1. The Welsh NHS Confederation welcomes the opportunity to respond to the Welsh Government’s consultation on the Draft Innovation Strategy for Wales.
2. The Welsh NHS Confederation represents the seven Local Health Boards, three NHS Trusts, Digital Health and Care Wales and Health Education and Improvement Wales (our members). We also host NHS Wales Employers.
3. Innovation, by its nature, is disruptive and can challenge existing ways of working or thinking. The strategy has a task of bringing about a cultural shift within organisations to encourage a flow of new ideas which could alter and transform the existing health and care landscape. The nature of innovation needs to be embraced by both government and NHS organisations alike. It will be important to do this in a controlled and balanced way which recognises the accountability for use of public money with a light-touch which will allow innovative behaviours to flourish in the NHS in Wales.
Comments on Strategy
4. The NHS in Wales has proven that it can innovate at pace during the COVID-19 pandemic, demonstrating the effectiveness of streamlining governance and decision-making. The NHS Wales COVID-19 Innovation and Transformation Study Report, published in June 2021, revealed seven emerging themes that need to be considered when embedding innovative and transformative practice. Areas include; more agile use of resource; staff wellbeing; working together; accelerated decision-making; sustaining the pace of innovation and change; digital access and confidence; and embracing new technology. The strategy needs to support continued service transformation, without adding to the complex innovation landscape.
5. The strategy is a broad document and as such resources could be diluted through addressing the range of activity described. There could also be more emphasis on the social and wellbeing benefits of pursuing the strategy, with currently too much focus on the financial gains.
6. It is also difficult to discern the distinctive elements of the strategy and what may make it something that is uniquely Welsh, comparable to the Wellbeing of Future Generations Act. There could be consideration around what legislative and regulatory changes the Welsh Government could undertake to better support innovation as part of the broader strategy.
7. Short term goals for the strategy could be to support the NHS to respond to some of the critical challenges it is currently facing, particularly around addressing the backlog and winter pressures. The strategy could help to deliver a more sustainable and resilient healthcare system, but it does need to have more visible links to patient safety, quality and outcomes that matter most to people.
8. In the medium/long term, the strategy could support the service through addressing issues which extend beyond the NHS’ reach but have a tangible impact on population health and wellbeing. There are opportunities to address economic growth, climate change, preventative activities, and workforce shortages.
9. To achieve these benefits, the strategy needs to be stronger on reporting, evidencing impact and the appropriate governance structures which would allow innovations to develop at pace. It will be important that the strategy actively simplifies the innovation landscape in Wales, which many find confusing, with clear accountability and ownership across all sectors and Government departments.
10. A lack of sustainable health and care workforce will be a significant barrier for enabling the time, space, and capacity for innovation within NHS organisations to be codesigned and implemented. Provision of training to NHS staff to equip them with skills which underpin innovative behaviours needs to be increased, including a strong innovative procuring thread through professional qualification and education programmes. Training for future NHS leaders should also focus on cultural change and engendering less risk-averse behaviours when the governance structures they are working within allows it to. There needs to be clearer definition of the role of Public Service Boards (PSBs) and Regional Partnership Boards (RPB’s) and their pivotable partnership role in facilitating a truly integrated strategy.
11. Investments made in innovation must also take place over the long-term to allow for proper development and implementation.
12. It will be important that the strategy can support the creation of environments in which innovation can thrive, which will effectively support the NHS respond to the short to long term challenges with which it is contending. Doing so will require a cultural and behavioural shift, which must be supported through light-touch governance and the appropriately skilled workforce.