Single Equality Scheme Medway Primary Care Trust 2010-2013
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Contents Foreword ........................................................................................................................................ i Introduction ...................................................................................................................................1 What do we mean by Equality? ...............................................................................................1 What is a Single Equality Scheme? ...........................................................................................2 Objectives of the Single Equality Scheme...............................................................................2 Additional and Support Documents:......................................................................................3 About Medway – People and Community ..............................................................................4 Geography and Demography ..................................................................................................4 Deprivation ...............................................................................................................................11 Health Inequalities...................................................................................................................12 Understanding Equality and Diversity: .................................................................................14 The Legal and Compliance Framework ...............................................................................14 Human Rights ..........................................................................................................................15 The Equality Strands and Statutory Duties...........................................................................16 Ethnicity ....................................................................................................................................16 Disability ...................................................................................................................................16 Gender .......................................................................................................................................17 Gender Identity ........................................................................................................................17 Age .............................................................................................................................................18 Sexual Orientation ...................................................................................................................18 Religion or Belief ......................................................................................................................19 Our Goals for the Future ...........................................................................................................20 NHS Medway ..............................................................................................................................22 NHS Medway Equality and Diversity Policy ......................................................................23 Workforce..................................................................................................................................24 Working in Partnership...........................................................................................................25 Strategic Theme 1: Promoting Equality Through Commissioning, Contracting and Procurement .............................................................................................................................28 Strategic Theme 2: Patient Experience ..................................................................................36
Strategic Theme 3: Workforce ................................................................................................38 Enabling Strategy 1: Leadership and Governance ..............................................................46 Enabling Strategy 2: Building the Evidence Base................................................................47 Enabling Strategy 3: Equality Impact Assessment ..............................................................50 NHS Medway Action Plan........................................................................................................54 Medway Community Healthcare ............................................................................................63 Medway Community Healthcare Equality and Diversity Policy .....................................63 Workforce..................................................................................................................................64 Working in Partnership...........................................................................................................65 Strategic Theme 1: Promoting Equality through Commissioning, Contracting and Procurement .............................................................................................................................67 Strategic Theme 2: Patient Experience ..................................................................................68 Strategic Theme 3: Workforce ................................................................................................71 Enabling Strategy 1: Leadership and Governance ..............................................................78 Enabling Strategy 2: Building the Evidence Base................................................................79 Enabling Strategy 3: Equality Impact Assessment ..............................................................82 Medway Community Healthcare Action Plan ......................................................................85 Appendix 1: Public Sector Equality Duties and Legal Framework...................................96 Appendix 2: Involvement and Consultation .......................................................................101 Appendix 3: The Medway PCT Single Equality Scheme Relationship with the CQC Regulation Framework ............................................................................................................112 Appendix 4: Acknowledgements...........................................................................................114
Foreword We are pleased to introduce the Single Equality Scheme – this is an important document, not simply because it ensures our compliance with the law, but because it is about the delivery of a fair service. This Scheme sets out our commitment to taking Equality and Human Rights into account in everything we do, whether that is in providing services, employing people, developing policies, communicating, consulting or involving people in our work. It provides a clear picture of the significant targets we have set in relation to Equality and Human Rights. It is a long term commitment driven by both equalities legislation, and by the needs and wishes of our local community and staff. For that reason, much of the work will be ongoing. Our Trust Board commits to monitoring our progress and reporting regularly and openly on the developments in this Scheme. Making sure the Action Plan in our Scheme happens is the responsibility of everyone in our organisation. This has to be planned and supported in an effective way so that everyone concerned can play their part in turning this Scheme into reality. We look forward to the work ahead, facing the challenges, and meeting the actions we have set ourselves – in order to achieve the goal of a world class commissioning organisation in a modern society where equity thrives in both access and outcome. The Single Equality Scheme is available in alternative formats on request. Please contact the Communications and Engagement Team on 01634 335 219 or internal.comms@medwaypct.nhs.uk.
Denise Harker Chairman
Marion Dinwoodie Chief Executive
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Medway PCT Corporate Section
Introduction Medway PCT is delighted to present its first Single Equality Scheme for the period 2010 - 2013. Broad ownership of the scheme and commitment to the actions contained in it are vital to its success and we have engaged with a wide range of internal and external stakeholders in developing our Scheme and Action Plans. We want to thank all of those people who contributed to the consultation process and to the greatest extent possible we have included your recommendations. Many of your ideas related to specific areas of service delivery or specific services and these comments, we have addressed through specific service plans rather than in this more strategic document. Medway PCT has been working hard to improve health inequality across Medway for many years and has always worked to avoid any forms of discrimination in either our service delivery or as an employer. However, we appreciate that our community is becoming increasingly diverse and our understanding of equality and diversity and how it impacts our community and staff is becoming more sophisticated. In addition, there is a changing legislative and regulatory framework that we need to operate within, which requires a more proactive and systematic approach to how we deliver equitable outcomes for everyone in Medway. This Single Equality Scheme is a step in that process. It is designed to be a public statement of our commitment to carrying out our work in a way that promotes equality.
What do we mean by Equality? Equality can mean many things to different communities and is a term often open to interpretation. At Medway PCT we consider that the definition of equality set out in the 2007 Equality Review provides a description that aligns with our goal of creating a great place to live and work. “An equal society protects and promotes equal, real freedom and opportunity to live in the way people value and would choose, so that everyone can flourish. An equal society recognises people’s different needs, situations and goals, and removes the barriers that limit what people can do and be”.
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What is a Single Equality Scheme? A Single Equality Scheme is a plan which outlines how we will promote equality through every aspect of our work. It takes into account the constant and rapid change among the communities we serve and their healthcare needs with a human rights based approach. All public bodies are required to have in place Race, Gender and Disability Equality Schemes which set out how they plan to meet the ‘general and specific duties’ contained in each of the following pieces of legislation:
The Race Relations (Amendment) Act 2000
The Disability Discrimination Act 2005; and
The Equality Act 2006.
This document should be considered as our strategic approach to embedding equality and diversity into how we do business; it does not contain objectives for the improvement of specific health services or specific areas of clinical need. These local service based objectives will be outlined in specific service development or improvement plans. This document aims to outline our overall vision for ensuring that equality and diversity becomes a core operating principle for our service planning and delivery, resource allocation, decision making and workforce development.
Objectives of the Single Equality Scheme At Medway PCT we recognise our responsibilities in law in relation to equality for:
Women and men (including transgender women and men);
Disabled people (including people with a learning disability, people who experience mental health conditions and people with sensory or physical impairments);
People in all ethnic groups (including refugees and asylum-seekers, gypsies and travellers and migrant workers);
Lesbians and gay men, bisexual and heterosexual people;
People of any religion or belief or none; and
People of all ages.
We also recognise the impact of social exclusion and disadvantage and we are committed to promoting social inclusion as part of our work on equalities and in anticipation of the new Single Equality Bill and the duties that we understand will be embedded in this legislation.
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We have developed this Single Equality Scheme to bring together our work in relation to disability, gender, gender identity, ethnicity, age, sexual orientation, religion or belief, together with social inclusion and human rights. It replaces our previous Race, Disability and Gender Equality Schemes and provides a single response to our obligations under the equality duties. The objectives of the Medway PCT Single Equality Scheme are to:
Support the achievement of Medway PCT’s challenging aims; including making the successful changes to the operating framework of NHS Medway and Medway Community Healthcare;
Discharge our responsibilities to promote equality of opportunity, eliminate unlawful discrimination, promote good relations between different groups and ensure compliance with our legal responsibilities; and
Deliver a coherent and sustainable plan for embedding equality and human rights into the work of Medway PCT, making sure that we have in place the systems needed to deliver on equality, diversity and human rights, to monitor our progress and report on our achievements.
This Single Equality Scheme follows a structure which outlines our approach and commitment to equality and diversity under a series of themes, with three enabling strategies which underpin all the strands of work. Our aim in drafting this document is to:
Clearly state our position in relation to promoting equality outcomes through all aspects of health service commissioning and delivery; and
Identify the priorities for action over the next three years to move the agenda forward and achieve tangible results.
Additional and Support Documents:
More information on equality law can be found in Appendix 1
Our proposed summary Action Plan can be found at Appendix 2
Consultation findings and our responses to them presented after the consultation period in Appendix 3
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About Medway – People and Community Geography and Demography Medway is geographically located in Kent, in South East England. Politically, Medway Council is now a unitary authority and independent from Kent County Council, although maintains close ties and enjoys a cooperative relationship.
Approximately 70% of the members of the 2006 Citizens’ Panel agreed that their neighbourhood is a place where people can get on well with one another. In 2007, the OfSTED TellUs2 survey of young people reported that 68% of Medway respondents answered “fairly good” or “good” to the question “What do you think of your place as a place to live in?”
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Traditionally known as “the Medway Towns”, the area of Medway is comprised of the towns of Strood, Rochester, Chatham, Gillingham and Rainham, as well as a number of rural areas, including the Hoo Peninsula. Medway is currently divided into 22 administrative wards: 1 Chatham Central
12 Rainham South
2 Cuxton and Halling
13 River
3 Gillingham North
14 Rochester East
4 Gillingham South
15 Rochester South and Horsted
5 Hempstead and Wigmore
16 Rochester West
6 Lordswood and Capstone
17 Strood North
7 Luton and Wayfield
18 Strood Rural
8 Peninsula
19 Strood South
9 Princes Park
20 Twydall
10 Rainham Central
21 Walderslade
11 Rainham North
22 Watling
Medway is also part of the Thames Gateway area and undergoing a programme of significant regeneration and growth. The population is currently estimated at 252,000 with a projected growth rate of 4.6% by 2018, although this figure does not take account of the likely impact of the Thames Gateway regeneration or the growth of universities. The regeneration programme is currently focused on brownfield sites along the waterfront, the redevelopment of Chatham as Medway’s city centre, development in Grain, Kingsnorth and Chattenden, as well as improvements to existing town centres. The regeneration is expected to bring housing, jobs and investment in transport and community facilities. It has also led to expectation of a population increase of approximately 50,000 over the next 20 years. This increase in population will present a number of challenges and opportunities for all public services across Medway and specifically create an increasingly diverse community and health profile.
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Age and Gender Medway currently has a young population but is ageing at a relatively rapid rate. At present, the average age in Medway is calculated at 37.4 years, compared to 38.1 in the South East and 39.1 for England. However, it is anticipated that the greatest proportion of population increase will be in the older age groups. The over 65 age group is expected to grow by 29% and the over 85 age group by 32%. In contrast, the under five age group is expected to grow by only 7%. The table below shows the current age distribution, based on Office for National Statistics (ONS) figures. Medway All Persons - All Ages
South East
England
253,500
8,380,100
51,446,200
Men - All Ages
49.3%
49.0%
49.2%
Women - All Ages
50.7%
51.0%
50.8%
All Persons - Aged 0-15
20.4%
19.0%
18.8%
All Persons - Aged 16-29
18.8%
17.5%
18.8%
All Persons - Aged 30-44
21.6%
21.1%
21.3%
Men Aged 45-64, Women Aged 45-59
22.5%
22.6%
22.0%
Men Aged 65+, Women Aged 60+
16.6%
19.9%
19.1%
The table below shows ONS population projections by age group to 2023. Although the table shows an overall increase, we can clearly see that the greatest and steadiest increase is in the older age groups. All other age groups show considerable fluctuation and the 15-29 age group actually shows an overall decrease rather than increase. Age Group
2008
2011
2013
2018
2023
Population % Change
0-4
16,200
17,100
17,300
17,300
17,100
6.4 6.3
5-14
32,200
31,200
31,400
33,400
34,500
12.7 12.7
15-29
51,100
51,500
51,600
49,100
47,800
20.2 17.6
30-44
54,900
52,800
51,700
52,100
55,500
21.7 20.5
45-60
49,300
51,400
52,700
54,400
51,700
19.5 19.1
60-85
45,300
47,900
49,500
53,100
58,000
17.9 21.4
85+
4,100
4,300
4,500
5,400
6,700
1.6 2.5
253,100
256,200
258,700
264,800
271,300
Total
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Within individual wards there is some variation in the age distribution. For example, the proportion of children within the population ranges from 18.2% in Rochester West to 25.8% in Princes Park. Similarly, the proportion of people aged over 65 ranges from 5.8% in Princes Park to 16.3% in Rainham North. It is likely that these concentrations are linked to the location of relevant services and facilities e.g. schools or nursing homes. In terms of gender the population is very evenly divided and demonstrates standard variation in life expectancy. Although life expectancy figures for both men and women in Medway are slightly lower than the averages for the South East and for England. Average Life Expectancy
Women
Men
Medway
80.8
76.4
South East
82.4
78.5
England
81.6
77.3
A similar difference can be seen in the figures for additional average life expectancy i.e. the number of years remaining at the age of 65. Average Additional Life Expectancy (at 65)
Women
Men
Medway
19.2
16.5
South East
20.5
17.9
England
19.9
17.2
Disability ONS figures put the disability free life expectancy for men in Medway at 61.9 years. This is lower than the average for the South East, at 64.7, but slightly higher than the English average of 61.7. For women, the disability free life expectancy is 64.2 years. Again, this is lower than the average for the South East, at 67, but the same as the English average, also 64.2 years. The proportion of people who identified themselves as living with a long-term illness in the last census was 15.6%. This is only marginally higher than the regional figure of 15.5% and lower than the national figure of 17.9%. ONS figures from February 2009 showed a total of 8,770 people claiming incapacity benefits in Medway. This included 840 claims for severe disablement
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allowance. Just over half (57%) of all claimants were men and the majority were of working age. Only 12% of claimants were aged over 60. As shown in the table below, we can see that the medical pattern of claims is broadly in line with regional and national figures. Medical Reason for Claiming
Medway
South East
England
40%
44%
42%
Diseases of the Nervous System
7%
8%
7%
Diseases of the Respiratory or Circulatory System
7%
6%
7%
18%
15%
17%
7%
5%
5%
21%
22%
22%
Mental Disorders
Musculoskeletal Diseases Injury or Poisoning Other
Ethnicity The population of Medway is predominantly white, with the Indian community currently representing the largest minority group. ONS population estimates from June 2007 provide the following distribution of ethnic groups in Medway’s population. Ethnicity
Medway
South East
England
All Ethnic Groups
252,200
8,308,700
51,092,000
Count
%
Count
%
Count
%
White
232,500
92.2
7,647,800
92.0
45,082,900
88.2
British
225,200
89.3
7,246,700
87.2
42,736,000
83.6
Irish
2,300
0.9
82,700
1.0
570,500
1.1
Other White
5,000
2.0
318,400
3.8
1,776,300
3.5
Mixed
3,700
1.5
126,700
1.5
870,000
1.7
White / Black Caribbean
1,200
0.5
33,600
0.4
282,900
0.6
500
0.2
16,500
0.2
114,300
0.2
White / Asian
1,300
0.5
43,200
0.5
260,900
0.5
Other Mixed
800
0.3
33,400
0.4
212,000
0.4
Asian or Asian British
9,300
3.7
288,200
3.5
2,914,900
5.7
Indian
5,700
2.3
140,800
1.7
1,316,000
2.6
Pakistani
1,400
0.6
80,200
1.0
905,700
1.8
Bangladeshi
1,000
0.4
25,800
0.3
353,900
0.7
Other Asian
1,200
0.5
41,600
0.5
339,200
0.7
White / Black African
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Medway PCT Corporate Section Ethnicity
Medway
South East
England
Black or Black British
3,800
1.5
130,100
1.6
1,447,900
2.8
Caribbean
1,400
0.6
47,000
0.6
599,700
1.2
African
2,100
0.8
73,200
0.9
730,600
1.4
400
0.2
9,900
0.1
117,600
0.2
Chinese or Other
2,800
1.1
115,900
1.4
776,400
1.5
Chinese
1,700
0.7
58,900
0.7
400,300
0.8
Other Ethnic Group
1,100
0.4
57,000
0.7
376,100
0.7
Other Black
Data from the Joint Strategic Needs Assessment (JSNA) shows that the proportion of White British people in the population is highest in the older age groups and lowest amongst children. There is also some variation amongst the wards of Medway. % White
% Asian or Asian British
% Mixed
% Black or Black British
% Other
Chatham Central
89.4
7.4
1.4
1.1
0.7
Gillingham South
91.6
4.8
1.6
1.1
0.9
River
91.7
2.8
1.4
1.6
2.6
Rochester S. And Hors
91.9
5.7
1.1
0.5
0.7
Rochester East
92.7
4.4
1.3
0.8
0.8
Strood North
92.7
4.9
1.0
0.7
0.7
Watling
93.2
4.3
1.0
0.8
0.8
Rochester West
93.8
2.3
1.3
1.7
1.0
Hempstead and Wigmore
93.9
3.6
1.0
0.6
1.0
Gillingham North
94.4
2.6
1.6
0.9
0.5
Luton and Wayfield
94.4
2.7
1.3
1.0
0.6
Princes Park
96.0
1.6
1.2
0.7
0.5
Lordswood and Capstone
96.1
1.7
1.0
0.5
0.6
Walderslade
96.3
1.8
1.0
0.5
0.4
Rainham South
96.3
1.5
1.1
0.5
0.7
Rainham Central
96.4
1.9
0.9
0.4
0.4
Strood South
96.5
1.5
0.8
0.6
0.6
Twydall
96.6
1.8
1.0
0.5
0.2
Strood Rural
96.7
1.7
0.7
0.4
0.5
Rainham North
97.3
1.3
0.8
0.3
0.3
Cuxton and Halling
97.8
1.1
0.7
0.0
0.4
Peninsula
98.1
0.7
0.5
0.3
0.4
Ward
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Religion or Belief The pattern of religion or belief within Medway’s population is broadly similar to the regional and national figures, with the majority identifying as Christian and those of no religion comprising the second largest group. However, as can be seen below, there are significantly fewer Jewish and Muslim people in the South East than there are in England and an even lower proportion in Medway. Conversely, the proportion of Sikhs in Medway is significantly higher than the national figure and more than twice the average for the South East. Religion
Medway
South East
England
Christian
72.0%
72.8%
71.7%
Buddhist
0.2%
0.3%
0.3%
Hindu
0.7%
0.6%
1.1%
Jewish
0.1%
0.2%
0.5%
Muslim
1.0%
1.4%
3.1%
Sikh
1.2%
0.5%
0.7%
Any other religion
0.3%
0.4%
0.3%
No religion
16.7%
16.5%
14.6%
Religion not stated
7.8%
7.5%
7.7%
Sexual Orientation There is currently no data held on sexual orientation for the population of Medway. Government estimates for the national population are that 5-7% are lesbian, gay or bisexual. This estimate is supported by Stonewall.
Gender Identity NHS data suggests that 1 in 4,000 people in the UK are currently accessing medical help for gender dysphoria (the feeling of being trapped in a body of the wrong sex). 1 There is no specific data for the population of Medway. The Department of Health estimates that the number of transsexual people (those who have undergone, are about to undergo or are currently undergoing gender reassignment treatment) in the UK is 1 in every 11,500. However, many organisations working with transpeople believe this to be an under-estimation. Please see Page 17 for more detail on gender identity.
1
http://www.nhs.uk/conditions/gender-dysphoria/Pages/Introduction.aspx
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Socio‐Economic Status This is dealt with under the heading of “Deprivation” below.
