THE CHARTERED SOCIETY OF PHYSIOTHERAPY SCOTLAND
49 North Castle Street, Edinburgh EH2 3BG
www.csp.org.uk
Tel 0131 226 1441
Email [email protected]
Chartered Society of Physiotherapy Scotland Consultation Response to the
Scottish Government AHP National Delivery Plan
To: Angela Worth
Scottish Government Health Directorate
Directorate for Chief Nursing Officer, Patients, Public and Health
Professions
GE19, St Andrew’s House
Regent Road
Edinburgh
EH1 3DG
By email: [email protected]
AHP strategic vision - introduction and comment
CSP Scotland greatly welcomes the publication of the AHP Delivery Plan. The Society
recognises the plan as a significant document. It offers both recognition of the role and
contribution of AHPs in health and social care, and the potential of these professions to
deliver improved services across the health and social care sectors. We see it as critical that
the contribution of AHPs is aligned to the National Outcome Framework for Health and
Social Care, the Health Quality Strategy for NHS Scotland and the 20:20 Vision for
Sustainable Quality in Scotland’s Healthcare. It remains essential that the allied health
professions are seen to have a specific and unique contribution in service provision and in
the wider aims of health policy in Scotland.
CSP Scotland feels that the proposals would benefit from being more specific and targeted
(eg SMART Objectives1). To some extent, the aims and objectives of the plan are bound up
with the ongoing roles of AHP leaders. It is, therefore, important to distinguish between the
role descriptors of the AHP leaders, and the objectives for AHP services. The plan would
benefit from the numbering the proposals for ease of future reference and progress
monitoring.
With regards to the structure of the document we would also suggest that chapter six,
Driving Improvement, Transforming Services is moved to become the new chapter one.
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Specific, Measurable, Achievable, Resourced and Timed objectives.
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This would establish the drive for change and the focus on service improvement first, which
could then be appropriately followed by the new chapter two, Professional leadership for
the new agenda, which starts to focus on the ‘how to’ aspect of the proposals.
The plan focuses a great deal on the role of ‘AHP Directors’. However, these roles are often
very different in each health board, particularly in scope of influence. Indeed, rather than
full ‘Director’ roles, the AHP leads are more often ‘Associate Director’ roles. There is still
considerable work to be done to forge leadership roles for AHPs across health & social care,
and it is our belief that if this Plan is going to achieve its expected outcomes, clear
direction needs to be given to local organisations to establish AHP Directors at Board
level, so that they can influence at the heart of organisations and lead the transformation of
services with authority.
It is noted that the Plan currently seeks only to ‘explore’ opportunities for corporate roles
and inter-professional working. CSP Scotland believes the Plan requires further commitment
in this area to meet the objectives. It has been a long standing aim of CSP Scotland to see
AHP Directors on the health boards, and the Scottish Government has committed to
building up the corporate roles of AHP Directors in every health board. However, in the ten
years this since ‘Building on Success’ this is yet to be delivered.
Whilst AHP Directors are ideally placed to enable change, the majority of community-based
AHP Leads at CHP level are employed as band 7s. As such their sphere of influence to direct
the development of integrated rehabilitation pathways and establish community reablement services is limited. There is also the concern that this aim may be compromised
further by developments in which CHP AHPs are reduced to band 6, and responsible to a
team lead nurse at Band 7.
Strengthening the connection between quality improvement and data collection is a
valuable and critical aspiration within the Plan, but only a potentially achievable objective
unless further national resource is committed to establishing integrated health & social
care information systems and processes. These systems must facilitate easy data
collection and information development across organisational boundaries and sectors,
enabling practitioners to learn and improve and ensure safe and effective services with
the best outcomes for patients.
The key proposals - are they sufficiently ambitious, are they achievable, and
are there any significant gaps that need to be addressed?
It is apparent that much of the focus of the Plan is related to adult and older peoples’ care,
and yet AHPs have a crucial role to play in paediatric and mental health care also. At
present the Plan does not give real consideration to either of these service areas and it is
our view that this Plan offers Scotland the opportunity to realise real benefit from the
impact of AHPs interventions in these two service areas.
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The CSP welcomes the emphasis on preventative care and early intervention, however the
input of AHPs in public health, prevention and health promotion could be further
strengthened throughout - specific comments are made in the appropriate proposal
sections.
The Proposals are ambitious but in our opinion achievable if supported by the appropriate
agencies and stakeholders. It is recommended according to the breadth of impact of the
proposals, that additional reference to collaborative working with colleagues such as nurses
and GP’s is considered throughout the document, as well as links to local authority and third
sector leisure and fitness provision, all of which is vital to successful implementation of the
Plan.
The CSP feels that further thought needs to be given to the development of the current and
future AHP workforce to ensure that it is equipped with the right skills across all health and
social care settings to fully deliver the Plan and meet the needs of the local population. In
particular we suggest that change on this scale requires establishment of a programme for
workforce development in line with local service developments.
The development and strengthening of leadership and succession planning is an essential
aspect of delivery. However, this must be set against the current context in which higher
banded roles are being lost through vacancy management and service redesign.
Consequently opportunities for many future AHP leaders are becoming restricted. CSP
Scotland would suggest a specific AHP leadership programme to identify and support
succession planning.
Prioritisation to support local implementation
While AHP leaders must drive the transformation of AHP services forwards, significant
change cannot be delivered by the AHPs in isolation and requires the co-operation,
facilitation and involvement of the full multidisciplinary team. To this end, the Scottish
Government must make clear that this is a plan for health boards to act upon, rather than
guidance for AHP leaders. For the plan to be successful at a local level we believe the
following areas are critical and call on Scottish Government consider how each of these
factors will be achieved:
1. Clear direction regarding implementation, will need to be given by the Scottish
Government to all Chief Executives of all NHS organisations and Health Boards, Chief
Nursing Officers, GPs and Directors of Adult Social Services and Heads of Social Work in
order for this Plan to succeed.
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2. Health and social care organisations will need to integrate this Plan into its strategy and
annual plans as will Local Authorities responsible for social care.
3. The active participation and support of the senior management and other health
professions, particularly medical and nursing staff, will be required to effect change.
4. The cultural change necessary to secure the delivery of these proposals should not be
underestimated and specific investment must be made by each health and social care
organisation to bring staff and service development initiatives together across
traditional organisational and working practice boundaries.
5. Support for AHP services to access the Change Fund is strongly recommended in view of
the resource implications associated with the commitment and time scales required by
this Plan.
The following sections of this response refer to the specific chapters, as numbered in the
draft plan, and provide further comment on some of the specific proposals contained in
each section.
1. Professional leadership for
accountability and impact
the
new
agenda:
visibility,
CSP Scotland feels that these proposals are appropriate, but would reiterate that
without whole organisations committing to the proposals and establishing supportive
cultural change programmes, it is likely that the objectives will not be fully realised. It is
vital that the unique contribution of the AHP workforce across service planning and
delivery is fully recognised and supported. Professional leadership must be positioned
and empowered to enhance and improve service delivery, both efficiently and
effectively, in health and social care.
The following are comments on some of the specific proposals contained in Section 1 of
the AHP National Delivery Plan.
Proposal
CSP comments

