Revised Service Framework for Respiratory Health and Wellbeing consultation response
questionnaire
REVISED SERVICE FRAMEWORK FOR RESPIRATORY
HEALTH AND WELLBEING
Consultation Response Questionnaire
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Revised Service Framework for Respiratory Health and Wellbeing consultation response
questionnaire
CONSULTATION RESPONSE QUESTIONNAIRE
You can respond to the consultation document by e-mail, letter or fax.
Before you submit your response, please read Appendix 1 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:
serviceframeworks@dhsspsni.gov.uk
Written:
Service Frameworks Unit
DHSSPS
Room D1
Castle Buildings
Stormont Estate
Belfast, BT4 3SQ
Tel:
(028) 9052 8283
Responses must be received no later than 2nd January 2015
I am responding:
as an individual
on behalf of an organisation
√
E
(please tick a box)
Name:
Dr John Knape
Job Title:
Head of Communications, Policy and Marketing
Organisation:
RCN Northern Ireland
Address:
17 Windsor Avenue
Belfast BT9 6EE
Tel:
028 90 384 600
Fax:
028 90 382 188
e-mail:
john.knape@rcn.org.uk
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Revised Service Framework for Respiratory Health and Wellbeing consultation response
questionnaire
Background
The Service Framework for Respiratory Health and Wellbeing was originally launched
in June 2009. It has recently been subject to a fundamental review and also to an
independent review by the Regulation and Quality Improvement Authority (RQIA).
The revised Framework includes 56 standards, which relate to a number of specific
conditions, as well as communication and patient and public involvement, health
improvement and protection, social emotional support, information, training, medicines
management, and palliative and end of life care.
Purpose
This questionnaire seeks your views on the revised Service Framework for Respiratory
Health and Wellbeing, and should be read in conjunction with the document which
includes the draft standards. It is particularly important to know whether the proposed
standards will ensure that health and social care services are safe, effective and
person-centred.
All Service Frameworks incorporate a specific set of standards that are identified as
generic. The generic standards were subject to a public consultation which closed on
6 August 2012. The standards have since been finalised and agreed.
We are therefore not seeking comment on these standards as part of this consultation.
The relevant standards are clearly marked as generic throughout the document.
The consultation questionnaire
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 provide some general feedback on the service
framework document and should be completed by all respondents.
Part B: provides an opportunity for respondents to give additional feedback relating to
specific standards and/or sections of the service framework.
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Revised Service Framework for Respiratory Health and Wellbeing consultation response
questionnaire
Please indicate which section(s) you are providing feedback on:
I am providing general feedback on the document and will complete Part
A. √
I am providing general feedback on the document with a focus on the specific
section(s) indicated in the table below and will complete Part A and Part B.
Please tick which sections or subsections you are providing feedback on
Summary of Standards
Section 6: Standards for specific conditions
6.1 Chronic Obstructive Pulmonary Disease (COPD)
Section 6: Standards for specific conditions
6.2 Oxygen Therapy in COPD
Section 6: Standards for specific conditions
6.3 Asthma in Adults
Section 6: Standards for specific conditions
6.4 Asthma in Children and Young People
Section 6: Standards for specific conditions
6.5 Community Acquired Pneumonia (CAP) in Adults
Section 6: Standards for specific conditions
6.6 Community Acquired Pneumonia (CAP) in Children and Young People
Section 6: Standards for specific conditions
6.7 Obstructive Sleep Apnoea/Hypopnoea Syndrome in Adults
Section 6: Standards for specific conditions
6.8 Obstructive Sleep Apnoea Syndrome in Children and Young People
Section 6: Standards for specific conditions
6.9 Long Term Ventilation in Adults
Section 6: Standards for specific conditions
6.10 Long Term Ventilation in Children and Young People
Section 6: Standards for specific conditions
6.11 Cystic Fibrosis
Section 6: Standards for specific conditions
6.12 Bronchiectasis
Section 6: Standards for specific conditions
6.13 Interstitial Lung Disease (ILD)
Section 7: Standards Relating to All Conditions
7.1 Pulmonary Rehabilitation
Section 7: Standards Relating to All Conditions
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Revised Service Framework for Respiratory Health and Wellbeing consultation response
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7.2 Transitional Care for Adolescents with Chronic Respiratory Disease
Section 7: Standards Relating to All Conditions
7.3 Acute Oxygen Therapy
Section 7: Standards Relating to All Conditions
7.4 Social and Emotional Support
Section 7: Standards Relating to All Conditions
7.5 Information
Section 7: Standards Relating to All Conditions
7.6 Training
Section 7: Standards Relating to All Conditions
7.7 Medicines Management
Section 8: Standards for Supportive and Palliative Care
Standard 55
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Revised Service Framework for Respiratory Health and Wellbeing consultation response
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Part A – General feedback on the document (all respondents please complete
this part).