Deprivation Overall Medway is not a deprived area, but at ward level we have some of the most affluent and some of the most deprived areas in the country. This does have an impact on people’s quality of life. In particular, the average health and life expectancy of people in the more deprived areas is not as good as the average for Medway as a whole. Of the 22 wards in Medway, three (Gillingham North, Chatham Central and Luton and Wayfield) are in the 20% most deprived in England and a further two (Rainham Central and Hempstead and Wigmore) are in the 20% least deprived. Furthermore, relative differences of deprivation can be found within small areas. For example, in River ward 35% of people live within neighbourhoods assessed to be in the 20% most deprived neighbourhoods in England and 28% live within the 20% least deprived. Just over a quarter (26%) of Medway’s workforce commute out of the area. Almost half the jobs in Medway are within the public or retail sectors. Within the other sectors Medway has a relatively low percentage of higher paid jobs. Consequently, the average income in Medway is 10% less than the national average. As expected, those areas with high levels of deprivation typically suffer on most domains of deprivation: income, employment, health, education, crime and living environment. The only domain that is an exception to this rule is the barriers to housing and services domain; this partly relates to the distance to services and so rural communities perform poorly on this measure. Children are marginally more likely to live in deprived neighbourhoods, whereas older people are more likely to live within the least deprived neighbourhoods. In common with national trends, the number of households which met the criteria for statutory homelessness in Medway was 1.7 per 1,000 households in 2007/08. This is slightly above the figure for the rest of the South East, at 1.6, but below the national figure of 2.5. (Source: Communities & Local Government and Medway statutory returns).
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Health Inequalities The life expectancy of a population is linked to deprivation and in Medway deprivation drives a significant loss of life years resulting from coronary heart disease and lung cancer. This is consistent with the link between deprivation and the lifestyle risk factors such as smoking, poor diet and obesity. Compared to the average for the rest of England, the population of Medway is:
Younger;
More likely to smoke;
More likely to be overweight;
Less likely to eat five helpings of fruit and vegetables; and
Likely to die younger.
People in the most deprived parts of Medway suffer more ill-health and live on average 6.8 years less than people in the least deprived areas. The major causes of death in Medway are heart disease, stroke, cancer, and respiratory disease. (Source: Joint Strategic Needs Assessment 2008 carried out by Medway PCT and Medway Council) Much of the lifestyle data in the JSNA comes from:
CACI HealthACORN data; and
ONS population estimates.
HealthACORN is a survey tool used to identify and understand the UK population and provides particular insight into the diet, exercise and illness attributes of the people in a community. HealthACORN data categorise a location’s residents into a number of broad health groups: Existing Problems, Future Problems, Possible Future Concerns and Healthy. Medway compares well to other areas, with 49% of the population categorised as ”healthy”. HealthACORN estimate that only 18% of local authorities have a larger proportion of people falling in the “healthy” category than Medway does. This is partly due to the relatively young age profile of Medway. The three most deprived wards – Gillingham North, Chatham Central and Luton & Wayfield – have the highest levels of people estimated to have future health problems. Smoking is a major concern in Medway. The latest available data suggests that Medway has the highest level of smoking of all local authority areas in the South East, at 31.3% of the adult population, enhancing the prospect of future smoking related illness in Medway.
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Compared to the rest of the South East, the figures relating to diet and obesity are fairly poor. Of the 67 local authorities in the South East, Medway has the sixth highest percentage of people that are obese and the third lowest percentage of adults that consume five or more portions of fruit or vegetables per day. Alcohol consumption and drug misuse amongst adults is typical of other localities. Alcohol consumption amongst young people is also in line with other localities, although the percentage of young people who stated in the 2007 OfSTED TellUs2 survey that they have never taken any drug is marginally lower than the national average. The teenage pregnancy rate in Medway has remained stubbornly high. Over a quarter (26%) of 14 year old girls are sexually active and 33% of 11-15 year olds do not always use contraception. The lifestyle information presented here suggests a relatively high risk of ill health, particularly in relation to cardiovascular disease and cancer. This risk will be most evident in the more deprived areas and will, therefore, contribute to health inequalities.
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Understanding Equality and Diversity: The Legal and Compliance Framework Legal Duties There are a number of legal duties on Medway PCT in relation to equality, which are summarised in Appendix 1. The legal duty to develop Equality Schemes relate to race, gender and disability but the Equality Act 2010 extends this obligation to the other strands. This is why Medway PCT, along with most other public sector bodies, has decided to produce a Single Equality Scheme. This has involved:
Research of legislation, best practice and NHS national policies;
Mapping of Medway PCT good practice and areas for improvement;
Establishing a monitoring framework for all relevant employment, training and service delivery areas;
Consultation with staff, service users and partners;
Communication of the scheme; and
Establishing mechanisms for managing the performance of the Scheme and production of an annual report.
Care Quality Commission (CQC) Requirements The Care Quality Commission is the independent regulator of health and adult social care services in England and their core function is to drive improvement across health and adult social care by:
Putting people first and championing their rights;
Acting swiftly to remedy bad practice; and
Gathering and using knowledge and expertise, and working with others.
All healthcare organisations are required to comply with the regulatory framework outlined by the CQC. Medway PCT had complied with all core standards, except for former criterion C7e, without significant lapse during the period 1 April 2009 to 30 September 2009. Core standard C7e required organisations “to challenge discrimination, promote equality and respect human rights” in accordance with the human rights and equality legislation, including the public duties to promote equality.
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On 1 April 2010 the CQC introduced a new registration and regulatory framework with specific areas of priority in relation to:
Involvement and information for service users;
Personalised care and treatment and support;
Issues of safety and safeguarding;
Suitability of staffing;
Quality of management; and
Suitability of management.
It should be noted that the standard of performance in relation to equality and diversity is now more firmly embedded in each of the core standards of performance rather than as a stand alone. In July 2010 Medway Community Healthcare obtrained full registration with no conditions .
Human Rights “A human rights based approach is about applying internationally agreed standards across the whole of healthcare. It’s a way of thinking and seeing that should underpin everything that we do.” Department of Health (2008) Human Rights in Healthcare: a short introduction Medway PCT is committed to a human rights based approach. We recognise that much of our work has the potential to promote key human rights, such as the right to life and the right to education. We also recognise that there are potential risks to human rights through some of our functions, for example the way in which we use and store confidential information about individual patients and staff (the right to respect for private and family life, home and correspondence). We also recognise that members of particular groups – disabled people, older people, younger people, BAME (black and minority ethnic) people, lesbians and gay men, transgender people and those who are socially excluded (such as homeless people) – may be more vulnerable to human rights breaches. This Single Equality Scheme and the actions it sets out are, therefore, a key part of our human rights based approach. Our Scheme sets out how we will promote, protect and monitor the right of everyone who works for or comes into contact with Medway PCT not to be discriminated against (Article 14).
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The Equality Strands and Statutory Duties The equality areas or strands within Medway PCT are gender, disability, ethnicity, age, religion or belief, sexual orientation and gender identity. The strands are inclusive of all people. As a statutory body Medway PCT has general duties to promote equal opportunities relating to race, disability and gender and to eliminate discrimination, as set out in the following legislation:
The Disability Discrimination Act (DDA) 1995 and 2005
The Race Relations Act 1976 (Amendment) 2000
The Equality Act 2006
Other relevant legislation:
The Employment Equality (Age) Regulations 2006
The Employment Equality (Sexual Orientation) Regulations 2003
The Employment Equality (Religion or Belief) Regulations 2003
The Human Rights Act 1998
The Gender Recognition Act 2004
The Sex Discrimination Act 1975
The Sex Discrimination (Gender Reassignment) Regulations 1999
Ethnicity The Race Relations Act 1976 as amended by the Race Relations (Amendment) Act 2000 makes it unlawful to discriminate against anyone on the grounds of their race, nationality, ethnic origin or culture, either directly, indirectly or by victimisation, in carrying out any public function that meets the general and specific duties in the Act. It is our aim to ensure that Medway PCT meet the requirements and the ethos of the general duty contained in the Race Relations (Amendment) Act 2000 to give regard to the need to eliminate unlawful discrimination and to promote equality of opportunities and good race relations. The Single Equality Scheme is a vital part of putting this duty into practice.
Disability The Disability Discrimination Act 1995 made it unlawful to discriminate against disabled people in relation to employment, provision of goods, facilities and services. Based on the definition provided by the Disability Rights Commission in
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2006, a “disabled person” is someone who has a physical or mental impairment, which has a substantial and long term adverse effect on his or her ability to carry out normal day to day activities. The 1995 Act extended the definition of disability to cover a wide range of physical, sensory and mental disabilities, including diabetes and those with long term conditions, mental health problems, learning difficulties, HIV, cancer, multiple sclerosis and mental health service users. Medway PCT supports the ‘social’ model of disability i.e. it is the barriers (both physical and attitudinal) which society puts in the path of disabled people which prevent them from living fuller lives, rather than their actual impairment.
Gender The Equality Act 2006 amends the Sex Discrimination Act 1975 and places statutory duties on all public bodies from 6 April 2006. The duty applies to men, women and transgender people. Transgender people are protected from discrimination and harassment on the grounds of gender reassignment, vocational training and services (from December 2007) under the Sex Discrimination Act. This includes those intending to undergo gender reassignment. Gender equality means being treated the same as others in society regardless of gender and having the same opportunities. Medway PCT recognises that men, women and transgender people all have different needs in healthcare. We are committed to achieving equal health outcomes for men, women and transgender people and providing services which meet the needs of all. We are also committed to making flexible working real and improving the work/life balance of all our staff, particularly parents and carers.
Gender Identity Gender identity relates to a person’s sense of knowing which gender they belong to. For example, if a person sees themselves as male and identifies as such, their gender identity is male, even if their body is biologically female. Gender dysphoria and gender variance are terms used to describe the feeling of being trapped in a body of the wrong sex and there is currently little information on the prevalence of this condition, although, as noted earlier, NHS data suggests that 1 in 4,000 people in the UK are currently accessing medical help for gender dysphoria. The term “transsexual” describes people who experience long-term and severe gender dysphoria and are about to undergo, are undergoing or have undergone treatment to alter their sex and realign their physical characteristics with their gender identity. This process is sometimes known as “transitioning”. A person
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who has transitioned from female to male may be known as a “trans man” and a person who has transitioned from male to female may be known as a “trans woman”. Transsexualism should not be confused with sexual orientation; like anyone else, transpeople may be gay, lesbian, bisexual or heterosexual. The Department of Health estimates that the number of transsexual people in the UK is 1 in every 11,500. However, many organisations working with transpeople believe this to be an under-estimation.
Age Age equality is concerned with responding to differences between people that are based on age and with avoiding preventable inequalities between people of different ages. We recognise that ‘ageism’ can have a profound affect on older and younger people, on the quality of their lives, their access to services and to employment. The Employment Equality Act (Age) Regulations (2006) makes age discrimination illegal in all aspects of employment. Whilst the legislation does not currently cover the provision of goods, facilities and services or the exercise of public functions, it is anticipated that age will be addressed in more detail within the new legislation resulting from the Single Equality Bill.
Sexual Orientation The Employment Equality (Sexual Orientation) Regulations (2003) prohibits discrimination, harassment or victimisation on the grounds of an employee’s sexual orientation. The Sexual Orientation Regulations (2007) encompasses the rights of gay, lesbian and bisexual people to goods and services and prohibits discrimination, harassment or victimisation on the grounds of sexual orientation. Whilst there are currently no general or specific duties, Medway PCT will ensure that sexual orientation is included within our approach to equality and diversity and, specifically, within our equality impact assessment processes. There is evidence that there is still homophobia and discrimination in parts of the NHS (‘Being the Gay One’ Stonewall and the Department of Health, 2007) and we are committed to combating discrimination of this kind.
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Religion or Belief The Employment Equality (Religion or Belief) Regulations (2003) prohibits discrimination to employees on the grounds of their religion or belief. The Equality Act 2006 identifies religion or belief as follows:
“Religion” means any religion and a reference to religion includes a reference to lack of religion; and
“Belief” means any religious or philosophical belief. A reference to belief includes a reference to lack of belief.
Medway’s population is multi-cultural and multi-faith and this brings with it diverse needs. The NHS Plan identifies these needs as religious, cultural, dietary and language. Whilst at present there are no general or specific duties, Medway PCT will ensure that religion or belief are included within our approach to equality and diversity and, specifically, within our equality impact assessment processes.
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Our Goals for the Future As well as delivering core, universal services, healthcare organisations share a commitment to addressing issues of health inequality. As we described earlier, deprivation is a key factor that impacts equal health outcomes and the key tool that we use to assess priorities and prioritise allocation of resources is the health impact assessment. However, there is also evidence to suggest that across the community there are additional factors relating to age, gender, ethnicity, sexual orientation, religion or belief and disability status that further impact on the way people access health services, their experience while using services and, ultimately, on their health. For example we know that there are significant variations in stroke risk factors, incidence and morbidity for different equalities groups:
More men than women experience a stroke, though women are twice as likely to die from a stroke than men;
African Caribbean and South Asian people (in particular men) in Britain have much higher rates of stroke than the general population;
Three quarters of those affected by stroke are over 65 but it can happen to people of any age;
Stroke has a greater disability impact than other chronic diseases and there are high rates of recurrent strokes, therefore many of those accessing the unit (and benefiting from it) will be physically disabled;
The incidence of stroke increases with decreasing socio-economic conditions; and
Risk of stroke is linked to smoking, obesity, diet, exercise and alcohol consumption – all of which, we know, vary by equality group. 2
There are similar patterns for Coronary Heart Disease (CHD):
1 in 5 men and 1 in 7 women die of CHD;
Some black and minority ethnic (BAME) groups living in the UK have a much higher death rate from CHD than average, including South Asian men and women and Eastern European men;
Deaths from CHD are strongly associated with levels of deprivation; and
2
From The Stroke Association (2006) Stroke Statistics at: http://www.stroke.org.uk/information/our_publications/factsheets/factsheets_and.ht ml
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The likelihood of dying from CHD increases dramatically with age: 68% of those dying of CHD in 2007 were aged over 75. 3
In the context of healthcare, therefore, the goal of a Single Equality Scheme and implementation plan is to provide a greater level of understanding and awareness of the impact that diversity has on the health outcomes experienced by different groups in our community. The work of the Single Equality Scheme will assist us to establish a better level of analysis in relation to differing health needs and service requirements and allow a more targeted approach to service development and delivery. We have developed our approach and Action Plan around three strategic themes and three enabling strategies. These have been chosen as areas which are cross-cutting in nature and where we can, therefore, make a wide-ranging positive impact without over-committing resources.
Strategic Themes: 1. Commissioning, Procurement and Supply Chain Management 2. Patient Experience 3. Workforce Enabling Strategies: 1. Leadership and Governance 2. Building the Evidence Base 3. Equality Impact Assessment
3
Source: British Heart Foundation Statistics web site at: http://www.heartstats.org/homepage.asp
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NHS Medway The role of NHS Medway is to improve health and healthcare in Medway. The organisation wants to make sure the right care is there when people need it, by planning and paying for all NHS healthcare for everyone who lives in Medway. NHS Medway delivers this goal through two distinct areas of accountability:
We commission and contract services across Medway; and
We host Medway Community Healthcare as a core provider of NHS services to the Medway community.
NHS Medway serves 280,000 people: the 252,000 who live in the Medway Council area (which marks our boundary and has done since 2006), plus others just over the border who are registered with Medway GPs (doctors). NHS Medway’s budget for 2010/11 is £441 million and we are responsible for using that money in the best possible way for the people of Medway. Our job is to lead health services locally so that we, working with our partners in the NHS and outside it, and with local residents, bring about real improvements to people's health and healthcare. What we want to see in Medway is:
People in control of their own health and well-being;
Very best quality healthcare when needed;
Joined-up, patient-centred services;
More choice and a much stronger voice for patients; and
Innovative, evidence-based care and support.
Our values include
Respect and dignity - treating patients and staff as individuals;
Commitment to quality of care - insisting on quality and getting the basics right;
Compassion - finding the time to listen and understand;
Improving lives through excellence and professionalism;
Working together for patients in everything we do; and
Showing that everyone counts.
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NHS Medway Equality and Diversity Policy At NHS Medway we embrace and accept our legal, social and moral responsibility in relation to equality and diversity. We are committed to delivering equality of opportunity for all service users, carers, staff and the wider communities. Our focus is to provide a service that is fair and accessible for the local population of Medway, while recognising the need to challenge and reduce health inequalities. We are committed to ensuring that everyone in Medway can access the care they need and that everyone is treated with dignity and respect. We do this initially through our commissioning process; i.e. how we make decisions about what services are available. We also ensure our staff are equipped with the necessary skills and knowledge to understand and work with individuals, groups and populations that historically have not accessed appropriate health services, or have sought the services at a later stage of their illness or condition. To help us meet the needs for health and healthcare of everyone in Medway, including those who are from seldom-heard groups, we are:
Reaching out into different communities in innovative ways recommended by those communities;
Targeting our health promotion initiatives to the people who need them most;
Gaining a better understanding of the cultural needs of people in Medway and any barriers that exist to achieving better health; and
Carrying out equality impact assessments which look at the impact on different communities of our policies and commissioning decisions, so that we can take corrective action where necessary.
We are also committed to achieving equality and diversity within our workforce. We strive to reflect the local population in our workforce and are committed to ensuring we are recognised as an employer who welcomes and promotes diversity and that we have a work culture where staff feel safe and where their contribution is valued. Progress to date has included:
Implementing a culture change programme to drive up the level of performance in Equality and Diversity across NHS Medway;
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Upgrading the role of the equality and diversity lead officer to demonstrate our commitment to increasing the equality and diversity profile across the organisation;
The roll-out of an equality and diversity training programme for all commissioning staff which is mandatory and supports them to promote equality through all aspects of the commissioning process;
The accreditation of NHS Medway under the Government's Positive about Disability scheme - 'Two Ticks';
The development of an improved Equality Impact Assessment Toolkit and plan for critical aspects of organisational policy and service development; and
establishing a project to cleanse the ESR workforce database to enable the organisation to improve its equality monitoring arrangements
Workforce To deliver effective services to our community we need to have a workforce that reflects the community population and can respond effectively to its diverse needs. Our current staff profile (December 2009) is: Gender:
80.4% women and 19.6% men.
7.4% aged under 25;
20.5% aged 26-35;
29.0% aged 36-45;
27.3% aged 46-55;
13.9% aged 56-65; and
2.0% aged over 65.
Age:
Ethnicity:
77.3% are White British;
5.1% are from Other White backgrounds (including Irish);
10% are from BAME backgrounds
7.7% were Undefined or Not Stated.
Disability:
3.1% have a declared disability.
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Sexual Orientation:
63.4% identified as heterosexual;
1.1% identified as lesbian, gay or bisexual (LGB&T); and
35.5% were Undefined or declined to disclose.
Across the organisation we have very high numbers of women employed. This is partially in relation to the traditional aspects of women’s employment in health and social services and partly relates to the opportunities for flexible and parttime working that women continue to access at higher levels than men. Additionally we have a relatively high level of BAME representation in relation to the local community, although we are aware that these patterns are typical in health service organisations across the country. Age is increasingly a consideration both in relation to business continuity but also in terms of providing employment opportunities for the relatively large number of young people in Medway. Employment opportunities for young people in healthcare tend to be in the lower band job roles, although we are making good progress in expanding apprenticeship opportunities across the service. Our representation of disabled employees is relatively low and we are concerned that this may relate to low levels of reporting as well as some improvement requirements in our recruitment and selection process. We are now a two tick employer and are developing a number of strategies to address representation. Across the organisation we have low levels of reporting of LGB&T staff members and are committed to building a culture where all staff feel confident to express themselves at work. Finally we are committed to building a more complete profile of our workforce by collecting more detailed information on staff representation through the organisation; i.e. at different bands of employment. Anecdotal evidence would suggest that across all the protected groups there is a degree of underrepresentation in senior roles but at this stage we have limited data to analyse this definitively.
