Part 1 Part 2 PRIMARY CARE CO-COMMISSIONING COMMITTEE 18 March 2016 Title of Report Supporting deaf patients to access primary care services Purpose of the Report The report is to provide the co-commissioning committee with information around current issues that have been raised by local deaf patients when accessing primary care services in Trafford. There is a legal requirement for NHS and Social Care to comply with the Accessible Information Standard by July 2016. The paper makes recommendations on how to move forward with the issues raised. Actions Requested Decision x Discussion x Information Strategic Objectives Supported by the Report 1. Consistently achieving local and national quality standards. 2. Delivering an increasing proportion of services from primary care and community services in an integrated way. 3. Reduce the gap in health outcomes between the most and least deprived communities in Trafford. 4. To be a financial sustainable economy. X x Recommendations a) EDHR to provide GPs with a briefing note to support them to comply with the Accessible Information Standard. b) Primary Care Team consider conduct a review of current provision of the 32 practices with EDHR, reviewing where the clusters of needs are regarding compliance of provision of data of protected characteristics. c) Primary Care Team consider reviewing with EDHR the CCG s current interpretation and translation policy and practice in light of the Accessible Information Standards, Healthwatch recommendations and best practice case studies in the Healthwatch report. d) The existing NHS SBS Interpretation & Translation Services framework agreement used by Greater Manchester CCG was extended up to October 2016. Trafford CCG collaborates with the retender for this framework which will commence in Spring/Summer
2016 for a 1st November start date. e) Interim arrangements, continue to use Language Line (the telephone service) and Language Empire (provider of face to face interpreting includes BSL). Both are on existing procurement frameworks. Discussion history prior to this Committee Financial Implications Risk Implications Equality Impact Assessment Over the last 12 months, discussions have taken place with Trafford Deaf Partnership (TDP) and Healthwatch Trafford with practice staff at Clinical Learning Events. Healthwatch Trafford produced a consultation and report around issues for deaf patients in healthcare. NHS England hosted events around improving translation services and consultation for the Accessible Information Standard which all GP s must be in compliance with. Currently translation services responsibilities sit with NHSE for Trafford. NHSE currently have a contract in place with Stockport Council for supporting translation services in Trafford, but this does not cover BSL interpretation services only spoken languages. Costs associated with legal challenges for noncompliance. 1. The current gaps in provision outlined in the research could put primary care at risk of noncompliance with the Equality Act 2010. 2. It also puts primary care at risk of non-compliance with the Accessible information Standards which is a mandatory requirement for NHS Trusts and GP practices set out in Section 250 of the Health and Social Care Act 2012. 3. It is more cost effective to book BSL interpreters than risk patients not turning up due to frustration or mistrust of the service 1. The information gathered has identified adverse effects from gaps in the support required for specific groups of patients. 2. The research highlights that a limited number of GP s in this patch seem to have the inclination to act upon this vital component of patients health. 3. There is a need for improvement in data collation to identify individuals in advance for support by BSL interpreters. 4. There is a need to consistently demonstrate due regard by working towards removing barriers created by ad hoc arrangements in place across GP practices which are affecting deaf patients experience and quality of local healthcare. Page 2
5. Good practice in place working with patients and stakeholder groups feedback to reduce inequalities. Communications Issues Public Engagement Summary Prepared by Responsible Director Signpost GP s and Practice Managers to compliance guidance, web pages etc, utilise existing forums and newsletters. Gather quantative data over 12 months of meeting compliance. Trafford CCG attends Trafford Deaf Partnership (TDP) meetings where this has been discussed with local charity Genie Networks and Healthwatch Trafford. Trafford CCG arranged for TDP to present at two clinical learning events, engaged with Healthwatch Trafford during their consultation for Getting it Right report, Heather Paul, Equity and Inclusion Business Partner Paul Hulme, Associate Director of Corporate Services and Organisational Development Page 3
SUPPORTING DEAF PATIENTS TO ACCESS PRIMARY CARE SERVICES 1 BACKGROUND 1.1 The paper is in the context of Trafford CCG s monitoring of its EDHR Strategy. There are three EDHR Objectives as part of its strategy, to be delivered over the four year period 2014 to 2017, these are:- a. Embed equality, diversity and human rights considerations into our commissioning decisions and the culture of the CCG. b. Ensure senior leadership is fully understanding of equality, diversity and human rights and effective in ensuring awareness and delivery of the EDHR agenda across the CCG and its membership practices. c. Ensure that health inequalities as they affect protected groups are measurably reduced. 1.2 Over the last 12 months Trafford s CCG Communications and Engagement Specialist, attended the Trafford Deaf Partnership meetings where issues faced by deaf patients in primary care across Trafford and poor patient experiences have been raised. Trafford Deaf Partnership also made presentations at two clinical learning events, with Healthwatch Trafford, to raise what the issues are; good practice and the recommendations from the Healthwatch Trafford Getting it Right report. GP practices then queried with Trafford CCG what the process and arrangements are for BSL interpreters in primary care. 1.3 Trafford CCG sought clarity with NHS England the booking of BSL interpreters. The responsibility for Translation and Interpreting services in Trafford, Oldham, Salford and Wigan for primary care currently sits with NHS England. The budget for Primary Care Translation and Interpreting Services is included within the co-commissioning delegated budgets to CCGs; therefore, responsibility for the provision of translation and interpreting services transfers back to the CCG as of 1st April 2016. 1.4 NHSE currently have a contract in place with Stockport Council (Language Line) for supporting translation services in Trafford, however, this does not cover BSL interpretation services only spoken languages. The advice from NHSE was that due to funding restrictions they needed to review BSL translation services in Trafford for primary care. Stockport has a population size of 283,300 which is more than Trafford s size of 230,000. Stockport CCG averages 110 primary care appointments per annum needing BSL interpreters at a cost of 6500. Page 4
