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Our responses to our consultations
UK-wide
RCOT and Specialist Section: Work responded to this consultation. The response can be found below.
The consultation document sets out:
• why the HCPC is involved in this piece of work;
• how registrants, employers and the wider health and care sector can work together to gain the benefits of effective preceptorship programmes;
• how the principles have been developed leading up to this consultation;
• how you can submit a response.
As part of this work, HCPC collaborated with Health Education England (HEE) and have engaged stakeholders across the 4 UK nations and 15 professions to build on existing examples of good practice in preceptorship.
The HCPC are proposing a 20% increase in registrant fees starting in July 2023. This would impact occupational therapists from August 2023 when the next renewal period for the profession begins.
Many RCOT members have contacted us to express their opposition to the proposed fees increase. Although we understand some of the rationale for why HCPC are proposing 20%, we strongly oppose this double the rate of inflation change.
The Department of Health and Social Care (GOV.UK) launched a consultation on Healthcare regulation: deciding when statutory regulation is appropriate. This consultation considered how the powers to introduce and remove professions from regulation might be used in the future. It asked for views on:
- the proposed criteria to make decisions on which professions should be regulated
- whether there are regulated professions that no longer require statutory regulation
- whether there are unregulated professions that should be brought into statutory regulation
England
The Department of Education launched a consultation seeking views on proposals to support childminders and childminder agencies (CMAs) and future policy development. We were invited by the Department of Education to respond to the single-issue question - should occupational therapists in primary care be able to make health declarations for prospective childminders? Further details about the consultation can be found here: www.gov.uk/government/consultations/childminder-recruitment-and-retention-consultation
RCOT response Childminder Health Checks 2024.pdf (PDF, 72.5KB)
This consultation launched by the Levelling Up, Housing and Communities Committee looked at what the Government can do to ensure disabled people have access to accessible and adaptable housing in England.
Members were asked to share their views on a new duty to improve disabled people’s access to communal areas of residential properties and how will this impact them and people requiring adaptations? This consultation regards the commencement and implementation of the remaining parts of section 36 of the Equality Act 2010. This legislation places a duty on landlords to make reasonable adjustments to the common parts of let residential premises when requested by a disabled person. ‘Common parts’ include outside areas, entrances, hallways, landings and stairwells.
Disabled people can already make such requests but there is currently no legal duty on the landlord to make reasonable adjustments to common parts. Before commencement, regulations will be needed to set out how the new arrangements will work. The government proposed that guidance would be drafted to help landlords and disabled people to understand their rights and obligations.
July 2022
The Government launched a public consultation on proposed changes to the Mental Capacity Act (MCA) Code of Practice for England and Wales, which included guidance on the new Liberty Protection Safeguards (LPS) system. The consultation document and the Code of Practice were also be published in Welsh. This was a joint consultation published by DHSC, Ministry of Justice, Department for Education and Welsh Government.
Link to consultation documents: https://www.gov.uk/government/consultations/changes-to-the-mca-code-of-practice-andimplementation-of-the-lps
July 2022
The Department of Health and Social Care (DHSC) and the Ministry of Justice (MoJ) consulted on the proposed changes to the Mental Capacity Act 2005 (MCA) Code of Practice, which includes guidance on the new Liberty Protection Safeguards (LPS) system. This consultation also sought views on the LPS regulations, which will underpin the new system.
The MCA applies in England and Wales, but some aspects of its application are devolved in Wales. The Welsh Government therefore informed this consultation.
The LPS will apply to people over the age of 16, and the Department for Education (DfE) has been involved in the development of this new system.
The government consulted on a number of documents:
- The Code of Practice
- LPS regulations
- LPS implementation products
Link to the consultation: https://www.gov.uk/government/consultations/changes-to-the-mca-code-of-practice-and-implementation-of-the-lps
July 2022
The government is committed to improving mental health and wellbeing outcomes, particularly for people who experience worse outcomes than the general population. This is a key part of their commitment to ‘level up’, and address unequal outcomes and life chances across the country.
The government has committed to develop a new cross-government, 10-year plan for mental health and wellbeing for England to support this objective. They want to ensure their new plan responds to the public’s priorities and set out what we can all do as a whole society to drive better outcomes. We all have mental health, and all have a part to play in changing things for the better.
A discussion paper and call for evidence to ask the public a range of questions to help develop the new plan was launched.
