Questionnaire
The aim of this consultation is to obtain views from interested stakeholders and the Trust
would be most grateful if you would respond by completing this questionnaire. Please
answer each question by writing (preferably typed) your comments in the space provided.
The closing date for this consultation is 5pm on Friday 8th May 2015 and we need to receive
your completed questionnaire on or before that date. You can respond to the consultation
in writing to the following address:
Chief Executive
Belfast Health and Social Care Trust
c/o Corporate Communications
Communications Department
1st Floor, Nore Villa
Knockbracken Healthcare Park
Saintfield Road
Belfast
BT8 8BH
You can email your response to:
stakeholdercomms@belfasttrust.hscni.net
Text Phone: 07827 974240
Before you submit your response, please read Appendix 4 at the end of this questionnaire
regarding the Freedom of Information Act 2000 and the confidentiality of responses to public
consultation exercises.
So that we can acknowledge receipt of your comments please fill in your name and
address or that of your organisation if relevant. You may withhold this information if
you wish but we will not then be able to acknowledge receipt of your comments.
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SECTION 1: ABOUT YOU
Consultee Details
Question 1(a):
I am responding as... (Please tick one option only)
[ ] A Service User
[ ] A Carer
[
] A Care Worker
[
] On behalf of a Provider Organisation
[ √ ] Other: Trade union and professional organisation
[
] I want my response to be treated as anonymous.
Question 1(b):
Please enter your details below:
Name
Dr John Knape
Job Title: (if applicable)
Head of Communications, Policy and Marketing
Organisation: (if applicable)
Royal College of Nursing
Address:
17 Windsor Avenue
City/Town:
Belfast
Postcode:
BT9 6EE
Email Address:
john.knape@rcn.org.uk
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SECTION 2: THE REASONS AND NEED FOR CHANGE
The reasons and the need for change is outlined in section 5 of the document
informed by the following:




EU Procurement Directives & Legislative Compliance
Feedback from Service Users and Carers
Strategic context and requirements of Transforming Your Care
Feedback from Service Providers
Question 2:
Do you agree with the reasons and the need for change in the document?
(Please tick one option only).
[
] Yes
[ √ ] No
If no, please explain why.
The RCN does not necessarily dispute the need for change in the outline
procurement model for domiciliary care services by reference to the factors
outlined at section 5 of the consultation paper on pages 12 and 13. However, the
RCN is unable to support the proposed reform model and supporting rationale
because of our fundamental disagreement with the definition of domiciliary care
set out in the foreword to the consultation document (page 5), at paragraph 1.1 on
page 9 of the consultation document and elaborated upon at paragraph 2.2 on the
same page.
Firstly, the foreword states that domiciliary care services include: “… the Trust
Programmes of Care for Older People, Physical and Sensory Disability, Mental
Health, Learning Disability and Children”. Paragraph 1.1 provides a formal
definition of domiciliary care but does not state by whom, with whom, or by what
rationale this definition has been determined or agreed. Paragraph 2.2 states that
domiciliary care services include inter alia assisting with “a service user’s health
needs (eg managing medication)” and “facilitating the provision of food and
nutrition”. Paragraph 2.3 includes palliative care within the scope of domiciliary
care services. Paragraph 7.2.2 on page 15, sub-titled Specialist care, refers to
“more complex packages, requiring clinical intervention”. If a service user
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requires “specialist care” and “clinical intervention”, by definition this extends
beyond the remit of domiciliary care and into the field of community nursing care,
delivered by, or under the direct supervision of, a registered health care
professional, most prominently specialist community nurses such as district
nurses, community children’s nurses or community mental health nurses. These
are not, in the judgement of the RCN, areas of practice that fall within the scope of
domiciliary care. To suggest that they are is disingenuous and potentially
dangerous.
