NHS Lincolnshire West
Clinical Commissioning Group (CCG)
Equality Strategy 2015 – 2018
Outlining our strategic direction in Equality, Inclusion and Human Rights (EIHR)
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Table of Contents
Foreword ……….......................................................................................................2
1. Background..........................................................................................................3
1.2 Our Values .........................................................................................................4
1.3 Demographic Information....................................................................................4
2. Legislative Framework ..........................................................................................5
2.1 Equality Act 2010.................................................................................................5
2.2 Public Sector Equality Duty (PSED)....................................................................5
2.3 Specific Duties for Public Sector Bodies..............................................................6
2.4 NHS Equality Delivery System (EDS2)................................................................7
3. Inclusion and equality ............................................................................................8
3.1 Linking Equality Objectives to the CCG’s vision and values…............................9
4. Information sharing and engagement.....................................................................9
5. Review and Renewal..............................................................................................10
Appendix 1 .................................................................................................................11
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Foreword:
NHS Lincolnshire West Clinical Commissioning Group (CCG) has committed to fully meeting
the diverse needs of our local population and workforce, ensuring that none are placed at a
disadvantage over others. The CCG is committed to take into account current UK legislative
requirements, embed them into procedures and deliver best practice. The CCG has from
inception in April 2013 followed the NHS Equality Delivery System (now EDS 2).
This strategy sets out the CCG’s intentions around Equality, Inclusion and Human Rights
(EIHR) for the next three years. The CCG has recently set its own five year plan following
on from the NHS Five Year Forward view. This strategy details the CCGs intentions
designed to ensure that EIHR remains at the heart of what we do. By doing so, the CCG
ensures the best possible outcomes for the local community; CCG staff and especially those
seldom heard groups who experience Health Inequalities. The CCG has an obligation to
understand and take action to reduce Health Inequalities for the population it serves as part
of the requirements of the Health and Social Care Act 2012.
The CCG is committed to identifying and understanding the healthcare experiences of the
population it serves, narrowing the gaps in the health of the population, raising the quality of
care and maximising the value and effectiveness of resources spent by or on behalf of the
CCG. At the heart of this is the recognition that every member of staff and every
organisation contracted to provide a service on the CCG’s behalf have a shared role in
delivering this aspiration. The Social Value Act legislation links with this and requires the
CCG to review and use its purchasing power to improve economic and environmental
wellbeing within the community it serves.
As a local employer the CCG is strongly committed to setting a best practice example. The
CCG aspires to pay all staff at the Living Wage and to work with NHS and non-NHS Provider
organisations to ensure that they also pay staff at or above the Living Wage.
The CCG is committed to understanding the needs, views and experiences of the population
it serves. In short the CCG commits to engage effectively, regularly and inclusively with the
wider population as part of its decision process. This includes, but is not limited to, the
protected characteristics of their age, disability, sex (gender), gender reassignment, sexual
orientation, marriage and civil partnership, race, religion or belief, pregnancy and maternity
status.
The CCG commits to ensure that when making decisions, appropriate and proportionate
consideration is given to; gender identity, socio-economic status, immigration status and the
FREDA principles of the Human Rights Act 1998.
Richard Childs
Lay Chair
Lincolnshire West CCG
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1. Background
Lincolnshire West Clinical Commissioning Group (CCG) covers an area to the West of
Lincolnshire which includes the city of Lincoln and the town of Gainsborough. It represents
37 General Practices. These practices provide services for people across 3 council areas,
being Lincoln, West Lindsey and North Kesteven. The CCG has approximately 223,770
people registered with a local GP.
The CCG is committed to ensuring that current and potential staff as well as NHS service
users will not be discriminated against on the grounds of social circumstances (including
relationship status) or background, gender and gender identity, race, age, disability,
pregnancy / maternity status, sexual orientation or religion. The CCG commits to work with
staff, providers, partners, patients, carers and communities to improve the health of our
population and reduce health inequalities for the people of Lincolnshire.
This strategy outlines Lincolnshire West CCG’s strategic direction in meeting the needs of
the population it serves, improving outcomes for that population and ensuring compliance
with the Public Sector Equality Duty and other relevant legislation.
1.2 Our values
Our values, as determined by our member practices, define our culture and shape our
decision making.
We will use our values to drive our ambitions for Lincolnshire West as we continue to move
forwards;
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Patient centered, population focused services (considering the individual patient
needs and the needs of the population as a whole).
