1The National Board

National Public Health Service for Wales / NHS Restructuring – Consultation Response

NHS Restructuring – Consultation Response
Submitted by:Dr Cerilan Rogers, National Director
National Public Health Service for Wales
1 Charnwood Court
Heol Billingsley
Parc Nantgarw
CF15 7QZ

Date:19/06/08 / Version:0b
Status:Draft
Target Audience:Welsh Assembly Government (on final approval)
Publication Status: Public (Internet) (on final approval)
Purpose and Summary of Document:
This document is a draft ofthe formal response of the NPHS to a Welsh Assembly Government consultation oproposals to restructure the NHS in Wales.
The response contains:

the overall organisational response to the specific consultation questions posed by the Welsh Assembly Government
some additional comments from an NPHS perspective
an appendix containing responses to the consultation questions from the particular perspectives of the child protection, health protection, dental public health and pharmaceutical public health.

Introduction

1The National Board

2The Structure of LHBs

3The Management of Community Services

4Engaging People Locally

5The Structure of LHB Boards

6The Structure of NHS Trust Boards

7Support Services

8Other Comments

Appendix – Specific Responses from NPHS Teams and Services

AChild Protection Service

A.1The National Board

A.2The Structure of LHBs

A.4Engaging People Locally

A.5The Structure of LHB Boards

A.8Other Comments

BHealth Protection Team

B.1The National Board

B.8Other Comments

CPharmaceutical Public Health Team

C.1The National Board

C.2The Structure of LHBs

C.3The Management of Community Services

C.5The Structure of LHB Boards

C.8Other Comments

DDental Public Health

D.1The National Board

D.2The Structure of LHBs

D.3The Management of Community Services

D.5The Structure of LHB Boards

D.8Other Comments

Submitted by: Dr Cerilan Rogers / Date: 19/06/08 / Status: Draft
Version: 0b / Page: 1 of 13 / Publication Status: Public
National Public Health Service for Wales / NHS Restructuring – Consultation Response

Introduction

Proposals to Change the Structure of the NHS Wales have been issued for consultation by the Welsh Assembly Government. This document represents the formal organisational response of the National Public Health Service for Walesto the consultation.

This response is predicated on the planning assumption, stated within the consultation documentation, that “an integrated public health system will be created that will retain the ability to deliver public health support at national, health community and local levels”. It is further assumed that the Unified Public Health System (UPHS) will encompass all services and functions currently within the scope of the NPHS.

In parallel with, and continuing beyond, the development of an NPHS response to the consultation, the organisation is also developing its thinking as to how the NPHS (as part of a UPHS) should provide specialist public health services within the new environment that will result from the implementation of the proposals.

The structure of this document is based on the seven sections within the WAG consultation proforma. However, the NPHS believes that underpinning all seven sections should be a reiteration of the NHS commitment health and wellbeing and on improving the health of the population.

The response contains:

the overall organisational response to the specific consultation questions posed by the Welsh Assembly Government
some additional comments from an NPHS perspective
an appendix containing responses to the consultation questions from the particular perspectives of the child protection, health protection, dental public health and pharmaceutical public health.

1The National Board

The NPHS believes that:

as part of the overall proposed restructuring, the establishment of a National Board for NHS Wales is to be welcomed
an NHS Board has the potential to more effectively plan, resource and manage new models of service delivery and support more effective transfers of care from secondary care to primary and community care services across Wales
the most appropriate organisational form for the National Board would be a Special Health Authority, as this provides the clearest accountability mechanisms and basis for interaction with the wider NHS Wales
any statutory responsibility of the National Board for the protection of the public (including child protection) at a national level must be clearly defined
public health considerations should be at the heart of the planning and performance management of NHS Wales to maximise the opportunities to improve health outcomes
the planning, resourcing and performance management of the NHS by the National Board should ensure an appropriate focus on health improvement and health protection
the planning, resourcing and performance management of the NHS by the National Board should also ensure an appropriate focus on primary and community service development and delivery as well as on the delivery of acute services (taking into account the fact that approximately 90% of patient contacts with the NHS are with primary care)
the planning and performance management of the NHS by the National Board should be evidence based and appropriately informed by health intelligence, and by expert clinical advice
the functions associated with the planning, securing, and performance management of specialised services for Wales should be incorporated into the functionality of the National Board for the NHS that is proposed in the consultation
as a result of the above, the National Board will need access to specialist public health services across all public health domains
the provision of such services to the National Board should be a core function of the UPHS/NPHS
the UPHS/NPHS should be represented on the National Board
the National Board will also need access toindependent and experienced clinical and professional advice from all sectors
the National Board may need to establish specific sub groups to facilitate the planning and performance management of particular types of service that across health sectors

Specific additional responses relating to specialised areas of interest are included in the appendix (sections A.1, B.1, C.1 and D.1).

