EQUALITY ANALYSIS AND ASSESSMENT OF OUTCOMES
Name of ‘activity’:
(Policy/strategy/procedures/services/projects/functions commissioning or decommissioning decision will be
referred to as ‘activity’ throughout the document.)
Dermatology / Skin
Date of commencing the assessment:
Date for completing the assessment:
12.12.13
1.12.14
Responsible Director/CCG Board
Member:
Mark Youlton
Directorate/Team:
Assessment Lead:
Paul Beech
Contact Details:
Acute commissioning
01282 644879
ENGAGEMENT AND INVOLVEMENT
Which protected groups and other
employees/staff networks do you intend
to involve in the equality analysis?
How will you involve people with protected
groups in the decision making related to the
policy development, commissioning decision or
service review?
Regular service review meetings:
We will meet Quarterly with clinical leads and service
managers who will support the decision making
process and sense check pathways and areas of
redesign. Other third sector/ voluntary members will
be involved at identified milestones throughout the
project plan.

GPwSI

Consultants/ Business Manager

GP’s
Patient Expert Group meetings
Public Health

The CCG will hold locality communication /
engagement events.

Public/ expert patient involvement – Options
of service delivery will be shared and views
will be sought to inform the service
specification

Patient focus group feedback analysis
GP participation Groups
Patient Advice Liaison Service (PALS)
Health Watch
Bidder Engagement
General Public (via CCG website)
Dermatology Project
Plan v2 160114.xls
IMPACT
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Which groups does the policy or
decision being made impact upon?
Service Users
X Yes
No
Carers or family
X Yes
No
General Public
X Yes
No
CCG Staff
Partner organisations
Yes
X Yes
X
No
No
How was the need for the ‘activity’
identified?
How is the activity meeting that need?
The CCG’s Integrated Strategic Plan 201318 sets out a strategic commitment to
deliver more care in the community and in
locations closer to patients.
The team will work collaboratively with other primary
and secondary care providers to ensure a
streamlined, seamless service for patients.
Supporting National Documentation –
Lessons for the NHS ‘Commissioning a
Dermatology Service’, Quality Standards
for Dermatology and Nice Guidance.
Dermatology is a specialty specifically
identified by the Department of Health as
being suitable for the relocation of a large
proportion of work from secondary care to
primary care under the Moving Care Closer
to Home policy. Our Health, Our Care, Our
Say; A New Direction for Community
Services (DH, 2006).
The service will provide a holistic approach to the
management of inflammatory skin disorders, with the
emphasis on providing support to enable patients to
manage their long term condition.
Service Specifications Outcomes (KPIs) to be added
once patient and public engagement has taken place.
Referrals to Dermatology services have
risen as a consequence of increasing
population numbers and frequency of
diseases such as skin cancer, leg ulcers
and atopic eczema. (Guidance for
Commissioning Dermatology Services –
BAD)
The existing procurement contract for the
community provider is due for review in
December 2014, therefore an opportunity
to test the market.
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What is the activity looking to achieve?
What are the aims and objectives?
Option A – Integrated Skin Service
Deliverables of Option A
Commissioning an integrated service will
involve decommissioning current service
providers and procuring a provider to
deliver both community and Hospital care,
within a fixed budget. The new service
provider will be given the option to subcontract with other providers on a prime
contracting basis. The provider will be
expected to use economies of scale and
reduction of inefficiencies in patient
pathways to provide the service within a
reduced financial envelope.

It is important to ensure that elements of
the existing workforce within the health
economy ie Direct Enhanced Services,
provided by General Practitioners continue
to be an integral part of the model to
enable patients to be treated in the most
appropriate place in the pathway










Total skin budget to one provider who may
subcontract other service providers
Integrated pathways to support patient
movement through the system, see ‘Appendix
1’for service model
Allows for greater innovation and service
improvements
Potential to deliver elements of Skin cancer
services in the community
Long term condition support and patient
management in the community
Increase the number of treatments available
within the community for skin conditions
Community based dressing clinic for patients
as required
Provide full range of services within each
locality including the newly built Colne Heath
Centre where applicable
Care provided by the most appropriate health
professional first time
Community referral/ sign posting patients to
support groups and third sector organisations
to improve holistic support
To be accessible through a single point of
access, leading to a coordinated approach for
Dermatology Services.

