Health and Social Care: Reform and Transformation

Health and Social CAre: reform and transformation

Getting the structures right

consultation Response Questionnaire

CONSULTATION RESPONSE QUESTIONNAIRE

Responding to the consultation

You can respond to the consultation document by e-mail, letter or fax using the this questionnaire.

If this document is not in a format that suits your needs, please contact us and we can discuss alternative arrangements.

Before you submit your response, please read Annex A about the effect of the Freedom of Information Act 2000 on the confidentiality of responses to public consultation exercises.

Responses should be sent to:

E-mail:

Written:HSC Reform

DHSSPS

Annex 1, Room1

Castle Buildings

Stormont Estate

Belfast, BT4 3SQ

Tel: (028) 90522177

Fax: (028) 90522244

The closing date for responses is 12 February 2016

Personal details

I am responding:as an individual

on behalf of an organisation

(please tick a box)

Name: / Louise Kennedy
Job Title: / Regional Policy & Information Coordinator
Organisation: / Women’s Aid Federation Northern Ireland
Address: / 129 University Street
Belfast, BT7 1HP
Tel: / 028 9024 9041
Fax:
e-mail: /

Background

On 04 November 2015, the Minister for Health, Social Services and Public Safety, Simon Hamilton MLA, announced his intention to reform the administrative structures for Health and Social Care in Northern Ireland. The accompanying document sets out the case for change and seeks views on the preferred option for reform. This questionnaire should therefore be read in conjunction with the full report.

The questionnaire can be completed by an individual health professional, stakeholder or member of the public, or it can be completed on behalf of a group or organisation.

Part A: provides an opportunity to answer questions relating to specific proposals and/or to provide general comments on the proposals.

Part B: provides an opportunity for respondents to give additional feedback relating to any equality or human rights implications of theproposals.

PART A

Q1. Do you agree that there is too much complexity in the current system and that it is not working to its optimum capacity?

Strongly agree Agree Neither Disagree Strongly disagree

Comments:
Women’s Aid would agree that the current system is complex and could be simplified and made more efficient. We believe that any exercise to reform the system should not only make it more streamlined and cost-effective, but should also aim to actively improve how the health and social care system meets the needs of its service users. We believe that an integrated system with clear levels of accountability and unambiguous means of implementing regional priorities at local level is essential to making the system work more effectively.

q2. DO YOU SHARE THE MINISTER’S VIEW THAT THE SYSTEM NEEDS TO BE BETTER AT ENABLING AND SUPPORTING INNOVATION?

Strongly agree Agree Neither Disagree Strongly disagree

Comments:
We agree that innovation should be supported, and that the health and social care system should be capable of being agile and moving with developments and evolving good practice in health and social care. We are also of the view that innovation for the sake of it is not necessarily helpful, if innovation is to be solely defined as new untested solutions, or if new ‘innovations’ are to replace services that are working well instead of enhancing them. In the context of this consultation it would therefore be useful to define what innovation means.
For example, making changes and implementing new untested solutions may be described as innovative, but it may be risky and may not result in better services or outcomes or represent the best use of public money. There is much work that has been delivered for many years which already adheres to best practice and provides the best solution for the issue at hand. In such situations, it is a matter of keeping in place what works, and effectively facilitating the evolution and development of those services to keep in line with good practice as it emerges. It is vital that all innovation and change within the health systemis thoroughly evidence-based.
Women’s Aid would also stress that funding for ‘innovation’ should not replace funding for existing core work where that work is valuable and in line with recognized good practice. Moving forward and improving the health system should be about building on what is working, changing what isn’t, and being able to innovate and change without overly cumbersome bureaucracy slowing down improvements.
We would also point out that expertisein the field in question is required to decide what innovations should be implemented and what would and would not work.To this end, consultation and partnership working with those at the front line of delivering care, including expert voluntary organisationswhich provide such services, are crucial.
Women’s Aid as an organization has supported women and their children who are affected by domestic violence for 40 years. We have continued to evolve our service provision based on the views and needs of our service users, evidenced best practice in the field of domestic and sexual violence, and the need to address emerging issues. For instance we support women and men affected by domestic and sexual violence through the 24 Hour Domestic & Sexual Violence Helpline; we have successfully worked in partnership with statutory agencies to provide innovative solutions to serious problems, such as perpetrator programmes with Women’s Safety Workers operating in parallel to tackle the issue of domestic violence; we have developedand tailored support programmes to help women recover from the complex negative impacts of abuse.
In this way we are innovative. However we also carry out workwhich has been in place for many years, such as refuge and outreach support, or advocacy and awareness-raising on behalf of victims of domestic abuse. These services may not be innovative in and of themselves, but they are absolutely vital services that could mean the difference between life and death for many women in Northern Ireland. Women’s Aid continues to innovate within the structures of service provision that we deliver, to keep up with recognized evidence-based good practice. However in these respects the fundamental nature of service we deliver has not changed, as it is recognized as what is needed. Change for the sake of it in this case would in fact be detrimental to those who use our services.