2The Structure of LHBs

The delivery of a comprehensive range of public health services to as many as 22 LHBs (in addition to other local and national stakeholders) has been a major challenge for the NPHS.

The NPHS is aware of the widely held view that, as an alternative to LHBs being reconfigured to align with new NHS Trust boundaries, LHBs and Trusts should also be merged to create ‘unified health boards’ responsible for the delivery of primary care, community and acute services in defined geographical areas.

The NPHS believes that:

public health considerations should be at the heart of decision making within the new LHBs (or unified health boards) to maximise opportunities to improve health outcomes
LHBs (or unified health boards) should retain a strong locality focus and continue to participate in partnerships with local government and other local agencies
local considerations should continue to influence the planning and delivery of services by the new LHBs (or unified health boards)
the planning and delivery of services by the new LHBs (or unified health boards) should be evidence based and appropriately informed by health intelligence
as a result of the above, the new LHBs (or unified health boards) will need access to specialist public health services provided by the UPHS/NPHS across all public health domains (Health Improvement, Health Protection, Health and Social Care Quality and Health Intelligence)
the provision of such services to the new LHBs (or unified health boards) should be a core function of the UPHS/NPHS
the UPHS/NPHS should be represented at Board level within the new LHBs (or unified health boards) by a Public Health Director
a reduction in the number of LHBs (or the establishment of 7/8 unified health boards) will greatly facilitate the delivery by the UPHS/NPHS of some specialist public health services to NHS Wales stakeholders
notwithstanding changes in NHS structures, it will be essential for the UPHS/NPHS to continue to engage fully with each of the 22 local authorities, with local partnerships and with the different agencies of the criminal justice system across all domains of public health
should unified health boards be the agreed ‘end point’ of the proposed restructuring, it would be advantageous to move straight to such an organisational solution, rather than having any form of interim structure which retained both new LHBs and Trusts
should unified health boards be established, they should maintain an appropriate focus on health improvement and health protection. The National Board should use its resource allocation and performance management mechanisms to ensure this
should unified health boards be established, they should maintain an appropriate focus on primary and community service development and delivery as well as on the delivery of acute services. The National Board should use its resource allocation and performance management mechanisms to ensure this
there would be considerable advantages in the establishment of a single LHB and a single NHS Trust (or a single unified health board) in North Wales, resulting in a total of seven LHBs/unified health boards, rather than the proposed eight

Specific additional responses relating to specialised areas of interest are included in the appendix (sections A.2, C.2 and D.2).

3The Management of Community Services

The NPHS believes that:

there are pros and cons to transferring the management and provision of community services from Trusts to LHBs
a clear definition of community services, and the resource allocation for them, may be difficult to achieve within a reasonable timeframe
there is a danger that any advantage to the transfer of community services from Trusts to LHBs could be outweighed, at least in the short term, by the disruption caused by such a transfer. Such a transfer would need to be managed carefully, with all relevant parties engaged and with an appropriate transfer of resources
the creation of unified health boards would remove the need to transfer community services from Trusts to LHBs
irrespective of the organisational ‘home’ of community services, it will be essential to ensure (including through resource allocation and performance management by the National Board) that there is an appropriate, and increasing, focus on the planning and delivery of community services
irrespective of the organisational ‘home’ of community services, it will also be essential to ensure that there are seamless interfaces between all health sectors. This is of particular importance in responding to the increasing challenge posed by the management of chronic disease, in ensuring the protection and safeguarding of children as they move between sectors and in the implementation of health protection programmes as managed networks
ensuring appropriate resourcing and leadership of community services is more important than the specific structures that are implemented

Specific additional responses relating to specialised areas of interest are included in the appendix (sections C.3 and D.3).

4Engaging People Locally

The NPHS believes that:

LHBs (or unified health boards) should retain a strong locality focus and continue to participate in partnerships with local government and other local agencies. This is of particular importance for health improvement and health protection
local considerations should continue to influence the planning and delivery of services by the new LHBs (or unified health boards)

Specific additional responses relating to specialised areas of interest are included in the appendix (section A.4).

5The Structure of LHB Boards

As stated above, the UPHS/NPHS should be represented at Board level within the new LHBs (or unified health boards) by a Public Health Director, in order to help ensure that:

public health considerations are at the heart of decision making within the new LHBs (or unified health boards)
the planning and delivery of the NHS by the new LHBs (or unified health boards) should be evidence based and appropriately informed by health intelligence and specialist public health advice
the new LHBs (or unified health boards) have appropriate access to specialist public health services across all public health domains

The overall detailed make up of LHB (or unified health board) Boards should be determined once the full remit and responsibilities of such organisations have been defined.