Quality focused (securing high quality, safe and effective health services for all).
Working together (delivering through strong partnership, comprehensive engagement
and good communications).
Innovating for improvement (creating an environment for involvement, innovation and
improvement).
Using resources responsibly (maximising use of limited resources balancing
competing needs).
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1.3 Demographic Information
Lincoln
Lincoln’s population has grown by 5.5% between 2000 and 2010 and it is estimated to be
89,700. 2008 projections show that it is predicted to grow to 95,800 by 2033.
The mid-2010 population estimates show the population of Lincoln to be 89,700. This is
made up of 15,100 people aged 0-15, 61,100 people aged 16-64 and 13,500 people aged
65 years and over.
There is a relatively even split between males and females, with 43,800 males estimated to
be living within the city boundary, compared to 45,800 females.
In November 2010 there were 740 working age people living in Lincoln claiming disability
related benefits.
Approximately 92.6% of Lincoln’s population is white British. The second largest group
identified is “other white”. Our knowledge of Lincoln suggests that a large proportion of this
would be Easten European migrants. The next largest group includes “Asian or Asian
British” people, followed by “Chinese or other ethnic group”.
Lincoln has the highest rate of homelessness, 4.65 per 1,000, more than twice the county
average of 2.19.
West Lindsey
The district of West Lindsey is the largest in the County of Lincolnshire, covering115,773
hectares (447 square miles). With a 2010 mid-year population estimate of 89,400, it is also
Lincolnshire’s most sparsely populated district, having just 77 people per hectare.
The population in this district is increasing at a rate higher than average for the country,
although this rate is currently decreasing. It is forecasted that the population will be around
111,800 by 2033. There are great differences in the characteristics and levels of need
across the district. Some wards rank among the highest levels of deprivation in the country
while others are among the most affluent.
With 20% of residents being over 65, the district has a significant elderly population, which is
growing as more people retire to the area. The increase in this aspect of the population is
counteracted by a reduction in the number of young people in their 20’s by 25% and in their
30’s by 22%. As such it is estimated that only 58% of the population will be of working age in
the next 10 years.
Only 2.4% of the population are from ethnic minority groups, compared to 16.4% nationally.
This figure rises to 3.6% in Gainsborough. Compared to other districts in Lincolnshire, West
Lindsey has seen little in-migration from the Accession countries.
Current disability levels in the district are similar to the national figures at 18.7% of the total
population. However, this is expected to rise as a proportion of the overall population as the
population ages. 8.32% of the population of Gainsborough South West ward are claiming
incapacity benefit or disability allowances, twice the average for the district.
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North Kesteven
The District of North Kesteven is a large, diverse, rural area, stretching from the Witham in
the east almost to the Trent in the west and from the sparsely populated villages to the south
of Sleaford to the more densely-populated Lincoln fringe in the north.
North Kesteven is one of seven districts in Lincolnshire and covers an area of 92,244
hectares (356 square miles). The District is characterised by small settlements and large
areas of arable farmland; 90% of land in the district has been classified as agricultural.
There are around 100 communities in the North Kesteven District. The population of the
District is 109,906 (Office for National Statistics mid year population estimate 2013).
There are two towns with approximately 17,671 people in Sleaford and 13,884 in North
Hykeham (Census 2011). Almost 40% of North Kesteven’s residents live in communities in
the Lincoln “fringe”, the area immediately surrounding Lincoln City (including North
Hykeham) and about 15% live in Sleaford.
Of the remaining 45%, about half live in 57 communities with fewer than 1,000 people and
the other half live in communities, not in the Lincoln fringe, with more than 1,000 people.
In many ways the North Kesteven population shows “traditional” characteristics.
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61% of the population aged 16 or over is married, the second-highest proportion in
England & Wales.
82% of the population describe themselves as Christian, the second-highest
proportion in the East Midlands (ONS, 2001).
99% of the population is white, compared to the national average of 91%. This
makes the District the seventh lowest in the East Midlands in terms of its black and
minority ethnic population and 65th lowest in England and Wales (ONS, 2001).