Working in Partnership Partnerships are core to the way that we work. They allow us to use public money in the most effective way and to ensure that services for people in Medway are joined-up and patient-centred. We work with Medway Council and other partners to plan services, in particular for children and young people, people with a learning disability or mental health problems and older people.
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We have a Public Health team led by Dr Alison Barnett, the Director of Public Health, jointly funded by Medway PCT and Medway Council which drives work to improve the health of local people. We work with a range of partners, including Medway Council and the police, as part of the Local Strategic Partnership and the Community Safety Partnership, participating in groups such as the Medway Community Cohesion Group and the Kent Equalities Network. We work with both Adult Social Care and Children’s services, having representation at a number of levels including the relevant safeguarding boards and subcommittees, and the health Overview and Scrutiny Committee of Medway Council. We commission some services (such as mental health and cancer) on behalf of the whole of Kent and Medway and our neighbouring primary care trusts commission other services on our behalf (for instance, commissioning of stroke services is led by NHS West Kent). We have formal agreements with voluntary groups, such as the Stroke Association, and work closely with Age Concern, HiKent and others. One new partnership in 2010 was set-up to protect people living in hospitals or care homes who lack the capacity to make their own decisions about the arrangements for their care or treatment. Since 1 April 2010, we have been working with Medway Council, NHS West Kent, NHS Eastern and Coastal Kent and Kent County Council to jointly provide a Deprivation of Liberty Safeguards (DoLS) service for people in Kent and Medway. Care homes or hospitals who believe they have to deprive someone of their liberty for their own safety must apply for permission to do so to the Kent and Medway DoLS Office. This service is one of the ways we deliver on our aim of promoting human rights in healthcare. Emergency planning is a further area where we work in partnership. Under the Civil Contingencies Act 2004, we have a legal responsibility to prepare for emergencies, such as flooding or flu pandemic, to ensure that people’s health needs will be met with minimal disruption. We have a Major Incident Plan that is fully compliant with the requirements of the NHS Emergency Planning Guidance 2005 and all associated guidance. We work closely with emergency services, other NHS trusts and Medway Council and with the Kent Resilience Forum, including carrying out joint exercises. In 2008/09 we:
Set up an NHS Medway Emergency Planning Committee;
Revised and tested our plan for a flu pandemic;
Updated our business continuity plans;
Contributed to the work of the Kent and Medway Local Resilience Forum and to the South East Coast Flu Committee;
Updated emergency training for key staff; and
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Reviewed the plans and preparedness of providers of healthcare in Medway, especially for flu pandemic, and for chemical, radiological or nuclear incidents.
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Strategic Theme 1: Promoting Equality Through Commissioning, Contracting and Procurement The Department of Health has identified the effective commissioning of local health services as one of the most critical functions of the modern NHS. The drive towards World Class Commissioning (WCC) is, therefore, aimed at improving health outcomes and reducing health inequalities through improved commissioning processes. Within the WCC framework there are 11 key competencies which describe the knowledge, skills, behaviours and characteristics that underpin effective commissioning. These competencies require that commissioners: 1. Are recognised as the local leader of the NHS; 2. Work collaboratively with community partners to commission services that optimise health gains and reductions in health inequalities; 3. Proactively seek and build continuous and meaningful engagement with the public and patients, to shape services and improve health; 4. Lead continuous and meaningful engagement with clinicians to inform strategy, and drive quality, service design and resource utilisation; 5. Manage knowledge and undertake robust and regular needs assessments that establish a full understanding of current and future local health needs and requirements; 6. Prioritise investment according to local needs, service requirements and the values of the NHS; 7. Effectively stimulate the market to meet demand and secure required clinical, and health and well-being outcomes; 8. Promote and specify continuous improvements in quality and outcomes through clinical and provider innovation and configuration; 9. Secure procurement skills that ensure robust and viable contracts; 10. Effectively manage systems and work in partnership with providers to ensure contract compliance and continuous improvements in quality and outcomes; and 11. Make sound financial investments to ensure sustainable development and value for money. In order to achieve ‘world class’ status primary care trusts will need to demonstrate that they are undertaking a full assessment of the needs of their population and prioritising investment in order to reduce health inequalities.
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WCC and Equalities The Department of Health has identified a number of these competencies as having specific relevance to equalities; in particular:
Competency 2 (work with community partners) – PCTs should “work collaboratively with community partners to commission services that optimise health gains and reductions in health inequalities”;
Competency 3 (engage with public and patients) – the PCT “proactively challenges and, through active dialogue, raises local health aspirations to address local health inequalities and promote social inclusion”;
Competency 4 (collaborate with clinicians) – the PCT “oversees and supports practice based commissioning decisions to ensure effective resource utilisation, reducing health inequalities and transforming service delivery”;
Competency 5 (manage knowledge and assess needs) – the PCT must have a “robust ongoing Joint Strategic Needs Assessment demonstrating a full working understanding of the current and future local population’s health and well-being needs, especially relating to relative inequalities in health outcomes and experience”; and
Competency 6 (prioritise investment) – the PCT “identifies and tackles inequalities of health status, access and resource allocation”.
In addition to the specific competencies listed above, WCC provides considerable opportunities to promote equality by:
Increasing the expertise of commissioners to pursue equality as an explicit goal;
Strengthening expertise in listening to patients and service users, and using the information they provide, disaggregated by equality group;
Strengthening the growing demand for more and better data from the NHS as a whole, and its constituent parts, enabling primary care trusts to set explicit targets which can be monitored, against which contracts can be managed; and
Providing appropriate and equalities sensitive local leadership.
In addition, WCC provides a framework in which primary care trusts can make strategic plans about their equalities work. This work relies on consultation and community engagement, and relates to each of the 11 competencies, and to areas where several competencies overlap or relate to each other in a variety of ways. For example, Competency 3 clearly includes involving equality groups as well as other groups in the locality. It relates to building partnerships with the voluntary sector (partly covered in Competencies 2 and 10). It links to Competency 5, which will enable the NHS to collect, analyse and use more
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comprehensive knowledge about equality groups. It also has implications for employment (partly Competency 1) and procurement (Competency 9). For each competency it is possible to suggest equalities related indicators at each of the four levels, thus enabling primary care trusts to plan their equalities work, and develop capacity in this area over the next few years. The overall implication of WCC for equality groups is that more focused and more expert commissioning will enable primary care trusts to contract more effectively. For example, by specifying the needs of particular groups of service users and managing their performance of contracts against those targets. This is a great opportunity to promote equality (of access, service provision and outcomes) for groups of service users who do not necessarily benefit from a general across the board improvement. The introduction of a greater degree of contestability would enable primary care trusts to require evidence of good performance on equalities from those tendering for NHS work. This represents an opportunity to work in partnership with contractors to raise performance in all contracts. This improved commissioning expertise will help primary care trusts to change the provider landscape, increasing the range and diversity of providers, using specialist and niche services where appropriate, again focusing on particular groups of service users and/or particular conditions (e.g. screening services for Muslim women). This too is an opportunity to make sure the provider landscape is representative of the community served and opened up to providers who would not necessarily benefit from more traditional commissioning processes. Many of the WCC competencies involve degrees of engagement with the public, service users, clinicians and other partners. This supports to a far greater degree than ever before the idea that profound change comes from knowing the communities we serve, really understanding and taking their needs into account in the way services are designed and delivered. Medway PCT’s Performance In 2008/09 Primary Care Trusts in England, including Medway PCT, were assessed on their commissioning performance for the first time. The WCC Assurance Panel assessed Medway PCT at stage two of four (with one being a starting point and four world class) on eight of the 11 key competencies, and at stage one on a further two. It put us at amber on the three governance areas: strategy, finance and Board. The Panel also described us as having strong potential for improvement. We aim to get a better rating on all these measures in 2009/10 and have plans in place to support this. These plans are set out in our Strategic Commissioning Plan which we developed during 2008/09 and an Organisational Development Plan which
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outlines the capacity building work that will be done inside the organisation to deliver these outcomes. We also developed a Commissioning Engagement Strategy which will allow us to involve more people in our decisions, and to involve them in more decisions, in a systematic way. As part of World Class Commissioning, all primary care trusts have set eight local health outcomes which they will achieve for their local population by March 2012. To do this we looked carefully at what would make the most difference to people in Medway. The local outcomes we chose are to:
Encourage more mothers to breastfeed;
Help over 1160 people a year stop smoking;
Support people with diabetes to gain control of their blood glucose;
Ensure many more people with symptoms of a Transient Ischemic Attack (mini stroke) have a brain scan within 24 hours;
Reduce early deaths from heart disease;
Halve the increase in alcohol-related admissions to hospital;
Encourage more over-65s to have a flu jab; and
achieve recovery for 54% of people using Improving Access to Psychological Therapies (IAPT) services.
All of these would contribute to the national priorities to:
Reduce health inequalities; and
Increase life expectancy.
Our Commissioning Process As we review and improve health services for people from Medway, we first assess need. We do this by looking at:
Information about the health of our population contained in the Joint Strategic Needs Assessment;
Programme budget information that benchmarks our spending on different services against the average for areas with a similar population to Medway’s;
Information from commissioning managers and managers of Medway Community Healthcare services about areas for improvement;
The views of patients, carers and members of the public;
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The views of our partners in health and social care; and
Models of best practice.
Having assessed how effective current services are at meeting need, we look at what could be improved and what is lacking. We work with patients and members of the public, clinicians and with our partners in health and social care to draw up specifications for new or improved services. We develop contracts which set out exactly what we expect the new service to deliver for patients. Part of this is about ensuring compatibility and integration between the new or improved service and other services. Then we identify a provider to deliver it and, once the service is established, we monitor performance carefully and ensure any issues are dealt with. The other major form of commissioning is practice-based commissioning (PBC). This is when GPs and other healthcare professionals work together to improve services for the people they serve. They look in detail at the needs of the population in their areas and identify what would enable the NHS to meet those needs. Business cases can be submitted to NHS Medway by PBC groups to enhance existing services or to create new services. All GPs in Medway participate in PBC which is organised in three areas: Rochester and Strood, Chatham, and Gillingham and Rainham. How We Make Sure that People Get Good Care We have detailed contracts with hospitals, GPs and the other providers from whom we commission most care. We carefully monitor their performance against a range of measures which include patient experience, patient safety and clinical effectiveness. During 2008/09 we held monthly meetings with both Medway NHS Foundation Trust and the Will Adams NHS Treatment Centre to monitor quality. In 2009/10 we will also have monthly quality performance meetings with Kent and Medway Partnership Trust, and Medway Community Healthcare. In 2009/10 for the first time, the NHS is introducing a financial incentive for providers who improve the quality of patient care. The Commissioning for Quality and Innovation (CQUIN) payment framework ties part of providers' income to quality and innovation improvements. These requirements - commonly known as CQUINs - cover a whole range of areas, including training - ensuring that staff get the updates they need – and patient surveys, looking at patient experience and satisfaction. They are mandatory in all contracts with acute hospitals - such as Medway NHS Foundation Trust - for 2009/10.
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At NHS Medway, we have also written them into contracts with Kent and Medway Partnership Trust, and Medway Community Healthcare.
Equality Proofing the Process The Department of Health has made a number of recommendations for commissioning organisations to assist with the implementation of the equalities dimensions of WCC. These are as follows:
The robust collection of quantitative and qualitative data is central to primary care trusts’ ability to commission world class health services. Primary care trusts should prepare to invest in the necessary systems and expertise to enable effective identification and segmentation of their local populations by healthcare needs. Performance data should be disaggregated by ethnicity, disability, gender wherever possible, in order for primary care trusts to monitor the impact of its commissioned services on the corresponding population groups.
Through their organisational plans, primary care trusts should ensure that they have sufficient equality and diversity capacity to support the commissioning function. This should include both training and development for commissioning managers (with particular emphasis on conducting Equality Impact Assessment) and specialist/dedicated support.
The criteria used by primary care trusts to prioritise investment should encourage the equitable allocation of resources according to need, and avoid exacerbating existing health inequalities. This is particularly important when considering the healthcare needs of smaller, seldomheard communities or groups, where local data and intelligence may be more difficult to obtain.
Promotion of equality and diversity should be taken account throughout the procurement process, from the initial stages of identifying service needs through to contract monitoring. The equality duties relevant to the provider need to be explicit and clearly stated within primary care trust’s contract conditions.
Primary care trusts should consider the unique strengths of third sector providers when developing strategies to increase choice of healthcare provision. Voluntary sector organisations can often provide cost effective and culturally appropriate services tailored to the needs of specific groups or communities.
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Primary care trusts are strongly encouraged to assess the impacts of their strategic plans and individual programmes of work (‘initiatives’) on key equality groups.
Promoting equality and tackling health inequalities should be a ‘golden thread’ running through all World Class Commissioning board support programmes; primary care trusts should ensure that training and development providers possess the necessary expertise to deliver in this area.
Managing Contractors This issue was a key priority in our Race, Disability and Gender Equality Schemes. It is clearly important that contractors understand our equality and diversity responsibilities. This is a concern throughout the public sector, as more work is outsourced and commissioning bodies become legally responsible for the equality aspects of work that others are delivering. Our key actions here are to ensure that:
All aspects of procurement (not only managing contractors) are equality proofed;
All specifications are informed by an equalities analysis of the work to be done;
All specifications have clear equality requirements; and
All relevant contracts have equality Key Performance Indicators (KPIs) against which performance is measured.
Arrangements for monitoring the outcome of equalities KPIs in contracts have been commissioned but are currently at an initial stage and need further development.
Key Outcomes/Actions We have two strategic intentions under this theme: 1. We will commission and decommission services that meet the needs of all of our community. This will be achieved through the following outcomes: We use a consistent approach to Equality Impact Assessment (EIA) as a core tool to inform our decision making in service development and commissioning across Medway; Where there is insufficient data to inform the EIA process we will use alternative community engagement and stakeholder consultation; and
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We will expect all EIAs to identify how the new service / change in service will promote or enhance equality as well as present actions to address any adverse impact. We will know we have been successful if we achieve Level 3 of the WCC competency framework by 2011. 2. Our contract and supply chain management will promote equality and inclusion and we will work with partners and providers who reflect this commitment and are the best match to meet our community’s needs. This will be achieved through the following outcomes:
We will embed equality and diversity performance into the selection criteria for potential suppliers and encourage relationships with small local suppliers; and
We will ensure contracts include clear requirements for equality monitoring and reporting which will be sent to the Equality and Diversity Steering Group as required and the Board annually with recommendations for improved performance.
We will know we have been successful when all services have in place a service improvement plan that incorporates equality and access improvement.
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Strategic Theme 2: Patient Experience This theme very specifically addresses the day-to-day experience of patients in accessing services, how they experience services being delivered and in health outcomes. This work does not aim to replicate service delivery plans or major public health campaigns, but to ensure that service users are experiencing equitable access and quality of care experience regardless of their ethnicity, gender, gender identity, disability, age, sexual orientation and religion or belief.
Patient Experience and Commissioning In line with new guidance, NHS Medway will ensure that patient experience is built into their commissioning processes and contract arrangements. Specifically, this will include: Incorporating different patient experiences from different equality groups into the development of service specifications e.g. learning disabled people may need more consultant / healthcare worker time to deliver the same patient experience as someone without a learning disability, particularly in terms of supporting their understanding of treatment, etc; and Ensuring that patient experience is monitored by providers and disaggregated by the equality groups to ensure patient experience can be linked to provider spend. This will enable NHS Medway to identify where spend is having a positive, neutral or negative effect on patient experience. NHS Medway will, therefore, focus on developing improved patient experience for all sections of the community through effective monitoring to support an understanding of the experience of all sections of the community. This will inform service planning and delivery and commissioning across NHS Medway and the provider services.
Key Outcomes/Actions We have two strategic intentions under this theme: 1. Patient access to clinical service will be needs based and where there are differential take up rates by equality strand these will reflect only differential clinical need or patient choice. This will be achieved through the following outcomes: We will increase reporting rates to a minimum of 60% across all service areas for gender, age, disability and ethnicity to better inform our understanding of who is accessing services; and
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We will continue to enhance the accessibility of all NHS Medway services whilst balancing new service requirements. We will know we have been successful in this when we achieve health improvements in minority groups at the same rate as the broader community. 2. Patients will experience a service where their dignity is respected, where their voice is heard and where they are extended compassion. This will be achieved through the following outcomes: Levels of satisfaction from patients will be consistent across equality strands and proportionate to service use; Staff responsible for collecting monitoring data will understand the value of monitoring data and provide clear explanations to service users; and Levels of complaints reported by service users will be consistent across equality strands and proportionate to levels of service use. We will know we have been successful in this if we continue to achieve our targets for patient satisfaction and reduction in complaints.
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Strategic Theme 3: Workforce This theme focuses specifically on the development of a workforce and work culture that promotes equality of opportunity and demonstrates our capacity to deliver services to our community.
Workforce Monitoring: What the Law Requires Under the Race Relations (Amendment) Act 2000 (Employment Duty), all public authorities with more than 150 staff must monitor, by racial group, the numbers of:
Staff in post;
Applicants for employment, training and promotion;
Staff who receive training;
Those who benefit or suffer detriment as a result of its performance assessment procedures;
Staff who are involved in grievance procedures;
Those who are the subject of disciplinary procedures; and
Staff who cease employment.
Authorities are required to publish the results of this monitoring annually. The Gender and Disability Equality Duties are less prescriptive but require public bodies to gather information on the effect of their policies and practices on men and women and have in place “arrangements for gathering information about the impact of policies and practices on recruitment, development and retention of disabled employees”. The workforce monitoring reports produced by NHS Medway demonstrate good practice by covering most equality strands i.e. age, gender, disability, ethnicity and sexual orientation, as well as covering working patterns. We also intend to report on staff by gender by Agenda for Change banding and will continue to analyse and report any gender pay inequity that emerges. In most areas reporting rates are good, although there is some work to be done to improve this, particularly in relation to sexual orientation and disability. We also intend to start reporting data relating to religion or belief. At present we report on staff in post, applicants for employment and staff who cease employment. There is some work required to enhance the scope of our workforce monitoring to include employee relations and access to training and
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development. In addition, a project to cleanse the workforce database is well underway and, once completed, will enable us to produce meaningful analysis of our workforce. Our monitoring information is reported annually to the Board and current data will be published after its submission in December 2010.
Profile of Our Staff The current workforce profile for NHS Medway is detailed earlier in the document (under “Workforce” on page 23). In broad terms we have a workforce where women are significantly over-represented in comparison with the local population. We also have an under-representation of disabled staff but we have good representation in terms of ethnicity, with the proportion of BAME staff being higher than the average for the local population. We do note that, generally speaking, health services outside large metropolitan centres often have a higher representation of BAME staff so our employment rate is more typical of health services generally. We have begun to collect data on sexual orientation and religion or belief, however, such data sets are still in their formation stages and do not provide reliable evidence at this stage for any further analysis or decision making. We will continue to expand this work to ensure we build a more complete understanding of our workforce. Further work is also required to determine whether the profile of our staff is representative at all levels of the organisation.
