The network supports the Government's objectives of empowering patients and involving clinicians more closely in decision making but has identifed "significant risks, worrying uncertainties and unexploited opportunities" in the proposals.
The NHS Confederation is calling for the Government to reduce the risks associated with the design and implementation of its healthcare reforms, following extensive consultation with members.
Read the NHS Confederation response to the white paper.
Supplementary consultation responses
Our response to Equity and excellence: liberating the NHS, was published alongside four responses to the detailed consultations;
Implications for Mental Health Services
In each of the responses, the network has highlighted the key issues for MHN providers.
Regulating healthcare providers
The Mental Health Network:
- agrees with proposals that Monitor’s role should be developed as independent economic regulator for Foundation Trusts (FTs) while CQC ensures quality
- believes close collaboration between Monitor and CQC will be required to make these proposals work
- supports proposal of the removal of the cap on private income of FTs
- believes that there is a need for transparent diagnostic processes to analyse the barriers to FT status
- is concerned that the reforms pose a threat to the integration of services
- supports proposals for a level playing field
- is pleased to see that choice will be extended to some mental health services, the provision of information and use of personal health budgets will play an important role
- GP commissioners will need to be supported to understand and be ready to discharge their duties as commissioners in relation to choice and competition.
Commissioning
The Mental Health Network:
- welcomes the increased involvement of clinicians in commissioning but believes that a wide range of healthcare professionals should be engaged in the Consortia commissioning process.
- believes the challenge will be to establish a balance between mainstreaming mental health care and protecting specialist services for complex and longer term conditions
- suggests mental health services should be commissioned across integrated care pathways
- thinks that the majority of mental health commissioning responsibilities should sit locally with GP consortia, with health and well-being boards supporting partnerships and integration
- suggests that the independent board should consider commissioning some aspects of specialist offender mental health in the first instance due to the complexity of service delivery and significant unmet needs of this group
- believes that GP consortia should work with specialist providers to develop and deliver a capacity building programme to ensure that GP consortia have the right expertise to commission the full range of mental health services.
Outcomes
The Mental Health Network proposes that:
- the government should develop overlapping outcomes frameworks for health, public health and social care, against a co-ordinated timetable to ensure the content is consistent and professionals from different sectors are working together to achieve shared outcomes
- the outcomes should be based on the principles of recovery
- some process measures should be maintained as they allow adverse outcomes to be predicted and intervention to be made much earlier
- the framework should incentivise the NHS to improve public mental health and prevent mental illness across primary and secondary care.
- the framework should seek to narrow the health inequalities in all the outcome indicators, with a specific focus to address the well known health inequalities of people with serious mental illness
- the outcomes framework addresses the physical needs of people with mental health problems and the mental health needs of people with physical ill health
- the use of PROMs is supported, alongside other measures of quality and success of an intervention
- whole life outcomes could be developed which could be supported an underpinned by the principles of recovery and include being supported to retain or gain employment, live independently and educational gains for young people
- housing is included as a key outcome for people with serious mental illness in the final framework
- there should be a focus to measure the experience of mental health care pathways and specific mental health services.
Increasing democratic legitimacy in health
The Mental Health Network:
- believes the proposed arrangements for local HealthWatch and HealthWatch England do not currently support the creation of a strong effective consumer body. It needs to be properly resourced with appropriate capacity development
- is concerned that there is not sufficient provision of complaints advocacy and support for choice and suggest asking Citizen’s Advice Bureaux to provide these services locally
- believes that specialist advocacy services should be retained to support the most marginalised and disadvantaged users of health and social care services
- supports the concept of health and well-being boards, but want the government to clarify the accountability mechanisms
- agrees that health and well-being boards should be underpinned by statutory powers if they are to support joint working on health and wellbeing. More information is needed on how the arrangements and powers will work in practice
- recommends that improving public mental health and well-being should be mainstreamed across public health, health and social care given the impact this can have across all health conditions, to the economy and to the community
- suggesst applying a cross government public health outcomes framework to hold local government and other public departments to account for improving public physical and mental health
- is clear that any definition of public health should include mental health, and provide clarity to enable localities to clarify the roles and responsibilities of different parts of the system
- health and well-being boards should have particular responsibility for ensuring the needs of vulnerable and marginalised groups, including those not registered with GPs, are identified and explicitly considered as part of commissioning to ensure their needs are met
- is concerned that improvements in children’s health and well-being must remain a key priority, and it must be clear how health and well-being boards will support joint working across children’s services and relevant agencies
- GP consortia should take account of the JSNA in their commissioning decisions
- Aligning both the funding of public health improvement and for healthcare services commissioned by GPs to population needs and deprivation identified in JSNAs will help to ensure resources are focused most on areas of greatest need.
If you have any comments on the white paper consultations responses or the reforms more broadly please do not hesitate to contact claire.mallett@nshconfed.org