This discussion paper asked people:
- how can we all promote positive mental wellbeing? (chapter 1)
- how can we all prevent the onset of mental ill-health? (chapter 2)
- how can we all intervene earlier when people need support with their mental health? (chapter 3)
- how can we improve the quality and effectiveness of treatment for mental health conditions? (chapter 4)
- how can we all support people living with mental health conditions to live well? (chapter 5)
- how can we all improve support for people in crisis? (chapter 6)
This discussion paper was published by the Department of Health and Social Care, and has been informed by conversations with stakeholders, people with lived experience and government departments.
Link to consultation: Mental health and wellbeing plan: discussion paper and call for evidence - GOV.UK (www.gov.uk)
The government has published a green paper on the future of the special educational needs and disabilities (SEND) and alternative provision (AP) system and undertakook a public consultation on the green paper’s proposals.
The government is committed to improving outcomes for children and young people with SEND and those in alternative provision. They want to work with children, young people, parents, carers and those who advocate and work with them, as well as local and national system leaders, to achieve this ambition.
February 2022
This consultation closed on 27th February. Thank you to everyone who completed the survey. You will find a summary of the survey responses below, as well as a letter sent to NHS England & Improvement and NHS Supply Chain by the AHP Federation, of which RCOT is a member.
What was the consultation about: Members were asked to comment on revised proposals for a new, single-colourway Allied Health Professions uniform for NHS staff in England.
NHS England and Improvement and NHS Supply Chain sought support from RCOT for a new, standardised AHP uniform, as part of an ongoing national uniform project. The outcome of the project will affect all occupational therapists and occupational therapy support workers employed by the NHS in England, in settings where a uniform is worn.
Members were asked to tell us whether they felt the proposed design and colour choices would meet the needs of occupational therapy practitioners, colleagues, patients and the public and whether RCOT should support the proposal that has been put forward.
Background to the national uniform project
During 2020 and 2021 NHS Supply Chain consulted NHS staff on a proposal to introduce a nationally standardised uniform across the NHS in England. AHPs, including RCOT members, responded to the staff-wide survey, as well as a separate survey specifically for AHPs. Details of the consultation process and results can be found here. Our response to the consultation can be found here.
We and other AHP professional bodies have continued to participate in discussions with NHS Supply Chain, to ensure that the views, priorities and preferences of occupational therapists and AHP colleagues are addressed in the design of the new uniform.
Ensuring a strong professional identity
RCOT, in collaboration with UNISON, surveyed our members in May 2021 to seek additional comments on the uniform proposals. A strong priority for respondents was that uniforms must help to reinforce a clear professional identity. Two thirds of respondents felt that having different coloured uniforms for each of the allied health professions was the most effective way of enabling patients, visitors and colleagues to distinguish between the different professions.
Addressing sustainability
Increasing sustainability and reducing procurement costs are key aims of the uniform project. Sustainability is a priority across the NHS, with NHS England publishing a commitment to Delivering a Net Zero NHS. A Greener AHP Hub has also been launched to support AHPs to improve their own environmental sustainability.
We recognise the important role that occupational therapists have in addressing sustainability through your professional activities. You can read more about this here.
Single colourway vs individual colours – considering the pros and cons
NHS Supply Chain have produced an options appraisal document in response to feedback from RCOT and other AHP professional bodies regarding the proposed design and colour of AHP uniforms. The appraisal examines the benefits and drawbacks of having different coloured uniforms for each individual allied health profession, in comparison with one colourway option to be worn by all allied health professionals. It considers key factors of:
- Patient and visitor safety
- Professional image and suitability
- Equality, diversity and inclusion
- Value for money
- Sustainability
- NHS Supply Chain: Hotel Services National Uniform Project (PDF, 699.04KB)
The RCOT members’ response to the consultation is summarised here
Summary of uniform survey results Feb22.docx (DOCX, 92.76KB)
You can read the letter from the Allied Health Professions Federation to NHSE&I and NHS Supply Chain
Northern Ireland
The Health and Social Care (HSC) Trusts across Northern Ireland have worked collaboratively to produce a draft 5 year regional Equality Action Plan and a draft 5 year regional Disability Action Plan. It is important to ensure that there is regional consistency in how services are provided. The draft Disability Action Plan outlines the measures, which we collectively will take to fulfil the dual disability duties under Section 49A of the Disability Discrimination Act 1995 (as amended) which are to promote positive attitudes towards people with a disability and, to encourage their full participation in public life. The draft Equality Action Plan, which is in addition to our Equality Scheme, outlines proactive measures that we will take to address the inequalities identified in a recently conducted audit of Section 75 inequalities in health and social care.