Recruitment and Selection Our recruitment and selection policy is based on Safer Recruitment – a Guide for NHS Employers (available from the Human Resources department) as published by NHS Employers which replaces HSC 2002/008 Pre and Post Appointment Checks for all Persons Working in the NHS in England, as well as employment legislation and good practice. Effective recruitment is crucial to the success of NHS Medway in providing a high quality service to patients. We rely on recruiting and employing people with the necessary skills, experience and qualifications to deliver organisational objectives and with the ability to make a positive contribution to our values and aims. We tend to recruit high calibre staff and will not appoint anyone to a post who does not meet the essential criteria specified in the person specification for each job.
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Successful recruitment not only means getting the right person for the job to fulfil current needs, but also depends on their ability to adapt to changing demands. It is, therefore, important that all our staff are flexible enough to welcome changes that internal influences, such as restructuring, and external factors, such as developments in healthcare approach, drugs, delivery and new technology etc will inevitably bring. All of these factors determine our future success as an organisation with a workforce equipped to take us forward. It is NHS Medway policy that all job vacancies are open to all internal applicants in order to allow opportunities for development of existing staff in line with our approach to talent management and succession planning. This process may occur prior to or alongside external recruitment methods depending on the nature of the post, suitability of internal candidates and future organisational needs. At least one member of the recruitment panel must have attended approved training in best practice for recruitment and selection, which will include annual updates as appropriate. Given our commitment to more actively promote diversity and to address the changing profile of our community we will update this programme to include “positive action in recruitment� to ensure panel members not only ensure that no discrimination occurs, but also develop recruitment processes which attract applications from a wider number of quality candidates and build our reputation as a modern and diversity friendly employer. NHS Medway aims to ensure no employee or job applicant is discriminated against either directly or indirectly on the grounds of gender, sex, ethnicity, colour or nationality, marital status, age, disability, sexual orientation, gender identity, religion or beliefs, domestic circumstances, political affiliation, trade union membership or HIV status. All recruitment procedures are designed to ensure that we do not discriminate on any of these grounds and discrimination in any form will not be tolerated. On-line short listing via NHS Jobs is a further assurance to this process. Assistance should always be provided for those applicants who may otherwise find it difficult to apply or be considered for a particular post (i.e. those who are disabled in some way). We guarantee any disabled applicant an interview, provided he/she meets the essential criteria within the person specification and arrangements should be made to accommodate their needs so far as is reasonably practicable at interview, for example ensuring the interview room is accessible for wheelchair users. This may mean individuals being accompanied to the interview or adaptation to tests as appropriate. It is expected reasonable adjustments to the workplace will be made in order to accommodate disabled employees wherever possible. Information on ethnic origin, disability, religion or belief, gender, age, sexual orientation and gender identity is collected by the Human Resources department from application forms for the purposes of monitoring. Selection practices and
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procedures will be regularly monitored by the Human Resources department and reviewed to ensure that individuals are selected, promoted and treated on the basis of their relevant merits and abilities. No applicant or employee will be disadvantaged by conditions or requirements that cannot be shown to be justified.
Equal Pay It is a legal requirement that single equality schemes address the issue of equal pay. NHS Medway will collect and analyse data on pay in relation to gender, ethnicity, disability and working patterns to determine if there are any differences in pay that have no apparent job related rationale. Appropriate action will then be taken to address any imbalance.
Learning and Development: Equality and Diversity Training Across NHS Medway we have been delivering a programme of equality and diversity training for staff at induction and more specialised training as they develop through their career. We have recently implemented a more specialised programme focusing on building equality and diversity into all aspects of the commissioning aspect of our work. In addition we have had a specialist equality consultancy, Equality Works, design and deliver training sessions for the NHS Medway Board. It is our aim to ensure our workforce is competent to address equality issues within both strategic and operational activities. Our ongoing learning and development in this area will include:
A range of equality and human rights courses aimed at different tiers of management and staff with an emphasis on service delivery;
A case study based impact assessment course;
A training course on using interpreters effectively;
Customer care – communicating with patients and monitoring;
Recruitment and selection for non managers;
Interview questioning – formulating equality and diversity questions;
Religious and Cultural awareness in healthcare;
Lesbian, Gay, Bisexual and Transgender Awareness; and
All aspects of disability in service delivery.
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Staff Engagement and Satisfaction We measure staff satisfaction through the national NHS Staff survey and our local staff survey conducted for commissioning staff only. The value of the NHS staff survey is that it provides data that is disaggregated by equality strand and compared with other services in the Strategic Health Authority. The 2009 Staff Survey was published in March 2010 and 462 staff members responded, comprising a response rate of 65%, up from 61% in 2008. The response rates and representation for the 2009 Staff Survey closely reflect our staff population, though it does not monitor all equality strands. Male Female White BAME Disabled Non Disabled
(10%) (90%) (90%) (10%) (20%) (80%)
We have included a number of responses which we consider highlight the experiences of different staff groups. Overall, the data would suggest that across the organisation:
Women generally achieve higher scores than men in areas of performance development, though men are slightly more motivated than women;
There are very slight variations in the experience of disabled and non disabled colleagues but none that suggest significant differences, other than in their general experience of discrimination and bullying by colleagues; and
BAME staff are on par with, and in many areas scoring higher than, their white colleagues. Notwithstanding, BAME staff do report higher levels of experiencing discrimination and are not so positive about career development opportunities.
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Gender
Ethnic Background Disabled
3 7 10
% staff who feel valued by work colleagues % working in a well structured team environment % using flexible work options
Male
Female
White
BAME
84
79
80
80
73
41
48
44
48
48
78
82
81
81
82
11
% feeling there are good opportunities to develop their potential at work
44
52
52
51
55
12
% receiving job related learning and development in past 12 month
79
83
82
82
90
58
70
78
69
70
30
35
38
33
47
49
59
69
57
59
9
5
7
5
5
13 14 15 24
% appraised in last 12 months % having well structured appraisals in past 12 months % appraisals with development plan in past 12 months % receiving physical violence from patients/ relatives
25
% experiencing physical violence from staff in past 12 months
2
1
0
1
0
26
% experiencing bullying/harassment from patients/ family in past 12 month
13
17
17
16
16
27
% experiencing bullying/ harassment from staff in past 12 months
13
15
20
15
19
28
Perception of effective action from employer towards bullying and harassment
3.40
3.54
3.47
3.53
3.49
30
% feeling pressure to attend work while unwell in past 3 months
15
19
25
19
19
4.01
3.88
3.79
3.88
3.93
33
44
40
43
43
82
96
90
95
86
7
4
9
4
11
37 38 39 40
Staff motivation at work % having equality and diversity training in past 12 months % believing PCT provides equal opportunity for career progression/ promotion % experiencing discrimination at work in last 12 months
A significant concern is that the 2009 survey suggests that BAME staff are experiencing higher levels of violence, bullying and harassment from both
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patients and colleagues and that they are less confident about the management response to these issues. Our lowest four performing areas in the survey relate to issues of staff engagement and we have identified actions in the Action Plan to address these concerns. In addition, a staff engagement group has recently been established and part of its remit is to analyse the findings of the staff survey and put forward solutions. The issue of harassment is part of this agenda. Flexible and Part‐Time Working The NHS 2009 Staff Survey indicated that we have a good take up of part-time and flexible working opportunities across all equality strands identified with a slight difference in men and women using flexible options at work.
Key Outcomes/Actions We have two strategic intentions under this theme: 1. We will have a workforce that can deliver services effectively to and for our community now and into the future. This will be achieved through the following outcomes: We will increase the percentage of seldom-heard groups across NHS Medway as a whole and across the position grades. Specific areas for attention include: o Increasing the representation/ reporting levels of disabled staff; o Increasing the representation/ or reporting of LGB&T staff; o Addressing the priority issue of older staff as both an issue of organisational sustainability and addressing the diversity needs of older and younger staff. All staff will develop equality and diversity skills and knowledge relevant to their work role at induction, as part of their leadership and management development and as it relates to specific specialist functional areas; and We will monitor and report HR practice by equality strand and take clear and timely action to address any patterns in relation to formal employee relations processes. We will know we have been successful in this when we achieve benchmark average or better in the NHS Staff Survey and a positive trend in local staff surveys.
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2. Our staff will experience a work culture where they are safe and respected; where they experience having a voice and making a difference. This will be achieved through the following outcomes: 
We will have open, transparent and dynamic engagement with all staff groups; and

All staff groups will experience a consistent level of satisfaction, management and development based on their job role and merit. We will know we have been successful in this when we improve our performance in the NHS Staff Survey.
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Enabling Strategy 1: Leadership and Governance NHS Medway has an Equality and Diversity Steering Group structure within both commissioning and service delivery, which provides an independent advocacy, scrutiny and leadership function across the organisation. We also have a Board champion for equality and diversity who ensures that the agenda is appropriately addressed within a strategic organisational context. The NHS Medway Equality and Diversity Steering Group (“E&D Steering Group”) has clear terms of reference and delegated authority to provide leadership to the Single Equality Scheme and to continue to explore mechanisms to further engage with key stakeholders. The Steering Group meets monthly and is chaired by the Director of Organisational Development and Workforce Planning. Evidence of progress against Equality and Diversity Implementation Plans, including the Single Equality Scheme, is reported to the E&D Steering Group by the Equality and Diversity Lead. The Director of Organisational Development and Workforce Planning provides related quarterly reports to the Board.
Key Outcomes/Actions Our enabling strategy is that we will achieve compliance and recognition with the CQC regulatory framework and World Class Commissioning standards. This will be achieved through the following outcomes:
The NHS Medway Board will reflect the demographic and diversity of the local community;
The Board will continue to monitor NHS Medway’s performance in equality and ensure compliance with governance structures;
The Board will communicate and enact a clear position for the organisation to follow for non-compliant services;
We will agree mechanisms for engaging with BAME, disabled, older and younger workers and LGB&T staff groups; and
We will agree appropriate actions which the Board will use when suppliers do not fulfil their contractual requirements in equality and diversity.
Framework for Delivery The Medway PCT Board has overall responsibility for ensuring the adoption of the Single Equality Scheme. The Chief Executive and the Executive Directors have responsibility for ensuring that this policy is implemented across the organisation. An annual report to the Board will include an assessment of compliance with statutory duties and a review of progress in implementing the arrangements specified in the Single Equality Scheme.
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Senior managers are responsible, through their leadership roles, for maintaining the profile of equality issues in NHS Medway and for promoting the Scheme within and, where appropriate, outside the organisation. They are also responsible for ensuring that staff are aware of their responsibilities and that they take advantage of the support and training available to help them carry these out. Senior managers will also ensure that relevant procedures are adhered to and appropriate action is taken in respect of staff or contractors who discriminate on the basis of any of the equality strands. All staff are responsible for promoting equality and for avoiding discrimination in the way they work. Staff are expected to participate in relevant training and learning opportunities provided within NHS Medway. We will invite recognised trade unions and professional associations to identify and appoint leaders who will support the implementation of the Scheme. These include: Unison, British Association of Occupational Therapists (BAOT), British Dental Association (BDA), British Dietetic Association (BDA), Chartered Society of Physiotherapists (CSP), Society of Podiatrists (SCP), Royal College of Nursing (RCN), British Medical Association (BMA) and Unite.
Enabling Strategy 2: Building the Evidence Base Like good clinical practice and effective business management, good practice equality and diversity needs to be data and evidence based. This underpinning theme outlines what effective data collection and monitoring is already happening across NHS Medway and outlines opportunities for further improvement.
Equalities Monitoring Equalities monitoring is the process of collecting, storing and analysing information about people’s gender, ethnicity, disability, age, religion or belief, sexual orientation and socio-economic status. Effective data collection/monitoring is essential in order to build a sound evidence base for service planning and delivery, as well as workforce development. This activity is, therefore, central to all of the strategic themes in this Single Equality Scheme. The main components of an effective monitoring system are:
Explaining to service users and staff why monitoring takes place;
Ensuring that those who collect the data understand its importance and can explain to others why it is necessary and how it benefits them;
Monitoring different aspects of work: o
Access;
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o Experience; o Outcome;
Giving specific staff responsibility for introducing and maintaining the system to ensure that it is effective;
Analysing the monitoring records regularly, with reports produced at a minimum of every six months;
That people only have to give information on a voluntary basis; and
That people should be invited to self-assess (rather than someone else doing it for them). If assessment is done by a third party, this must be distinguished from self-assessment data.
It is important to be clear about categories for ethnic monitoring and to consult local communities on which categories to use e.g. by breaking down a category such as ‘Black African’ or ‘White Other’. This will ensure that the data collected accurately reflects the local population or workforce. Monitoring must also be part of an ongoing cycle of identifying and exploring patterns, changing the way we deliver services and checking to see whether the changes are working. We will adopt the following principles of good practice in our data collection and monitoring:
We will be clear about why we want the information and what it will be used for − including who will have access to it;
We will reassure the person we are asking for the information that it will not affect the service they obtain/any benefits they might receive, etc;
We will make sure that the person understands that giving this information is voluntary;
We will choose an appropriate moment to gather the information − this might happen naturally as part of a needs assessment, but if not, it is often best to wait until the enquiry or issue at hand has been dealt with;
We will allow the person to self-classify wherever possible and be clear about the categories available;
We will acknowledge the information we are given but will not comment on it in a negative or positive way − our job here is to collect facts;
We will reassure the person about the confidentiality of the information, and if appropriate explain that the information is protected by the Data Protection Act;
We will get the person’s explicit consent to store the information; and
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We will think about how to ask the questions beforehand.
Community Engagement There is a clear and growing requirement for public sector bodies to engage with local people about the services they provide. Guidance from the I&DeA on Comprehensive Area Assessments states that public sector bodies will be required to show:
How the public has been involved in setting priority outcomes; and
How the public has been involved in assessing how these outcomes have been delivered.
Our Single Equality Scheme will build on the partnership work developed in consultation and engagement on the Joint Strategic Needs Assessment and the Joint Strategic Needs Assessment for Mental Health. It is recognised that engagement with community groups and organisations needs to develop further and in particular for the purposes of the Scheme effectively incorporate underrepresented communities. This development will take place by utilising existing structures and networks and specifically by:
Working with existing umbrella groups addressing diversity and equality. This will include Kent Equalities Network online forum and Medway Community Cohesion Group. This will enable key personnel and resources available for work on equality and diversity to work together with public sector partners on how consultation and engagement is currently being undertaken with under-represented groups.
Identifying key communities or sections of the community where there is little or no contact from public sector partners e.g. gypsies and travellers, deaf people, people going or having gone through gender transition. Mechanisms for consultation and engagement with these sections of the community will then be put in place.
HR will review current engagement mechanisms with staff from underrepresented groups to ensure communication and actions are developed to improve delivery on equality and diversity in the workforce.
This process will support the public sector organisations, together with NHS Medway, in building up community knowledge and staff knowledge contacts so that engagement becomes ongoing. The process will not only be about key documents and service information being passed to community groups/networks for comment, but the development of a clear communication route from the umbrella groups to the public sector partners and NHS Medway. This will support NHS Medway, Medway Community Healthcare and partners in
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developing genuine engagement and trust with communities and staff. This will be done by ensuring that standards for consultation and engagement are developed and include:
Clarity on the questions/areas of work being consulted on and who needs to be consulted;
A clear plan for engagement that addresses all the agreed standards and has been costed and resourced;
All information is made available in appropriate formats;
All responses are recorded accurately;
The responses to the consultation are fed back to all participants; and
The engagement influences strategy and service delivery demonstrating the success of the engagement process.
The effectiveness of the consultation and engagement will be monitored and measured as part of the ongoing review process on the Single Equality Scheme.
Key Outcomes/Actions Our enabling strategy is based on achieving the following outcomes:
We will have in place a reliable data gathering and analysis process, proportionate to the service capability, which ensures a more complete and comprehensive profile of our community across all equality strands.
Enabling Strategy 3: Equality Impact Assessment Equality Impact Assessment (EIA) is a key driver for each of our commitments and provides the critical systems tool for identifying priority areas for action and making real and tangible improvements. This work is particularly relevant for NHS Medway as a key mechanism to aid service development and service changes and the opportunity to promote equality through such developments. An EIA is a systematic appraisal of the actual or potential effects of a function or policy on different groups of people. It is conducted to ensure compliance with public duties on equality issues (which in some areas go beyond a requirement to eliminate discrimination and encompass a duty to promote equality), but more importantly to ensure effective policy making that meets the needs of all groups. Like all other public bodies, NHS Medway is required by law to conduct equality impact assessments of all functions and polices that are considered relevant to the public duties and to publish the results.
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An EIA must be completed when developing a new function, policy or practice, or when revising an existing one. In this context a function is any activity of NHS Medway, a policy is any prescription about how such a function is carried out, for instance a strategy, guidelines or manual, and a practice is the way in which something is done, including key decisions and common practice in areas not covered by formal policy. It is important that all policies are informed by the knowledge of the impact of equalities issues accumulated across the organisation. Staff working on policy development should contact the relevant Equalities Lead to discuss the issues arising in their policy area as early as possible in the development process and before commencing the EIA.
Our EIA Process Our EIA process has been constructed as a two-stage process in order to reduce the amount of work involved where a policy proves not to be relevant to any of the equalities groups or duties. Our toolkit is available for all staff to download from the EIA section of our website. The initial screening tool should be completed in all cases, but duplication of material between it and the full EIA should be avoided. For instance, where relevance to an equalities issue is self-evident or quickly identified this can be briefly noted on the initial screening and detailed consideration of that issue reserved for the full assessment. Further guidance on this will be given by the relevant Equalities Lead.
Embedding the Process We recognise that completing EIAs is a key requirement under the equality duties and also the specific duties of the Care Quality Commission. We have taken a number of significant steps to establish and embed processes for conducting assessments. These have included:
The development of an EIA framework to cover all strands and socioeconomic status, including a toolkit, flowchart summarising the EIA process, template and screening template/guidance;
The inclusion of EIA on the recent equalities training programme delivered to commissioning staff;
Completed assessments on at least 24 policies, procedures and functions;
The publication of completed initial and full EIAs on our web site;
Establishing a corporate EIA programme; and
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Providing EIA training for staff.
We are also working towards establishing an EIA Sub-Group to provide quality assurance to completed assessments. Overall responsibility for the EIA process will sit with the Equality and Diversity Steering Group. The EIAs we have completed so far demonstrate that staff across the organisation are developing skills in identifying both the negative and positive impacts on particular groups which might arise from their policies and practice. The assessments have also revealed significant gaps in our equalities evidence base, both in terms of our employment and our service provision. In order to develop our assessments, we recognise that we must develop ongoing mechanisms for consulting particular groups within our workforce, our partners and the communities we serve. Our toolkit has recently been revised to include guidance on consultation and two workshops were held during June 2010 to launch the revised process. In addition, we are working with Medway Community Healthcare to establish a joint consultation forum for EIAs. We also need to identify clearer actions from our assessments, including actions to change policy or practice, to support or mitigate implementation, to consult and gather evidence and to monitor future impacts. These actions need to be built into Action Plans to ensure effective performance management. A good development would be to use this tool to help us to promote equality, as well as to understand discriminatory barriers and remove them.