To provide a triage, assessment and
treatment service for all GP referrals of
patients registered with an East Lancashire
GP including both children and adults.

Deliver a service that demonstrates equity of
access to protected groups.

Develop and provide individualised care plans
in partnership with patients and their ‘carers’.

Achieve patient focused health outcomes,
particularly gain confidence in the use of selfmanagement skills of patients’ own health and
skin condition.

Work with health professionals within Pennine
Lancashire to provide advice and education
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on the long-term self-management of chronic
skin conditions.

Deliver a value for money service that has
sustainable consistent delivery with
measurable performance management and
clear improved outcomes for patients.

To continue to support GPs by educating
primary care provision ie utilising the Advice &
Navigation Scheme
Services currently provided:
 GP with Special Interest (GPwSI) providing a restricted range of services in the community
at various Health Centres across East Lancashire.
 Comprehensive range of Consultant led services provided by ELHT in an Acute setting.
EVIDENCE OF ANALYSIS
What Evidence have you considered as part of the Equality Analysis and
Assessment of Outcomes?

All research evidence base references including nice guidance and
publication – please give full reference

Guidance for Commissioning Dermatology Services - BAD

Lessons for the NHS (commissioning a Dermatology service) – BAD Jul 2013

Quality Standards for Dermatology – Primary Care Contract Jul 2011

Revised Guidance and Competences for the provision of services using GPwSI Dermatology & Skin Surgery – DH 2011

Model of Integrated Service Delivery in Dermatology Skin Care Campaign - 2007

NICE Support for Commissioning Psoriasis - Aug 2013

NICE Atopic Eczema in children pathway overview – Sep 2013

NICE Improving Outcomes for People with Skin Tumours including Melanoma (update) 2010
Local population:

The East Lancashire CCG Advice & Navigation scheme which sign posts GP’s to the
correct service has identified a gap in the required service level for Dermatology in the
community.

There is a lack of local data around skin diseases but the majority of patients have mild
problems that can be, and usually are, easily self-managed. The table below depicts the
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frequency of skin diseases:
Frequency in
population
(National)
Frequency in
East Lancashire
based on
population of
382359
Eczema
15%
57354
Psoriasis
2%
7647
15% (80% of
adolescents)
57354(45883)
Urticaria
10%
38236
Rosacea
1%
3824
Skin Cancer –
all types
10%
Diagnosis
Acne
Melanoma
1/10000/year
Epidermolysis
Bullosa
50/million live
births/year
38236
38/382359
WHAT OUTCOMES ARE EXPECTED/DESIRED FROM THIS POLICY/PROPOSAL?
Who will benefit from this policy/proposal and in
what way will they benefit?
Patients / Public Sector
Clinicians
CCG
Acute Trust
What are the benefits to patients and Staff?
Patients / Public
 Care is delivered closer to home by an
appropriate clinician for assessment and
treatment.
 Facilitation of well supported selfmanagement for those with inflammatory
skin disorders.
 Increase in range and number of
treatments offered in the community.
Does the policy/proposal explicitly involve the
elimination of inequality, or the promotion of
equality?
The Integrated Dermatology Skin Service aims
to promote equality by delivering a multidisciplinary service between GP’s, GPwSI,
Specialist Nurses and traditional Secondary
Care led services and that demonstrates equity
of access to protected groups.
What targets/indicators will be used to measure
these to provide assurance to the CCG and
patients?



The service provider will conduct
customer satisfaction surveys on a biannual basis
Patient and referrer feedback is reviewed
and acted upon by the provider/s
Patients to participate in the friends and
family test
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
Improved patient quality of life, and
return to work or normal social function
where appropriate.
 Reduced waiting times.
 Improve outcomes of patients through
the service
Clinicians
 Improved staff skill mix in the community
service i.e. specialist nurses
 Reduce unnecessary referrals to
secondary care that can be seen in the
community.
 Release limited Secondary Care
resources for activity that only they can
provide (more acute & complex
diagnoses) to support the delivery of the
18 week journey.
 Improved management of patients in
general practice through improved
referrer knowledge and education.
CCG
 High quality and accessible services for
patients
 Improved patient experience across
localities
 Shift of treatments from Secondary care
to a community setting at reduced rate to
deliver efficiency savings (QIPP)
 Increase support for GPs / Training


