British Psychological Society response to the Welsh Government. Together for Mental Health Delivery Plan
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1 British Psychological Society response to the Welsh Government Together for Mental Health Delivery Plan About the Society The British Psychological Society, incorporated by Royal Charter, is the learned and professional body for psychologists in the United Kingdom. We are a registered charity with a total membership of just over 50,000. Under its Royal Charter, the objective of the British Psychological Society is "to promote the advancement and diffusion of the knowledge of psychology pure and applied and especially to promote the efficiency and usefulness of members by setting up a high standard of professional education and knowledge". We are committed to providing and disseminating evidence-based expertise and advice, engaging with policy and decision makers, and promoting the highest standards in learning and teaching, professional practice and research. The British Psychological Society is an examining body granting certificates and diplomas in specialist areas of professional applied psychology. Publication and Queries We are content for our response, as well as our name and address, to be made public. We are also content for the Welsh Government to contact us in the future in relation to this inquiry. Please direct all queries to:- Joe Liardet, Policy Advice Administrator (Consultations) The British Psychological Society, 48 Princess Road East, Leicester, LE1 7DR consult@bps.org.uk Tel: About this Response This response was jointly led for the British Psychological Society by: Dr Carolien Lamars CPsychol AFBPsS, Division of Clinical Psychology Nicola Massie CPsychol AFBPsS, Division of Counselling Psychology With contributions from: Dr Julie Highfield CPsychol, Division of Clinical Psychology Dr Adrian Neal CPsychol, Division of Clinical Psychology We hope you find our comments useful. Dr Ian J Gargan CPsychol AFBPsS Chair, Professional Practice Board
2 Consultation response form: - Together for Mental Health Delivery Plan ( ) Overview Proposed Together for Mental Health Delivery Plan How to respond Responses should be submitted by 4 April 2016 to: mentalhealthandvulnerablegroups@wales.gsi.gov.uk Alternatively you can send the form to: Further information and related documents Mental Health and Vulnerable Groups Health and Social Services 4 th Floor, North Welsh Government Cathays Park Cardiff CF10 3NQ Large print, Braille and alternative language versions of this document are available on request. Contact details If you have any queries on this consultation, please mentalhealthandvulnerablegroups@wales.gsi.gov.uk Data protection How the views and information you give us will be used Any response you send us will be seen in full by Welsh Government staff dealing with the issues which this consultation is about. It may also be seen by other Welsh Government staff to help them plan future consultations. The Welsh Government intends to publish a summary of the responses to this document. We may also publish responses in full. Normally, the name and address (or part of the address) of the person or organisation who sent the response are published with the response. This 2
3 helps to show that the consultation was carried out properly. If you do not want your name or address published, please tell us this in writing when you send your response. We will then blank them out. Names or addresses we blank out might still get published later, though we do not think this would happen very often. The Freedom of Information Act 2000 and the Environmental Information Regulations 2004 allow the public to ask to see information held by many public bodies, including the Welsh Government. This includes information which has not been published. However, the law also allows us to withhold information in some circumstances. If anyone asks to see information we have withheld, we will have to decide whether to release it or not. If someone has asked for their name and address not to be published, that is an important fact we would take into account. However, there might sometimes be important reasons why we would have to reveal someone s name and address, even though they have asked for them not to be published. We would get in touch with the person and ask their views before we finally decided to reveal the information. Responses to consultations may be made public on the internet or in a report. If you would prefer your response to be kept confidential, please tick here: 3
4 1. Contact Details Your name: Organisation (if applicable): British Psychological Society Contact telephone number (0116) Your address St Andrews House 48 Princess Road East Leicester LE1 7DR United Kingdom 2. Are you responding as an individual or on behalf of an organisation? Please tick box. Individual On behalf of an organisation (please tell us which organisation) British Psychological Society 4
