales) Act 2006 will be made in order to remove these rights from the public. Currently, Community Health Councils do receive clinical analysis and advice on service change proposals very early on the proposal development stages. We believe that these statutory rights should continue into the new citizen s voice body. 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? Whilst the proposal of creating a clearer underpinning legislative framework for HIW is acceptable, there is no clear indication within the proposals of how this will lead to more integration and closer working between HIW and CSSIW. Are there any specific issues you would want us to take into account in developing these proposals further? The White Paper appears to suggest that simply working to a similar framework will promote more integration between HIW and CSSIW. This ideal is simplistic and the way in which the two inspectorates are required to work jointly requires greater exploration before the proposals can be developed further. 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? NO What issues should we take into account if this idea were to be developed further? It is accepted that housing the existing inspectorates within a new Welsh Government Sponsored Body has the potential of bringing more independence from the Welsh Assembly Government. The pooling of resources and creation of an integrated system are notions which the Aneurin Bevan Community Health Council would certainly agree with. However, the proposals provide no clear explanation of how the new system would work. The difficulties of incorporating the existing inspectorates into a single new body whilst retaining the independence of each inspectorate body are complex. Ensuring governance and accountability arrangements are adequate and robust, 16
while allowing for each individual body to retain its independence is essential and there is no guarantee within the proposals that this is achievable. This model of incorporating the inspectorate within an overarching and independent body is currently found in Scotland with the Healthcare Improvement Scotland model where it has been found that it is difficult to maintain the independent identity of each inspectorate. Therefore, we are concerned that by pursuing independence from the Welsh Government, the proposals will in fact decrease the independence of each inspectorate contained within the new body. 17