The Provider will be required to deliver a
performance framework relating to the
service, designed to inform the CCG as
the commissioner about the performance
against the outcomes and KPIs.
Evaluation of evidence from the service
to demonstrate future requirements.
Acute Trust
 Reduce hospital waiting times for
patients
 Treating patients with complex long term
conditions and biologic therapies that
require clinical management and
governance of a consultant
 Increased estate for secondary care
HUMAN RIGHTS, PRIVACY IMPACT, COMMUNITY COHESION AND COST
If the decision removes or engages a person’s absolute right the
Does the ‘activity’ raise
policy/decision will need to be changed. Where it is a Limited or Qualified
any issues in relation to
Human Rights as set out Right the decision needs to be proportional and legal. (State below your
in the Human Rights Act assessment)
1998
Does not impact on any human rights
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Derm human rights
screening tool Jan 14.docx
Have you carried out a
Privacy Impact
Assessment?
NHS Lancashire PIA
Proforma V2 (281009).doc
Does the ‘activity’ raise
any issues for
Community Cohesion?
What were the findings of the privacy impact assessment when
carried out: (For support please contact Information Governance).
We have considered a PIA and have come to the conclusion that it is
not required as there would be no genuine risk to the privacy of the
individual
[complete the attached PIA]
If the policy positively impacts some groups and negatively impacts or
overlooks other sections of the community, what effect will this have on the
relationship between these groups? Please state how will you manage this
relationship?
There are no obvious reasons to why Community Cohesion should
not be integrated as service provision will continue to be provided in
all localities
What is the overall cost
of implementing the
‘activity’?
Please state: Cost & Source(s) of funding
Cost saving are anticipated from implementing this service
The CCG does not wish to disclose this information
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EQUALITY ANALYSIS AND IMPACT ASSESSMENT
Does the ‘activity’ have the potential to:



Group
Have a positive impact (benefit) on any of the groups?
Have a negative impact / exclude / discriminate against any person or group?
Explain how this was identified? Evidence/ Consultation?
Positive
Negative
Reasons for positive / negative impact – (Please include all evidence you have considered as
(Y/N)
(Y/N)
part of your analysis e.g. population statistics, service user data broken down by equality group
e.g. those undergoing liposuction in the last 12 months including ethnicity, gender, age,
disability/long term conditions).
Y
N
Y
N
Age
There will be a positive impact on this protected group, prevalence of Psoriasis estimated to be
1.3 to 2.2% in the UK. Men and women are affected equally and cases can occur at any age
although uncommon in children and the majority of cases occur before the age of 35. 70% are of
working age between 18 – 64 years. The incidence rates of BCC increase with age, and
over the age of 55 the age-specific incidence rates are higher in males than females. This gap
increases with age and is greatest for the 85 and older age group. The incidence of BCC is
rising, with evidence suggesting an estimated annual percentage increase of 1.4% for males and
1.9% for females between 1992 and 2003. The largest reported increase in incidence
was seen in the 30–39 age group
There will be a positive impact on this protected group. The specification for the new service will
include requirement for Equality Act 2010 compliance and offer care closer to home.
Disability
Disabled users of the service will have communication needs and the need for BSL interpreters
and information in different formats will be considered as part of this proposal.
Marriage &
Civil
Partnership
Pregnancy and
N/A
N/A
The service will promote equality of opportunity for all adults
N/A
N/A
Looking at the data, there is nothing to suggest a negative impact. Due consideration is given to
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maternity
Y
N
women who are pregnant and new mothers who are breastfeeding.
The service will take into account the particular needs of people from different ethnic and cultural
backgrounds reflecting the diverse needs of people across East Lancashire as displayed in the
table below.
Average Race Groups
Group
White British
White Irish
White Other
Mixed
Asian/Asian British
Black/Black British
Chinese
Other
Race
People
382359
333264
2294
5812
3594
32348
688
3824
459
% Total
87.16
0.60
1.52
0.94
8.46
0.18
1.00
0.12
One of the most significant changes in the demography has been the increase in numbers of
different ethnic minorities coming to live and work in the UK especially from Eastern European
community’s i. e members of the Polish communities.
In the absence of routine or uniform gathering of ethnicity another source of information is use of
requests for Interpreting Services. This gives an indication of the language needs of minority
ethnic minorities and the statistics could be extrapolated for the purposes of the Equality Impact
Assessment. They could indicate the level of demand for foreign language interpreters in the
Dermatology services, inherently affected by the proposed reconfiguration of the service. We
recognise that a need for an interpreter is not a proxy indicator for minority ethnic people, but
only those who are not competent in English as a foreign language. This information could be
used in the consultation process to engage with ethnic minority organisations to gather
anecdotal or qualitative information to help inform the equality assessment.
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The need for Interpretation and translation will need to be considered as part of this proposal
Religion or
belief
Y
N
Y
N
Y
N
Sex
Due consideration will be given to sessions commissioning in line with religious and cultural
needs (Friday prayer, Saturday Sabbath). Providers will have a responsibility to have due
regard to equality target groups via the service specification
Men and women are affected equally for Psoriasis and cases can occur at any age although
uncommon in children and the majority of cases occur before the age of 35.Eczema affects 1 in
12 adults in the UK. The incidence rates of BCC increase with age, and over the age of 55 the
age-specific incidence rates are higher in males than females. This gap increases with age and
is greatest for the 85 and older age group. The incidence of BCC is rising, with evidence
suggesting an estimated annual percentage increase of 1.4% for males and 1.9% for females
between 1992 and 2003. The largest reported increase in incidence was seen in the 30–39 age
group.
Discrimination and homophobia can have a significant impact on LGB people’s engagement with
society and infrastructures in society. It also has a significant impact on how they are treated by
some health care providers.
There is no local statistics available for this protected group.The IHS data in the survey period
April 2011 to March 2012 indicate that:


Sexual
orientation




Gender
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Y
N
93.9 per cent of adults identified themselves as Heterosexual/Straight,
1.1 per cent of the surveyed UK population, approximately 545,000 adults, identified
themselves as Gay or Lesbian,
0.4 per cent of the surveyed UK population, approximately 220,000 adults, identified
themselves as Bisexual,
0.3 per cent identified themselves as ‘Other’,
3.6 per cent of adults stated ‘Don’t know’ or refused to answer the question,
0.6 per cent of respondents provided ‘No response’ to the question.
Discrimination and homophobia can have a significant impact on LGB people’s engagement with
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reassignment
Carers
Y
N
Deprived
Communities
Y
N
Y
N
society and infrastructures in society. It also has a significant impact on how they are treated by
some health care providers. Evidence from stonewall.org.uk
All staff members will adhere to company policy and will have undertaken the relevant Equality
and Diversity training.
From the latest CCG report (Dec13 publication) and results from 5915 GP patient surveys, within
East Lancashire there are 5508 heterosexual/straight people, 66 Gay/Lesbians, 43 Bi-sexual, 36
other and 262 preferred not to say.
The service will promote equality of opportunity for all adults and those with caring
responsibilities by offering flexibility and access for appointments.
The service will promote equality in accessing service delivery as the service specification will
cover all localities therefore reducing the impact on the deprivation.
The service is aimed at treating mild to moderate conditions within the community. Where
issues occur such as correspondence with homeless patient’s normal NHS rule will apply.
Table 1 Households accepted as homeless and in priority need, April 2012 to March 2013 LCC
Vulnerable
Groups e.g.
Homeless, Sex
Workers, exmilitary
Burnley
Hyndburn
Pendle
Ribble Valley
Rossendale
Households
accepted as
homeless
Number per
1,000
households
Rank of 326
authorities in England
(by per 1,000
households)*
61
8
22
16
15
1.69
0.24
0.58
0.64
0.52
139
305
282
274
288
Other
(please state)
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N/A
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Risk Assessment
Risk Score:
if moderate or high (please state what will be done and how this mitigates the risk):
Actions required to
reduce/eliminate
the negative impact
Low
Resources
required*
(see guidance
note below)
Who will lead on
action?
Target completion date
No major change in
policy / Continue
policy
Adjust policy
Moderate
High
Stop and reconsider
policy
* ‘resources required’ is asking for a summary of the costs that are needed to implement the changes to mitigate the negative impacts
identified.
Monitoring and Review
Please describe briefly, how the action plan will be monitored?
Date of the next review of the Equality Analysis/Action Plan?
The action plan will be monitored in line with the project plan at
regular intervals.
December 2014
Which CCG Committee will be responsible for Monitoring?
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East Lancashire CCG
Signature of person completing the impact assessment:
Signature of Competent Equality Officer:
Shabir Abdul
Jayne Tebbey
Date Completed:
Date received: 11 February 2014
On-going
Date Reviewed: 14 February 2014
Date Signed Off by CCG Committee:
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Equality Risk Assessment - Severity score
Descriptor
Objectives /
Projects
Patient Experience
Complaints
Staffing and
Competence
1
Insignificant
2
Minor
3
Moderate
4
Major
Project plan and objectives are
