Wendy Morgan

Healthcare Standards for Wales Consultation

Quality, Standards and Safety Improvement Division

Health and Social Services Directorate General

Welsh Assembly Government

CathaysPark

Cardiff

CF10 3NQ5 February 2010

Dear Sir/Madam,

Re: Consultation – Revised Healthcare Standards for Wales

As Chief Executive for Public Health Wales I write in response to the invitation to offer comment on the above consultation document.

The document was distributed widely across Public Health Wales and I am pleased to enclose the a response and have also listed below some of the comments received:

Response

  • The reduction of standards to 28 is welcomed.
  • The revised Healthcare Standards reflect the wide range of responsibilities of the new Health Boards but can be adapted to Public Health Wales
  • Public Health Wales welcome the decision to allow the wording of the standards to be amended to enable staff to their relevance and applicability.
  • The removal of domains has removed considerable areas of overlap and duplication.
  • The linkage of the healthcare standards to the Governance e-manual is welcomed.
  • Standard 24 now includes claims along with incidents and complaints it would be useful to consider how this links in with the WRMS on Claims which also has the sections on learning and linking claims, complaints and incidents.
  • Difficult to comment further in absence of the revised self assessment framework.

I trust you find these attached response helpful, however should you wish to discuss any of the issues we have raised in this response further, please do not hesitate to contact me.

Yours sincerely

Mr Bob Hudson

Chief Executive

Enc.

Healthcare Standards for Wales

Consultation on the revision of the Healthcare Standards for Wales

Public Health Wales
Address
14 Cathedral Road
Cardiff
Postcode: CF11 9LJ
Email Address

1.Are the standards straightforward to understand and is the language clear?

Yes
No
No View
Comments:
The standards are straightforward to understand for managers, engaged clinicians and other people with an interest or involvement in the NHS. They are not easily accessible to a lay public audience.
The language used is often alien to staff working in public health as they still have a secondary care focus and the use of the term ‘Healthcare’ means that many of the standards do not apply easily to the work of Public Health Wales. Its replacement with NHS makes a big difference in applicability. Likewise, there are a number of references to patients which should be adapted to include service users.
Public Health Wales welcome the decision to allow the standards to be amended to enable staff to understand and see their relevance and applicability.
The Director for Communications has amended the Healthcare Standards to make them applicable to all NHS services, including public health. The changes made are small but will encourage Public Health Wales staff to engage with the standards rather than see them as an onerous management tool into which their work is shoe horned.
Tenses are not used consistently and these too have been amended for consistency.

2. Do you agree with the proposal to remove the four domains?

Yes / √
No
No View
Comments:
The removal of the four domains has removed considerable areas of overlap and duplication.

3. Are the revised standards more relevant for healthcare teams? Can they be used by healthcare teams to identify ways to improve quality and safety of care?

Yes / √
No
No View
Comments:
The standards appear to have been formulated in a way that allows them to be used at a health team level as well as the strategic organisational level. In addition they are entirely relevant for the independent health sector and should prove helpful in GP practices, for example in terms of benchmarking and improving services.

4. Are the standards presented in a logical sequence?

Yes / √
No
No View
Comments:
In general the standards appear to be presented in a logical sequence. However, it is unclear why safeguarding is positioned between patient feedback and environment. The suggested placement for safeguarding would be either following health protection or after safe and clinically effective care.