This statement could be better converted into an
active proposal, such that Health Boards and social
care services will take steps to include AHP leaders in
the future development of rehabilitation and reablement services.
AHP directors and leads in the new
community health and social care
partnerships will be ideally placed to lead
the development of rehabilitation and reablement services across health and
social care.
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Proposal
CSP comments

AHP leaders of health and social care
teams will drive improvement locally,
strengthening the connection between
quality improvement for people who use
services and the collection of data to
demonstrate outcomes and service
impact.
Further national commitment to resource the
development of integrated health and social care
information systems is likely to be necessary to
support improved data collection.

AHP directors should explore
opportunities to adopt corporate
leadership roles in clinical engagement
and inter-professional working.
In establishing AHPs in positions of influence so that
the transformation agenda can be driven forward, this
proposal must be an objective for health boards to
explore with the involvement of AHP Directors, if
opportunities that are identified are to be effectively
exploited.

AHP directors and leaders across health
and social care will consider how to
strengthen AHP leadership within and
across agencies, including succession
planning.
Similarly, it will be necessary for whole organisation
change to identify how to strengthen AHP leadership
to develop this agenda.
2. Delivering integrated outcomes: reshaping care and enabling
independent living
CSP Scotland believes there is a risk in engaging in structural changes, from the
destabilising impact of staffing restructuring, and the potential loss of professional
leadership that can result. By contrast the focus of integration must be on the role of
joint budgets, working relationships, and accountability within and between existing
structures.
CSP Scotland has more detailed written and oral evidence on the integration of health
and social care to the recent Scottish Parliament Health and Sport Committee Inquiry. A
copy of this evidence can be provided.
The following are comments on some of the specific proposals contained in Section 2 of
the AHP National Delivery Plan.
Proposal
CSP comments