fully inclusive of all protected
groups impacted up – an
equality analysis has been
carried out
Unsatisfactory client/patient
experience not directly related
to patient care
Locally resolved complaint
relevant to equality or human
rights
Project milestones include
reviews of the equality
analysis and evidence of
engagement with
protected groups
Unsatisfactory
client/patient experience –
readily resolvable
Justified complaint
peripheral to equality and
human rights
Equality analysis done but
minimal evidence of
programme of review or
action plan to mitigate
negative impacts
Mismanagement of
client/patient care
Equality analysis done but
no evidence of programme
of review or action plan to
mitigate negative impacts
There has been no full
equality analysis carried
out – risks not mitigated
through action plan
Serious mismanagement
of client/patient care
100% of staff have received
training in Equality and Human
Rights and feel competent to
deliver EDHR in relation to their
job role
75% of staff have received
training in Equality and
Human Rights and feel
competent to deliver
EDHR in relation to their
job role
Below excess claim.
Justified complaint
involving indirect
discrimination or breach of
a person’s qualified or
limited human rights
50% of staff have received
training in Equality and
Human Rights and feel
competent to deliver
EDHR in relation to their
job role
Claim above excess level.
Multiple justified
complaints involving
equality discrimination or
breach of a person’s
absolute human rights
25% of staff have received
training in Equality and
Human Rights and feel
competent to deliver
EDHR in relation to their
job role
Totally unsatisfactory
client/patient outcome or
experience
Multiple claims or single
major claim
Potential cost
Inspection / Audit
Up to £10K
Minor recommendations. Minor
non-compliance with standards
£10,000 - £25,000
Recommendations made.
Non-compliance with
standards
Adverse Publicity /
Reputation
Contained within the
organisation. Rumours
Local media – short term.
Minor effect on staff
morale
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£0.25m - £0.5m
Reduced rating.
Challenging
recommendations. Noncompliance with core
standards
Local media – long term.
Significant effect on staff
morale
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£0.5m - £1m
Enforcement action. Low
rating. Critical report.
Major non-compliance with
core standards
National media up to 3
days
5
Catastrophic
Non-delivery of key
objective / service due to
lack of staff. Loss of key
staff. Critical error due to
insufficient training
Staff not had any training
in Equality and Human
Rights
£1m plus
Prosecution. Zero rating.
Severely critical report
National media >3 days.
MP concerns (Questions in
the House)
2 – Likelihood score
Descriptor
Frequency
Probability
1
Rare
Not expected to occur
for years
<1%
Will only occur in
exceptional
circumstances
2
Unlikely
Expected to occur
at least annually
1-5%
Unlikely to occur
3
Possible
Expected to occur
at least monthly
6-20%
Reasonable chance
of occurring
4
Likely
Expected to occur
at least weekly
21-50%
Likely to occur
5
Almost Certain
Expected to occur
at least daily
>50%
More likely to
occur than not
4
4
Moderate
8
Significant
12
Significant
16
High
20
High
5
5
Moderate
10
Significant
15
High
20
High
25
High
1 (severity) x 2 (likelihood) = total risk score and rating
Likelihood
1
2
3
4
5
1
1
Low
2
Low
3
Low
4
Moderate
5
Moderate
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2
2
Low
4
Moderate
6
Moderate
8
Significant
10
Significant
Severity
3
3
Low
6
Moderate
9
Significant
12
Significant
15
High
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