5 3. Structure of delivery plan Together for Mental Health, the Welsh Government s 10 year strategy to improve mental health and wellbeing was published in 2012 following significant engagement and consultation with key partner agencies, stakeholders, services users and carers It is a cross-government strategy and covers all ages, ranging from a whole population approach in improving the mental well-being of all residents in Wales, through to the support needed for those with a severe and enduring mental illness. The strategy consists of five chapters and is underpinned by 18 outcomes. These were subject to detailed formal consultation in 2012 and remain unchanged for the lifetime of this delivery plan. These outcomes have been mapped to the Goals contained within the Wellbeing of Future Generation (Wales) Act Following feedback from stakeholders we have laid out the priority areas, by subject, detailing links back to the relevant chapter areas where required for ease of reading Question 1 Do you feel that there are any priority areas missing from the delivery plan? Please tick appropriate box Yes No Partly Where you have ticked Yes or Partly please explain what you think these are. Mental and physical health The Society believes that Together for Mental Health does not address the interplay between mental and physical health. In Designed to Improve Health and the management of Chronic conditions in Wales: An integrated model and framework (WAG 2007), WAG acknowledged that while good public health and an ethos of responsibility for one s own health and well being are cornerstones for policy development, it had to be acknowledged that some people will have experienced mental health problems preceding and contributing to the onset of chronic health conditions, and others will have developed mental health problems as a consequence of living with a chronic health condition. These chronic health conditions also contribute to concerns regarding work, relationships and caring responsibilities. In the NHS England, a Parity of Esteem has been introduced, in which equal rights for people with mental and physical health difficulties has been adopted, which has gone some way to acknowledge mental health needs of people who have medical conditions. Improving Access to Psychological Therapies (IAPT) has a long -term conditions drive (with mixed results), which also gives people with physical health conditions access to psychological therapies. The strategy would be enhanced if this group of people was also acknowledged as requiring psychological support and that links to other WG health strategies were made explicit. 5
6 separately?utm_source=twitter&utm_medium=social&utm_term=thekingsfund National Statistics (2006). A Profile of long-term and chronic conditions in Wales. Welsh Assembly Government. National Institute for Health and Clinical Excellence (2009). Depression in Adults with a chronic physical health problem: treatment and management. Naylor, C. (2012). Effective chronic care means recognising the importance of mental health. The King s Fund. Welsh Assembly Government (2007). Designed to Improve Health and the management of Chronic conditions in Wales. An integrated model and framework. World Federation for Mental Health (2010). Mental Health and Chronic physical illness. The need for continued and integrated care. 4.3 To promote mental well-being and where possible prevent mental health problems developing. While there are several references to staff in the strategy and how they are required to undertake training and deliver the required high level quality of care, there is little focus on addressing the mental health of the workforce. Just like the people they provide care for, staff can be susceptible to mental and physical health difficulties, some of which can be related to the nature of the work undertaken, work stress and pressures. This can lead to difficulties for the organisation in sustainability (staff retention and turnover) and challenges of absenteeism / presenteeism. The need for leadership qualities is mentioned in the strategy, but the systemic and organisational aspects of large care provider like the NHS and local authorities need to be acknowledged and the impact this can have on staff morale and ultimately on the quality of care provided. There is a need to address the wider health & well-being of staff within the Local Health Boards (see question 2). Question 2 Within each priority area we have identified a number of goals and key actions. Do you feel these are the right ones? Please tick appropriate box Yes No Partly Where you have ticked No or Partly please provide an explanation and any alternative suggested wording. In your answer please state which priority area/goal or key action you are commenting upon. Priority 4. Section 4.3. See above: address the staff / workforce perspective. There is currently one key action within the Key Actions column, we would like to suggest the following three additional ones. ii) For Health Boards to develop employee well-being strategies which explicitly identify both the individual and organisational responsibility to promote well-being. 6