July 2022
This consultation set out the Department of Health’s proposals for implementing the recommendations of the Power to People report, available on the DoH website.
There has been widespread engagement on this paper with a variety of stakeholders including those who use health and social care services, those who work in social care, employers, trade unions, service providers and family carers. These views will play a key role in supporting the Department to bring forward solutions and actions to meet the urgent as well as long term challenges facing the adult care and support system in Northern Ireland.
The consultation paper was divided into six chapters which are:-
- Sustainable System Building - To build a stable, sustainable adult social care system.
- A Valued Workforce - that staff who work in social care will be valued, competent and resilient.
- Individual Choice and Control - To ensure the individual has control over the decisions affecting their social wellbeing and their care and support needs.
- Prevention and Early Intervention - A renewed focus on prevention and early intervention to support people to achieve their own social wellbeing.
- Supporting Carers - Carers will be supported in their caring duties and entitled to support in their own right.
- Primacy of Home - The purposes of adult social care, including group care services, is to support citizens to live well in their own home in connection to their families, social networks and communities, providing maximum choice and control of their daily living arrangements and their care and support provision.
Following this consultation, the Department intends to develop a 10-year plan to address the many challenges in the organisation, funding, commissioning, planning and delivery of adult social care services.
Link to consultation: https://www.health-ni.gov.uk/consultations/consultation-reform-adult-social-care
Scotland
More than a third of children and young people in Scotland’s public and grant-maintained schools have an identified additional support need. Working under the direction of the Scottish Government’s policies, local authorities are responsible for identifying, providing and reviewing the additional support needs of children and young people.
The Committee is launching its inquiry with a call for people to share their experiences of how services are provided to people with additional support needs. The Committee is keen to hear from parents, teachers, support staff, carers, pupils themselves and support organisations.
The inquiry will consider how Scottish legislation that aimed to support children and young people, including 2004’s Additional Support for Learning Act, has been implemented and is working in practice.
The Committee is particularly interested in hearing views about the presumption that children and young people should receive a ‘mainstream education’, which aims to ensure they could be included alongside their peers; the impact of COVID-19 on the availability of additional support; and what happens when people are in dispute with their local authority over the services provided to a child or young person.
Addition Support for Learning Inquiry, RCOT Response December 2023.docx (DOC, 87.91KB)
Wales
The Children, Young People and Education Committee is conducting an inquiry into childcare and education access for disabled children and young people and the extent to which childcare providers, schools and local authorities meet their duties under the Equality Act 2010.
The Welsh Government want to put rules in place for how care and support services are commissioned in Wales.
These changes would become part of a Code of Practice. The Code of Practice is made under a law called the Social Services and Well-being (Wales) Act. There is already Codes of Practice for other parts of the law, but this new one will say what the rules are for how care and support services are commissioned.
RCOT Response – Rebalancing care support programme.docx (DOC, 92.66KB)
The Welsh Government plans to develop a national framework for social prescribing that would set a common set of standards and ensure consistent delivery.
They want to:
• develop a common understanding of the language used to describe social prescribing
• agree a model of social prescribing for Wales
• understand what is already happening across Wales, what is working well and what isn’t
• identify what action can be taken on a once for Wales basis
• help embed social prescribing services in areas where they either don’t exist or need to be developed further
• find out which technological solutions they need to develop
The Health and Social Care (Quality and Engagement) (Wales) Act 2020 places a duty of candour on NHS bodies in Wales. This Consultation sought views on the Regulations and Statutory Guidance needed to implement that duty.
The Welsh Government consulted on:
- how they introduce the Duty of Candour to NHS organisations through new statutory guidance and statutory regulations
- amending the 'Putting Things Right' regulations and guidance to enable the Duty of Candour to integrate with them
Joint professional bodies response to the Duty of Candour consultation Dec 22.docx (DOCX, 146.17KB)
Members were asked to share their views on a new duty to improve disabled people’s access to communal areas of residential properties and how will this impact them and people requiring adaptations?
This consultation regards the commencement and implementation of the remaining parts of section 36 of the Equality Act 2010. This legislation places a duty on landlords to make reasonable adjustments to the common parts of let residential premises when requested by a disabled person. ‘Common parts’ include outside areas, entrances, hallways, landings and stairwells.
Disabled people can already make such requests but there is currently no legal duty on the landlord to make reasonable adjustments to common parts. Before commencement, regulations will be needed to set out how the new arrangements will work. The government proposed that guidance would be drafted to help landlords and disabled people to understand their rights and obligations.