In broad terms, the age profile of the District is similar to the national average. The
mid-2008 population estimates (ONS1, 2009) show 23% of the population is aged 19
and under, 58% of the population is aged 20-64 and 20% of the population is aged
65 or over. However, these figures mask significant differences within finer age
bands. The proportion of children of infant school age and below is less than the
national average, the number of 20 to 34-year-olds is lower than the national
average, whilst 55-year-olds and older are over represented in comparison to the
national figures (ONS2, 2008). The number of people aged over 65 in the District is
projected to further increase and be over 5% higher than the national figure by 2016
(ONS2, 2008).
Health - whilst health outcomes are generally good, there are specific pockets of
health inequality related, in particular, to gender (men) and level of deprivation and
District-wide challenges related to obesity, road safety and the increase in the 50
plus population over the next few years.
Demographic change - the increase in the 50 plus population is a general challenge,
which requires attention, in terms of the accessibility to services and the
environment, reducing poverty and the development and co-ordination of services for
older residents, particularly related to independent living.
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2. Legislative Framework
2.1 Equality Act 2010
The Equality Act received Royal Assent in 2010 with the majority of the provisions coming
into force on 1st October 2010. Further provisions came into force as follows:
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Positive action; recruitment and promotion – 5 April 2011
Public Sector Equality Duty (PSED) – 5 April 2011
Age discrimination protections in the provision – 1 October 2012 (of services and
public functions)
In addition to the Act, specific duties were identified and came into force on 10 September
2011 as The Equality Act 2010 (Specific Duties) Regulations 2011. These specific duties
require public bodies to publish relevant proportionate information showing compliance with
the PSED, and to set Equality Objectives. The Equality Act unifies and extends the previous
100 pieces equality legislation and regulations. The Act identifies nine characteristics as
protected by the Act:
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Age - including specific ages and age groups
Disability - including cancer, HIV, multiple sclerosis, and physical or mental
impairment where the impairment has a substantial and long-term adverse effect on
the ability to carry out day-to-day activities
Race - including colour, nationality and ethnic or national origins
Religion or belief - including a lack of religion or belief, and where belief includes
any religious or philosophical belief
Sex
Sexual orientation - meaning a person’s sexual orientation towards persons of the
same sex, persons of the opposite sex and persons of either sex
Gender re-assignment - where people are proposing to undergo, are undergoing or
have undergone a process (or part of a process) for the purpose of reassigning the
person’s sex by changing physiological or other attributes of sex
Pregnancy and maternity
Marriage and civil partnership
2.2 Public Sector Equality Duty (PSED)
Section 149 of the Equality Act 2010 imposes a duty on public authorities in the exercise of
their functions to have due regard to the need to:
1. Eliminate unlawful discrimination, harassment and victimisation and any other
conduct that is prohibited by or under the Act.
2. Advance equality of opportunity between persons who share a relevant protected
characteristic and persons who do not share it.
3. Foster good relations between persons who share a relevant protected characteristic
and persons who do not share it.
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The CCG has committed that as part of the decision process officers will ensure that robust
and proportionate Equality Analysis and Due Regard is taken around any decision which the
CCG takes. In addition the CCG will ensure that this can be effectively demonstrated.
I.
Eliminating discrimination:
a. The Act prohibits direct and indirect discrimination, harassment and
victimisation of people with relevant protected characteristics
II.
Advancing equality of opportunity involves:
a. Removing or minimising disadvantage experienced by people due to their
personal characteristics
b. Meeting the needs of people with protected characteristics
c. Encouraging people with protected characteristics to participate in public life
or in other activities where their participation is disproportionately low.
III.
Fostering good relations involves:
a. Tackling prejudice, with relevant information and reducing stigma, and
b. Promoting understanding between people who share a protected
characteristic and others who do not.
Having due regard entails considering the above three aims of the PSED in all the decision
making as in:
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How the organisation acts as an employer
Developing, reviewing and evaluating policies
Designing, delivering and reviewing services
Procuring and commissioning
Providing equitable access to services
The legislation acknowledges that in some circumstances compliance with the PSED may
involve treating some persons more favourably than others, but not where this would be
prohibited by other provisions of the Act.
2.3 Specific Duties for Public Sector Bodies
Public authorities for the purpose of the Public Sector Equality Duty (PSED) are listed in
Schedule 19 of the Act. NHS organisations are listed as public authorities. In addition,
bodies that exercise public functions are subject to the PSED in the exercise of those
functions (see section 149(2) of the Act). The provision of commissioned NHS services is a
‘public function’.