CSP Scotland supports the development of dedicated
access to physiotherapy and OT services, and has
supported the enhanced roles of physiotherapists in
Minor Injuries units, for example, where efficient early
intervention is both cost effective and provides better
AHP directors will work towards ensuring
that emergency admission services have
dedicated access to physiotherapy and OT
services to prevent unnecessary
admissions to hospital and coordinate
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Proposal
appropriate support/team interventions
to individual patients at risk of future
readmissions or falls
CSP comments
patient outcomes.
It should further be noted that more emphasis needs
to be placed on public health and in particular,
preventative care. AHPs can be placed based out of
hospitals - preventing patients from presenting to
accident and emergency hospitals, through the
establishment of physiotherapists within Minor
Injuries Units.
Similarly, falls prevention, enhanced respiratory care,
pulmonary rehabilitation services, and other long term
condition specific interventions could be the subject of
these proposals

AHP directors will work in partnership
with colleagues in the Scottish Ambulance
Service, community alarms/telecare
services and NHS 24 to ensure older
people who fall and present with frailty
syndromes have timely access to AHP
services to prevent unnecessary
admissions to hospital and further falls.
The establishment of integrated falls pathways must
be driven locally but may also benefit from a national
approach, given the multiple agencies that will need to
be involved.

Falls leads within each CHP/community
health and social care partnership will
lead implementation of the Falls Care
Bundles approach by 2013 and will work
within multi-professional teams and
partners to integrate falls prevention,
management and monitoring; reduction
of falls within hospital settings should be
integrated as part of systematic
approaches to care improvement.
Integrated outcomes: The ‘Falls care bundles’
approach is being piloted in Fife but it is prudent to
examine and evaluate its impact before it forms part
of a national strategy.
Effective falls rehabilitation needs to be better
supported and resourced beyond health & social care,
for example, exercise interventions supported in the
community. Optimal outcomes cannot be delivered by
health alone, and the plan needs to also strengthen
the ties that rehabilitation services have with council
and other community based provision.
In some circumstances, day hospitals remain ideally
placed in community settings where there is access to
the appropriate multidisciplinary team.

AHPs from across health and social care
will work to actively reduce length of
hospital stay and improve patient flow
through interventions to enhance
recovery and early supported discharge.
This is a key area to address and the differing funding
strands of health and social care currently present
significant challenges in tackling and improving
supported discharge. The reduction in AHP workforce
and capacity also presents challenges in any attempt
to improve the patient flow.
There are also particular challenges around specific
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Proposal
CSP comments

conditions such as in stroke and neurology unless
specialist teams are in place.
The need for closer partnership working is clear, but
the current proposals need more specific definition as
to how aims can be achieved.

AHP directors will work in partnership
with nursing and medical directors to
drive improvements in the care of older
people in hospitals.
Seventy per cent of NHS AHP resource
and activity will be sited within the
community by 2015, and NHS
rehabilitation activity in the community
will increase by 50% by 2015.
Consideration might be given to national pathways,
particularly around dementia care and older peoples’
services.
A baseline measure must first be established to show
within each Board area what percentage of
rehabilitation is currently community based, and what
percentage of AHPs provision is based in the
community. Appropriate targets for 2015 could then
be established for each Board area.
In this regard, a shared understanding or definition of
‘the community’ would be helpful in developing local
targets.
CSP members in Scotland have also questioned how
this shift will be achieved within the current financial
limitations. It is clear that community-based settings
remain under resourced and are currently unable to
accommodate additional case loads being moved from
the acute setting. Furthermore ambitions around
improved data collection and use of IT also present
specific challenges in community settings.
CSP Scotland would support this aim if it is facilitated
by the required financial investment in community
based-services. Already, CSP members report that
acute based staff are moving to take on community
roles whilst their training and supportive framework is
insufficient.

AHPs will continue to deliver faster access
to diagnostics as part of the redesign of
community pathways and contribute to
the achievement of existing targets.
There remains the risk that service redesign and
workforce planning may seek to grow economies of
scale and work in the opposite direction.
This is a welcome proposal, provided that each Board
area runs an audit of current practice and establishes
an appropriate target for access to diagnostics as a
consequence.
Training requirements must also be factored into the
plans, and this includes support for any related
extended scope roles.
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3. Improving health and well-being: strengthening partnership and
promoting resilience
Alongside patient groups and health professionals, CSP Scotland has strongly supported the
development of self-management for people with long term conditions. Schemes that provide
people with greater control over their health care and empower individuals to better meet their
health needs can both improve outcomes and also prevent or reduce chronic episodes in many
conditions.
The national guidance is therefore welcomed. In addition to general comments made above in
relation to partnership working and the profile of the AHP contribution to services, further
comment on some of the specific proposals is outlined below.
Proposal
CSP Comments