7 iii) For Health Boards to demonstrate their commitment to develop working cultures that support well-being. iv) For Health Boards to evidence implementation of NICE recommendations that support employee well-being. Priority area 7, 7.8 There is no specific reference to individuals with an intellectual disability in the prison population. This is a group of people who are particularly vulnerable within the criminal justice system. The same applies for older people in prison, who might be developing cognitive changes/ dementia. Children and Young People with Neuro Disabilities in the Criminal Justice System a Position Statement (2015). The British Psychological Society, Leicester. Priority area 4.1 While there is emphasis on providing psychological therapies at all levels in the service, it will be important to ensure that staff are appropriately trained and supervised when delivering therapies. In order to provide mindfulness intervention, staff will need to have received the appropriate training to the level where they can provide the training from a recognised trainer. The Matrix, which sets out evidenced psychological interventions for a range of conditions, will be a useful reference point. There are several performance measures that refer to staff having received training. In order for training to be successful, implemented and impact on the care that is provided, a positive learning environment is required. Further recommendations and guidance about the need for organisational and systemic change will be beneficial, in order to ensure that training actually impacts on the quality of care provided. In the same light, the Community of Practice while a good idea proves difficult to implement in larger geographical areas and with on-going staff shortages. Considering local facilitated learning opportunities, like Schwartz rounds or team formulation sessions, might well be vehicles were staff can share their ideas and views about their work with certain people, thus enhancing our understanding, contributing to the team formulation, that will subsequently informs and helps to implement care plans. Please see attached Clinical Psychology Forum, Special issue: The Francis Report. In order for the services across the NHS, Local authority and third sector to work together, more will need to be done at a systemic level to make this happen. In some areas the vision and philosophy of the three parties are very disparate. While clinicians on the ground work well together, the obstacles are at the higher levels where there is a lack a joined up thinking and approach. The physical environment in which care is provided also requires attention, as this can contribute to or alleviate presenting problems. The Kings Fund has designed environmental audit tools for wards that provide care for people with dementia. 7
8 Question 3 Do you think we have the correct balance between improving the mental health and resilience of the whole population and the care and treatment for those individuals with mental health problems? Yes No Partly Where you have ticked No or Partly please say what are the gaps / actions you would propose were added. The document is focused on the delivery of mental health services. It does not address the underlying wider issues, often predisposing and environmental factors, which contribute to the development of mental health difficulties. These include: childhood abuse, trauma, or neglect the death of someone close to you severe or long-term stress unemployment or losing your job social disadvantage, poverty or debt homelessness or poor housing caring for a family member or friend a long-term physical health condition drug and alcohol misuse domestic violence or other abuse as an adult significant trauma as an adult, such as military combat, being involved in a serious accident or being the victim of a violent crime physical causes for example, a head injury or a condition such as epilepsy can have an impact on behaviour and mood (it is important to rule out causes such as this before seeking further treatment for a mental health problem) Mental Health problems what causes them, an introduction: Mind (2013) Especially with the current Austerity policy these aspects will be very relevant. The Spirit Level: Why Greater Equality Makes Societies Stronger (Picket, K. & Wilkinson, R., 2011) sets out very clearly the link between social inequalities and a range of physical and mental health conditions. Further references to other WG policies that are addressing these issues can enhance Together for Mental Health. Poor mental health rarely occurs in isolation as documented above and addressing the challenges and subsequent needs of people with mental health difficulties is complex and multi-faceted. Unlike a medical condition, where a cause of a condition has usually a well-evidenced treatment plan, this is often not the case in mental health difficulties. Rarely does one approach effectively meet the needs of the individual. The document refers to delivering evidence based high quality services. It is therefore important to acknowledge that some people with complex needs might require more specialist services, from staff that are familiar with the process of psychological formulation. This is a key skill employed by practitioner psychologists to address the multiple causes, effects and response to mental health/psychological distress. The Core Purpose and Philosophy of the Profession (DCP, 2010, pp.5-6) states: Psychological formulation is the summation and integration of the knowledge that is acquired by this assessment process that may involve psychological, biological and systemic factors and procedures. The formulation will draw on psychological theory and research to provide a framework for describing a client s problem or needs, how it developed and is being 8
