Policy responses and statements

Name of organisation:

Scottish Executive Justice Department: Safer Communities Division

Name of policy document:

Draft National Quality Standards for Substance Misuse Services

Deadline for response:

28 April 2006

Background: The Action Plan in October 2004 which followed the Executive's Review of Drug Treatment and Rehabilitation Services recommended development of national standards with an emphasis on outcomes for service users, together with systems for monitoring and evaluation. This recommendation addresses the lack of an overarching agreed framework which describes the quality of provision and delivery required in services for drug misusers and people with alcohol problems.

To begin this process, representatives of drug and alcohol services, service commissioners and regulatory bodies such as the Care Commission and the Social Work Inspection Agency have met with the Executive to plan a workable framework of quality standards which focus particularly on practical aspects of the quality and integration of services for people with substance misuse problems.

The Steering Group arrived at a consensus about the principles which should underpin the development of quality standards and a framework in which these standards are set.

There should be a set of common standards across Scotland, published by Scottish Ministers but with local ownership.

• There should be no added burden on services (in the form of another layer of inspections) without being of clear benefit.
• Any evaluation of the use of quality standards should be supportive and address those aspects of practice not covered in existing inspections.
• The standards will cover both drug and alcohol services.
• The implementation of the standards will seek to improve services.
• Development should build on existing good practice.
• There should be substantial service user and community input to any evaluation of the implementation of the standards.

The Steering Group has also drafted 11 overarching standards, each with its set of underpinning statements, and the Executive sought views on these.

COMMENTS ON
SCOTTISH EXECUTIVE JUSTICE DEPARTMENT
DRAFT NATIONAL QUALITY STANDARDS FOR SUBSTANCE MISUSE SERVICES

The Royal College of Physicians of Edinburgh is pleased to respond to the Scottish Executive on its consultation on the Draft National Quality Standards for Substance Misuse Services.  The College welcomes the development of these quality standards and bases its comments on discussions in the Scottish Intercollegiate Group on Alcohol, of which it is a constituent member.

The Quality Standards were arrived at by a steering group which involved representatives of drug and alcohol service commissioners and regulatory bodies such as the Care Commission and the Social Work Inspection Agency.  They reached consensus about the principles that should underpin the development of quality standards.  It is noteworthy that the standards will count for both drug and alcohol services.  They have drafted 11 overarching standards, each of which has a set of underpinning statements, and we are invited to comment on these.

It is noteworthy that the paper emanates from the Justice department, and this may imply that they are chiefly concerned with services for offenders or those where an element of coercion is involved.  The majority of patients with drug and particularly alcohol problems attend on a voluntary basis and are treated as out-patients.  Residential care is rarely required.  It is surprising that the Health Department does not seem to have a prominent part in this consultation.

THE STANDARDS

The ambitions of the standards are admirable.  The problem will be in implementing them and in ensuring that they are uniformly distributed throughout Scotland.

Statement 1 concerned with providing the client with “all the information needed to help you decide about using the service” seems eminently sensible.

Statement 2 involves access to quality surroundings when engaging with the service.  This is a praiseworthy aim.  The supporting statement here states, “The service will employ and train its staff to make sure you are treated with respect and dignity” might also add “with evidence-based effective therapies”.

Statement 3 concerns involving the patient in a full assessment “which makes sure that decisions about your care and support are based on your needs”.  This is good practice but conflicts with some of the later statements where the needs of the family and the community are also given understandable priority.  It does not address the problem when the needs emphasised by the individual conflict with the apparent needs of others.

It also raises the question of sharing information with other services.  There is no mention of the “need to know” principle, and some clients may be concerned that this waiving of the right of confidentiality is not really addressed in this document.

Statement 4 concerns receiving a personal plan “setting out the service that will be provided to meet your needs”.  This is a reasonable and attainable request.

Standard 5: “The service will work with you to achieve the jointly agreed actions in your personal plan”.  This seems self evident, but of course the quality with which this is delivered varies considerably and it is good to have this standard established.

Statement 6:  “You will be able to discuss and plan your long-term support with service staff involving your family, other organisations, services or representatives as appropriate”.  The question of appropriateness in whose eyes, perhaps needs to be considered.

Statement 7 concerns quality, support and care and this is a very reasonable requirement.

Statement 8:  “The service will work with a wide range of partners including other services so that your needs are met”.  This wide-ranging standard will have huge implications for the quality of services in a community, if rigorously applied, particularly the requirement for local services to be able to meet the needs of specific identified groups and the need for evidence-based practice.

Statement 9: “The service you receive has been designed with you, your family and the needs of the local community in mind” again raises the question about who determines the limits of involvement of other services and other individuals.  The phrase “how the local community are involved with the service will be clearly laid out” raises questions again of the freedom of the individual and confidentiality and needs to be clarified.  For example, the requirements would be different for offenders compared with others.  There is no opinion given on the balance of needs between what may be competing interests.  Hopefully, in most cases they will be pulling in the same direction.

Statement 10:  “Your views will be sought in order to constantly monitor the type, delivery and development of services”.  This concerns the acceptability of the service to the user.  It does not concern efficacy that is in some ways an even more important question.

Statement 11: “You will have all the information you need about arrangements for ending your contact with the service”.  This seems a reasonable expectation, although some may be concerned about passing on information on to others and grounds for doing this.

CONCLUSIONS

The Standards seem equally applicable to individuals with alcohol and/or drug problems.  It is disappointing that so little emphasis is placed on the use of evidence-based practices.

The goals are admirable, but there is a danger that they will be viewed as a “wish list”.  What sanctions can be brought to bear if a local community does not achieve these standards and what extra resources will be available to make it attainable?

 The vast majority of people with alcohol and drug problems are attending of their own free will and on a voluntary basis.  It is questionable whether it is right that in seeking help with these particular conditions they should waive some of their rights to confidentiality.  On the other hand, some of the individuals will be attending as a result of a Court order, or as part of a Social Work supervision programme.  Their rights are somewhat different from those who are attending on a purely voluntary basis.  These issues have not been addressed in this paper, but are important in determining the appropriateness of some of the standards.

Copies of this response are available from:

Lesley Lockhart,
Royal College of Physicians of Edinburgh,
9 Queen Street,
Edinburgh,
EH2 1JQ.

Tel: 0131 225 7324    ext 608
Fax: 0131 220 3939

[28 April 2006]