Policy responses and statements
- Name of organisation:
- Welsh Assembly Government
- Name of policy document:
- National Framework for Continuing NHS Health Care
- Deadline for response:
- 30 May 2008
Background: The draft Framework provides guidance to underpin decision-making on the provision of continuing NHS health care for adults, and the arrangements to support this decision-making, including disputes and complaints procedures. It will replace existing guidance WHC (2004) 54/NAFWC 41/2004 and WHC (2006) 046/NAFWC 32/2006
The draft Framework also aims to deal with the decision making process. Attached to the revised framework is a decision support tool which has been produced by the Department of Health for England. It is proposed that this should be used in Wales with the aim that it provides a more consistent approach in the interpretation of the eligibility criteria for Continuing NHS Health Care.
Purpose:
The purpose of this revised framework is to provide a consistent foundation for the processes involved in the assessment for commissioning and provision of NHS Continuing Healthcare across Wales. In particular, the intention is to ensure that there is a consistent, equitable and appropriate application of the decision making process determining eligibility for continuing NHS health care. This framework will provide the basis for implementation across Wales and will influence the development of revised local implementation plans that reflect and respond to local needs and service provision. Whilst the Local Health Boards will lead on the revision of existing implementation plans, this will be done in conjunction with all relevant local partners to ensure that the final document takes into consideration the legal responsibilities of Local Authorities and other partners.
COMMENTS ON
WELSH ASSEMBLY GOVERNMENT
NATIONAL FRAMEWORK FOR CONTINUING NHS HEALTH CARE
The Royal College of Physicians of Edinburgh is pleased to respond to the Welsh Assembly Government on its consultation on a National Framework for Continuing NHS Health Care. The College has consulted with a number of Fellows actively working in Wales, and has previously responded to a similar consultation on the National Framework for NHS Continuing Health Care in England.
As in other parts of the UK, the need to consider criteria for NHS Continuing Health Care has arisen because of the reduction in the number of continuing health care beds in specialties such as Geriatric Medicine, Psychiatry, Learning Disabilities and Young Disabled Services, and an increasing emphasis on Community Care. Traditionally, the NHS would have funded all care costs including accommodation costs in these institutions but, as the consultation document points out, day-to-day care and accommodation costs in the patient’s own home would not normally have been met by the NHS. The issue that arises, therefore, is mainly in relation to alternative institutional provision such as private nursing homes and the extent to which the NHS should be responsible only for the nursing care, or for all care costs. The requirement for local authorities to means test their services adds further complication to this picture. In Scotland, the concept of free personal care has to some extent simplified this process, and the promotion of joint working between local authorities and health services in community health partnerships has produced many fewer problems in this respect than has been experienced in England and Wales.
The desire to have a fair and consistent approach is, however, to be welcomed and as a body of clinicians we recognise the difficulties and complexities of trying to apply a cut-off point in what is a continuum of health care. It is important in this assessment and decision making process that the patient should be at the centre and that a holistic and pragmatic approach be taken, and we therefore particularly welcome paragraphs 27 through 30 of the draft guidance. It is important that the assessment is multi-disciplinary eg in the field of geriatric medicine this process is well established with hospital multi-disciplinary teams. Concern has been expressed by our Fellows at the complexity of the paperwork associated with the decision support tool. There is an opportunity here to look at assessment processes in their totality and to aim to simplify paperwork between health and social services, both for people who require NHS continuing health care and also those who require lower levels of NHS input. A single assessment process would seem, in these circumstances, to make a lot of sense.
In previous responses, the College was also keen that government departments recognised that patients’ health care needs may change, and the emphasis in this present consultation on reassessment is to be welcomed. However, the implication in the consultation that all patients ie both those receiving NHS continuing health care and those receiving lesser levels of service would be reassessed after 3 months suggests a workload that might be very difficult to complete in the time scales envisaged.
The emphasis in paragraph 47 that the clinical opinion of the medical staff responsible for the patient must be included is clearly welcome. The guidance in paragraph 75 that the decision of the multi-disciplinary team should only in exceptional circumstances be rejected, and not for funding reasons, is also to be welcomed.
It does seem from a clinical view point that much of this guidance is made necessary by the different funding mechanisms for health and social services. There remains, therefore, an opportunity to look at joint funding for this type of care for chronic long-term conditions. The abolition of the distinction between health and social services funding would, at a stroke, simplify the system and remove many of the current grounds for contention and debate.
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
[30 May 2008] |