1.4 The Accessible Information Standard known officially as SCCI1605 Accessible Information is a new information standard for implementation by all organisations that provide NHS or adult social care. Compliance with information standards of this type is a mandatory requirement, including NHS Trusts and GP practices by July 2016. This is set out in section 250 of the Health and Social Care Act as responsibility for GP practices. The Accessible Information Standard aims to ensure that people who have a disability or sensory loss receive information that they can access and understand, for example in large print, braille or via email, and professional communication support if they need it, for example from a British Sign Language (BSL) interpreter. The Specification also makes clear that commissioners must support providers to comply with the Standard, including through contracts, tariffs, frameworks and performance-management arrangements. Commissioners must also seek assurance from providers in this regard. 2. Research findings 2.1 NHSE does not fund the provision of BSL interpreters as these arrangements were not in place within the transferred service arrangements from Trafford Primary Care Trust (PCT). It does fund the provider of language interpreters and therefore this contractual gap needs clarity re providers of BSL. 2.2 Getting it Right Report 2015 Healthwatch Trafford produced the Getting it Right report after extensive consultation with deaf patients, BSL interpreters, service providers (including GP practices) and commissioners. GP practices were asked about the processes and practices in place for deaf patients. Healthwatch Trafford received 11 responses and these have been shared with Trafford CCG. 2.21 Themes that came out of the responses were:- None of the practices had a staff member trained in BSL All respondents noted they had alerts on clinical systems that flagged up if a patient was deaf Four respondents said they do not have visual displays to alert patients it s their turn for their appointment, though two respondents said they greet patients personally Six respondents said they do not have an agreed procedure when a deaf patient requests an appointment. One answered that the deaf patients husband s rings Nine respondents said they do not have a procedure for booking interpreters for emergency appointments Page 5
Another respondent wanted a best practice guide to work from and to be told what the process is for booking interpreters. 2.3 Other research carried out :- Practice Survey for supporting deaf patients using BSL Trafford Council BSL Interpretation service arrangements: o Genie Networks o Other CCGs in the region A summary of these are attached in Appendix 1. There are some good practice examples across GM regarding CCG s and with other local organisations such as Trafford Council where lessons have been learned and this intelligence can be utilised in Trafford. 3. SUMMARY BSL interpretation services are currently not included in the contract with Stockport Council who provides interpretation and translation services for GP practices in Trafford on behalf of NHSE. This is a retained service with Stockport Language Line.who do not provide BSL Interpreters. There are ad hoc arrangements in place across Trafford GP practices which are not clear and result in gaps that are affecting deaf patients experiences of local healthcare. In order to begin to raise awareness, Deaf Awareness Training was commissioned in 2015 for CCG staff and also provided for Practice Managers through representatives of the Deaf Partnership. The CCG will reiterate the message to GPs that they may be putting Deaf people at a disadvantage when accessing healthcare services by not ensuring appropriate access to BSL interpreters. This could also result in a failure to comply with the Human Rights Act 1998 - in particular the right to be free of inhumane or degrading treatment (article 3) and the right to a personal and family life (article 8). This disadvantage is also likely to be in breach of the duties outlined in the Equality Act 2010, which requires service providers to avoid unlawful discrimination and to make reasonable adjustments. Patients want clarity on the process for accessing BSL in primary care in Trafford. Some practice staff also indicated the need for clarity and a clear process for arranging interpreters for appointments and how deaf patients can access their practice to arrange appointments. However, there is no one model which is the right way and different models have developed based on evidence and research to achieve high quality service delivery. According to Sick of It, Deaf people do not get equal Page 6
access to physical health services (Sign Health, 2014). The study reported the poor quality of Deaf people s access to GP services including problems with diagnoses and treatment, and a lack of accessible information. 3. RECOMMENDATIONS The recommendations below will reduce the risk of Trafford CCG and NHS England being non-compliant with their obligations under the Equality Act 2010: a) EDHR to provide GPs with a briefing note to support them to comply with the Accessible Information Standard. b) Primary Care Team consider conduct a review of current provision of the 32 practices with EDHR, reviewing where the clusters of needs are regarding compliance of provision of data of protected characteristics. c) Primary Care Team consider reviewing with EDHR the CCG s current interpretation and translation policy and practice in light of the Accessible Information Standards, Healthwatch recommendations and best practice case studies in the Healthwatch report. d) The existing NHS SBS Interpretation & Translation Services framework agreement used by Greater Manchester CCG was extended up to October 2016. Trafford CCG collaborates with the retender for this framework which will commence in Spring/Summer 2016 for a 1 st November start date. e) Interim arrangements, continue to use Language Line (the telephone service) and Language Empire (provider of face to face interpreting includes BSL). Both are on existing procurement frameworks. Page 7