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The Equality Act 2010 (Specific Duties) Regulations 2011 require all listed public bodies to:
1. Publish information to demonstrate its compliance with the duty imposed by section
149(1) of the Act. This must be done no later than 31st January 2012 and at
subsequent intervals not greater than one year beginning with the date of the last
publication.
2. Prepare and publish one or more objectives, by 6th April 2012 and subsequently at
intervals not greater than four years, it thinks it should achieve to do any of the things
mentioned in section 149 of the Act.
Note: As the formal responsibilities of Clinical Commissioning Groups (CCGs) did not come
into effect until 1st April 2013, the initial duty to prepare and publish objectives for these
public bodies has been set to 13th October 2015.
The publication of information needs to include the following:
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Its employees (for authorities with more than 150 staff)
People affected by its policies and practices (for example, service users)
The information must be published in a manner that is accessible to the public
Procurement and commissioning (anyone who exercises public functions, must also,
in the exercise of their functions have due regard to this duty)
2.4 NHS Equality Delivery System (EDS2)
“EDS will support CCGs to provide fair, accessible and appropriate services to meet the
health needs of all patients while helping to ensure equity in quality and reduced health
inequalities.” (Dr Amrik Gill, GP)
The Equality Delivery System (EDS2) framework was designed by the NHS to support NHS
organisations to meet their duties under the Equality Act.
The EDS2 has four goals, supported by 18 outcomes. The CCG will use the EDS2 as a
toolkit to meet the requirements under the Equality Act and we believe this will impact
positively across all the activities of the CCG.
The CCG has published its EDS2 evidence on its website annually in line with the January
deadline. In addition the CCG has published its Equality objectives in line with the October
deadline and these objectives, combined with updates on progress can be found on the
relevant page via the link below.
http://www.lincolnshirewestccg.nhs.uk/equality-and-diversity
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Compliance with the EDS2 model is key to the CCG’s strategy since the following goals
focus towards the CCG’s priorities around patients and staff.
The four EDS2 objectives are:
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Better health outcomes.
Improved patient access and experience.
A representative and supported workforce.
Inclusive leadership.
For each EDS2 outcome, there are four grades to choose from:
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Excelling (all protected groups) – Purple
Achieving (for most (6-8) protected groups) – Green
Developing (for some (3-5 protected groups) – Amber
Undeveloped (no evidence at all, few or no protected groups) – Red
It is the CCG’s intention to attain a minimum of ‘achieving’ across all four goals within the
timeframe of this strategy.
3. Inclusion and equality
Responding to the requirements as outlined above offers many challenges and opportunities
for the CCG. Responding to them individually will ensure compliance and unnecessary
duplication. Taking account of the CCG’s constitution, vision and priorities, the need to be
transparent, accessible and engaging with patients and communities and making sure that it
takes account of the diverse health needs of their growing complex and diverse communities
require an inclusion and equality strategy to ensure direction. This strategy thus seeks to
embrace everything that the CCG aspires to achieve in the coming years.
At the heart of this strategy is a new approach to integrate inclusion and equality issues into
everything that we do. By becoming an inclusive organisation, one that listens, and responds
to the people (patients, staff, partners and stakeholders) it serves, by meeting their diverse
needs and addresses the local health inequalities successfully, the CCG will be an efficient,
effective and productive organisation.
The inclusive approach will not only deliver on legal obligations but also provide a direct
synergy with the work on quality and addressing health inequalities. This can be achieved by
focussing on improving the organisations’ performance whilst reducing inequitable health
gaps between characteristic groups and communities. These are usually associated with
poor levels of ill-health, take-up of treatment, and the outcomes from healthcare given that
some people from protected groups are at times disproportionately affected and as a result
experience difficulties in accessing, using and working in the NHS.
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When analysing the outcomes for services and employment, we will also extend the analysis
and engagement beyond the protected groups to other groups and communities who face
stigma and challenges in accessing, using or working in the NHS. For example, carers,
people who are homeless, sex workers and people who use recreational drugs.
By developing this integrated model of addressing inequalities and providing an equitable
and fair service to all the residents in the area we believe we will be more successful in
meeting our various obligations and local needs.
3.1 Linking Equality Objectives to the CCG’s vision and values
Our former Equality Objectives:
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Better health outcomes for all
Collation of evidence to demonstrate changes made as a result of CCG involvement.
Reduction in equalities
Access in equalities
Access to service not denied on unreasonable groups.
