Letter from Daniel Smith, Welsh Food Alliance
to the clerk of the Committee
NHS WALES BILL
The evidence to Welsh Members is presented in
two parts. Firstly, proposed amendments. Second, a response to
the ATM Review/Report on the future of CHCs (Annex 2). Please
find enclosed recent newsletters providing relevant information
about our work (not printed).
Members will observe that we have addressed
these issues from a public health perspective, in the spirit set
out in the Wanless Report. We welcome specific questions on our
evidence since they are based on the practical work of our members
who firmly support a long-term view in securing our future health
10 June 2002
Memorandum submitted by the Welsh Food
DRAFT NHS (WALES)
Briefing from the Welsh Food Alliance, to be
read in conjunction with Hilda Smith's response (see Annex 2)
to the ATM report. Suggested amendments in italics.
The Bill requires LHB and other NHS bodies to
consult CHCs on matters relating to health services. This essential
change needs to extend beyond NHS bodies, and include health-related
services. (The difficulty in using paragraphs 18 and 19 of the
1996 regulations is that it excludes a wide range of organisations
needed to consult with CHCs in their new role).
We need to extend beyond the current illness
service, and properly include health promotion and preventative
health aspects, as recommended by the Wanless Report"Securing
our Future Health: Taking a Long Term View" (April 2002).
Our amendments are designed to achieve this objective. (See our
comments about the need to integrate health and well being at
Policy and strategy across health and local
authorities needs to be strengthened to support the public health
function, which is currently lacking, has been emphasised by others
(see the article by Kevin Morgan and Gareth Williams, W Mail
11 June 2002, and the attached Alliance newsletter reference
to a Food and Health Policy Council and North Karelia (not printed
here). It is noted that we still await a public consultation on
Stage One of the NHS Public Health Review, promised earlier this
(3) Wales Centre for Health
(1) Functions of the Centre (page 2)
Insert new (b)
" (b) assess policy and evaluate
integrated working in Wales" at line 16
" (c) develop and share expertise in
promoting and sustaining public participation" at line
"Appointment of one/two pay members able
to represent a public interest point of view. "
Old line 18
(renumber old (c) and (d))
(4) Health Professions in Wales (page
(2) add new "(d) by the appointment
of appropriate lay representation" at line 9
(4) Health Professions Wales
(1) add new "(c) other specified health
and well-being professionals" line 40
(2) add new "(d) promote and sustain
the professional standards of training, testing, certification,
and retraining in relation to health and well-being in Wales.
(5) amend after care at line 38, by adding
"and health and well-being"
(6) amend after care at line 39, by adding
"and health and well-being"
Note: Changing situations demand different solutions
therefore we need to look imaginatively and with vision about
what the future may require, without having to seek further parliamentary
time. We have identified the need for a new multi disciplinary
profession termed a "Community Food Adviser". Therefore
we are seeking a generic term to cover such a new profession.
This aspect requires further consideration and clarification.
Schedule 1 Draft NHS (Wales) Bill
Clause 1 (a) after health service insert "
(including health promotion and health prevention services)
" line 8
Note: this enables the term "Health Services"
to reflect a health and well being agenda as far as one can within
the NHS Act 1977.
2(a) Insert after NHS Trust "local
authorities, and other bodies (including health-related elements
of local bodies partnerships) " at line 20-21
Note: this amendment seeks to include elements
such as drugs and alcohol abuse, and food security, where the
lead could be from non NHS bodies, such as the police, probation,
or local authorities.
2. New Sub Clause after (d)
" (e) the co-operation between Health
Authorities, Local Health Boards, Strategic Health Authorities,
Local Authorities, Primary Care Trusts, NHS Trusts and other Bodies,
and (Community Health) Councils with respect to such matters,
and on such occasions, as may be prescribed; " at line
Note: the term co-operation implies a duty to
work with CHCs, whereas the term consultation is weaker in terms
of the public having a role in participative policy formulation
as set out by the Health and Social Services Minister in her preamble
to the "Improving Health in Wales" 2001 public consultation.
Renumber (e) now new (f)
Second line, after "health," delete
service and insert "and related services" line 23
Old (f) line 28 should be amended to read "Health
Authorities. Local Health Boards, and other bodies" for reasons
Wales Centre for Health
Regulation 7(a) refers to the appointment of
Centre members. We strongly recommend that one or two appropriate
people be appointed who have sufficient knowledge and expertise
of health and related services who are able to represent a public
point of view in appropriately shaping the Centre's work. The
voluntary sector public health representation would seem to be
an appropriate place to identify such person(s). We see this as
a necessary check and balance, in a publicly accountable and funded
General Powers (page 9) at line 4 onwards
16(2) That includes, in particular
(a)(i) Co-operating with other
public authorities, and other bodies in the provision of information,
about matters related to the protection and improvement of health
Add "and the assessment of policy and
evaluating integrated working in Wales"
Add new sub clause (a) (ii)
" (a)(ii) developing and sharing
expertise in promoting and sustaining public participation related
to the protection and improvement of health in Wales. "
Food Policy Adviser
Welsh Food Alliance
10 June 2002
(Strengthening partnerships between the
voluntary sector and the NHS on Wales)
We have commented that this document is restricted
to partnership working between the Voluntary Sector and the NHS.
