Central Lancashire Community Health Link
(a Patient and Public Involvement Forum)
Response to the Public Consultation on CATS implementation in
Cumbria and Lancashire
Preface
This response is based upon evidence obtained from the following: meetings with
senior directors of all acute NHS Trusts in Central Lancashire; verbal and written
communications from patients and the public; opinions and issues raised during the
arranged CATS public meetings; our research of Select Committees; Government
reports; Department of Health publications; articles and letters in the press; CATS
publications; attendances and presentations at Health Overview and Scrutiny
Committee meetings, and, finally, feedback from the Link’s members and its patient
and public networks.
It is clear that the consultation document is extremely limited by restricting patient
and public involvement to that of addressing the issues pertaining only to CATS site
location and number of specialties. As a consequence, the questions asked in the
response form are similarly limited and the analysis and conclusions that can be
drawn from the answers to these questions must also be similarly limited.
From the public and patient outpourings, it is clear that above all other matters the
public and patients have most concerns about (i) taxpayers money being used to
fund healthcare provision in the private sector, (ii) how the 18 week target can be
achieved without compromising on the quality and standards of healthcare for
patients, and (iii) serious consequential damage to the NHS hospitals in Central
Lancashire. Moreover they see the limited scope of the consultation as having
denied patients and the public full and proper consultation and engagement in the
real issues.
Denial of the opportunity for the public to have a full and proper consultation is
evidenced by the many issues raised by them in the various public meetings, in the
press and in correspondence with the Link. Furthermore, as a result of the restrictive
involvement of the public in the consultation process, it has been necessary for the
PCTs to provide further and detailed information on the proposals.
Our response is based upon answering the questions posed in the consultation
document in the order stated in the response form. We, however, have taken the
opportunity to amplify aspects pertaining to key issues of concern which the public
have manifested their desire to engage in.
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Section 1: Location of sites
Question 1a - Do you consider the sites under consideration the most
appropriate for Cumbria and Lancashire?
The proposed sites within our area (Central Lancashire) are as follows:
Ormskirk District General Hospital, L39 2AZ – appropriately sited for West
Lancashire patients.
Preston Healthport, PR2 8DW – not appropriately sited unless the recently proposed
NHS CATS site at Chorley is implemented, because Preston Healthport is not central
to the population it is proposed to serve.
Question 1b – Are there other factors of which we should be aware in relation
to the ability to access or use any of the sites identified above (eg transport,
parking, availability of complementary facilities) or do you have another site
preference?
The impact on journey times for patients is significantly more acute for the majority of
residents in Chorley and South Ribble, which the proposed CATS site at Chorley
would resolve.
We are concerned about the accuracy and independence of the information provided
on the PCTs CATS website. For example, the Netcare model used to determine
indicative workloads for each of the facilities based upon evidence provided by the
‘Netcare commissioned independent healthcare analysis agency’, summarised in
table 4, is incorrect as regards the quoted data relating to Preston Healthport bus
numbers. This raises doubts on the extent of the errors in the rest of the data and
also on the validity of its analysis and independence.
Section 2: Impact on the wider health service
Question 2a – What issues do you consider will need to be addressed as a
result of the introduction of CATS services (for local patients, hospitals and
GPs)
FOR LOCAL PATIENTS
 The diagnosis and treatment protocols followed in the CATS service should be
like-for-like with those currently in operation in the NHS.
 All CATS centre clinicians should have training, skills and levels of clinical
expertise and registered competence, based on a standardised, independent
assessment system in accordance with the recommendations expressed in
paragraph 76 (conclusion No. 10) of the House of Commons Health Committee
‘Independent Sector Treatment Centres’ Fourth Report of Session 2005-06,
25.07.06 HC934-1
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
Like-for-like governance arrangements should apply and be subject to like-for-like
monitoring and assessment against standards by the NHS commissioners. Likefor-like clinical protocols, accountability and complaints procedures should be
adopted for all CATS centres.
The evidence we have gathered to date clearly indicates that the planned CATS
service will not meet the above like-for-like requirements and this may seriously affect
patient care.