Q3. Would reduced bureaucracy in terms of HSC structures allow the system to respond more quickly to changing demands?

Strongly agree Agree Neither Disagree Strongly disagree

Comments:
Streamlining bureaucracy is an effective means of making a system more responsive to necessary change. In the case of the current health system, there are certainly improvements that can be made.
However any streamlining should not affect the quality assurance and regulation that is required to sustain a quality service that meets standards of excellence and the needs of service users. Nor should it be at the expense of processes which are in place to ensure that health policy and practice result in a health system that is grounded in equality.

Q4. Will bringing performance management into the Department help to improve lines of accountability?

Strongly agree Agree Neither Disagree Strongly disagree

Comments:
We agree that lines of accountability should be clearly established, and that they should be simplified.
In terms of performance management, the type of performance management implemented is as pertinent to this question as where performance management sits. A performance management system should be intuitive, measure only what matters and not put too undue an administrative or bureaucratic burden on those collecting data and reporting, especially if they are also involved directly in service delivery. It should also meaningfully link in with systems in place to improve service, as opposed to merely being a perfunctory box-ticking exercise.
It would be helpful if a diagram of the new proposed structures and lines of accountability was devised, to illustrate the difference between the proposals and the current model as illustrated on page 11.

Q5. The Donaldson report and the Department’s Review of Commissioning both concluded that a full, competitive commissioning process is too complex and transactional for an area as small as Northern Ireland. Do you agree?

Strongly agree Agree Neither Disagree Strongly disagree

Comments:
Women’s Aid accepts this statement. As Northern Ireland is a small area with a comparatively small population, it makes sense for a simplified commissioning system to operate.
We would also advocate reviewing commissioning processes themselves to ensure that the processes result in the best outcome for service users, particularly where specialist services are needed. There are a number of commissioning models which are specifically designed to suit specialist service commissioning, with emphasis on service designs and related specifications that are competent, cost-effective and outcome-focused.For example, Scottish Women’s Aid has developed draft guidance with COSLA, the representative voice of Scottish local government, specifically on commissioning domestic violence services.Other existing resources, such as the Hardicker model for planning children’s services, should be firmly embedded in service planning. Resources like these should be used to tailor commissioning processes for specialist services and ensure the best outcome for service users.

Q6. Do you agree that Trusts are best placed to assess local needs and should therefore have a greater level of responsibility and autonomy for planning services in their area?

Strongly agree Agree Neither Disagree Strongly disagree

Comments:
We believe that this question is more complex than a simple ‘yes’ or ‘no’.
While we agree that Trusts are in a good position to understand the local complexities of their area and understand need there, we do not believe that Trusts should have complete autonomy to separately plan services in the area for a number of reasons.
Firstly, in a place the size of Northern Ireland there will be some services that are not required to be replicated in all Trust areas. For example The Rowan SARC is based in Antrim but serves the whole of Northern Ireland. For services such as these a regional overview is necessary and it should not be for one Trust to plan and pay for such services alone if they are to service the whole of NI.
Secondly, there are some services that are required in all areas of Northern Ireland and it should not be for Trusts to decide whether or not to have such a service in their area. For example domestic violence support services are needed in all areas of Northern Ireland as domestic violence is a huge problem in all areas of Northern Ireland. Any system put in place here should not result in a scenario where services exist in some Trusts and not in others if they are needed in all areas.
Furthermore, any system where Trusts have more autonomy to make planning decisions must integrate regional requirements into them. For example, Trusts should be obligated to implement regional obligations from regional government strategies such as the Stopping Domestic & Sexual Violence strategy at local level, and there should be strong communication between regional bodies responsible for regional strategy implementation and Trusts who are making practical planning and financial decisions that would affect the delivery of such regional strategies and outcomes. Regional overview and accountability on meeting the needs of people is key, otherwise regional health strategies risk being little more than aspirational documents with no practical enforceability at local level where much of the work needs to be carried out and funded.
In summary, there must be regional communication and collaboration to ensure sufficient and consistent service provision across Northern Ireland, avoid duplication and wastage of money, and prevent a ‘postcode lottery’ of services. There should also be sufficient flexibility in any system to facilitate work carried out by voluntary sector organisationswho provide important public services.