Partnerships, Contracts and Service Level Agreements The impact, or potential impact, of any work under contract or other arrangement should be considered for an EIA but may not require a full one, e.g. business cases and service specifications should be assessed. Contracts will require a statement reflecting our commitment to equalities, together with a requirement to collect equalities data about patients and staff; and have equality and diversity policies and practices. It is also important to consider other arrangements, such as service level agreements, which may not be monitored corporately. In partnerships we should make effort, where possible, to ensure that:
Equality is incorporated into partnership values and aims;
The Steering Group is representative of all community groups;
We encourage and promote equality of opportunity; and
There is no conflict with our commitment to equality and diversity.
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Priority EIAs Our intention is to deliver high quality and high level impact assessment that makes a difference to service development and improvement. Our priorities are set out in our Corporate Equality Impact Assessment Programme April 2010 to March 2011, which also sets out the relevance to equalities of each function or policy being assessed. Each EIA will be the subject of some consultation and involvement and a range of methods will be used to ensure they are effective. As the nature of our work varies considerably from function to function, different kinds of consultation and involvement will be appropriate for different EIAs. The methods used must be described in each EIA. The same is true of accountability so the arrangements for monitoring and reviewing must be described in each EIA.
Key Outcomes/Actions Our enabling strategy is to ensure that EIAs will be used as a core business decision making process. This will be achieved through the following outcomes:
An annual corporate EIA programme will be published and conducted with the equality analysis identifying how service changes/ new policy will promote equality;
We will work with our partners and suppliers to agree a consistent approach to Equality Impact Analysis to inform our shared decision making across Medway;
We will require an Equality Impact Analysis to be conducted on all new or substantially changed service and policy developments as part of the business case proposition;
Our equality impact assessments will not only address potential negative impacts, but also describe how the new service/ policy will promote equality of access, experience and outcomes across the relevant strands.
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NHS Medway Action Plan (Please note: Actions have been cross-referenced to the general Equality Duties to allow the reader to clearly see the relevance of the action to the General Equality Duties. These are listed and numbered on pages 107-111 ) Strategic Theme 1: Promoting equality through commissioning, contracting and procurement Strategic Intention: We commission and decommission services that meet the needs of all of our community Success Measure: Medway PCT achieves Level 3 in the WCC competency framework by 2011 Outcome
Action
We use health equity audits across our commissioning portfolio to identify inequities in service access and outcome.
Complete health equity audits in priority areas and produce action plans to reduce inequities.
We use a consistent approach to Equality Impact Assessments (EIAs) as a core tool to inform our decision making in service development and commissioning across Medway
Complete the EIA of the Strategic Commissioning Plan and develop an Action Plan to mitigate any identified negative equality impacts. Work in partnership with all health service partners to agree a consistent approach to conducting and analysing EIAs to embed equality analysis into our decision making.
Completion Date
Lead Director Public Health/Commissioning and Performance/ Mental Health
Year 1 December 2010
Commissioning and Performance/ Public Health/
Equality Duty Relevance: 1-3, 4, 6, 8, 10 & 12 Where there is insufficient data to inform the EIA process we will use alternative community engagement and stakeholder consultation
We will continue to develop our evidence base (Enabling Strategy 3) to ensure a more reliable source of decision making information. We will identify any clear gaps in our data set relating to the community profile and develop a strategy to engage with the community to determine the best mechanism for building our understanding.
Ongoing work. Report 6 monthly to E&D Steering Group
Commissioning and Performance/ Mental Health/ Medical Director /Clinical Performance Nurse
Equality Duty Relevance: 1-3, 4, 6, 8-10 & 12
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We will expect all EIAs to identify how the new service/ change in service will promote or enhance equality as well as present actions to address any adverse impact
We will continue to build staff knowledge and awareness of the EIA process to ensure impact analysis actively promotes increased access and equality rather than only mitigating negative impact.
Year 1 By December 2010 and built into relevant new staff induction
Organisational Development and Workforce Planning
Equality Duty Relevance: 1-3, 4, 6, 8, 10 & 12 Strategic Intention: Our contract and supply chain management promotes equality and inclusion and we work with partners and providers who reflect this commitment and are the best match to meet our community’s needs. Success Measure: All services have in place a service improvement plan that incorporates equality and access improvement. Outcome
Action
Completion Date
Lead Director
We will embed equality and diversity performance into the selection criteria for potential suppliers and encourage relationships with small local suppliers
We will develop a communication strategy to prepare our existing suppliers to work within the upcoming “National Equalities Framework” for procurement which will be rolled out as a result of the Equalities Act
Year 1 March 2011
Organisational Development and Workforce Planning
We will update our tendering and procurement documents to comply with the new framework and actively communicate through our procurement process our commitment to working with partners who promote equality
Year 1 March 2011
Equality Duty Relevance: 1-3, 4, 6, 8, 10 & 12 We will ensure contracts include clear requirements for equality monitoring and reporting which will be sent to the E&D Steering Group as required and the Board annually with recommendations for improved performance
Clear monitoring and reporting requirements will be built into all new contracts proportionate to the size of the contract and service delivery requirements. Equality and diversity performance will be reviewed as a core component of all contract and service reviews and reported bi-annually to the E&D Steering Group and annually to the Board. Equality Duty Relevance: 1-3, 4, 6, 8, 10 & 12
Year 1 September 2010 and rolled-out with contract renewal process
Public Health/ Commissioning and Performance/ Mental Health/ Medical Director /Clinical Performance Nurse Public Health/Clinical Performance Nurse/ Commissioning and Performance/ Mental Health/ Medical Director
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Strategic Theme 2: Patient Experience Strategic Intention: Patient access to clinical service is needs based and where there are differential take up rates by equality strand these reflect differential clinical need or patient choice. Success Measure: We achieve health improvements in minority groups at the same rate as the broader community Outcome
Action
Increase reporting rates to a minimum of 60% across all service areas for gender, age, disability and ethnicity to better inform our understanding of who is accessing services
Develop partnership with GPs using the CQUIN process to increase equality monitoring data at point of referral. Develop communication strategy to ensure all primary care providers understand the value of monitoring data and how it will be used.
Completion Date
Year 1 September 2011
Lead Director Clinical Performance/ Medical Director Organisational Development and Workforce Planning
Develop a communication strategy for service users to understand why monitoring data is collected and how it will be used. Equality Duty Relevance: 2, 6 & 12 Continue to enhance the accessibility of all Medway PCT services whilst balancing new service requirements
Ensure issues of accessibility are included in all service improvement plans to inform prioritisation of resource allocation to high need services. This could include but not limited to: Physical access Access for sensory impaired service users Service opening hours Access for carers
Year 1 – March 2011. Reported annually to the E&D Steering Group
Director of Finance and Assurance/ Commissioning and Performance/ Mental Health
Equality Duty Relevance: 4, 6-8 plus CQC Regulation 15
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Strategic Intention: Patients experience a service where their dignity is respected, where their voice is heard and where they are extended compassion Success Measure: We continue to achieve our targets for patient satisfaction and reduction in complaints Outcome
Action
Levels of satisfaction from patients is consistent across equality strands and proportionate to service use
Patient survey tool(s) contain request for patients to include monitoring information with a clear explanation for why this is being requested. Any themes or patterns emerging in the patient survey are reported to the E&D Steering Group on a bi-annual basis.
Completion Date
Lead Director
Year 2 December 2011. Report biannually to E&D Steering Group and annually to the Board
Organisatoinal Development/ Communications
Year 1 December 2010 for current staff
Organisational Development and Workforce Planning
Year 1 August 2011
Company Secretary
Equality Duty Relevance: 1, 2, 4, 6, 10 & 12 Staff responsible for collecting monitoring data understand the value of monitoring data and can provide clear explanations to service users
Skills and knowledge in equalities monitoring is embedded in the equality and diversity training for all staff Equality Duty Relevance: 1, 2, 4, 6, 10 & 12 plus CQC Regulations 21 & 22
Levels of complaints reported by service users is consistent across equality strand and proportionate to levels of service use
Complaints documents contain request for monitoring data and include a clear explanation for why it is being requested. Staff responsible for analysing complaint data update their analysis and reporting process. Any themes emerging in patient survey are reported to the E&D Steering Group bi-annually. Equality Duty Relevance: 1, 2, 4, 6, 10 & 12 plus CQC Regulation 19
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Strategic Theme 3: Workforce Strategic Intention: We have a workforce that can deliver services effectively to and for our community now and into the future Success Measure: Medway PCT achieves benchmark average or better in the NHS Staff Survey and a positive trend in local staff surveys. Outcome
Action
We will increase the percentage of seldom-heard groups across Medway PCT as a whole and across the position grades. Specific areas for attention include: Increasing the representation/ reporting levels of disabled staff Increasing the representation/ or reporting of LGB&T staff Addressing the priority issue of older staff as both an issue of organisational sustainability and addressing the diversity needs of older and younger staff
We will collect monitoring data by equality strand across all levels of the organisation to identify any specific areas of concern.
Completion Date
Lead Director
Year 1 2011
Organisational Development and Workforce Planning /Assistant Director of Equality and Human Rights
Year 2 July 2011
Organisational Development and Workforce Planning/ Assistant Director of Equality and Human Rights
We will continue to explore new ways to expand NHS as an Employer of Choice for under-represented groups and work to identify real or perceived barriers to employment. For example: the NHS Race for Health Programme and Stonewall accreditation process. Equality Duty Relevance: 1, 2, 4, 6, 10 & 12
All staff will develop equality and diversity skills and knowledge relevant to their work role at induction, as part of their leadership and management development and as it relates to specific specialist functional areas
Equality and diversity training for new staff will be refreshed in line with the changing requirements of the Equality Act 2010 and public duty requirements. Equality and diversity skills will be incorporated into each staff member’s personal development plan. All staff to be involved in policy or service development will participate in mandatory EIA training Our recruitment and selection training will be refreshed to incorporate “positive action in recruitment” component to support the more positive approach to building a more representative workforce. Equality Duty Relevance: 1-3, 4, 6, 8, 10 & 12
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We will monitor and report HR practice by equality strand and take clear and timely action to address any patterns in relation to formal employee relations processes
Equality strand data will be recorded and analysed in relation to number of staff subject to formal HR process; in particular sickness absence, grievance, disciplinary and capability. Any patterns and trends in the data relating to equality strand will be reported to the Equality and Diversity Steering Group
Year 1 November 2010 – reported to E&D Steering Group biannually
Organisational Development and Workforce Planning
Equality Duty Relevance: 1-3, 4-8, 10-12 Strategic Intention: Our staff experience a work culture where they are safe and respected; where they experience having a voice and making a difference Success Measure: We will improve our performance in the NHS Staff survey Outcome
Action
We will have open, transparent and dynamic engagement with all staff groups
A workable framework will be designed and implemented to ensure effective consultation and engagement with: Disabled staff BAME staff LGB&T staff This framework will enable the organisation to consult with equality groups in relation to: EIA on internal processes / HR policy formation and changes Providing critical friend advice on organisational development generally.
Completion Date
Lead Director
Year 1 February 2011
Organisational Development and Workforce Planning
The framework developed will ensure that the equality representative(s)/ groups have a clearly understood purpose and clear influencing and reporting mechanism through to the E&D Steering Group. Equality Duty Relevance: 1-3, 4-8, 10-12
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All staff groups experience a consistent level of satisfaction, management and development based on their job role and merit
The NHS Staff Survey responses will be analysed by equality strand to determine any patterns in experience or development which could require attention.
Year 1 March 2011
Organisational Development and Workforce Planning
We will prioritise the development of a staff mental health and well being programme and reinforce organisational behaviour standards in relation to bullying and harassment Equality Duty Relevance: 1-3, 4-8, 10-12 Enabling Strategy: Leadership and Governance Outcome: We will achieve compliance and recognition with CQC regulatory framework and World Class Commissioning Standards Outcome
Action
Completion date
Lead Director
The Medway PCT Board will reflect the demographic and diversity of the local community
The Board will continue to explore opportunities to appoint non-executive directors who contribute to the Board’s diversity
Year 2 July 2013
Chief Executive
Year 1 December 2010 and with each new Board appointment
Chief Executive
Equality Duty Relevance: 3, 6, 9 & 12 The Board will continue to monitor Medway PCT’s performance in equality and ensure the compliance with governance structures
The Board of Medway PCT participates in equality and diversity briefing sessions to build their knowledge of governance and compliance requirements. A clear equality and diversity reporting structure will be outlined which aligns with this plan and monitors performance in commissioning, through service delivery and across the workforce. Equality Duty Relevance: 1-3, 4, 6, 10 & 12 plus CQC Regulations 21 & 22
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The Board will communicate and enact a clear position for the organisation to follow for non-compliant services
Medway PCT to develop a policy and an agreed management process for non-compliant services for Board approval Equality Duty Relevance: 1-3, 4, 6, 10 & 12
Year 2 December 2011
Chief Executive
Outcome
Action
Completion Date
Lead Director
We have in place a reliable data gathering and analysis process, proportionate to the service capability, which ensures a more complete and comprehensive profile of our community across all equality strands
Develop an implementation plan to update all monitoring pathways to include sexual orientation and religion or belief
Year 2 February 2011
Mental Health/ Commissioning and Performance/ Organisational Development and Workforce Planning
Enabling Strategy: Building the Evidence Base
Develop communication plan to ensure all staff have a clear understanding of why monitoring data is required and how it will be used. Equality Duty Relevance: 2, 6 & 12 We will have in place a reliable data gathering and analysis process, proportionate to the service capability, which ensures a more complete and comprehensive profile of our staff across all equality strands
Expand the current staff monitoring process to analyse and report recruitment, turnover, sickness absence, grievance and discipline, bullying and harassment and development processes such as access to training and development Equality Duty Relevance: 1-3, 6 & 12
Year 1 January 2011
Organisational Development and Workforce Planning
We will have in place a reliable data gathering and analysis process, proportionate to the service capability, which ensures a more complete and comprehensive profile of our supply chain across all equality strands
Conduct a diversity audit of the existing supply chain to assess:  Level of ownership/leadership  Business size  Business location
Year 1 January 2011
Mental Health/ Commissioning and Performance
Equality Duty Relevance: 2, 3, 6, 8, 9 & 12
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Enabling Strategy: Equality Impact Assessment Outcome: Equality Impact analysis will be used as a core business decision making process Outcome
Action
An annual corporate EIA programme will be published and conducted with the equality analysis identifying how service changes/ new policy will promote equality
EIA corporate plan published
We will work with our partners and suppliers to agree a consistent approach to Equality Impact Analysis to inform our shared decision making across Medway
Agree a shared EIA approach between Medway PCT and key service delivery partners
We will require an Equality Impact Analysis to be conducted on all new or substantially changed service and policy developments as part of the business case proposition
All EIAs on service development or improvement are tabled with the E&D Steering Group for consideration and feedback
Completion Date Year 1 January 2011
Equality Duty Relevance: 1-3, 4, 6-8, 10 & 12
Equality Duty Relevance: 1-3, 4, 6-8, 10 & 12
Year 1 With major partners by January 2011 Roll out plan by April 2011
Lead Director Organisational Development and Workforce Planning Organisational Development and Workforce Planning
Year 2 September 2011
Organisational Development and Workforce Planning
Year 1 December 2010
Organisational Development and Workforce Planning
Equality Duty Relevance: 1-3, 4, 6-8, 10 & 12 Our EIAs will not only addresses potential negative impact but also describe how the new service/ policy will promote equality of access, experience and outcomes across the relevant strands.
New EIA toolkit and guidelines published and implemented. All new EIAs monitored by the Equality and Diversity Steering Group. Equality Duty Relevance: 1-3, 4, 6-8, 10 & 12
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Medway Community Healthcare Medway Community Healthcare is a £55 million business with nearly 1,238 staff providing a wide range of both planned and unscheduled care in local settings such as healthy living centres, St Bartholomew’s Community Hospital, and people’s homes. It was formed in April 2009 from the services directly provided by Medway PCT as a first step in separating the provision and purchasing of these services. Medway Community Healthcare delivers a wide range of high quality community health services for Medway residents; from health visitors and district nurses to speech and language therapists and out-of-hours emergency care. The Transforming Community Services agenda means the way community healthcare services are provided is changing. Medway Community Healthcare aims to be the first choice of a range of options for providing community health services for local people in Medway and beyond. Medway Community Healthcare has a strong track record of partnership working with local primary care clinicians, Medway Council and other key stakeholders. As an independent organisation, Medway Community Healthcare will be able to compete with other service providers from the NHS, independent and voluntary sectors for NHS contracts in the health service marketplace created by the Government to drive quality, innovation and productivity through healthcare in England.
Medway Community Healthcare Equality and Diversity Policy At Medway Community Healthcare we embrace and accept our legal, social and moral responsibility in relation to equality and diversity. We are committed to delivering equality of opportunity for all service users, carers, staff and the wider community. Our focus is to provide a service that is fair and accessible for the local population of Medway, while recognising the need to challenge and reduce health inequalities. We are committed to ensuring that everyone in Medway can access the care they need and that everyone is treated with dignity and respect. We ensure our staff are equipped with the necessary skills and knowledge to understand and work with individuals, groups and populations that historically have not accessed appropriate health services, or have sought the services at a later stage of their illness or condition. To help us meet the needs for health and healthcare of everyone in Medway, including those who are from seldom-heard groups, we are:
Reaching out into different communities in innovative ways recommended by those communities;
Targeting our health promotion initiatives to the people who need them most;
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Gaining a better understanding of the cultural needs of people in Medway and any barriers that exist to achieving better health; and
Carrying out equality impact assessments which look at the impact on different communities of our policies and commissioning decisions, so that we can take corrective action where necessary.
We are also committed to achieving equality and diversity within our workforce. We strive to reflect the local population in our workforce and are committed to ensuring we are recognised as an employer who welcomes and promotes diversity and that we have a work culture where staff feel safe and where their contribution is valued. Progress to date has included:
Redesigning the role of the equality and diversity lead officers to demonstrate our commitment to increasing the equality and diversity profile across the organisation;
Over 53% of Medway Community Healthcare staff have received face-to-face equality and diversity training during 2009/10;
The quality of workforce data for Medway Community Healthcare has been significantly refined in the last six months; and
Publication of patient data for ethnicity, gender and age to monitor access to services and
The development of an improved Equality Impact Assessment Toolkit and an corporate EIA programme for critical aspects of organisational policy and service development.
Workforce To deliver effective services to our community we need to have a workforce that reflects the community population and can respond effectively to its diverse needs. Our current staff profile (December 2009) is: Gender:
92% women and 8% men.
Age:
6.45% aged under 25;
19.08% aged 26-35;
27.22% aged 36-45;
31.3% aged 46-55;
15.46% aged 56-65; and
0.48 aged over 65.
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Ethnicity:
87% are White British;
13% are from BAME backgrounds
Disability:
5% declared as disabled.
Sexual Orientation:
61% identified as heterosexual;
1.1% identified as Lesbian, Gay or Bisexual; and
38% were Undefined or declined to disclose.