We have profound concerns about the omission of any reference in the document to
the continuity of care between different private CATS providers and NHS Trust
providers. The document also fails to address the very important issues of
confidentiality of patients’ medical records, the integrity of patients’ medical records
and secure and accurate transfer of clinical data between different providers.
FOR LOCAL GPS
More than 50 GPs in Chorley, Preston and South Ribble have signed open letters to
the press expressing their concerns about the impact of the proposed CATS services
on Lancashire Teaching Hospitals NHS Foundation Trust.
 GPs’ fears that the CATS service will take funding away from the Lancashire
Teaching Hospitals NHS Foundation Trust which will undermine its ability to
provide key services, especially Accident and Emergency provision on both its
hospital sites.
 GPs’ concerns over the weakened interaction with health care professionals
staffing CATS schemes.
 Absence of mechanisms to demonstrate to GPs and local people how the CATS
service will deliver improved services.
 Absence of reference or planning of continuance of the improved services on
termination of the contract.
 Absence of reference to risk assessment to current NHS services upon
termination of the contract.
FOR HOSPITALS
The evidence gathered from meetings with key NHS directors in Acute Hospital
Trusts in Central Lancashire indicates:
 Concerns that the planned CATS activities will not be carried out by existing NHS
providers even within existing resources.
 Concerns on the impact of the diversion of clinical activity and resources away
from diagnosis and clinical assessment on the future training of NHS staff.
 Concerns over the future viability of existing specialties following the
implementation of the CATS services, for example the diminution of ENT
provision.
 Concerns over the non-inclusion of an additional NHS provided CATS service to
enable a realistic comparison of the performance with the equivalent Netcare
CATS service. Implementation of the Chorley NHS CATS centre would enable
this comparison to be made. A better comparison would be between the ‘to be
negotiated’ NHS CATS centre at Preston and the Preston Healthport centre.
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Question 2b – How do you think these issues can best be addressed?
Our evidence is that there has been inadequate pre-consultation involving the NHS
family, patients, carers and the public. We wish it to be known, specifically, that this
Forum was not involved in any pre-consultation.
Our evidence from meetings attended is that there are seriously publicly-expressed
differences between Acute Hospital NHS Trusts, GPs and Primary Care Trusts as to
what exactly is being proposed, due to the shifting positions of the PCTs prior to the
last OSC meeting and in the interim. The consultation document basically lacks
clarity and sufficient detail about the proposals, evidenced by:
 the addition of further information placed on the CATS dedicated website since
publication of the consultation document
 the additional CATS leaflet published and distributed to clarify what CATS is and
isn’t
 and complete absence of information about current waiting lists and predicted
specialties and geographical areas where the 18 week target is not expected to
be met by December 2008.
In the light of all the complexity and unresolved issues to be addressed, we
strongly advocate that proper consultation takes place between the NHS
family, patients, carers, their representative bodies, voluntary/community
organisations, and the general public in accordance with common sense and
established good practice.
Section 3: Referrals and Patient choice
Question 3a - Do you agree that GPs should have a choice of whether to refer
patients to CATS services?
We agree that GPs should have a choice of whether to refer patients to CATS
services but only in consultation with the patient.
Question 3b – When should patients make their choice of preferred provider for
any further treatment following initial attendance at a CATS centre?
The patient should make the decision in consultation with their GP following CATS
attendance.
Question 3c – If GPs refer patients to CATS, should they be able to choose the
specific elements of CATS services that they believe are required for their
patient (eg direct access to diagnostic tests)?
This question is ambiguous. GPs should choose the specific elements, in
consultation with the patient, within their competence and professional responsibility.
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Question 3d – How should patients be informed about the availability of CATS
services?
All patients and members of the public should be informed by all means possible,
including the media.
Section 4: Specialties and clinical activities under consideration
Question 4a: Are the selection criteria (long waiting times, limited capacity and
suitability for community setting) and appropriate way of determining the
clinical specialties for CATS?
Yes.
Question 4b – Are the specialties and clinical activities under consideration the
right ones for Cumbria and Lancashire, particularly to ensure that no patients
are waiting longer than 18 weeks from GP referral to treatment in any
specialty?
