National Public Health Service for Wales
Response to Consultation: HSCWB Strategy Guidance
Response to
Consultation: Draft
HSCWB Strategy
Guidance and Changes to
the Associated
Regulations
Version: Final
Author: Dr Cerilan Rogers
Date:14/02/06
Page: 1 of 4
Status: Approved
National Public Health Service for Wales
Response to Consultation: HSCWB Strategy Guidance
Q.1 Do you agree with the proposed changes to the
Health, Social Care and Well-being Strategies
(Wales) Regulations 2003 – as identified in Annex B
Overall, the National Public Health Service (NPHS) is supportive of the proposed changes
laid out in Annex B.
The NPHS particularly welcomes the proposal to drop the requirement for a separate local
consultation for conducting needs assessments and agrees that consultation should be limited
to the draft Health, Social Care and Wellbeing (HSCWB) Strategy itself.
We agree that the Strategy should address inequalities relating to disability, race, gender,
language, age, sexual orientation, and religion and belief.
The NPHS strongly supports the alignment in planning timescales between the HSCWB
Strategy and both the strategic framework for Designed for Life and Children and Young
People’s Plans. However, three years is a short period of time over which to demonstrate real
change and is shorter than the five years originally envisaged. In order to maintain
coordination with other strategies and to provide an opportunity to achieve and demonstrate
change, a six year cycle for HSCWB strategies should be considered.
Q2 Is the Draft Guidance clear on the tasks and the
expectations?
The NPHS welcomes its role to lead the health needs assessment for the HSCWB Strategy.
However, more detail is needed as to what this entails and what the function of the Local
Public Health Director (LPHD) will be in this process. The NPHS believes that the role of the
LPHD, with the support of the wider NPHS, should be one of leadership, supporting Local
Health Boards (LHBs) and Local Authorities (LAs) and/or Local Service Boards, in assessing
health needs and existing local provision and helping to prioritise investment in, and
decommissioning of, services and interventions.
The use of annual reports to highlight progress in tackling inequalities in health requires
careful consideration, given that the production of these can be very time consuming and
could easily overwhelm the limited resources that exist. We believe that any such reports
should be independent LPHD/NPHS reports and that this status should be explicitly stated.
The emphasis on the importance of health needs assessment being seen as part of an ongoing
process and not a one off exercise is welcomed, as is the emphasis given to health needs
assessment informing commissioning plans and tying closely with needs assessments
undertaken for other strategies. However, there is an acknowledgement that the high level
health needs assessments for the HSCWB strategies are not sufficiently detailed to inform
specific commissioning objectives and separate, additional work will be required.
The NPHS has some concerns in terms of gaps that currently exist in data sources and the
need for further investment in health needs assessment processes. For example, the need for
small area geography health data is highlighted in Annex A of the proposed guidance.
Version: Final
Author: Dr Cerilan Rogers
Date:14/02/06
Page: 2 of 4
Status: Approved
National Public Health Service for Wales
Response to Consultation: HSCWB Strategy Guidance
Publishing mortality and hospital admission data by small area is restricted by small numbers,
unstable rates and the need to observe data confidentiality and non disclosure guidance from
Office for National Statistics (ONS). Primary care data are the best source of information for
this purpose and the NPHS needs access to anonymised individual level primary care data to
be able to respond to this agenda. Further development of primary care data to inform
strategic processes is an urgent requirement.
We welcome the proposal to have shared outcome measures. A focus on outcomes and
measurement is important and a common set of indicators across Wales would be very helpful
for comparative purposes. However, it would be useful to have a clear definition of the word
‘outcome’ in this proposed context. In addition, greater clarity is needed as to whether these
indicators would link into the work of Trusts and LHBs and whether national indicators would
take precedence over local indicators.
The NPHS is very encouraged by the centrality of the HSCWB Strategy with respect to the
commissioning agenda expressed in the proposals. However the HSCWB Strategy guidance
needs to be clear about expectations relating to LHBs and LAs collaborating in
commissioning health care and social care services, as well as community developments, to
make best use of their combined resources to promote the health and wellbeing of their
populations in an integrated way.
The draft guidance suggests that where common health and wellbeing needs are identified
between local/ neighbouring/ established/ statutory partners, this should drive partnership
commissioning and provide economies of scale, resulting in cost effective services or
interventions. The NPHS could be more clearly indicated as supporting regional
commissioning partnerships. Appropriate independent professional advice from the NPHS
could also be made available to assist the commissioning process.
Q3. Is the relationship
strategies clear?
between
the
various
The NPHS believes that the document provides a good overview of the relationship between
the various strategies, with the Community Strategy overarching the HSCWB Strategy, the
Children and Young People’s Plan and the Local Development Plan. However, more clarity is
needed as to how the draft HSCWB Strategy guidance and other associated plans and
frameworks e.g. the Community Services Plan, Children and Young People’s Plan and
Framework for Chronic Conditions, link with each other.
Closer links between the HSCWB Strategy and the work of Community Safety Partnerships
would help ensure that the health and wellbeing aspects of problems that are often considered
to be criminal justice issues can be appropriately addressed.
The CMO’s proposed Public Health Strategy would provide an opportunity to further
articulate these and other connections.
Q4. Are there issues that you think are omitted?
The potential for the NPHS to be involved in evaluating local and central implementation of
policies could be highlighted in the guidance.
Version: Final
Author: Dr Cerilan Rogers
Date:14/02/06
Page: 3 of 4
Status: Approved
National Public Health Service for Wales
Response to Consultation: HSCWB Strategy Guidance
The interface between primary care and public health and the opportunities afforded by the
introduction of the new GP contract, particularly in relation to secondary prevention and
anticipatory care, need to be recognised and placed within a community planning framewok.
We agree with the focus on children in terms of prevention, but also note that there seems to
be a lack of emphasis on services for older people within the draft guidance.
The theme of safeguarding children needs to be reflected in all aspects of policy/strategy
discussions and service commissioning for adults or children. Therefore the NPHS feels that
the HSCWB Strategy guidance should include reference to Section 28 roles and
responsibilities under the Children Act 2004, to safeguard the welfare of children and young
people.
We recognise that the amount of intersectoral and public engagement work that is envisaged
within the guidance will be very challenging and require a substantial increase in the capacity
of Local Public Health Teams and their partners.
Version: Final
Author: Dr Cerilan Rogers
Date:14/02/06
Page: 4 of 4
Status: Approved