9 maintained. Psychologists will be able to draw on a number of models (bio-psychosocial) to meet needs or support decision-making and so a formulation may comprise a number of provisional hypotheses. This provides the foundation from which actions may derive. Psychological intervention, if considered appropriate, is based upon the formulation. While a psychologist will consult an evidence base, the unique and complex nature of some people s mental health difficulties will require a multi faceted and integrated intervention, drawing on a range of evidene basis as well as practice based evidence, that is underpinned by a person centred clinical formulation. Question 4 The introduction to the delivery plan provides information on the prudent health and care agenda. Do you think we should include any other actions in the delivery plan around the prudent agenda and how this is rolled out across Wales in terms of best practice? Yes No Where you have ticked Yes please explain what else you feel could be done? While the prudent health care agenda is understandable in the current financial climate, it does appear to ignore the important role that prevention can play in doing a bit more at certain times, in order to avoid further crisis happening further down the line. Public Health Strategies need to developed further to include the role of people s behaviour and possible behavioural change. Psychology s main business is understanding the complexities of people s behaviour and drawing on well developed models of behavioural modification, behavioural activation, motivational models, that can all help in implementing preventative strategies, at primary, secondary and tertiary level. Question 5 Do you think the actions will provide a positive impact of the proposals for people with the following protected characteristics:- Disability Race Gender and gender reassignment Age Religion and belief and non-belief Sexual orientation Human Rights Children and young people Yes No Partly Where you have ticked No or Partly please explain why. The needs of people with an intellectual disability and mental health needs are not directly addressed. These individuals are particularly susceptible to poor mental health co-morbidly with other health conditions. 9
10 People with mental health problems and borderline intellectual functioning are particularly difficult to treat (Hassiotis et al., 1999) and are at risk of receiving no mental health service, due to the lack of communication between mainstream psychiatry services and intellectual disability psychiatry services (Hassiotis et al., 2000; Moss et al., 1996; Roy et al., 1997). A very high proportion of people with intellectual disabilities are receiving prescribed psychotropic medication, most commonly anti-psychotic medication (40%-44% long-stay hospitals; 19%-32% community-based residential homes; 9%-10% family homes; Branford, 1994; Clarke et al., 1990; Robertson et al., 2000b). Anti-psychotics are most commonly prescribed for challenging behaviours, despite no evidence for their effectiveness in treating challenging behaviours and considerable evidence of harmful side-effects (Emerson, 2001). Question 6 Do you think the actions will provide a positive impact on the opportunities for use of the Welsh language? Yes No Partly Where you have ticked No or Partly please explain how you feel we could strengthen opportunities for using Welsh to ensure it is treated no less favourably than the English language? While certain professional groups seem to have a solid proportion of Welsh speaking clinicians, other professions continue to struggle to provide services through the medium Welsh, e.g. Psychiatry and Psychology. The North Wales Clinical Psychology Programme in Bangor has a targeted marketing and recruitment strategy to encourage Welsh speaking candidates to apply for training in Bangor. However, from national equal opportunity data collected by Clearing House Leeds, only 1% of all applicants identify themselves as Welsh speaking. To address this at an earlier stage in students careers, events are held with secondary school students to consider studying Psychology and undergraduate psychology students to consider careers in Clinical Psychology, ideally in Bangor. Apart from training Welsh speakers locally, it is also important to attract Welsh speaking clinicians back to Wales. While there will be personal reasons for relocating back to Wales, the reputation of the Welsh NHS needs to improve in terms of world class services and research. Addressing the stigma of mental health is likely to contribute to more Welsh speaking people considering careers in psychology. 7. Additional Comments We have asked a number of specific questions. If you have any related issues which we have not specifically addressed, please use the space below to comment. 10
11 The Society believes that while the aim to address the stigma associated with Mental Health is central to the strategy, the document itself will benefit from attention to the language use around mental health. A range of terms are utilised, not all of them are de-stigmatising. If the aim is to maintain mental health, then people might experience mental health difficulties or problems. A limited and consistent range of terms is required; otherwise the strategy undermines its own intention. 11
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