Across the organisation we have very high numbers of women employed. This is partially in relation to the traditional aspects of women’s employment in health and social services and partly relates to the opportunities for flexible and part-time working that women continue to access at higher levels than men. Additionally we have a relatively high level of BAME representation in relation to the local community, although we are aware that these patterns are typical in health service organisations across the country. Age is increasingly a consideration both in relation to business continuity but also in terms of providing employment opportunities for the relatively large number of young people in Medway. Employment opportunities for young people in healthcare tend to be in the lower band job roles, although we are making good progress in expanding apprenticeship opportunities across the service. Our representation of disabled employees is relatively low and we are concerned that this may relate to low levels of reporting as well as some improvement requirements in our recruitment and selection process. We are now a two tick employer and are developing a number of strategies to address representation. Across the organisation we have low levels of reporting in relation to sexual orientation and are committed to building a culture where all staff feel confident to express themselves and be themselves at work. Finally we are committed to building a more complete profile of our workforce by collecting more detailed information on staff representation through the organisation; i.e. at different bands of employment. Anecdotal evidence would suggest that across all the protected groups there is a degree of under-representation in senior roles but at this stage we have limited data to analyse this definitively.
Working in Partnership Partnerships are core to the way that we work. They allow us to use public money in the most effective way and to ensure that services for people in Medway are joined-up and patient-centred. We work with Medway Council and other partners to deliver services, in particular for children and young people, people with a learning disability or mental health problems and older people. Page 65 of 118
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We work with a range of partners, including Medway Council and the police, as part of the Local Strategic Partnership and the Community Safety Partnership, participating in groups such as the Medway Community Cohesion Group and the Kent Equalities Network. We work with both the Health and Adult Social Care, and the Children and Adults Overview and Scrutiny Committee of Medway Council. We have formal agreements with voluntary groups, such as the Stroke Association, and work closely with the British Heart Foundation, Age Concern, HiKent and others. One new partnership in 2010 was set up to protect people living in hospitals or care homes who lack the capacity to make their own decisions about the arrangements for their care or treatment. Since 1 April, we have been working with Medway Council, NHS West Kent, NHS Eastern and Coastal Kent and Kent County Council to jointly provide a Deprivation of Liberty Safeguards (DoLS) service for people in Kent and Medway. Care homes or hospitals who believe they have to deprive someone of their liberty for their own safety must apply for permission to do so to the Kent and Medway DoLS Office. This service is one of the ways we deliver on our aim of promoting human rights in healthcare. Emergency planning is a further area where we work in partnership. Under the Civil Contingencies Act 2004, we have a legal responsibility to prepare for emergencies, such as flooding or flu pandemic, to ensure that people’s health needs will be met with minimal disruption. We are developing a Major Incident Plan that is fully compliant with the requirements of the NHS Emergency Planning Guidance 2005 and all associated guidance. We work closely with emergency services, other NHS trusts and Medway Council and with the Kent Resilience Forum, including carrying out joint exercises. In 2008/09 we:
Set up an Medway PCT Emergency Planning Committee;
Revised and tested our plan for a flu pandemic;
Updated our business continuity plans;
Contributed to the work of the Kent and Medway Local Resilience Forum and to the South East Coast Flu Committee;
Updated emergency training for key staff; and
Reviewed the plans and preparedness of providers of healthcare in Medway, especially for flu pandemic, and for chemical, radiological or nuclear incidents.
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Strategic Theme 1: Promoting Equality through Commissioning, Contracting and Procurement Medway Community Healthcare has identified the effective commissioning of local health services as one of the most critical functions of the modern NHS. The drive towards World Class Commissioning (WCC) is, therefore, aimed at improving health outcomes and reducing health inequalities through improved commissioning processes. Medway Community Healthcare with its knowledge and understanding of the diversity of the local Medway population is in a strong position to identify gaps in service provision, particularly around health inequalities, that need to be addressed
Managing Contractors This issue was a key priority in our Race, Disability and Gender Equality Schemes. It is clearly important that contractors understand our equality and diversity responsibilities. This is a concern throughout the public sector, as public authorities are legally responsible for the equality aspects of work that others are delivering. Our key actions here are to ensure that:
All aspects of procurement (not only managing contractors) are equality proofed;
All specifications are informed by an equalities analysis of the work to be done;
All specifications have clear equality requirements; and
All relevant contracts have equality Key Performance Indicators against which performance is measured.
Key Outcomes/Actions Our strategic intention under this theme is: 1. Our contract and supply chain management will promote equality and inclusion and we will work with suppliers who reflect this commitment and are the best match to meet our community needs. This will be achieved through the following outcomes:
Suppliers will better understand equality legislation and be set on a path from basic compliance to exemplary performance; and
We will ensure all contracts include clear requirements for equality monitoring and reporting which will be reported to the E&D Steering Group bi-annually and the Board annually with recommendations.
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Strategic Theme 2: Patient Experience
This theme very specifically addresses the day-to-day experience of patients in accessing services, how they experience services being delivered and in health outcomes. This work does not aim to replicate service delivery plans or major public health campaigns but to ensure that service users are experiencing equitable access and quality of care experience regardless of their ethnicity, gender, disability, age, sexual orientation and religion or belief. Patient experience is a critical performance and success measure and a core requirement of the Care Quality Commission Regulations as outlined in Appendix 3. These requirements are important to us as they recognise that how a service is delivered is as important as the health outcome e.g. reduction in blood pressure. Work in this area includes a requirement to develop improvements and receive feedback linked to the needs of people from each equality group. The focus of our work on patient experience will link to, and be developed through, the five dimensions of patient experience, as follows: Access and Waiting Lists - This will include building equalities monitoring into any reviews of patients on waiting lists. Specifically in terms of access, there will be contact with key sections of the community as outlined in the consultation and engagement section of this Scheme. Safe and High Quality Coordinated Care - In terms of safety, the Scheme will link to the safeguarding policies and work already in place, ensuring that equality and diversity implications for people from different equality groups have been identified. For example, the safety needs of a black middle aged patient on a predominantly white ward will be different to the needs of a white patient with dementia. The coordinated care experience will need to work with the different cultures and different levels of understanding that patients may have. Better Information / More Choice - In the context of equality and diversity this will mean targeted and tailored information and targeted and tailored services to the different equality groups, whether that be taking account of dietary requirements or religious beliefs. The personalisation of services to individuals will support work in this area but only providing that staff have the skills and competencies required to tailor services appropriately. Building Better Relationships - Improvements in this area will be supported by developing the skills and knowledge of our workforce to better understand the needs of a diverse community and consider care and service needs through an equality and diversity “lens�. Over time this will help us to improve our understanding of the local population and so respond more effectively to the needs of specific sections of the community. This will be combined with effective management of diversity to support identification of specific areas for development that would improve patient experience. Improvements in relationships will also be supported by our equality and diversity training. Clean, Comfortable and Friendly Environment - Improvements in patient experience in this area will be supported by improved diversity in the workforce and learning and development, as noted above.
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Monitoring Patient Experience Medway Community Healthcare has explicitly built equality and diversity into its patient surveys and the data will be analysed and reported through the governance framework. The monitoring undertaken will draw on best practice and will specifically:
Identify methods of carrying out surveys that capture the patient experience when the experience is taking place; and
Ensure there is a clear focus on the emotional experience of patients as well as meeting their immediate treatment needs.
Key Outcomes/Actions We have two strategic intentions under this theme: 1.
Patient access to clinical service will be needs based and where there are differential take up rates by equality strand these reflect only clinical need or patient choice. This will be achieved through the following outcomes:
improved reporting rates across equality strands and across all service areas as follows: o Gender: 100% by end of year 1; o Ethnicity: 60% by end of year 1 and 80% by end of year 3 (reduction in not stated from current 46% to 35% in year 1, 25% in year 2 and 15% in year 3),
Reporting includes Disability, Sexual Orientation & Religion or Belief by the end of year 1: o o o
Disability: 50%; Sexual Orientation: 20%; Religion or Belief: 30%;
Consistently high and equitable levels of reporting across all equality strands by the end of year 3.
Access to services improved for BAME groups from current 1.4% to 2% in year 1, 3% in year 2 and 3.9% in year 3, and by end of year 3 is consistent with access to services for White groups; and
Our Engagement Strategy will take full account of under-represented communities / seldom-heard groups and the requirement to encourage participation of disabled people in the public life of Medway Community Healthcare. We will know we have been successful when Medway Community Healthcare achieves full compliance with the CQC regulations in regard to equality, diversity and human rights, particularly Regulation 17h, and when we are fully compliant with the Equality Duties.
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2.
Patients will experience a service where their dignity is respected, where their voice is heard and where they are extended compassion. This will be achieved through the following outcomes: 
Levels of satisfaction from patients is consistent across equality strands and proportionate to service use;

Staff responsible for collecting and monitoring data understand the value of monitoring data and can provide clear explanations to service users; and

Levels of complaints reported by service users are consistent across equality strands and proportionate to levels of service use. We will know we have been successful if we continue to achieve our targets for patient satisfaction and reduction in complaints, also when we meet CQC Regulation 17h and are fully compliant with the Equality Duties.
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Strategic Theme 3: Workforce This theme focuses specifically on the development of a workforce and work culture that promotes equality of opportunity and demonstrates our capacity to deliver services to our community.
Workforce Monitoring: What the Law Requires Under the Race Relations (Amendment) Act 2000 (Employment Duty), all public authorities with more than 150 staff must monitor, by racial group, the numbers of:
Staff in post;
Applicants for employment, training and promotion;
Staff who receive training;
Those who benefit or suffer detriment as a result of its performance assessment procedures;
Staff who are involved in grievance procedures;
Those who are the subject of disciplinary procedures; and
Staff who cease employment.
Authorities are required to publish the results of this monitoring annually. The Gender and Disability Equality Duties are less prescriptive but require public bodies to gather information on the effect of their policies and practices on men and women and have in place “arrangements for gathering information about the impact of policies and practices on recruitment, development and retention of disabled employees”. The workforce monitoring reports produced by Medway Community Healthcare demonstrate good practice by covering most equality strands i.e. age, gender, disability, ethnicity and sexual orientation, as well as covering working patterns. We also intend to report on staff by gender by Agenda for Change banding and will continue to analyse and report any gender pay inequity that emerges. In most areas reporting rates are good, although there is some work to be done to improve this, particularly in relation to sexual orientation and disability. We also intend to start reporting data relating to religion or belief. At present we report on staff in post, applicants for employment and staff who cease employment. We also report participation in formal processes such as grievance and disciplinary processes through our committee structure. We have also recently added training and development to our workforce monitoring. Our reports are published quarterly on our website. The annual report will be published by the end of Quarter 1 in the new financial year e.g. the 2009/10 report will be published by the end of Quarter 1 2010/11. Action setting is evidenced through the minutes of the Equality and Diversity Steering Group.
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Profile of Our Staff The current workforce profile for Medway Community Healthcare is detailed earlier in the document. In broad terms we have a workforce where women are significantly overrepresented in comparison with the local population. We also have an underrepresentation of disabled staff but we have good representation in terms of ethnicity, with the proportion of BAME staff being higher than the average for the local population. We do note that, generally speaking, health services outside large metropolitan centres often have a higher representation of BAME staff so our employment rate is more typical of health services generally. We can estimate from available workforce data that 1.15% of our workforce are gay, lesbian or bisexual. This compares to approximately 5% of the local Medway population. However, we only have data for 63% of our workforce. We will continue to expand this work to ensure we build a more complete understanding of our workforce. The religion or belief data of our workforce is collected but currently not reported on. We are improving our reporting processes to address this issue. Further work is also required to determine whether the profile of our staff is representative at all levels of the organisation.
Recruitment and Selection Our recruitment and selection policy is based on Safer Recruitment – a Guide for NHS Employers (available from the Human Resources department) as published by NHS Employers which replaces HSC 2002/008 Pre and Post Appointment Checks for all Persons Working in the NHS in England, as well as employment legislation and good practice. Effective recruitment is crucial to the success of Medway Community Healthcare in providing a high quality service to patients. We rely on recruiting and employing people with the necessary skills, experience and qualifications to deliver organisational objectives and with the ability to make a positive contribution to our values and aims. We tend to recruit high calibre staff and will not appoint anyone to a post who does not meet the essential criteria specified in the person specification for each job. Successful recruitment not only means getting the right person for the job to fulfil current needs, but also depends on their ability to adapt to changing demands. It is, therefore, important that all our staff are flexible enough to welcome changes that internal influences, such as restructuring, and external factors, such as developments in healthcare approach, drugs, delivery and new technology etc will inevitably bring. All of these factors determine our future success as an organisation with a workforce equipped to take us forward. It is Medway Community Healthcare’s policy that all job vacancies are open to all internal applicants in order to allow opportunities for development of existing staff in line with our approach to talent management and succession planning. This process may
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occur prior to or alongside external recruitment methods depending on the nature of the post, suitability of internal candidates and future organisational needs. At least one member of the recruitment panel must have attended approved training in best practice for recruitment and selection, which will include annual updates as appropriate. Given our commitment to more actively promote diversity and to address the changing profile of our community we will update this programme to include “positive action in recruitment� to ensure panel members not only ensure that no discrimination occurs, but also develop recruitment processes which attract applications from a wider number of quality candidates and build our reputation as a modern and diversity friendly employer. Medway Community Healthcare aims to ensure no employee or job applicant is discriminated against either directly or indirectly on the grounds of gender, sex, ethnicity, colour or nationality, marital status, age, disability, sexual orientation, gender identity, religion or beliefs, domestic circumstances, political affiliation, trade union membership or HIV status. All recruitment procedures are designed to ensure that we do not discriminate on any of these grounds and discrimination in any form will not be tolerated. On-line short listing via NHS Jobs is a further assurance to this process. Assistance should always be provided for those applicants who may otherwise find it difficult to apply or be considered for a particular post (i.e. those who are disabled in some way). We guarantee any disabled applicant an interview, provided he/she meets the essential criteria within the person specification and arrangements should be made to accommodate their needs so far as is reasonably practicable at interview, for example ensuring the interview room is accessible for wheelchair users. This may mean individuals being accompanied to the interview or adaptation to tests as appropriate. It is expected reasonable adjustments to the workplace will be made in order to accommodate disabled employees wherever possible. Medway Community Healthcare works with Access to Work to ensure staff have the resources to do their jobs where, for example, certain impairments have been identified. Information on ethnic origin, disability, religion or beliefs, gender, age, sexual orientation and gender identity is collected by the Human Resources department from application forms for the purposes of monitoring. Selection practices and procedures will be regularly monitored by the Human Resources department and reviewed to ensure that individuals are selected, promoted and treated on the basis of their relevant merits and abilities. No applicant or employee will be disadvantaged by conditions or requirements that cannot be shown to be justified. Current monitoring of the recruitment process at Medway Community Healthcare indicated that there are some specific areas for action in relation to recruitment and selection which are outlined in the Action Plan.
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Equal Pay It is a legal requirement that Single Equality Schemes address the issue of equal pay. Medway Community Healthcare collects, analyses and reports on gender pay rates on a quarterly basis. The following table is an example of the report that is presented to the Medway Community Healthcare Equality and Diversity Steering Group. This is for one quarter only and suggests some differences in part-time and full-time rates of pay, although this needs further analysis to determine any trends across grades. We will continue to publish these reports and take action to address any specific issues identified. Assignment Category
Employee Category
Fixed Term Temp
Full-Time
Part-Time
Permanent
Full-Time
Part-Time
Data
Male
Female
Medium of Salary Value Medium of Hourly Rate Medium of Salary Value Medium of Hourly Rate Medium of Salary Value Medium of Hourly Rate Medium of Salary Value Medium of Hourly Rate
£17,880.33
£23,422.83
Gender Medium Difference £5,542.50
£9.14
£11.98
£2.83
£10,215.14
£9,030.60
£1,184.54
£7.66
£11.27
£3.62
£26,167.52
£27,045.89
£878.37
£13.40
£13.85
£0.45
£12,027.49
£12,293.26
£265.77
£11.65
£11.20
£0.45
Sample report - Medway Community Healthcare, September 2009
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Learning and Development: Equality and Diversity Training It is our aim to ensure our workforce is competent to address equality issues within both strategic and operational activities. Our ongoing learning and development in this area will include:
A range of equality and human rights courses aimed at different tiers of management and staff with an emphasis on service delivery;
A case study based impact assessment course;
A training course on using interpreters effectively;
Customer care – communicating with patients and monitoring;
Recruitment and selection for non managers;
Interview questioning – formulating equality and diversity questions;
Religious and Cultural awareness in healthcare;
Lesbian, Gay, Bisexual and Transgender Awareness; and
All aspects of disability in service delivery.
Staff Engagement and Satisfaction We measure staff satisfaction through the national NHS Staff Survey. The value of the NHS staff survey is that it provides data that is disaggregated by equality strand and compared with other services in the Strategic Health Authority. The 2009 Staff Survey was published in March 2010 and 462 staff members responded, comprising a response rate of 65%, up from 61% in 2008. The response rates and representation for the 2009 Staff Survey closely reflect our staff population, though it does not monitor all equality strands. Male Female White BAME Disabled Non Disabled
(10%) (90%) (90%) (10%) (20%) (80%)
We have included a number of responses which we consider highlight the experiences of different staff groups. Overall, the data would suggest that across the organisation:
Women generally achieve higher scores than men in areas of performance development, though men are slightly more motivated than women;
There are very slight variations in the experience of disabled and non disabled colleagues but none that suggest significant differences, other than in their general experience of discrimination and bullying by colleagues; and
BAME staff are on par with, and in many areas scoring higher than, their white colleagues. Notwithstanding BAME staff do report higher levels of experiencing discrimination and are not so positive about career development opportunities.
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Gender Disabl ed Male Female 3 7 10 11 12 13 14 15 24 25 26 27 28 30 37 38 39 40
% staff who feel valued by work colleagues % working in a well structured team environment % using flexible work options % feeling there are good opportunities to develop their potential at work % receiving job related learning and development in past 12 month % appraised in last 12 months % having well structured appraisals in past 12 months % appraisals with development plan in past 12 months % receiving physical violence from patients/relatives % experiencing physical violence from staff in past 12 months % experiencing bullying/harassment from patients/family in past 12 months % experiencing bullying/ harassment from staff in past 12 months Perception of effective action from employer towards bullying and harassment % feeling pressure to attend work while unwell in past 3 months Staff motivation at work % having equality and diversity training in past 12 months % believing PCT provides equal opportunity for career progression/ promotion % experiencing discrimination at work in last 12 months
Ethnic Background White BAME
84
79
80
80
73
41
48
44
48
48
78
82
81
81
82
44
52
52
51
55
79
83
82
82
90
58
70
78
69
70
30
35
38
33
47
49
59
69
57
59
9
5
7
5
5
2
1
0
1
0
13
17
17
16
16
13
15
20
15
19
3.40
3.54
3.47
3.53
3.49
15
19
25
19
19
4.01
3.88
3.79
3.88
3.93
33
44
40
43
43
82
96
90
95
86
7
4
9
4
11
A significant concern is that the 2009 Staff Survey suggests that BAME staff are experiencing higher levels of violence, bullying and harassment from both patients and colleagues and that they are less confident about the management response to these issues. Our lowest four performing areas in the 2009 Staff Survey relate to these factors and we have identified actions in the Action Plan to address these concerns. Flexible and Part‐Time Working The NHS 2009 Staff Survey indicated that we have a good take up of part-time and flexible working opportunities across all equality strands identified with a slight difference in men and women using flexible options at work.