There is insufficient information in the document to give an informed opinion. The
specialties under consideration in the document have been variously reduced in
number in different PCT areas following publication. Two cases, for example, are, at
the Lancashire County Council Adult Health and Social Care Committee meeting on
13 February 2007, the PCT Chief Executive informed the Committee that in East
Lancashire only 3 specialties were being considered and, in our area, only five
specialties were referred to in the Central Lancashire PCT’s staff newsletter
published recently on their website.
Section 5: Any other comments
As regards the consultation document, we are gravely concerned that the
consultation document is essentially a promotional vehicle for the merits of the
preferred bidder (Netcare) CATS services only. We also regret the constraints
enforced on the PCTs by the Department of Health CATS policies that prevented the
PCTs engaging properly, as they would normally, with patients and the public on the
key issues of concern.
We believe that the consultation process is inadequate, based upon the following
evidence:

pre-consultation, including pre-consultation with patients and the public and
representative patient and public involvement organisations, did not occur in
accordance with established good practice;
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



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the 8 week consultation period is too short and flouts the minimum 12 week
consultation period advised and stated in the Cabinet Office Code of Practice on
Consultation (criterion 1);
lack of clarity of the proposals, balance and absence of key information in the
consultation document to enable an informed understanding of the proposals, the
real issues affecting patients and the arguments for and against, all of which
necessitated the PCTs having to provide additional clarifying leaflets, 2 clarifying
reports to the Joint Health Overview and Scrutiny Committee, clarifying
advertisements in local press, and finally, continual clarifying information on the
dedicated CATS website - available only to a restricted cross-section of the
public;
restricted distribution of the consultation document in omitting to send the
consultation document to key organisations, for example, parish councils.
insufficient time to enable adequate consultation meetings to be arranged;
proposing policy changes ‘on-the-hoof’, during the consultation period, for
example, by introducing the principle of Plurality, and the further example, of
agreeing to operate NHS-run CATS facilities within NHS hospital settings, all
within the consultation period.
We include here a small sample of the comments we have received from patients
and the public which illustrate the public’s concerns about the consultation process:
“I went to the public meeting re: Clinical Assessment and Treatment Services
but was unable to get into the hall. I think that the hospital should be allowed
to run the service with the funding going to them not the private sector.”
“We wish you to tell us the full details and stop this cover up.”
“We feel very strongly that the CATS scheme is a dreadful mistake unless
carried out within the NHS. To say that it will only draw on “new” money
(whatever that means!) is just a way of obfuscating. Why not use this money
within the NHS to improve problem areas?”
“I am in favour of the new CATS centres. But employ NHS staff. There are
newly qualified doctors/nurses unable to find work. PS. I do not work for the
NHS.”
“We want a public vote not just a “sham” public consultation about the PCTs
plans in regards to the CATS.”
“Who decided to go independent sector Netcare? I have my grave doubts
over how this has been handled. Why have the patients not been consulted
before now? The publicity re: consultation has been terrible. The public do
not realise what is going on! PCT = Mr Blair’s/Mr’s Hewitt’s puppets. PCT
should question policy- not just go along for ride like sheep.”
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“We are very concerned about CATS arrangements – these have already
been set up and the so-called “consultations” are not so – we are just being
told what has been set-up – this is scandalous on such an important subject.
The public must be consulted first by these public servants. “
“This is not consultation. This is information giving i.e. This is what we are
going to do! Wrapping it up as ‘Patient’s Choice’ is a farce. This is
privatisation of the NHS.”
“The CATS consultation is CAT! I get the feeling that the public are being
made fools of by the PCT, SHA and Government because they are not being
listened to.”
Section 6: About you
This response is from an organisation:
Central Lancashire Community Health Link (a PPI Forum)
c/o Black Health Agency,
Farington Business Park,
Golden Hill Lane,
Leyland
PR25 3GG
We would like to receive a full version of the consultation report sent to our Coordinator, Pauline Blackie at the above address.
For further information about this response or the Central Lancashire Community
Health Link please contact our Forum Support Office, details below:
Central Lancashire Community Health Link
c/o Black Health Agency
Farington Business Park
Golden Hill Lane
Leyland
PR25 3GG
Tel. 01772 431195
Email: ppil@blackhealthagency.org.uk
Central Lancashire Community Health Link
Supporting Patient and
Public Involvement Forums
in Central Lancashire
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