Specific additional responses relating to specialised areas of interest are included in the appendix (sections A.5, C.5 and D.5).

6The Structure of NHS Trust Boards

Should unified health boards be established, then the points set put in section 5 would apply. Should Trusts be retained as distinct entities from LHBs, the NPHS believes that:

having removed the commissioner/provider distinction, it will be particularly important to ensure that public health considerations are at the heart of decision making within Trusts
local considerations should influence the planning and delivery of services by the Trusts
the planning and delivery of services by the Trusts should be evidence based and appropriately informed by health intelligence and specialist public health advice
as a result of the above, the Trusts will need access to specialist public health services across all public health domains (Health Improvement, Health Protection, Health and Social Care Quality and Health Intelligence)
the provision of such services to Trusts should be a core function of the UPHS/NPHS
public health (through the UPHS/NPHS) should be represented at Board level by the Public Health Directoridentified for the equivalent LHB
the overall detailed make up of Trust Boards should be determined once the full remit and responsibilities of such organisations have been defined

7Support Services

Although the NPHS is included in the list of ‘managed/hosted’ bodies in Annex C of the main consultation document, public health is outwith the scope of the consultation question relating to a ‘single shared services body’. The future organisational arrangements for public health are being addressed separately by the Unified Public Health System Project.

8Other Comments

The NPHS believes that:

investment in the prevention of ill-health and the promotion of good health is a key priority in improving health in Wales and reducing health inequality
all new NHS structures should continue to have, and explicitly recognise, their health improvement responsibilities as a core part of their function. Change process within NHS bodies may carry the risk of the important upstream agenda receiving less priority than that afforded to NHS service delivery. This should be avoided. Similarly maintaining patient safety and high quality standards during any change process will be important (e.g. secondary prevention as in cardiac rehabilitation)
the commitment to and achievement in health improvement activity that has been made by existing NHS bodies e.g. in achieving the Corporate Health Standard, should be sustained and further improved by any new NHS organisations
good partnership working on health improvement, e.g. between LHB and LAs as part of the HSCWB strategy process, has begun to develop. Such partnership working should be sustained and further developed as a result of the changes
the restructuring process highlights opportunities to further strengthen the commitment to improving health in Wales. In considering the proposals, theUPHS/NPHS will seek to deploy its resource so as to support developments in health improvement as an equal priority to improving health and social care services, whilst maintaining its ability to respond effectively to health protection issues.
the development of local clinical governance systems and the consequent management of risk, should be built upon
it is important to highlight the potential risks to children during the anticipated period of uncertainty and restructuring within NHS Wales.During this period of change and transition, robust child protection systems must be maintained until clear lines of accountability are re-established
the restructuring of NHS Wales will require legislation and statutory guidance to be amended to reflect the new structures. This will include legislation and guidance related to child protection (e.g. Children Act 2004), health protection and emergency planning and response (e.g. Civil Contingencies Act)
the role that the various NHS bodies, including the UPHS/NPHS, will have in the response to major incidents and the appropriate membership of Local Resilience Fora and other related groups needs to be considered and clearly defined

Specific additional responses relating to specialised areas of interest are included in the appendix (sections A.8, B.8 and D.8).

Appendix – Specific Responses from NPHS Teams and Services

Note: The numbering of sub sections within this appendix is designed to relate to the specific consultation questions. As each section only contains responses to some questions, there are intentional gaps in the numbering sequence.

AChild Protection Service

A.1The National Board

In implementing the new arrangements, it will be necessary to ensure that:

the National Board holds responsibility for clinical governance for safeguarding children and delivery of Statutory functions required under Section 28 of the Children Act 2004

there are clear and unambiguous lines of accountability for safeguarding children throughout NHS Wales (including during the transitional period)
robust arrangements are in place to ensure that all NHS bodies are compliant with child protection legislation
the UPHS/NPHS Designated child protection function (Nurse, Doctor and team), which is clearly defined in the statutory guidance (under the Children Acts 1989 and 2004) would be in a position of authority to advise the National Board and the rest of NHS Wales on child protection issues
the UPHS/NPHS Child Protection Service is mandated by the National Board to continue to provide the strategic leadership to the whole of the NHS in Wales in respect of safeguarding children

A.2The Structure of LHBs

The proposed new LHBs and Trusts mustcomply with the statutory arrangements for safeguarding children, including fulfilling their duty to work in partnership (section 25 of the Children Act 2004) and listen to the voices of children (section 27 of the Children Act 2004).

1The National Board

Contents

Introduction

1The National Board

2The Structure of LHBs

3The Management of Community Services

4Engaging People Locally