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Key Outcomes/Actions We have two strategic intentions under this theme. 1. We will have a workforce that can deliver services effectively to and for our community now and into the future. This will be achieved through the following outcomes:
We will achieve a more diverse workforce;
We will have improved year on year reporting and representation of: o
Disabled staff from current 28% not stated/reported and 4.95% estimated workforce against 12.5% local population;
o
LGB&T staff from current 36.8% not stated/reported and 1.14% estimated workforce against 5% estimated general UK population;
o
BAME staff in occupational groups and staff bands where they are under represented;
o
Men in occupations where they are under represented;
We will have an improved age profile across the organisation particularly in regard to the 16-25 age band from current 5.2% workforce;
We will improve development opportunities for minority groups who are underrepresented at different staff bands in the organisation, particularly in regard to BAME groups at Bands 3 and 4;
We will eliminate any forms of transgender discrimination;
All staff will develop equality and diversity skills and knowledge relevant to their work role at induction, as part of their leadership development and as it relates to specialist functional areas; and
We will monitor and report HR practices by all equality strands and take clear action to address any patterns in relation to formal employee relations processes. We will know we have been successful when we achieve benchmark average or better in the NHS Staff Survey and a positive trend in local staff surveys and when our staff understand what is important to people based on their needs, preferences and diversity. This will improve patient experience and enable Medway Community Healthcare to meet CQC Regulations 21 and 22 and comply fully with the Equality Duties.
2. Our staff will experience a work culture where they are safe and respected; where they experience having a voice and making a difference. This will be achieved through the following outcomes: We will have open, transparent and dynamic engagement with all staff groups; and All staff groups will experience a consistent level of satisfaction, management and development based on their job role and merit We will know we have been successful when we improve our performance in the NHS Staff Survey. Page 77 of 118
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Enabling Strategy 1: Leadership and Governance Medway Community Healthcare’s Equality and Diversity Steering Group meets bimonthly and is currently chaired by the Director of Human Resources and Organisational Development. Progress against equality and diversity action plans, including this Scheme, is reported to this group by the Equality and Diversity Lead. Both employment and patient monitoring reports are presented to the group on a quarterly basis by the Equality and Diversity Lead. Recommendations are made to the group for approval, for example, positive action measures. The Equality and Diversity Steering Group reports into the Board of Medway Community Healthcare. Evidence of this can be found in the Equality and Diversity Steering Group minutes which are published on its website.
Key Outcomes/Actions Our enabling strategy is to maintain CQC registration and achieve full compliance with all sections of the regulations. This will be achieved through the following outcomes:
Medway Community Healthcare’s Board will reflect the demographic and diversity of the local community; and
The Board will continue to monitor Medway Community Healthcare’s performance in equality and ensure compliance with governance structures and equality indicators.
Framework for Delivery Medway Community Healthcare’s Board has overall responsibility for ensuring the adoption of the Single Equality Scheme. The Managing Director and the Executive Team have responsibility for ensuring that this policy is implemented across the organisation. An annual report to the Board will include an assessment of compliance with statutory duties and a review of progress in implementing the arrangements specified in the Single Equality Scheme. Senior managers are responsible, through their leadership roles, for maintaining the profile of equality issues in Medway Community Healthcare and for promoting the Scheme within and, where appropriate, outside the organisation. They are also responsible for ensuring that staff are aware of their responsibilities and that they take advantage of the support and training available to help them carry these out. Senior managers will also ensure that relevant procedures are adhered to and appropriate action is taken in respect of staff or contractors who discriminate on the basis of any of the equality strands. All staff are responsible for promoting equality and for avoiding discrimination in the way they work. Staff are expected to participate in relevant training and learning opportunities provided within Medway Community Healthcare. We will invite recognised trade unions and professional associations to identify and appoint leaders who will support the implementation of the Scheme. These include:
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Unison, British Association of Occupational Therapists (BAOT), British Dental Association (BDA), British Dietetic Association (BDA), Chartered Society of Physiotherapists (CSP), Society of Podiatrists (SCP), Royal College of Nursing (RCN), British Medical Association (BMA) and Unite.
Enabling Strategy 2: Building the Evidence Base Like good clinical practice and effective business management, good practice equality and diversity needs to be data and evidence based. This underpinning theme outlines what effective data collection and monitoring is already happening across Medway Community Healthcare and outlines opportunities for further improvement.
Equalities Monitoring Equalities monitoring is the process of collecting, storing and analysing information about people’s gender, ethnicity, disability, age, religion or belief, sexual orientation and socio-economic status. Effective data collection/monitoring is essential in order to build a sound evidence base for service planning and delivery, as well as workforce development. This activity is, therefore, central to all of the strategic themes in this Single Equality Scheme. The main components of an effective monitoring system are:
Explaining to service users and staff why monitoring takes place;
Ensuring that those who collect the data understand its importance and can explain to others why it is necessary and how it benefits them;
Monitoring different aspects of work: o
Access;
o
Experience;
o
Outcome;
Giving specific staff responsibility for introducing and maintaining the system to ensure that it is effective;
Analysing the monitoring records regularly, with reports produced at a minimum of every six months;
That people only have to give information on a voluntary basis; and
That people should be invited to self-assess (rather than someone else doing it for them). If assessment is done by a third party, this must be distinguished from self-assessment data.
It is important to be clear about categories for ethnic monitoring and to consult local communities on which categories to use e.g. by breaking down a category such as ‘Black African’ or ‘White Other’. This will ensure that the data collected accurately reflects the local population or workforce. Monitoring must also be part of an ongoing cycle of identifying and exploring patterns, changing the way we deliver services and checking to see whether the changes are working.
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We will adopt the following principles of good practice in our data collection and monitoring:
We will be clear about why we want the information and what it will be used for − including who will have access to it;
We will reassure the person we are asking for the information that it will not affect the service they get/any benefits they might receive, etc;
We will make sure that the person understands that giving this information is voluntary;
We will choose an appropriate moment to gather the information − this might happen naturally as part of a needs assessment, but if not, it is often best to wait until the enquiry or issue at hand has been dealt with;
We will allow the person to self-classify wherever possible and be clear about the categories available;
We will acknowledge the information we are given but will not comment on it in a negative or positive way − our job here is to collect facts;
We will reassure the person about the confidentiality of the information, and if appropriate explain that the information is protected by the Data Protection Act;
We will get the person’s explicit consent to store the information; and
We will think about how to ask the questions beforehand.
Community Engagement There is a clear and growing requirement for public sector bodies to engage with local people about the services they provide. Guidance from the Improvement and Development Agency on Comprehensive Area Assessments states that public sector bodies will be required to show:
How the public has been involved in setting priority outcomes; and
How the public has been involved in assessing how these outcomes have been delivered.
Our Single Equality Scheme will build on the partnership work developed in consultation and engagement on the Joint Strategic Needs Assessment and the Joint Strategic Needs Assessment for Mental Health. It is recognised that engagement with community groups and organisations needs to develop further and in particular for the purposes of this Scheme effectively incorporate under-represented communities. This development will take place by utilising existing structures and networks and specifically by:
Working with existing umbrella groups addressing diversity and equality. This will include Kent Equalities Network online forum and Medway Community Cohesion Group. This will enable key personnel and resources available for work on equality and diversity to work together with public sector partners on how consultation and engagement is currently being undertaken with underrepresented groups.
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Identifying key communities or sections of the community where there is little or no contact from public sector partners e.g. gypsies and travellers, deaf people, people going or having gone through gender transition. Mechanisms for consultation and engagement with these sections of the community will then be put in place.
HR will review current engagement mechanisms with staff from underrepresented groups to ensure communication and actions are developed to improve delivery on equality and diversity in the workforce.
This process will support the public sector organisations, together with Medway Communtiy Healthcare in building up community knowledge and staff knowledge contacts so that engagement becomes ongoing. The process will not only be about key documents and service information being passed to community groups/networks for comment, but the development of a clear communication route from the umbrella groups to public sector partners and Medway Community Healthcare. This will support, Medway Community Healthcare and partners in developing genuine engagement and trust with communities and staff. This will be done by ensuring that standards for consultation and engagement are developed and include:
Clarity on the questions/areas of work being consulted on and who needs to be consulted;
A clear plan for engagement that addresses all the agreed standards and has been costed and resourced;
All information is made available in appropriate formats;
All responses are recorded accurately;
The responses to the consultation are fed back to all participants; and
The engagement influences strategy and service delivery demonstrating the success of the engagement process.
The effectiveness of the consultation and engagement will be monitored and measured as part of the ongoing review process on the Single Equality Scheme.
Key Outcomes/Actions Our enabling strategy will be achieved through the following outcomes:
We will have in place a reliable data gathering and analysis process, proportionate to the service capability, which ensures a more complete and comprehensive profile of our community across all equality strands;
We will have in place a reliable data gathering and analysis process, proportionate to the service capability, which ensures a more complete and comprehensive profile of our staff across all equality strands; and
We will have in place a reliable data gathering and analysis process for equality performance monitoring, proportionate to the service capability, which ensures a more complete and comprehensive profile of our supply chain across all equality strands.
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Enabling Strategy 3: Equality Impact Assessment Equality Impact Assessment (EIA) is a key driver for each of our commitments and provides the critical systems tool for identifying priority areas for action and making real and tangible improvements. This work is particularly relevant for Medway Community Healthcare as a key mechanism to aid service development and service changes and the opportunity to promote equality through such developments. An EIA is a systematic appraisal of the actual or potential effects of a function or policy on different groups of people. It is conducted to ensure compliance with public duties on equality issues (which in some areas go beyond a requirement to eliminate discrimination and encompass a duty to promote equality), but more importantly to ensure effective policy making that meets the needs of all groups. Like all other public bodies, Medway Community Healthcare is required by law to conduct equality impact assessments of all functions and polices that are considered relevant to the public duties and to publish the results. An EIA must be completed when developing a new function, policy or practice, or when revising an existing one. In this context a function is any activity of Medway Community Healthcare, a policy is any prescription about how such a function is carried out, for instance a strategy, guidelines or manual, and a practice is the way in which something is done, including key decisions and common practice in areas not covered by formal policy. It is important that all policies are informed by the knowledge of the impact of equalities issues accumulated across the organisation. Staff working on policy development should contact the relevant Equalities Lead to discuss the issues arising in their policy area as early as possible in the development process and before commencing the EIA.
Our EIA Process Our EIA process has been constructed as a two-stage process in order to reduce the amount of work involved where a policy proves not to be relevant to any of the equalities groups or duties. Our EIA template and toolkit are available to download on the EIA section of our website, together with additional guidance materials. The initial screening tool should be completed in all cases, but duplication of material between it and the full EIA should be avoided. For instance, where relevance to an equalities issue is self-evident or quickly identified this can be briefly noted on the initial screening and detailed consideration of that issue reserved for the full assessment. Further guidance on this will be given by the relevant Equalities Lead.
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Embedding the Process We recognise that completing EIAs is a key requirement under the equality duties and also the specific duties of the Care Quality Commission. We have taken a number of significant steps to establish and embed processes for conducting assessments. These have included:
The development of an EIA framework to cover all equality strands and socioeconomic status, including a toolkit, flowchart summarising the EIA process, template and screening template/guidance;
Completed assessments on at least 24 policies, procedures and functions;
The publication of completed initial and full EIAs on our website;
Establishing a corporate EIA programme;
Setting up an EIA Sub Group which reports to the Equality and Diversity Steering Group and provides quality assurance to completed assessments; and
Providing EIA training for staff.
The EIAs we have completed so far demonstrate that staff across the organisation are developing skills in identifying both the negative and positive impacts on particular groups which might arise from their policies and practice. The assessments have also revealed significant gaps in our equalities evidence base, both in terms of our employment and our service provision. In order to develop our assessments, we recognise that we must develop ongoing mechanisms for consulting particular groups within our workforce, our partners and the communities we serve. Our toolkit has recently been revised to include guidance on consultation. In addition, we are working with NHS Medway to establish a joint consultation forum for EIAs. We also need to identify clearer actions from our assessments, including actions to change policy or practice, to support or mitigate implementation, to consult and gather evidence and to monitor future impacts. These actions need to be built into Action Plans to ensure effective performance management. A good development would be to use this tool to help us to promote equality, as well as to understand discriminatory barriers and remove them.
Partnerships, Contracts and Service Level Agreements The impact, or potential impact, of any work under contract or other arrangement should be considered for an EIA but may not require a full one, e.g. business cases and service specifications should be assessed but contracts will require a statement reflecting our commitment to equalities, together with a requirement to collect equalities data about patients and staff; and have equality and diversity policies and practices. It is also important to consider other arrangements, such as service level agreements, which may not be monitored corporately.
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In partnerships we should make efforts where possible to ensure that:
Equality is incorporated into partnership values and aims;
The committee or steering group is representative of all community groups;
We encourage and promote equality of opportunity; and
There is no conflict with the PCT’s commitment to equality and diversity.
Priority EIAs Our intention is to deliver high quality and high level impact assessment that makes a difference to service development and improvement. Our priorities are set out in our Corporate Equality Impact Assessment Programme April 2010 to March 2011, which also sets out the relevance to equalities of each function or policy being assessed. Progress against this programme will be reported quarterly and annually to the Equality and Diversity Steering Group by the Equality and Diversity Lead / EIA Sub Group. Each EIA will be the subject of some consultation and involvement and a range of methods will be used to ensure they are effective. As the nature of our work varies considerably from function to function, different kinds of consultation and involvement will be appropriate for different EIAs. The methods used must be described in each EIA. The same is true of accountability so the arrangements for monitoring and reviewing must be described in each EIA.
Key Outcomes/Actions Our enabling strategy is that we will embed equality analysis into all service decision making, using a shared and rigorous EIA process. This will be achieved through the following outcomes:
An annual Corporate EIA Programme will be published and conducted with the equality analysis identifying how service changes / new policy will promote equality;
80% compliance on completed assessments;
An EIA sub group will be established to provide quality assurance to complete EIAs;
Quarterly and annual EIA reports will be produced; and
Our EIA toolkit will include clear and comprehensive details on how to carry out consultations, promote good race relations and involve disabled people.
These outcomes will enable Medway Community Healthcare to meet CQC Regulations 9, 11, 12 & 14 and comply fully with the Equality Duties.
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Medway Community Healthcare Action Plan (Please note: Actions have been cross-referenced to the general Equality Duties to allow the reader to clearly see the relevance of the action to the General Equality Duties. These are listed and numbered on pages 107-111 ) Strategic Theme 1: Promoting equality through commissioning, contracting and procurement Strategic Intention: Our contract and supply chain management promotes equality and inclusion and we work with suppliers who reflect this commitment and are the best match to meet our community needs Success Measure: All service providers will have equality and diversity practices aligned with Medway Community Healthcare (MCH) or where appropriate have a service improvement plan in place to achieve alignment Completion Date
Outcome
Action
Lead Director
Suppliers better understand equality legislation and are set on a path from basic compliance to exemplary performance.
Prepare our existing suppliers to work within the newly announced “National Equalities Framework” due for completion by Spring 2011 (General Duty Relevance 1-3, 6, 8, 9 & 12)
Year 3 July 2013
Assistant Director of Business & Performance
Update our tendering and procurement documents to comply with the new framework and actively communicate through our procurement process our commitment to working with partners who promote equality (General Duty Relevance 1-3, 6, 8, 9 & 12)
Year 2 July 2012
Assistant Director of Business & Performance
We will ensure all contracts include clear requirements for equality monitoring and reporting which will be reported to the E&D Steering Group bi-annually and the Board annually with recommendations
Clear monitoring and reporting requirements will be built into all new contracts through the introduction of a supplier questionnaire requiring both potential and existing suppliers to provide evidence that equality monitoring and practice meets MCH requirements, proportionate to the size of the contract and service delivery requirements (General Duty Relevance 1-3, 6, 8, 9 and 12)
Year 1 July 2011
The above outcomes will demonstrate compliance with the
Ensure Equality and Diversity performance is
Assistant Director of Business & Performance
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Equality Act and Care Quality Commission (CQC) Regulations 15, 21 & 22 and how MCH uses procurement to drive equality and consider how spending decisions and services affect people from different groups
included as a core component of all supplier service reviews and reported bi-annually to the E&D Steering Group (General Duty Relevance 13, 6, 8, 9 and 12)
Year 1 The above outcomes will demonstrate compliance with the Equality Act and Care Quality Commission (CQC) Regulations 15, 21 & 22 and how MCH uses procurement to drive equality and consider how spending decisions and services affect people from different groups July 2010
Strategic Theme 2: Patient Experience Strategic Intention: Patient access to clinical service is needs based and where there are differential take up rates by equality strand these reflect only clinical need or patient choice. Success Measure: Medway Community Healthcare achieves compliance with the CQC regulations in regard to equality, diversity and human rights Outcome
Action
Improved reporting rates across equality strands across all service areas:  Gender: 100%  Ethnicity: 60% (reduction in not stated from current 46% to 35% in year 1, 25% in year 2 and 15% in year 3).80% by end of year 3. Reporting includes Disability, Sexual Orientation and Religion or Belief by the end of year 1:
Deliver staff training to ensure all staff understand the relevance of collecting monitoring data. (General Duty Relevance 2, 6 and 12) Improve reporting system across all service areas. (General Duty Relevance 2, 6 and 12)
Completion Date Year 1 April 2011
Lead Director Assistant Director of Operations and Equality & Diversity (E&D) Lead
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Disability: 50% Sexual Orientation; 20% Religion or Belief: 30%
Year 3 September 2013
Consistent and equitable high levels of reporting across all equality strands
Access to services improved for non-White groups from current 1.4% to 2% in year 1, 3% in year 2 and 3.9% in year 3 and by end of year 3 is consistent with access to services for White groups.
Engagement Strategy takes full account of under-represented communities/seldom-heard groups and the requirement to encourage participation of disabled people in the public life of MCH. The above outcomes will enable MCH to meet CQC Regulations 9 and 17 and comply fully with the Equality Duties.
Improve quality and regularity of equality monitoring and reporting to better inform understanding of who is accessing services, including reporting on Did Not Attend (DNA) rates by equality strands (General Duty Relevance 1 and 2).
End of Year 1 September 2011
Assistant Director of Operations and E&D Lead
All service improvement plans include an analysis of access needs to ensure prioritisation of resource allocation to high need services. This should include but not be limited to: Physical access Access for sensory impaired service users Service opening hours Access for carers (General Duty Relevance 4, 6-8 and CQC Regulation 15)
End of Year 1 September 2011
Assistant Director of Operations and E&D Lead
Develop measures to improve engagement and consultation with under-represented communities/seldom-heard groups and the participation of disabled people in the public life of MCH (General Duty Relevance 2, 3, 6-9, 12 and CQC Regulations 10 and 17)
End of Year 1 September 2011
Assistant Director of Business & Performance
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Strategic Intention: Patients experience a service where their dignity is respected, where their voice is heard and where they are extended compassion Success Measure: We continue to achieve our targets for patient satisfaction and reduction in complaints Completion Date
Outcome
Action
Levels of satisfaction from patients is consistent across equality strands and proportionate to service use
Patient survey tool(s) contain request for patients to include equality monitoring information with a clear explanation for why this is being requested. Build E&D into patient experience survey questions. Any themes or patterns emerging in the patient survey are disaggregated by equality strands and reported to the E&D Steering Group on a six monthly basis. (General Duty Relevance 1, 2, 4, 6, 10, 12)
Year 1 Sept 2010
Assistant Director Clinical Standards
Develop equality and diversity indicators for equality strands to support and improve patient experience across all equality groups (General Duty Relevance 1, 2, 4, 6, 10, 12)
Year 2 Sept 2011
Assistant Director Clinical Standards
Staff responsible for collecting monitoring data understand the value of monitoring data and can provide clear explanations to service users
Skills and knowledge in equalities monitoring is embedded in equality and diversity training for all staff (General Duty Relevance 1, 2, 4, 6, 10, 12 and CQC Regulations 21 & 22))
Year 1 July 2011
Director of HR and OD & E&D Lead
Levels of complaints reported by service users are consistent across equality strands and proportionate to levels of service use
Complaints documents are reviewed to ensure they contain a request for equalities monitoring data and a clear explanation for why it is being requested. (General Duty Relevance 1, 2, 4, 6, 10, 12 and CQC Regulation 19)
Year 1 July 2011
Assistant Director of Governance
Year 1 July 2011
Assistant Director of Governance
The above outcomes will enable MCH to meet CQC Regulation 17 and comply fully with the Equality Duties.