The local health partnerships will be key vehicles of work to
sustain health and well-being. This is particularly important
in addressing, for example, food security issues* (access, affordability,
availability) to which we see no reference in any WAG/NafW document.
Voluntary sectors also interface with Unitary Authorities, for
example, helping to sustain people in their homes. This area of
joint working is little mentioned yet vitally important. (*In
April we wrote to every Welsh MP concerning the EDM 607Food
Poverty Eradication Bill.)
Alternative Review of the Structure and
Staffing Arrangements for CHCs in Walesto be read in conjunction
with comments on the NHS (Wales) Bill
1. After reading (a) the Wanless Report
on preventive health and the integration of health and social
care, the CMO's Report "Health in Wales," and "Targetting
health improvements for all"; (b) drawing upon my own experience
of serving on CHCs, Regional and District Health and local authorities;
(c) community development expertise; and (d) in preparing evidence
for "Better HealthBetter Wales" Mark 2;
1 have come to the following conclusions:
2. In my view the main recommendation is
streamlined line management via the Association and large Federations.
This flies in the face of the evidence provided by Health Authorities,
Local Health Groups and Hospital Trusts. This review has an emphasis
on the importance of line management issues, rather than ways
of encouraging public involvement and representation, which in
my view is essential.
3. A locally based and focused CHC is in
a much better position to become a vital part of local community
life and to interact effectively with primary and community care
providers, health service commissioners and local Health Alliances.
At a time of decentralisation of most Health Authority functions
to local Health Boards it appears contradictory to further centralise
CHCs. It is at the local level where co-terminosity is most important,
but this requires higher level strategy and policy to support
the public health function, which is currently lacking.
4. Therefore this review ignores the fundamental
function of CHCs which is to represent and reflect the interests
and concerns of individuals and local communities. Has any evidence
been sought from individuals or communities that have used CHC
services, of from relevant voluntary and community organisations?
5. The reason why CHCs vary so widely in
the range and quality of services they provide is not the absence
of centralised line management, as it is suggested, but the absence
of guidelines and performance monitoring arrangements. The Association
should be developed to provide these servicesand to undertake
research into user and community involvementrather than
as indicated in the central control of staff.
6. Have any surveys been conducted into
general public knowledge and perception of CHCs, and the important
work they should be doing for the local community?
7. It is essential that CHC staff be answerable
to their local members, not to remote Federations, or to Association
officials. For example, in Newport I suggest that a local CHC
officer with a remit and overall responsibility for Newport, would
be more effective in developing relationships, both statutory
and voluntary, and a cohesive integrated approach to participative
policy development that is required.
8. The report recommends that all members
should be "selected by and open and local appointment process."
This is very imprecise, for what body would be responsible for
making the appointments, which must be open and accountable? Any
appointment process should be arms length from the CHC itself,
and appointed according to Nolan principles, and properly supervised
by the National Assembly Public Appointments Unit. We should aim
to have every sector of the community represented, including the
disabled and the immune compromised. There should be no age discrimination.
This will ensure a wide coverage of major issues of concern to
both health and local authority functions, and be a means of integration,
which will be of increasing importance.
9. An alternative would be to organise public
elections, but this could possibly politicise CHCs and would not
ensure a cross-section of people with different experience and
interests. However it would give the public the opportunity to
participate fully in electing their representatives, and taking
a keener interest in health related issues in their community.
10. Membership should include people who
have a commitment to public health and preventive measures. In
terms of joint working this is important. What is required is
to make public health more integral of the CHC and the local authority,
which will fit into the pattern desired by the National Assembly
for Wales. This will make the CHC link with local Health Alliances
more effective. The CHC should also be required to submit reports
to the local authority led local Health Alliance.
11. This can be beneficial as members often
have considerable knowledge and experience in their selected field.
However, it is essential that they be locally based, and locally
represented, with an understanding of the importance of health
12. There is an advantage in maintaining
two members appointed by the National Assembly for Wales. That
is not reflected in the NHS Wales Bill. This will help ensure
that local CHCs are appraised of national issues which local members
should be aware of in the dynamic environment within which health
and social care now operate. They should be selected from lists
of people responding to advertisements. All NafW members should
meet on a twice-yearly basis with the Minister to report progress
but also to be appraised on the national issues that the NafW
felt should be taken on board by local CHCs. This could help ensure
that we develop integrated local policies that reflect not only
needs of patients and users of local services, through tracking
the considerable increase in public expenditure on health and
social care, but are in line with overall Welsh Assembly Government
policy, which also has an emphasis upon prevention ands public
health, as part of a long term strategy.
13. It is essential that CHCs should be
co-terminous with LHG/LHBs. They must be given adequate resources
and guidance, and their resources should be monitored and evaluated
to include the wider public health agenda.