Q1. Please indicate your views on the following statement (please circle response)
“In general the language and organisation of the document is easy to follow.”
Strongly agree
Agree
Neither
Disagree
Strongly disagree
Comments:
In general terms, the RCN endorses the revised service framework for respiratory
health and well-being, published for consultation by the DHSSPS.
The RCN notes and welcomes the engagement of Northern Ireland Board member
Anne Marie Marley in the development of the revised service framework,
particularly in respect of the standards covering COPD and palliative care. We also
welcome the engagement and involvement of respiratory nurse specialists in the
preparation of the revised service framework.
The revised service framework is logically structured. However, the RCN has some
misgivings over the accessibility of a document that is 299 pages in length and
difficult to download and print out. If the impact of the revised service framework is
to be maximised, it must be fully accessible and understandable to the nurses and
the other health care professionals who will be responsible for delivering the
service framework, and who are variously both responsible and accountable for
meeting the standards set out within it. The RCN notes (page 57) the intention to
publish an easy access version of the framework for the benefit of service users
but we believe that it is equally important to publish a summary version that will be
equally accessible for health care professional staff. The RQIA’s review of the
implementation of the preceding service framework noted the need to review
arrangements for disseminating information such that “referring practitioners have
a clear understanding about the services available in their area”. The RCN concurs
with this assessment.
The RCN is disappointed to note that, at many stages, the service framework
document is incomplete. On page 91, for example, the performance indicator
relating to independent advocacy is “to be determined”. Page 100 refers to the
anticipation that baseline results will be available in November/December 2013.
Page 104 states that a baseline will be established by March 2014. Page 121
states that a regional LES is “to be agreed”. These omissions and anomalies do
not enhance the confidence of stakeholders in the capacity to implement the
revised service framework.
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Revised Service Framework for Respiratory Health and Wellbeing consultation response
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Q2. Please indicate your views on the following statement (please circle response)
“The standards covered by the service framework are important for those with
respiratory disease”.
Strongly agree
Agree
Neither
Disagree
Strongly disagree
Comments:
The RCN believes that the proposed service framework has the potential to deliver
real and lasting improvements to the care of people in Northern Ireland with
respiratory conditions. It is comprehensive in its scope and covers all aspects of
respiratory services that have been highlighted by patients, service users and
carers as being important to them.
However, the RCN believes that the sheer size and scope of the framework will
present significant implementation challenges to HSC trusts, particularly within the
current financial climate and the anticipated service cuts that will be required
during 2015-2016. As usual with DHSSPS consultations on proposed service
developments, there is little or no indication provided in relation to how the
implementation process will be resourced and this makes it difficult for
stakeholders to provide an informed judgement on the capacity of the proposed
developments to improve patient care. This point is elaborated upon in response to
question 10 below. A further flaw in the service framework is the tendency to
ascribe responsibility to an implausibly large group of organisations and bodies in
such a manner as to obscure who is actually accountable for delivering the
standard. On page 91, for example, responsibility for promoting independent
advocacy resides variously with the Health and Social Care Board, the Public
Health Agency, LCGs, Primary Care Partnerships, HSC trusts, GPs, the voluntary
and community sector, the independent sector and the Patient and Client Council.
The RCN suggests that this list is so exhaustive as to be essential meaningless.
Q3. Please indicate your views on the following statement (please circle response)
“Overall this framework will provide an opportunity to help set priorities for
commissioning services for respiratory disease”.
Strongly agree
Agree
Neither
Disagree
Strongly disagree
Comments:
Whilst the RCN agrees in general theoretical terms with the above statement,
many of the standards are dependent for their achievement upon the availability of
the types of specialist community nursing teams envisaged in overarching
standard 11 (pages 116-117) but which simply do not exist in many areas of
Northern Ireland. Resourcing and workforce constraints, including the availability of
staff training and education, are likely to diminish the capacity of HSC
organisations to deliver the service improvements that the framework is designed
to secure. Resource and capacity planning is required and there is a particular
need to develop and support specialist respiratory teams that are available on a
24/7 basis. The RCN is concerned to note that an undertaking to extend specialist
access within the community on a seven day basis is given with no attempt to even
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Revised Service Framework for Respiratory Health and Wellbeing consultation response
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acknowledge the significant resourcing and workforce implications of this
commitment. The RCN also believes that there is a need to support the
implementation of the revised service framework on a 24/7 basis through
enhanced district nursing support. This will not only improve standards of care but
will also help to reduce pressures on emergency departments and unscheduled
care services.
The standards depend in many respects upon the collation and analysis of a
significant volume of performance data. We question whether the necessary
information technology infrastructure is in place to facilitate this activity and,
particularly in the current financial climate, whether the availability of IT support
and clerical staff support is sufficient to ensure that the burden of this work does
not fall upon professional nursing and other health care staff to the detriment of
their clinical responsibilities.