Q7. Do you agree that these are the right structural changes to make to streamline and simplify the Health and Social Care system?

Strongly agree Agree Neither Disagree Strongly disagree

Comments:
It is difficult to answer this question comprehensively without seeing in more detail how the new system might work in practice. Any reform process should ensure that no vital functions are lost if HSCBoard is abolished. There should also be adequate staffing and resources in the remaining organisations to take on the work generated by the structural change. It would also be important to recognize that much good work is done on account of good working relationships between the HSC Board and organisations like Women’s Aid, and on account of expertise on issues built up within the Board. When looking at changes to systems, it should be borne in mind that such structures are often more than just a structure – they are people with individual fields of expertise, knowledge and understanding. If a new system is unable to identify and replicate such expertise and knowledge, this could be to the detriment of groups with certain needs such as victims of domestic violence.It would also be useful to know where other existing structures would sit within the new structure, for example the Children & Young People Strategic Partnership, and where service planning would sit in relation to these.
Any new system should result in fewer silos and more cooperative, integrated, joined-up working.Quality, safety and the effective meeting of healthcare needs should be of equal, if not more, importance than financial performance and productivity within a new system. There should be consistency across Northern Ireland, both in the services that are available to people and in the standards which those services meet.

Part B

Equality Implications

Section 75 of the Northern Ireland Act 1998 requires the Department to “have due regard” to the need to promote equality of opportunity between persons of different religious belief, political opinion, racial group, age, marital status or sexual orientation; between men and women generally; between persons with a disability and persons without; and between persons with dependants and persons without. The Department is also required to “have regard” to the desirability of promoting good relations between persons of a different religious belief, political opinion or racial group.

The Department has also carried out an equality screening exercise to determine if any of these recommendations are likely to have a differential impact on equality of opportunity for any of the Section 75 groups. At this stage, it is considered that a full Equality Impact Assessment will be required. We are waiting for some supporting information to complete the Screening. It will be published on the Department’s website when complete.

We invite you to consider the recommendations from a section 75 perspective by considering and answering the questions below. Answering these questions will contribute to the completion of the Department's Screening template and the screening outcome.

Q1. Are the actions/proposals set out in this consultation document likely to have an adverse impact on any of the nine equality groups identified under Section 75 of the Northern Ireland Act 1998? If yes, please state the group or groups and provide comment on how these adverse impacts could be reduced or alleviated in the proposals.

Yes / No
Comments:

Q2. Are you aware of any indication or evidence – qualitative or quantitative – that the actions/proposals set out in this consultation document may have an adverse impact on equality of opportunity or on good relations? If yes, please give details and comment on what you think should be added or removed to alleviate the adverse impact.

Yes / No
Comments:

Q3. Is there an opportunity to better promote equality of opportunity or good relations? If yes, please give details as to how.

Yes / No
Comments:

Q4. Are there any aspects of these recommendations where potential human rights violations may occur?

Yes / No
Comments:

Please return your response questionnaire.

Responses must be received no later than 12 February 2016

Thank you for your comments.

AnnexA

FREEDOM OF INFORMATION ACT 2000 – CONFIDENTIALITY OF CONSULTATIONS

The Department will publish a summary of responses following completion of the consultation process. Your response, and all other responses to the consultation, may be disclosed on request. The Department can only refuse to disclose information in exceptional circumstances. Before you submit your response, please read the paragraphs below on the confidentiality of consultations and they will give you guidance on the legal position about any information given by you in response to this consultation.

The Freedom of Information Act gives the public a right of access to any information held by a public authority, namely, the Department in this case. This right of access to information includes information provided in response to a consultation. The Department cannot automatically consider as confidential information supplied to it in response to a consultation. However, it does have the responsibility to decide whether any information provided by you in response to this consultation, including information about your identity should be made public or be treated as confidential.

This means that information provided by you in response to the consultation is unlikely to be treated as confidential, except in very particular circumstances. The Lord Chancellor’s Code of Practice on the Freedom of Information Act provides that:

• The Department should only accept information from third parties in confidence if it is necessary to obtain that information in connection with the exercise of any of the Department’s functions and it would not otherwise be provided;
• The Department should not agree to hold information received from third parties “in confidence” which is not confidential in nature;
• Acceptance by the Department of confidentiality provisions must be for good reasons, capable of being justified to the Information Commissioner.

For further information about confidentiality of responses please contact the Information Commissioner’s Office (or see web site at: ).

Produced by:

Department of Health, Social Services and Public Safety,

Castle Buildings, Belfast BT4 3SQ

Telephone (028) 90522177

December2015

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