This proposal is appropriate but must be supported by
the various frameworks, including education. CSP
Scotland suggests that Higher Education Institutions
be consulted regarding the impact of these proposals
on the relevant curricula. NHS Education (NES) should
also direct a competency assessment, linked to
workforce planning that would result in appropriate
training programmes being delivered to support the
development of competencies for AHPs across all
sectors to deliver self management programmes for
patients and other relevant practice areas within
community environments.
AHPs will work within an ASSET-based
model to develop partnerships with
agencies, including those in the leisure
and voluntary sectors, to enhance
community capacity building; these will
be integrated as components within new
models of rehabilitation by the end of
the end of 2012
It should also be noted that forging community based
initiatives with community organisations is also time
consuming and support may be needed to facilitate
engagement.

AHPs from across health and social care
will ask patients and service users about
their work status as an essential
component
within
their
initial
assessment and will initiate support to
individuals to enable them to remain or
return to work (to be implemented by
2012)

AHP directors will continue to ensure CSP Scotland would also support an additional
redesigned musculoskeletal pathways proposal indicating the health promotion role of AHPs
and how this can be augmented to impact on health
are implemented within NHS boards
improvement targets in Scotland.
This is an increasingly important aspect of AHP
intervention. The establishment of pathways
specifically designed to manage vocational
rehabilitation should also be part of this proposal.
Specialist vocational rehabilitation may also need to
be provided for those requiring supervision and
expert advice.
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4. Workforce engagement: maximising our people resource and
realising potential
In outlining the workforce proposals, CSP Scotland would recommend that the precise workforce
figures for September 2011 be utilised in the national delivery plan. This acts as a benchmark of
capacity and a reference point for future development. CSP Scotland comment on some of the
specific proposals is outlined below.
Proposal
CSP comments

An AHP data platform should be
established to provide ongoing analysis
and intelligence on the AHP workforce
and assist AHP directors to undertake
annual workforce modelling with key
stakeholders from higher education
institutions and health and social care.
This will enable the projection of AHP
workforce requirements to meet service
needs
The needs of local populations should first be
identified, to ensure that workforce planning can be
appropriately tailored. This must include some
horizon scanning as new ways of working are
developed and must be accounted for in workforce
planning activities.

AHP directors will initiate a review of
AHP working practices in NHSScotland
to maximise efficiency and productivity,
introducing different working patterns in
partnership with staff side. Releasing
Time to Care will be integrated into all
AHP service improvement systems and
will be delivered by 2013
Seven-day services are likely to require an increased
workforce to support the capacity for increased
activity, if they are to be implemented safely and
effectively. As an ambitious aim to deliver this
objective by 2013, CSP Scotland would encourage the
Scottish Government to develop changes, in
partnership with the staff side in the NHS.

AHPs in social care should explore how
improvements in productive working
can be delivered, building on the
achievements so far delivered through
the implementation of the Guidance for
the Provision of Equipment and
Adaptations
There remains concern amongst CSP members that
the drive for improvements in productivity may result
in lower staff morale or increase levels of stress if
poorly managed. Partnership working is essential to
delivering sustainable improvements to services.
Partnership with higher education institutions must
form part of the delivery plan process.
Consideration must also be given to the development
of future roles, from support worker to consultant
roles.
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5. Delivering sustainable quality: preventative spending
strengthened and user and carer experience enhanced
The opportunities to exploit the change fund are crucial to demonstrating the cost
effectiveness and efficiency of AHP led provision. However, there remain limitations in
the extent to which the funds can be effectively accessed by AHPs. In addition,
preventative spend may not produce savings in the same financial year, therefore
incentives must be developed to realise savings from investing in preventative care over
longer time frames, if positive change is to be encouraged.
CSP Scotland comment on some of the specific proposals is outlined below.
Proposal
CSP comments
 AHP directors will work in partnership
with analytic and research colleagues to
grow the health economic base for AHP
interventions across health and social
care
This type of activity is likely to be crucial in driving
effective change. Funding for research is equally
important and it would be helpful to identify a ringfenced funding from which this activity could be
supported. It would also be appropriate to have a
proposal that links other aspects of government
activity around cost effective preventative spend to
be linked with the delivery plan. New competencies
for AHPs in the area of economics linked to service
improvement would be of real value under this
initiative. There needs to be clear definitions and an
understanding of the AHP activity that is being
benchmarked, for effective economic evaluation.
 AHP services will implement the national There will need to be clarity on what information
data set for NHSScotland in the form of a will be captured in the e-health programme in the
dashboard, with full support from e- future.
health to ensure robust data capture to
inform reporting by 2013
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6. Driving improvement: transforming services
As suggested in the initial comment, CSP Scotland believes the proposals in this chapter are
the key drivers for change and the focus for service improvement. We recommend that this
should be the first chapter, enabling the new chapter two, ‘Professional leadership for the
new agenda’, and later sections, to focus on the ‘how to’ aspect of the proposals.
Proposal
CSP comments