The RCN also questions whether the current commissioning structures and the
annual commissioning cycle in Northern Ireland are fit for purpose in securing the
implementation of the revised service framework. Implementation should be
required within the 2015-2016 commissioning direction and subsequently
addressed within the individual commissioning plans that derive from it. These
documents should already have been published to allow for effective consultation
and subsequent editing to take place prior to the plans being finalised and
published well in advance of the start of the 2015-2016 business year. This
process, of course, has not even begun.
On a more specific level, the wording of the effective quality dimension for
standard 12 (page 119) implies somehow that it is the responsibility of people with
COPD to develop their own self-management plan. The equivalent wording within
standard 21 (page 143) and standard 26 (page 157) is more acceptable.
Over-arching standard 52 on training is particularly important and the RCN
endorses the associated commentary and performance indicators. However, we
question whether the commitment to delivering the requisite training and
professional development activity is shared throughout the HSC and, more
importantly, whether the resources to deliver it actually exist within the current
financial climate. Meeting this standard will be challenging for HSC trusts but
particularly so within primary care, where GP-employed nurses often experience
real difficulties in being released and supported to undertake training and
professional development activity.
Page 58 refers to the implementation of service frameworks influencing the
education and training agenda and curricula content and to “a commitment to
lifelong learning and personal development”. The RCN questions whether the
evidence exists to demonstrate that this is happening, particularly in an
environment where nurses report experiencing difficulty in accessing even
mandatory training requirements.
There is a need to commission more places on the specialist practice degree
course at the Queen’s University of Belfast and to explore the potential role of the
advanced respiratory nurse practitioner or respiratory nurse specialist.
In primary care, there is no payment system for the preventative work of early
focused case finding or prompt exacerbation management. Accordingly, there is no
onus on GP practices to engage with the local community respiratory specialist
teams in order to initiate good palliative care services for patients at that stage of
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Revised Service Framework for Respiratory Health and Wellbeing consultation response
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their illness. It would appear that GP practices are effectively being paid simply for
the collection of data. The undertaking (page 176) to manage children and young
people in the most appropriate setting and to avoid inappropriate admission also
has significant resourcing and staffing implications that are not addressed.
On page 254, reference is made to an “HSC trust/ICP report” without explaining
what this is. The role and status of ICPs within the implementation of the service
framework is unclear. Similarly, the responsibility of LCGs within the
commissioning process is not specified.
Page 263 refers to a GMS training group that will determine the level of
postgraduate COPD training to be undertaken by registered nurses. The RCN is
not aware of what this group is, how it is constituted and what remit it has for
making decisions about professional nurse education. On page 278, reference is
made to the need for effective communication between the GP/consultant and “key
worker” but the bulk of palliative care services are delivered by registered nurses
and the RCN finds it incomprehensible that nursing is omitted from this
requirement, or unhelpfully dismissed by the use of the phrase “key worker”.
Q4. Which of these standards will have the greatest impact on the health and
wellbeing of people who use respiratory services, and why?
Comments:
Given that different standards relate to different patient groups and different
physical conditions, the RCN considers this question to be unhelpful and irrelevant.
The consultation purports to define a service framework, which implies some
degree of integration and co-ordination across the various areas of practice and
the various patient and client groups. Singling out one standard or group of
standards as somehow being more important than others implies that certain
patient or client groups may be considered to be more important than others. The
RCN does not agree with this underlying assumption.
Q5. Which of these standards might affect existing or potential health inequalities for
people in Northern Ireland, and how? Please consider social, economic and
geographic challenges in response to this question.
Comments:
For the same reasons as outlined in response to question 4 above, the RCN
regards this question as irrelevant and ill-conceived. The consultation purports to
define a service framework, which implies some degree of integration and coordination across the various areas of practice and the various patient and client
groups. Singling out one standard or group of standards as somehow having a
greater potential than others to affect existing or potential health inequalities seems
to be entirely pointless and contrary to the very purpose of a service framework.
In relation to generic standard 9 on safeguarding, the RCN endorses the emphasis
upon the responsibilities of HSC staff and would note that this is a fundamental
part of the professional duty of care for registered practitioners. In respect of
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Revised Service Framework for Respiratory Health and Wellbeing consultation response
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practices such as the positioning of additional beds and the continued existence of
mixed gender accommodation in many settings within the HSC, it is clear that this
standard is not being universally met.
Equality implications
Before completing this section, please refer to Appendix 2 which relates to equality of
opportunity, and the guidance regarding this produced by the Equality Commission
for Northern Ireland.
Q6. What is the likely impact on equality of opportunity for those affected by this
policy, for each of the Section 75 equality categories?