Engaged and well supported staff
Inclusive recruitment and selection and access to flexible working
Work carried out to complete objectives to date:
Key activities this year have been:
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Developing and delivering equality and human rights training for staff and Governing
Body members
Developing a local equality and diversity competency framework for staff and
Governing Body members
Ensuring that providers are required to monitor equality as part of their service level
agreements
Carrying out joint work with Public Health to discover the health needs of new arrival
communities from Eastern Europe
Developing pre-information for people with access requirements as part of the
outpatient referral process
Improve awareness of health issues for lesbian, gay, bisexual and trans people
We have agreed and implemented a two-stage Equality Analysis process to assess policies
and functions relating to the design and commissioning of services.
These analyses assist us with our duty to show “due regard” to promoting equality of
opportunity, eliminating discrimination and promoting good relations between groups.
We held a workshop in order to carry out an equality analysis on our integrated plan. The
notes of this workshop can be found in the appendices.
Equality Analysis has been mainstreamed into our Governing Body processes, assessing
everything we do, to minimise the impact on groups of people.
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We appreciate the value and the benefits that equality, diversity and human rights have for
an organisation such as ours. Everything we do is assessed and amended to ensure that no
individual is detrimentally affected by the commissioning decisions that we make.
The support and hard work that the staff have put in place to drive and deliver our work is
second to none. At the forefront of our minds, has been how we ensure that service users,
patients and carers receive the right healthcare that meets their individual needs. We have
ensured that assessing our policies and practices (new and old) limits the negative impact
that they could have on those who are protected under the Equality Act 2010 and those who
are not.
We will build on our achievements so far, embedding and mainstreaming equality into
everything we do and making a difference that changes culture and improves the lives of
those individuals in our care. In so doing, we have reviewed our work to date and have set
the following objectives going forward.
Objectives 2015-2017
1. Work with people with protected characteristics to develop co-produced factsheets to
increase our understanding health inequalities for diverse groups
2. Develop outreach and project work to engage with those groups at most risk of
health inequalities as highlighted by the Joint Strategic Needs Assessment
3. Develop robust performance management arrangements to ensure that both NHS
and non-NHS provider organisations are operating at best practice levels in equality
and inclusion
4. Ensure that all staff have training on the Public Sector Equality Duty and how to
evidence due regard to the same.
4. Information sharing and engagement
A cornerstone of the NHS reforms and delivering on the PSED will be how we communicate,
share information and engage with:
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Patients
Carers
Staff
People from the protected characteristic groups
Voluntary sector, and
Others
This effectively will deliver a two-way flow of information. By developing an inclusive
approach with sustained engagement with local interests including protected and
disadvantaged groups will assist in collating evidence and using the evidence to influence
our performance and decision making.
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By promoting collaboration within the local health economy and partners such as local
authorities to share best practice, undertake joint engagement activities, encourage joinedup thinking, sharing qualitative and quantitative evidence in addressing local inequalities.
The CCG has developed an engagement strategy which outlines the CCG’s current and
future plans to engage with and understand the views of the population of West Lincolnshire.
5. Review and Renewal
The CCG’s Equality Lead and Governing Body will continue to regularly review and update
this strategy and publish updates accordingly.
For further information and to discuss any related concerns please contact:
Rebecca Neno, Deputy Chief Nurse, NHS LWCCG on 01522 513355 Ext 5461 or via
[email protected]
Claire Darbyshire, Senior Quality & Engagement Manager, NHS LWCCG on 01522 513355
x 5351 or via [email protected]
Karen Duncombe, Equality and Human Rights Specialist, Arden & GEM CSU on 01522
515343 or via [email protected]
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Appendix 1 CCG’s Equality Objectives
1. Work with people with protected characteristics to develop co-produced factsheets to
increase our understanding health inequalities for diverse groups
2. Develop outreach and project work to engage with those groups at most risk of
health inequalities as highlighted by the Joint Strategic Needs Assessment
3. Develop robust performance management arrangements to ensure that both NHS
and non-NHS provider organisations are operating at best practice levels in equality
and inclusion
4. Ensure that all staff have training on the Public Sector Equality Duty and how to
evidence due regard to the same.
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Lincolnshire West CCG’s EDS2 evidence is published on the CCG’s website, see link
below:
http://www.lincolnshirewestccg.nhs.uk/equality-and-diversity
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