AHP leaders of health and social care teams will
drive improvement locally, strengthening the
connection between quality improvement for
service users and the collection of data to
demonstrate outcomes and service impact
Integrated services might be best located
together, and this might be considered at a
local level where appropriate. A shared
understanding of data definitions for
counting and reporting is essential within a
data culture of ‘use once – share often’

AHP directors will work with the Quality Hub to This proposal should include the further
develop a cadre of AHP leaders as improvement development of AHP consultant posts and
the professional leadership strategy for
champions
AHPs.

AHP directors will work collaboratively with
colleagues in social care to increase the
utilisation of technology such as tele-care and
tele-rehabilitation by 40% as an integral part of
rehabilitation services by 2014
There is currently no baseline measure to
monitor and implement this change target.
An initial audit would therefore benefit this
aim.
There is the opportunity also to target telerehabilitation to bring services closer to
people. It is unclear whether this proposal is
Scotland wide, or target for every health
board, and this needs to be clarified.
Additional comments

CSP Scotland identifies a need to consult with health boards, as each is likely to be at a
different stage with different aspects of the proposals. Continued direction at the
national level will also be required to continue to progress the plan into the future. This is
particularly the case around data collection, and in the broad direction of changes.

Professional leadership remains vital for the delivery of the aims and proposals in this
Plan. However at health board level there are significant challenges in developing and
supporting professional leadership, both uni-professionally and at an AHP level.
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
More mention might also be made of the implicit cultural shift that will be required to
ensure the proposed changes have the maximum impact.

Service users must be involved in the development of changes to provision and access to
care.

CSP Scotland would warn against making structural changes to deliver these objectives. If
the drive becomes interpreted as a need to move staff to new employment models, or to
restructure leadership roles, concerns for job security and employer transfer could yet
derail the objectives that are outlined.

The drive for improvement in quality patient centred care must remain a priority in the
delivery plan for AHPs in Scotland.
For further information, please contact:
Kenryck Lloyd-Jones, CSP Policy Officer for Scotland
Email [email protected]
The Chartered Society of Physiotherapy
The Chartered Society of Physiotherapy (CSP) is the professional, educational and trade
union body for the UK’s 51,000 chartered physiotherapists, physiotherapy students and
support workers.
CSP Scotland has around 4,000 members in Scotland. Approximately sixty percent of
chartered physiotherapists work in the NHS. CSP members also work in education,
independent practice, the voluntary sector and with other employers, such as sports clubs
and large businesses. More than 98% of all physiotherapists in Scotland are members of CSP
Scotland. Physiotherapy is the fourth largest health care profession in the UK, and the largest
of the allied health professions.
Physiotherapy is grounded in a solution-focussed and patient-centred approach to health
and well-being.
Kenryck Lloyd-Jones, CSP Policy Officer for Scotland
Email [email protected]
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ANNEX
AHP NATIONAL DELIVERY FORM
RESPONDENT INFORMATION FORM
Please Note this form must be returned with your response to ensure that we handle
your response appropriately
1. Name/Organisation
Organisation Name
The Chartered Society of Physiotherapy
Title Mr
Ms
Mrs
Miss
Dr
Please tick as appropriate
Surname
Lloyd-Jones
Forename
Kenryck
2. Postal Address
49 North Castle Street
Edinburgh
Postcode
EH3 5BF
Phone
-0131 226 1441
Email
[email protected]
3. Permissions - I am responding as…
/
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Group/Organisation
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(a)
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available to the public (in Scottish
Government library and/or on the Scottish
Government web site)?
Please tick as appropriate
(b)
Yes
(c)
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will be made available to the public (in the
Scottish Government library and/or on the
Scottish Government web site).
No
Where confidentiality is not requested, we will
make your responses available to the public
on the following basis
Please tick ONE of the following boxes
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available?
Please tick as appropriate
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Yes, make my response, name and
address all available
or
Yes, make my response available,
but not my name and address
or
Yes, make my response and name
available, but not my address
(d)
We will share your response internally with other Scottish Government policy teams who may be addressing the
issues you discuss. They may wish to contact you again in the future, but we require your permission to do so.
Are you content for Scottish Government to contact you again in relation to this consultation exercise?
Please tick as appropriate
Yes
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