14. CHCs should be required to liase at
NHS Trust level to monitor the provision of hospital and specialist
services, and at the Association level to agree guidance and monitoring
procedures, and a co-ordinated response to national policy issues.
15. CHC staff should be accountable to CHC
members via the chairperson. Employment functions for CHC staffbut
not general line management responsibilitiesshould be the
function of an independent body funded for the purpose by the
National Assembly for Wales.
16. All meetings of the CHC, including Association
and Federation Executive meetings should be open to members of
the public, and should be held where they are accessible by public
transport, with adequate publicity to encourage wider public involvement.
Staff and their continuous professional development
are important aspects of an efficient and effective CHC. Equal
attention should be given to CHC members as valuable human resources.
This report does not address the wider aspect of how CHC's operate
in a new environment of co-terminosity, which will be of increasing
importance in ensuring that all members are accountable and function
in their local area.
It is in this way that CHCs in future will be
acknowledged for their effectiveness in improving local health
and well being. They will have the important role as a check and
balance which all systems require. This will also require effective
communication and participation of local people if we are to realise
the promise set out by the First Secretary and the Health Minister
in the report "Improving Health in Wales."
It will also ensure the most effective use of
large amounts of public expenditure on CHCs, that we live up to
the faith and expectations of the Minister in keeping CHC structures
in Wales, and that the considerable increases in public expenditure
are spent efficiently and effectively in improving health and
well being in Wales, with increased public participation.
Note: Our report should be read in conjunction
with the ATM consultants report, the Ministers letter of 28 March
2002, and a second forthcoming consultation on the NHS (Wales)
Bill, on additional CHC functions and other matters. (not printed)
Welsh and Food Alliance
10 June 2002
NHS Wales Bill, and the future role and
effectiveness of CHCs
1. REPORT OF
1.1 Today the Press Release, and the Patient
Consultation Report, including 350 comments from members of the
public in the Castleton/ Marshfield Areas (Newport) arising from
the proposed withdrawal of services deserves studying. Not only
about the lack of primary care services and relating this to inadequate
public transport, population growth, but of the lack of an effective
service, brought to the attention of the CHC only by the threat
of closure of temporary GP services.
Shortcomings now revealed by this survey:
(1) Why did the Newport CHC, as a CECEwatchdog11,
not know of the poor primary care position earlier? What of other
(2) Are the public aware of, and therefore
able to make the their views known to this CECEwatchdog11?
(3) From this report, services at St Mellon's
(Cardiff) appear less than adequate. Is there a poverty of expectation
is some areas?
(4) Significantly, in a changed system next
year, without a good surveillance, and clinical governance system,
how are we to ensure that the checks and balances within the system
that the CHC provides will be effective?
(5) What can we learn from the Castleton
Report that will help us to reform the work of CHCs? What changes
will be required to have an effective surveillance system with
CHCs empowered to have a wider role and an effective membership?
With the dearth of people to work in a voluntary capacity (for
example, school governors), and with increased duties as proposed,
how will we be able to obtain the quality and number required?
If we fail in this then the whole policy of keeping CHCs in Wales
OF CHC ROLE
2.1 I can make available representations
made by the Family Planning Association (FPA) in 1974, that was
agreed by the incoming Health Minister of the new Labour government.
This changed policy so that the new government accepted the necessity
of CHC independence if they were to command public confidence.
An important issue is raised at paragraph 22 of the FPA document,
where it states "they should be in accommodation which is
separate from any of the offices or hospitals of the AHA in order
to ensure that they are not only independent but seen to be so".
2.2 We are not now adhering to this in Gwent,
for example. The checks and balances I believe are impaired where
there is a public perception, whether true or otherwise, that
CHCs are controlled and part of the Health Authority. For the
sake of our impartial role, we should continue to strictly adhere
to this principle.
2.3 It will be even more important in future
when GPs as independent contractors, are part of delegated LHB
arrangements, with enormous control over budgets for health and
community services that will be integrated at the local authority
level. CHC members should have voting rights, and with the voluntary
sector, take the lead in public involvement and consultation matters.
3. HOSPITAL VISITING
3.1 How can we reduce the onerous duties
placed upon voluntary CHC members? One apparently obligatory duty
is hospital visiting. Is this essential for all members? A small
team could take this responsibility. There are other ways of collecting
information from patients. A slip of paper put into a locked CHC
box on departure, and collected, analysed, and reported upon by
CHC member to a subsequent meeting should be sufficient.
3.2 NHS managers should effectively control
standards of cleanliness and repair in NHS wards, toilets and
showering areas, with appropriate quality control systems in place.
This is not rocket science, and occurs in Motorway Service Stations,
where the contractor is obliged to promote and maintain standards.
3.3 Psychologically it is wrong to be put
in a situation of having to speak with patients about possible
complaints with a senior staff member present. Often all that
is achieved is feed back from staff and there ought to more adequate
ways of achieving this through the system.
3.4 Some CHC members may not, through disability,
be able to visit medical wards. More people now have immune deficiency,
and should not be prevented from serving on CHCs if we are to
have an inclusive equalities policy.
I hope Committee members find this submission
20th June 2002