Minor
Major
None
√
If you have indicated minor or major, please provide details:
Q7. Are there opportunities to better promote equality of opportunity for people within
the Section 75 equalities categories?
Yes
No
√
Q8. To what extent is the policy likely to impact on good relations between people of
different religious belief, political opinion or racial group?
Minor
Major
None
√
If you have indicated minor or major, please provide details:
Q9. Are there opportunities to better promote good relations between people of
different religious belief, political opinion or racial group?
Yes
No
√
Comments:
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Revised Service Framework for Respiratory Health and Wellbeing consultation response
questionnaire
Q10. Please use the box below to insert any further comments, recommendations or
suggestions you would like to make in relation to the revised Service Framework for
Respiratory Health and Wellbeing.
Comments:
The RCN fully supports the objective of improving and developing standards of
care for people with respiratory conditions and we accept that the draft service
framework is well-intentioned in this respect. It is essential that the implementation
of the strategy is fully-funded, year on year, and (as noted in response to question
2 above) that associated accountabilities are specified. Many of the standards
assume that new services or service developments have already been established.
However, in many aspects of the service framework, business cases have not
even been submitted to enable the commissioning process to begin. The
paragraph on affordability on page 59 states that additional costs will be sought
through “existing service developments and commissioning processes”. Given the
challenging financial position for 2015-2016 set out in the recent DHSSPS draft
budget consultation paper, it is difficult for stakeholders to have any confidence in
this process. The failure to outline how the significant resourcing implications of the
revised service framework will be addressed serves only to undermine the
laudable purpose of the exercise. These issues need to be resolved in order to
build and sustain the confidence of health care professionals and, more
importantly, patients and service users, in the capacity of the revised service
framework to secure its commendable objectives.
Please continue and complete Part B, or return your response questionnaire.
Responses must be received no later than 2nd January 2015.
Thank you for your comments.
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Revised Service Framework for Respiratory Health and Wellbeing consultation response
questionnaire
Part B – Feedback relating to specific standards and/or sections of the service
framework.
If necessary please copy and complete this part of the questionnaire for each section
or standard you are reviewing.
Please insert the specific section or standard you are reviewing in the box provided
e.g.
Section 6.1: Chronic Obstructive Pulmonary Disease (COPD)
or
Standard 20: Diagnosis of Asthma
Q(i). Please indicate your views on the following statement (please circle response)
“It was easy to locate my specific standard/section of interest in the Service Framework
document.”
Strongly agree
Agree
Neither
Comments:
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Disagree
Strongly disagree
Revised Service Framework for Respiratory Health and Wellbeing consultation response
questionnaire
Q(ii). Service frameworks are viewed as active documents which evolve over time to
include new scientific evidence for improving care. Are you aware of any key evidence or
other information which is missing, and which would alter the nature of this particular
section/ standard?
Yes
No
Comments:
Q(iii). Please indicate your views on the following statement (please circle response)
“The performance indicators and the expected performance levels are reasonable,
and they will help progress towards achieving the overarching standard(s).”
Strongly agree
Agree
Neither
Comments:
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Disagree
Strongly disagree
Revised Service Framework for Respiratory Health and Wellbeing consultation response
questionnaire
Q(iv). Please indicate your views on the following statement (please circle response)
“I plan to use the/these standard(s) to improve my practice, or services, for people
with respiratory disease.”
Strongly agree
Agree
Neither
Disagree
Strongly disagree
Comments:
Q(v). Please use the box below to insert any further comments, recommendations or
suggestions you would like in relation to this particular standard or section.
Comments:
Please return your response questionnaire.
Responses must be received no later than 2nd January 2015.
Thank you for your comments.
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Revised Service Framework for Respiratory Health and Wellbeing consultation response
questionnaire
Appendix 1
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:
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Revised Service Framework for Respiratory Health and Wellbeing consultation response
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http://www.informationcommissioner.gov.uk/). For further information about this
particular consultation please contact John Maguire (contact details are shown on
page 2).
Appendix 2
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Revised Service Framework for Respiratory Health and Wellbeing consultation response
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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.
In keeping with the above statuary obligations and in accordance with guidance
produced by the Equality Commission for Northern Ireland, the Department has carried
out a preliminary equality screening exercise to determine if the standards proposed
in the revised Service Framework for Respiratory Health and Well Being are likely to
have a significant impact on equality of opportunity and should therefore be subjected
to an Equality Impact Assessment (EQIA). The Department has concluded that an
EQIA is not required. This decision will be revisited following the completion and
evaluation of the public consultation.
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Revised Service Framework for Respiratory Health and Wellbeing consultation response
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Produced by:
Department of Health, Social Services and Public Safety,
Castle Buildings, Belfast BT4 3SQ
Telephone (028) 90528283
http://www.dhsspsni.gov.uk
October 2014
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