Paragraph 5.3 states that: “The future model will focus on the changing needs of
service users providing the right level of care and support within the widest
context of community care”. However, this statement does not appropriately
delineate the type of care that is to be provided. Patients and clients with complex
care needs being cared for at home may require support to meet their personal
care needs. Domiciliary care workers are, of course, well-placed to meet these
personal care needs. However, when it comes to meeting the health needs of
patients and clients, they require skilled, professional nursing care directed,
supervised or provided by a registered nurse who has been trained to provide that
care and is accountable for the quality of care provided and the experience of the
patient or client. We must never lose sight of the fact that people with personal
care needs require personal care but patients and clients must be appropriately
assessed and a prescribed plan of care developed to meet any identified health
needs. That plan of care must be provided directly by, or implemented under the
direction and supervision of, an appropriate health care professional. Where a
patient or client has identified nursing needs, then care must be provided within a
nursing context.
The glossary at appendix one defines “care” as “where a care worker performs a
task for the service user that they cannot do for themselves. This definition is
imprecise. Is it intended that it embraces any “task”, including those related to a
service user’s health needs?
The RCN is unable to endorse the proposed outline procurement model for
domiciliary care services because we fundamentally dispute the Belfast Health
and Social Care Trust’s definition of domiciliary care and its conception of which
professional groups should be delivering that care. We wish formally to record
our concerns at this definition, which are further elaborated upon in response to
question six below, and request an urgent meeting with the Belfast Health and
Social Care Trust in order to address these issues.
4
SECTION 3: SERVICE PRINCIPLES
Question 3:
Do you agree with the service principles outlined in section 6 of the document?
(Please tick one option only)
[
] Yes
[ √ ] No
If no, please explain why and / or let us know how you think these could be improved.
It would be impossible to disagree with the criteria listed at paragraph 6.2 in
respect of the delivery of any service. However, the key issue is that the RCN is
unable to endorse the proposed model for purchasing domiciliary care services
because, as noted in response to question two above, we fundamentally disagree
with the Belfast Health and Social Care Trust’s definition of what constitutes
domiciliary care. Paragraph 6.2.1 refers to “a range of social care provision” but
does not specify how and to what extent this “range” will encompass the
statutory, private/independent and voluntary sectors. Paragraph 6.2.3 proposes
“no significant alteration to the proportionate split between statutory and nonstatutory services” but does not state how the Belfast Health and Social Care
Trust defines “significant” in this respect. Paragraph 7.2.1 states that the Belfast
Health and Social Care Trust will not “operate geographical zones within the trust
area as part of its procurement model”, which could lead to concerns about
inequity of service provision within and across the trust area. Paragraph 7.2.2 and
paragraph 12.2 refer to a regional procurement process for meeting complex
needs involving a combination of personal care services and nursing care
services. The inclusion of nursing care services by definition takes this
procurement process beyond the appropriate remit of domiciliary care. The RCN
requests further details of this “regional procurement process” and by whom it is
being conducted. Paragraph 7.4 refers to a service specification document that
will be made available as part of the tender process. The RCN believes that this
important document should be the subject of consultation and we are concerned
that it has been omitted from the current consultation process.
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SECTION 5: EQUALITY SCREENING
SECTION 4: PROPOSED PROCUREMENT MODEL
Question 5:
This proposal has been equality screened as an ongoing screening. Do you agree
with this outcome?
The model for purchasing services from non-statutory providers is outlined in
[section
] Yes9 of the document.
[ √ ] No
If
no, please
Question
4: let us know why.
Do you agree with the Trust’s proposed model for purchasing services from nonstatutory providers? (Please tick one option only)
[ ] Yes
The RCN is unable to endorse any equality screening process associated with
[ √ ]proposed
the
No
model for purchasing domiciliary care services because, as
noted throughout this consultation response, we fundamentally disagree with
If
no,Belfast
pleaseHealth
explainand
whySocial
and letCare
us know
howdefinition
you think this
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be improved.
the
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of what
domiciliary care. We believe that the proposal to deliver aspects of nursing and
health care within a domiciliary care model has significant equality and human
rights implications.
