Evaluation on Consultation of the Lincoln walk in centre proposal for closure, based on info received via a freedom of information request.

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Following information received via Facebook from a post on the Lincolnite, and the comments made raising concerns over its closure, a Freedom of Information request was sent to the CCG asking for:

The recent request for public (https://www.surveymonkey.co.uk/r/wic-consultation) consultation states:

Since 2014, a number of reviews have been carried out to understand how and why people access and use the Walk-in-Centre. These reviews enabled us to understand the needs of those attending the Walk-in-Centre to develop future models of health services.

Following these reviews, evidence suggests that many people who use the Walk-in-Centre do not need to do so, and can be treated more appropriately elsewhere.

I request under the Freedom of Information Act:

Details of when and how these reviews where carried out?

What questions were asked/ the responses?

A copy of the findings of these reviews? Specifically relating to how, where and when these 

people could have been treated more appropriately elsewhere?

In response three documents have been received in relation to his request (copies available by contacting iggy@haloabletec.co.uk )

A report from Greater East Midlands Commissioning Support Unit (Route ways) July – October 2014.

A report from Public Health and the CCG, walk in centre review 1 September 2016

Lincoln walk in Centre key attendance data (for public consultation) event 2017

Evaluation

This information received has been evaluated in line with section 149 Duties under Equalities Act 2010, the basis of current Equalities Impact Analysis best practices, with consideration of the Gunning principles. (Note this isn’t the only piece of legislation or policy that requires effective consultation there are many others that are also relevant).

The Public Sector Equality Duty (section 149) consists of a general equality duty and specific duties, which help authorities to meet the general duty.

The aim of the general equality duty is to integrate considerations of the advancement of equality into the day-to-day business of public authorities.  In summary, those subject to the equality duty, must in the exercise of their functions, have due regard to the need to:

Eliminate unlawful discrimination, harassment and victimisation and other conduct that is prohibited by the Act. 

Advance equality of opportunity between people who share a characteristic and those who don't.

Foster good relations between people who share a characteristic and those who don't.

When considering what due regard is the act helps by defining it as such:

Removing or minimising disadvantages suffered by people due to their protected characteristics.

Taking steps to meet the needs of people from protected groups where these are different from the needs of other people.

Encouraging people from protected groups to participate in public life or in other activities where their participation is disproportionately low. (EHRC web site)

Current practise states that the best way of doing this is to produce an Equality Impact Assessment, using all the relevant protected characteristics (Age, Disability, Gender reassignment, Marriage and civil partnership, Pregnancy and maternity, Race, Religion and belief, sex and sexual orientation).

An Equality Impact Assessment is a process designed to ensure that a policy, project or scheme does not discriminate against any disadvantaged or vulnerable people. It helps by demonstrating:

Ensure that your decisions impact in a fair way: where there is evidence that particular groups will be negatively affected by a decision, action should be taken to address this.

Make your decisions based on evidence: EIA provides a clear and structured way to collect, assess and put forward relevant evidence.

Make decision-making more transparent: a process which involves those affected by the policy and which is based on evidence is much more open and transparent. This is more likely to engender trust in decision-makers and in your decisions.

Provide a platform for partnership working: EIA offers an opportunity for organisations to work in partnership to consider the impact on members of their shared communities and how they might best collaborate and co-ordinate financial decisions.

In order for the EIA to be relevant previous court decisions (Gunning principles) have stated that the process should ensure:

1. Issues are to be considered at the start.

2. People involved in the consultation need to have the necessary information to consider the effects of the decision (known and carried out usually through an Equality Impact Assessment). Both how positive and negative impacts the decision will have. If negative how these will be mitigated.

3. Adequate time for consideration and response is given

4. The people making the final decision must be aware of the views of the people’s views and use the information in making the decision. 

Comments

Having examined the reports, I would make the following comments.

Route ways report (July October 2014) not mentioned in public health report or final consultation report as a way of asking why the centre is considered important in public view. The Answers given in this report very relevant as it’s the only current one based on the views and perception of the public.

There also seems to be change on who uses the centre and the purpose in this report from the others, but no explanation is given.

2016 -Report Public Health and CCG, relies on data based on age, race, and poverty. No other data for disability or sexuality or religion or maternity. This is a core omission if the current needs. 19.1% of the population, with regard to disabilities are not considered, particularly as these will be those who according to their data sets are effected severely by poverty, mobility and additional health needs. This may also be similar for maternity and pregnancy factors and could skew some of the data and implications that the university has more of an effect then it does

This report concludes that usage is based on convenience rather than need.  However data shows advice given in line with current advice re self-care (STP) advice. -  Where would these approx. 30 thousand a year patients go and isn’t this one of the primary aims of the centre (see extract from public health and ccg below).

Another conclusion made in this report is excessive use by foreign nationals and this being down to university? I’m surprised considering the area and prevalence of Eastern European Communities in that area that this factor hasn’t been considered as an impacting factor.

The key attendance data 2017:- public health report and data for the CCG key attendance data seems to be out by about 5000 a year? Yet the data sets are the same? This needs to be checked to get accurate figures.

One of the main reasons outcomes for usage is that “guidance given helped” (report also says 67% referred back to GP) nothing is known as to if this referral was necessary or any follow up action which may have been required by the GP, and whether that this early intervention actually helped people. 32% where given a prescription this still seems like a substantial amount of need. Which cannot be met by chemists or self-care.

It would also have been relevant to know whether the highest rates of attendance (guidance given only) compares at other Doctors and usage in the county.

Conclusion

It is my opinion that the service at the moment fulfils its primary need well and is as commissioned to provide just what it is doing.

"The Walk in Centre on Monks Road in Lincoln is intended to provide fast access to health advice, emergency contraception and treatment of minor ailments, infections; or injuries such as cuts, strains and sprains health promotion and screening". (Public health and CCG report 2016).

The report the only one seen from 2014 is the only one to date that shows what people’s views and wants are, these have to be taken into consideration before any view is given.

Considering (according to news reports) that a decision to close the centre was made before a proper consultation had occurred is clearly wrong according to the principles of the Equality Act.

How can the decision makers say or show that all parts of the principles under the Gunning requirements have been complied with if a decision has been made on data that is partial and does not include disability or other relevant protected characterises, or that the decision makers have made the facts without fully considering service usage by all the relevant protected characteristics and the impact specific to them.

The last report being used in the current consultation again does not show the full data needed to comply with the Equality Act and therefore any consultations that have been held made even as a rear guard action after public opinion must be considered to be failing in providing the decision makers with the full and relevant data to make such an important decision.

Further the Equality process states that where negative impacts are shown it is imperative that these are mitigated. A clear plan should be given by the CCG and relevant parties showing how they expect the needs are to be met (at this point I have yet to see this). Again it’s my opinion that this can only be met by showing how this and other plans i.e. The Sustainable Transformation Plan or say the Joint Service Needs Assessments can or has the capacity for meeting these needs.

Please note: This is not a report on whether they should or should not close the walk in centre. It is based on my opinion on whether they have currently (12/07/17) complied with the statutory duties that are required by the organisation when carrying out such activities and consultations based on information received.