Link to consultation: https://www.gov.uk/government/consultations/improving-disabled-peoples-access-to-let-residential-premises-reasonable-adjustments-to-common-parts-a-new-duty
July 2022
The Government launched a public consultation on proposed changes to the Mental Capacity Act (MCA) Code of Practice for England and Wales, which included guidance on the new Liberty Protection Safeguards (LPS) system. The consultation document and the Code of Practice were also be published in Welsh. This was a joint consultation published by DHSC, Ministry of Justice, Department for Education and Welsh Government.
July 2022
The Department of Health and Social Care (DHSC) and the Ministry of Justice (MoJ) consulted on the proposed changes to the Mental Capacity Act 2005 (MCA) Code of Practice, which includes guidance on the new Liberty Protection Safeguards (LPS) system. This consultation also sought views on the LPS regulations, which will underpin the new system.
The MCA applies in England and Wales, but some aspects of its application are devolved in Wales. The Welsh Government therefore informed this consultation.
The LPS will apply to people over the age of 16, and the Department for Education (DfE) has been involved in the development of this new system.
The government consulted on a number of documents:
- The Code of Practice
- LPS regulations
- LPS implementation products
Link to the consultation: https://www.gov.uk/government/consultations/changes-to-the-mca-code-of-p...
June 2022
As part of its inquiry into the impact of the waiting times backlog on people in Wales who are waiting for diagnosis or treatment, the Health and Social Care Committee sought written evidence from health and social care stakeholders on the plan for transforming and modernising planned care and reducing waiting lists published by the Welsh Government on 26 April 2022. published by the Welsh Government on 26 April 2022.
The Committee asked for views on the following matters:
• Whether the plan will be sufficient to address the backlogs in routine care that have built up during the pandemic, and reduce long waits.
• Whether the plan strikes the right balance between tackling the current backlog, and building a more resilient and sustainable health and social care system for the long term?
• Whether the plan includes sufficient focus on:
o Ensuring that people who have health needs come forward;
o Supporting people who are waiting a long time for treatment, managing their expectations, and preparing them for receiving the care for which they are waiting, including supported self-management;
o Meeting the needs of those with the greatest clinical needs, and those who have been waiting a long time;
o Improving patient outcomes and their experience of NHS services?
• Whether the plan provides sufficient leadership and national direction to drive collective effort, collaboration and innovation-sharing at local, regional and national levels across the entire health and social care system (including mental health, primary care and community care)?
• Whether the plan provides sufficient clarity about who is responsible for driving transformation, especially in the development of new and/or regional treatment and diagnostic services and modernising planned care services?
• Are the targets and timescales in the plan sufficiently detailed, measurable, realistic and achievable?
• Is it sufficiently clear which specialties will be prioritised/included in the targets?
• Do you anticipate any variation across health boards in the achievement of the targets by specialty?
• Is there sufficient revenue and capital funding in place to deliver the plan, including investing in and expanding infrastructure and estates where needed to ensure that service capacity meets demand?
• Is the plan sufficiently clear on how additional funding for the transformation of planned care should be used to greatest effect, and how its use and impact will be tracked and reported on?
• Does the plan adequately address health and social care workforce pressures, including retention, recruitment, and supporting staff to work flexibly, develop their skills and recover from the trauma of the pandemic?
• Is there sufficient clarity about how digital tools and data will be developed and used to drive service delivery and more efficient management of waiting times?
March 2022
Social Care Wales asked for comments on their plan for the professional mental health workforce for health and social care in Wales.
They developed the plan with Health Education and Improvement Wales (HEIW) to respond to the actions outlined in Together for Mental Health. To make sure they develop a full approach to supporting people, the plan includes all parts of the workforce who play a role in mental health services.
The actions they suggested in the consultation were a result of the engagement, research and analysis they have carried out.
February 2022
The Health and Social Care Committee of the Welsh Parliament held an inquiry into mental health inequalities.
The Committee looked for views about:
- Which groups of people are disproportionately affected by poor mental health in Wales? What factors contribute to worse mental health within these groups?
- For the groups identified, what are the barriers to accessing mental health services? How effectively can existing services meet their needs, and how could their experience of using mental health services be improved?
- To what extent does Welsh Government policy recognise and address the mental health needs of these groups? Where are the policy gaps?
- What further action is needed, by whom/where, to improve mental health and outcomes for the groups of people identified and reduce mental health inequalities in Wales?
The committee wanted to ensure that their work is informed by experiences, needs, and views that reflect the diversity of the people and communities affected by these issues.