As noted
previously,
RCN
is unable
endorsetothe
proposed
model for
More
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RCN
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purchasing
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weproposal”.
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(page
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In relation
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reference to TUPE arrangements (paragraph 7.4), the RCN does not accept the
domiciliary
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Thiscommentary
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question
two
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nor do we
that
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elaborated
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specifically,
section 13 provides any clear evidence of how the adverse effect upon service
paragraph
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using
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What, precisely does this
much more
transparent
its intentions
in this respect.
entail, what types of case are encompassed within its remit, in what sense is
this arrangement “flexible”, and does this simply refer to the allocation of the
residue of otherwise unallocated cases? The RCN believes it would be helpful if
the Belfast Health and Social Care Trust could provide further information
about these issues. Paragraph 10.2 refers to “the required standards and
service users’ needs”. It is important to specify what these standards are, by
whom they will be monitored, and which key performance indicators will be
used to measure progress and audit compliance.
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Freedom of Information Act (2000) – Confidentiality of Consultations
Belfast Trust will publish an anonymised summary of responses following completion of
the consultation process; however your response, and all other responses to the
consultation, may be disclosed on request. We can only refuse to disclose information in
limited 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 general right of access to any
information held by a public authority, namely, Belfast Trust in this case. This right of
access to information includes information provided in response to a consultation. We
cannot automatically consider information supplied to us in response to a consultation as
information that can be withheld from disclosure. However, we do 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 withheld.
Any information provided by you in response to this consultation is, if requested, likely to
be released. Only in particular circumstances would information of this type be withheld.
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SECTION 6: FURTHER COMMENTS
Question 6:
Do you have any further comments you would like to make regarding the Trust’s
proposal for the procurement model for domiciliary care services?
[ √ ] Yes
[
] No
If yes, please let us know what you think.
Paragraph 11.2 refers to the introduction of an electronic call monitoring
system that will inter alia facilitate communication and assist with the
protection of lone workers. The RCN would be interested to know if the Belfast
Health and Social Care Trust plans to make this system available to
community nursing staff such as district nurses, who also face welldocumented difficulties in both these respects. The objective of “accurately
recording the time spent by care workers in the home” should not be used as
a means to impose arbitrary limits upon home visits that do not take into
account the specific care needs of the individual service user.
This consultation raises fundamental issues about the relationship between
nursing care and domiciliary care and how this relationship is to be managed
in the best interests of patient and clients. The DHSSPS Central Nursing and
Midwifery Advisory Group [CNMAC], of which the RCN is in membership, has
already been made aware of particular concerns within the HSC over the
increasing extent of tasks and procedures being undertaken by direct
payments staff, particularly within the practice areas of child health, adult
physical and sensory care, and learning disability. The RCN is aware that
individuals working in these roles within a domiciliary care framework are
undertaking procedures such as insulin administration, tracheostomy care,
catheterisation, enteral feeding and a range of other forms of care and
intervention. The RCN has also been made aware of confusion over
governance and liability around delegation in these circumstances.
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For domiciliary care workers, residential care staff, and staff in supported
living, it would appear that their roles and responsibilities have evolved, rather
than been formally delegated, to the extent that they are undertaking tasks
such as enteral feeding, stoma care, emergency rescue medication (for
epilepsy), transcribing medication, minor dressings and catheter care. Also
reported in this context are issues such as complex skin care management,
complex care planning around bowel management and palliative care and the
administration of medication (oral, liquid, creams, eye/ear drops) to individuals
in their own homes.
In summary and by way of a conclusion, the RCN reiterates that we are unable
to endorse the proposed outline procurement model for domiciliary care
services because we fundamentally dispute the Belfast Health and Social Care
Trust’s definition of domiciliary care and its conception of which professional
groups should be delivering that care. The RCN believes that this definition,
alongside the issues outlined above, has significant implications for patient
and client safety, quality and experience. We wish once again formally to raise
our concerns over this proposed outline procurement model and its
underlying assumptions.
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