5. Are there any gaps or areas that are not adequately addressed?

Yes
No / √
No View
Comments:

6. Are there any comments on the individual standards you wish to make?

Yes / √
No
No View
Comments:
Healthcare Standard 1: “(a) accessible” is unclear. Does this relate to distance to services for example in rural environments, or does it relate to issues of disability?
Healthcare Standard 2: A valuable inclusion would be the mention of UNCRC to acknowledge the Rights of Children.
Where “Equality and Diversity” are referred to, notice should be paid to REc 3.2 of the Human Rights Inquiry “Where appropriate, government departments should include human rights more explicitly in the standards applied to public services”.
Healthcare Standard 3: Consideration needs to be given to including “promoting healthy lifestyles and enabling healthy choices”.
Healthcare Standard 4: Health Protection d), it is a moot point whether screening is a health protection service. It could also be defined as a Health Improvement service and could therefore appear under Standard 3. This point is reinforced by the fact that the other four paragraphs under Standard 4 fit comfortably with Health Protection services. Consideration should therefore be given to consulting with Screening staff.
With reference to health inequalities it is not clear how (a) to (e) will seek to address inequalities per se as the bullets make no reference to inequalities, targeting interventions etc.
Healthcare Standard 6: It may be worth referring to “recognised and structured methods of engagement and involvement”. It is not just about providing assurance but it is also about demonstrating, through feedback, that views have been considered.
Could Healthcare Standards 6 and 9 be closely linked?
Healthcare Standard 7: The following additional points should be included:
-ensure the needs assessment and public health advice inform service planning, policies and practices
-use NSFs, national plans and priorities to improve health and prevent disease
-ensure that services are provided to patients on the basis of equitable access dependant on need.
Under the 7a list “rehabilitation and re-enablement” should be included so that it reads:
-provide all aspects of care including referral, assessment, diagnosis, treatment, rehabilitation and re-enablement, discharge etc …..
How will the dignity and respect element be monitored? If it is reliant on complaints alone, many who feel disrespected or whose dignity is disregarded may be incapable of complaining i.e. not confident enough to make a complaint.
Healthcare Standard 8: The following inclusion should be added:
-are provided with information on any changes to lifestyle that would improve, or prevent further deterioration of their condition.
The information also needs to be understandable and clear. In terms of timeliness, information needs to be provided more than once in order for the patient / carer (for example providing information at the time of diagnosis may be appropriate but repetition at a later date may be necessary to allow for understanding and processing.)
Healthcare Standard 10: An additional point to highlight the specific role of health in safeguardingwould be helpful. For example'Provide all aspects of necessary healthcare including referral, assessment and treatment in atimely way, consistent with any national timescalesand best practice'.
It would also be helpful if feedback to health providers could separate out Safeguarding Children and Safeguarding Vulnerable Adults. This would enhance the capability of HealthBoards and Trusts to focus on the specific systemsand processes which should be addressed to improve performance.
Healthcare Standard 11: Is the standard explicit enough in referring to safety and well maintained to emphasise the need for cleanliness?
Healthcare Standard 13: “(b) within pathways” should be amended to read “(b) within pathways when clinically appropriate”.
Healthcare Standard 18: The opening statement should be amended to read “……safe and sufficient supply of blood and blood products through ….”.
Healthcare Standard 19: Effective Communication the term “effective, appropriate and timely communication” is open wide interpretation. Effective, appropriate and timely communications for one person in one situation would not be for another person in another situation. It is therefore difficult to set standards here which are genuinely meaningful.
Healthcare Standard 24: Systems for complaints should be promoted, easy to understand and be presented in a way that shows that complaints are important to service improvement.

7. Do you agree with the proposal to align, as far as possible, the National Minimum Standards, which are applicable to the independent healthcare sector, with the healthcare standards which are applicable to NHS bodies?

Yes / √
No
No View
Comments:

8. We have asked a number of questions, but are there any other issues that you would like to raise?

Yes / √
No
No View
Comments:
The revision of the standards is welcomed andthese appear to be clear, strong and fit for purpose. However, the standards, whilst very worthy and important, are meaningless without the measures needed to judge their effectiveness. The effectiveness measures will influence the process and systems necessary to ensure compliance. Therefore, the revision of the Healthcare Standards document remains only a general statement of principles and aspirations divorced from the means of achieving them.
The revision of the Healthcare Standards is also an important opportunity to take a human rights based approach and incorporate the language of human rights within them
It should be noted that there is no reference in any of the standards to achieving wellbeing.