Complaints information and data collected is reported by equality strands to the E&D Steering Group and other MCH committees on a quarterly and annual basis and action plans implemented where issues emerge (General Duty Relevance 1, 2, 4, 6, 10, 12 and CQC Regulation 19)
Lead Director
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Strategic Theme 3: Workforce Strategic Intention: We have a workforce that can deliver services effectively to and for our community now and into the future Success Measure: Medway PCT achieves benchmark average or better in the NHS Staff Survey and a positive trend in local staff surveys. Completion Date
Outcome
Action
Achieve a more diverse workforce.
Continue to improve equality monitoring across all levels of the organisation to identify areas for priority action. (General Duty Relevance 1, 2, 4, 6, 10, 12)
Year 1 Sept 2011
Director of HR and OD and E&D Lead
Consider monitoring reasonable adjustments
Year 1 Sept 2011
E&D Lead
Years 1-3
Director of HR and OD and E&D Lead
End of Year 3
Director of HR and OD and E&D Lead
Improved year on year reporting and representation of: Disabled staff from current 28% not stated/reported and 4.95% estimated workforce against 12.5% local population. LGB&T staff from current 36.8% not stated/reported and 1.14% estimated workforce against 5% estimated general UK population. BAME staff in occupational groups and staff bands where they are under represented. Men in occupations where they are under represented. Improved age profile across the organisation particularly in regard to the 16-25 age band from current 5.2% workforce. Improved development opportunities for minority groups who are under-represented at different staff bands in the organisation, particularly in regard to BAME groups at Bands 3 and 4.
Explore new ways to expand MCH as an employer of choice for under-represented groups and work with equality champions to identify real or perceived barriers to employment: e.g. NHS Race for Health, participation in Stonewall 2011 workplace equality index and inclusion in top 100 employers Consider undertaking a range of positive action measures that may include: Year 1: Conduct exit interviews to improve age, ethnicity, gender and LGB&T profiles across organisation Target BAME groups, young males, disabled people and LGB&T people in recruitment advertising Provide positive action statements and staff profiles on the website for BAME groups and disabled people Distribute job bulletin directly to BAME and disabled communities and organisations
Lead Director
September 2011
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Year 2: Introduce positive action traineeships and other work placement opportunities for disabled people Develop career pathways to retain staff Expand apprenticeship programme to improve age profile across organisation Year 3: Develop mentoring programmes for BAME staff at Bands 2-4 and disabled staff or make use of existing national programmes Develop proactive social partnership with BAME, disabled and LGB&T communities and organisations through staff placements in the community (General Duty Relevance 1-3, 4, 6, 7, 8, 9, 10, 12)
September 2012
Eliminate any forms of transgender discrimination
Work with organisations that represent transgender people to identify specific barriers to employment or progression in MCH, e.g. the Gender Trust, including Corporate membership. (General Duty Relevance 10-12)
Year 1 September 2011
Director of HR and OD and E&D Lead
All staff have developed equality and diversity skills and knowledge relevant to their work role at induction, as part of their leadership development and as it relates to specialist functional areas.
Equality and Diversity training for all new staff will be refreshed in line with the changing requirements of the Single Equalities Act, Public Duty requirements and the new CQC regulations (General Duty Relevance 1, 2, 4, 6, 10, 12)
Year 1 September 2011
E&D Lead
Equality and Diversity skills will be incorporated into each staff members personal development plan with all staff involved in policy development participating in EIA training (General Duty Relevance 1, 2, 4, 6, 10, 12)
Year 2 September 2012
Director of HR & OD
September 2013
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Monitor and report HR practices by all equality strands and take clear action to address any patterns in relation to formal employee relation processes
Our recruitment and selection training will be refreshed to incorporate a “positive action in recruitment” component to support the more positive approach to building a representative workforce (General Duty Relevance 1, 2, 4, 6, 10, 12)
Year 1 September 2011
E&D Lead and HR Resourcing Supervisor
Equality strand data will be recorded and analysed in relation to number of staff in formal HR processes, in particular, staff in post, applicants for employment, training and promotion, staff who receive training, those who suffer detriment as a result of performance assessment procedures, staff involved in grievance procedures, staff who are the subject of disciplinary procedures and staff who cease employment, reported to the E&D Steering Group (General Duty Relevance 1,2, 4, 6, 10, 12)
Year 1 2011
E&D Lead
The above outcomes will enable staff to understand what is important to people based on their needs, preferences and diversity. This will improve patient experience, enable MCH to meet CQC Regulations 21 and 22 and comply fully with the Equality Duties. Strategic Intention: Our staff experience a work culture where they are safe and respected; where they experience having a voice and making a difference Success Measure: We will improve our performance in the NHS Staff survey Outcome
Action
Open, transparent and dynamic engagement with all staff groups
A workable framework will be designed and implemented to ensure effective consultation and engagement including establishing champions for: Disabled staff BAME staff LGB&T staff
Completion Date Year 1 September 2011
Lead Director Director of HR & OD and E&D Lead
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This framework will enable the organisation to consult with equality groups in relation to: EIA on internal/ HR policy formation and changes Providing critical friend advice on organisational development generally Development of resources on intranet accessible to all staff to support above equality groups The framework developed will ensure that the equality representative(s)/ groups have a clearly understood purpose and clear influencing and reporting mechanism through to the E&D Steering Group. (General Duty Relevance 2, 3, 6, 8, 12 and CQC Regulations 21 & 22) All staff groups experience a consistent level of satisfaction, management and development based on their job role and merit
Staff survey responses will be analysed by equality strands to determine any patterns in experience or development which could require attention. (General Duty Relevance 1, 2, 4, 6, 10, 12) Review existing arrangements and support for staff in relation to violence, bullying and harassment from both colleagues and patients, with a particular focus on Black & Minority Ethnic (BAME) staff in response to results from the 2009 Staff Survey
Year 1 September 2011
Director of HR & OD
Year 1 September 2011
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Enabling Strategy: Leadership and Governance Outcome: We will achieve compliance and recognition with CQC regulatory framework Completion Date
Outcome
Action
Lead Director
The MCH Board will reflect the demographic and diversity of the local community
The Board will continue to explore opportunities to appoint non executive directors who contribute to the Board’s diversity (General Duty Relevance 3, 9,12)
Years 1-3
Managing Director
The Board will continue to monitor MCH performance in equality and ensure compliance with governance structures and equality indicators.
The Board of MCH participates in equality and diversity briefing sessions to build their knowledge of governance, compliance requirements and the business case for Equality & Diversity (General Duty Relevance 1,2, 4, 6, 10, 12 and CQC Regulations 21 and 22)
Year 1 September 2011
Managing Director
Outcome
Action
Completion Date
Lead Director
We have in place a reliable data gathering and analysis process, proportionate to the service capability, which ensures a more complete and comprehensive profile of our community across all equality strands
Improve patient monitoring pathways to include all equality strands (General Duty Relevance 2, 6 and 12)
Year 1 September 2011
Assistant Director Business and Performance
We will have in place a reliable data gathering and analysis process which ensures a more complete and comprehensive profile of our staff across all equality strands
Expand the current staff monitoring process to report and analyse, grievance and discipline, bullying and harassment, all equality groups by Agenda for Change bandings, staff with caring responsibilities, return rates of women from maternity leave, development processes such as requests for training, applications for promotion and annual trends regarding the gender pay gap. To develop objectives on how to address issues
Year 1 September 2011
Director of HR & OD
Enabling Strategy: Building the evidence base
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identified through monitoring. (General Duty Relevance 2, 6 and 12 and CQC Regulations 21 and 22) Publish annual workforce and patient monitoring reports We will have in place a reliable data gathering and analysis process for equality performance monitoring, proportionate to the service capability, which ensures a more complete and comprehensive profile of our supply chain across all equality strands
Conduct a diversity audit of the existing supply chain to assess: Level of ownership/leadership Business size Business location (General Duty Relevance 2, 3, 6, 8, 9, 12)
E&D Lead Year 1 April 2011 Year 1 September 2011
Assistant Director Business and Performance
Enabling Strategy: Equality Impact Assessment Outcome: We will embed equality analysis into all service decision making, using a shared and rigorous EIA process
Outcome:
Action
Completion Date
An annual Corporate EIA Programme will be published and conducted with the equality analysis identifying how service changes/ new policy will promote equality 80% compliance on completed assessments
EIA Corporate Programme published (General Duty Relevance 1-3, 4, 6-9, 10 & 12
Year 1 September 2011
Assistant Director of Governance and E&D Lead
EIA sub group established to provide quality assurance to completed EIAs.
EIA sub group established and reporting to Equality and Diversity Steering Group (General Duty Relevance 1-3, 4, 6-9, 10 and 12)
Year 1 September 2011
Assistant Director of Governance and E&D Lead
Quarterly and annual EIA reports produced
Produce quarterly and annual EIA reports for E&D Steering Group (General Duty Relevance 1-3, 4, 6-9, 10 and 12)
Year 1 September 2011
Assistant Director of Governance and E&D Lead
Lead Director
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EIA toolkit includes clear and comprehensive details on how to carry out consultations, promote good race relations and involve disabled people
Review and revise EIA toolkit to include more detail on how consultation should be carried out, how to promote good race relations and how to involve disabled people, as part of the EIA process
Year 1 September 2011
E&D Lead
The above outcomes will enable MCH to meet CQC Regulations 9, 11, 12 & 14 and comply fully with the Equality Duties
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Appendix 1: Public Sector Equality Duties and Legal Framework There are a number of important laws that have been introduced with the aim of reducing and tackling discrimination, particularly in the workplace, including: Equal Pay Act Sex Discrimination Act Race Relations Act Disability Discrimination Act Protection from Harassment Act Human Rights Act Local Government Act Employment Equality (Religion or Belief) Regulations Employment Equality (Sexual Orientation) Regulations Civil Partnership Act Gender Recognition Act Equality Act Racial and Religious Hatred Act Employment Equality (Age) Regulations Equality Act
1970 1975 1976 and (Amendment) 2000 1995 and 2005 1997 1998 2000 2003 2003 2004 2004 2006 2006 2006 2010
In addition to these are the three public duties around race, disability and gender that underpin our Single Equality Scheme.
Race Equality Duty The Race Equality Duty was introduced in December 2001. The Race Relations Act 1976, as amended by the Race Relations Amendment Act 2000, places a general duty on all public authorities, when carrying out their functions, to have due regard to the need to: 1. Eliminate unlawful racial discrimination under the Race Relations Amendment Act 2000; 2. Promote equality of opportunity; and 3. Promote good relation between people of different racial groups.
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Disability Equality Duty In December 2006, the Disability Discrimination Act 1995 was amended to place a duty on all public bodies to promote disability equality. This affects all public bodies. The Disability Equality Duty requires the public sector to actively promote disability equality, and is similar to the duty to promote race equality under the Race Relations (Amendment) Act. The Act sets out what is known as the “General Duty”. This means that all organisations must have due regard to the need to eliminate unlawful discrimination and promote equal opportunities for disabled people. We also need to consider the elimination of harassment of disabled people, promotion of positive attitudes and the need to encourage the participation of disabled people in public life. 4. Eliminate unlawful discrimination; 5. Eliminate harassment of people with disabilities that is related to their disability; 6. Promote equality of opportunity between disabled people and other people; 7. Take steps to take account of people with disabilities, even where that involves treating people with disabilities more favourably than others; 8. Promote positive attitudes towards people with disabilities; and 9. Encourage participation of disabled people in public life.
Gender Equality Duty A public sector duty on gender equality was introduced in the Equality Act 2007. The duty is modelled along the lines of the existing race and disability duties, with a clear focus on outcomes. The Equality Act 2007 sets out the framework for the gender duty by legislating for a general duty which will require public bodies to: 10. Ensure that they do not unlawfully discriminate between women and men when carrying out their employment or service functions; 11. Harassment that is unlawful under the Sex Discrimination Act 1975 and the Equal Pay Act 1970; and 12. Promote equality of opportunity between men and women.
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Specific Duties The duties give key public bodies a Specific Duty which defines for them a framework to use to meet the General Duty. The main element of this is the requirement to produce Disability, Gender and Race Equality Schemes. Each of the specific duties has informed the framework of this Single Equality Scheme. It is important to note that there are differences within each of the three duties, for example, under the Disability Discrimination 2005 there are specific requirements to involve disabled members of the public – including patients, carers, and staff - in the development and ongoing monitoring of the Scheme. Specifically it is required that organisations:
Involve disabled people in producing the Scheme and developing the Action Plan;
Identify how they will gather and analyse evidence to inform their actions and track progress;
Set out how they will assess the impact of their existing and proposed activities on disabled people;
Produce an Action Plan for the next three years; and
Report on their progress every year and review and make appropriate revisions to this Scheme at least every three years.
In producing this Single Equality Scheme, we have also sought to anticipate the Equality Act 2010.
Equality Act 2010 The Single Equality Bill was initially introduced on 27 April 2009 and became an Act of Parliament on 8 April 2010. The Equality Act 2010 is intended to provide a new cross-cutting legislative framework to protect the rights of individuals and advance equality of opportunity for all; to update, simplify and strengthen the previous legislation; and to deliver a simple, modern and accessible framework of discrimination law which protects individuals from unfair treatment and promotes a fair and more equal society. The provisions in the Equality Act will come into force at different times to allow time for the people and organisations affected by the new laws to prepare for them. The Government is currently considering how the different provisions will be commenced so that the Act is implemented in an effective and proportionate way. However, it is anticipated that the Act’s core provisions will come into force in October 2010.
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The Act will make equality legislation simpler and stronger in a number of different ways: Simpler Law Less complex and unwieldy law, through:
Replacing nine major pieces of legislation and around 100 other instruments with a single Act.
Harmonised definitions and exceptions so there are common approaches, where appropriate.
Clear and consistent protection, through:
Levelling up protection for people discriminated against because they are perceived to have, or are associated with someone who has, a protected characteristic, so providing new protection for people like carers;
Clearer protection for breastfeeding mothers;
Levelling up protection from discrimination in private members’ clubs; and
Extending the scope to use positive action.
Giving people better access to their rights, through:
Simpler, clearer law and guidance so that employers and service providers are clear what they need to do to comply;
Giving employment tribunals powers to make recommendations in more cases, to help employers improve their practices and their compliance; and
Protecting people from dual discrimination – direct discrimination because of a combination of two protected characteristics.
Stronger Law Better, more inclusive public services which help people achieve their potential, through:
A new duty on strategic public bodies to consider reducing socio-economic inequalities;
A new integrated Equality Duty on public bodies;
Using public procurement to improve equality.
Fairer services for older people, through:
Banning age discrimination in service and public functions.
More transparency, through:
A power to require gender pay and employment equality publishing by public bodies;
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Encouraging businesses to publish their gender pay gap, with a power to require this if insufficient progress is made voluntarily; and
Stopping employers using pay secrecy clauses to prevent employees discussing their own pay.
More rights for disabled people, through:
A new right for disabled people who live in leased homes to have reasonable adjustments made to communal areas like entrances and hallways, provided they meet the cost;
Requiring schools to provide auxiliary aids and services for disabled pupils, for example special equipment and large-print books, where reasonable;
Preventing employers asking job applicants questions about disability or health before making a job offer, except in specified circumstances; and
Increasing the number of wheelchair-accessible taxis.
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Appendix 2: Involvement and Consultation We developed this Scheme in the following manner. We carried out a document and data review. Then we consulted our staff in various ways. Most importantly, we engaged with and then consulted community groups and we held a consultation event with members of the public. We used the feedback from these events to confirm the issues and priorities, and to change them, or to change the emphasis, in the final draft of the Scheme.
Document and Data Review We conducted a review of all the previous equality and diversity plans developed by Medway PCT including:
The previous draft Single Equality Scheme published in 2008;
The 2009/10 equality and implementation plan developed for commissioning;
The Medway PCT and Medway Community Healthcare Action Plans which outline vision, values, service and equality priorities;
The World Class Commissioning strategy which describes outcomes by March 2012;
The Medway Community Healthcare Integrated Business Plan;
Medway PCT Strategic Commissioning Plan.
In addition we reviewed our most reliable sources of information in relation to monitoring our equality and diversity performance which include:
Patient monitoring data;
Staff surveys and monitoring data; and
Previous Equality Schemes.
Direct Engagement and Involvement To ensure that the revised Single Equality Scheme is compliant, the developmental process undertaken to inform the drafting of the Scheme adhered to the formal guideline of a 12 week consultation period. Hence, the engagement and consultation framework for this Scheme has consisted of an initial robust six week period of engagement which has included the following:
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Internal Consultation
Initial interviews with senior stakeholders (Board Members and Executive Team Members);
High level dialogues with Executive Team Members and Assistant Directors (Strategic Leadership of Equality and Diversity briefing session for Board Members and Action Planning days at the joint meeting of Executive Team Members and Assistant Directors); and
Discussion with staff members at focus groups and during the roll-out of the Equality and Diversity corporate training programme.
Consultation Response Summary The following areas of good practice were identified during consultation with staff attending equality and diversity training. The issues have been grouped according to whether they were voiced by a high, medium or low number of respondents. High:
Good flexible working provision and support for work/life balance.
Equality and diversity training is provided for all staff.
Good community engagement.
Medium:
Clear efforts to develop a diverse workforce.
Patient and stakeholder engagement is improving.
Low:
The recruitment process is fair and open.
There are good staff support schemes.
There is clear support for the NHS vision.
Good progress towards single sex wards in hospitals.
The Equality and Diversity Group meets regularly.
Data collection is good.
“NHS Medway is a very enlightened employer”.
Staff engagement is good.
Extended hours in service provision.
Joint working with council.
The following areas for development and improvement were identified during consultation with staff attending equality and diversity training. The issues have been grouped according to whether they were voiced by a high, medium or low number of respondents.
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High:
Internal communication and access to information for staff
Visibility of equality leads
Catering at training events (better provision for vegetarians)
More innovative approach to patient and public engagement required in order to reach everyone
Medium:
Disabled access to Pembroke Court
Accessibility of sites and out of hours services
Consultation and engagement with staff
Low:
Interpreters required for patients who do not speak English
Engagement with ethnic minorities in Medway could be better
Consultation and engagement should be ongoing and meaningful, not just lip service
Engagement with parents could be better
There is a need to ensure that external stakeholders / public understand what is being communicated
Consultation should be targeted to engage with those who are interested in specific areas or initiatives
Leadership and demonstrable good practice on equalities from top down
Service provision should be more targeted and based on community need
Need to reflect diversity of population in service provision
More effort should be made to share knowledge / lessons learned among staff teams and avoid duplication of work
More tailored training opportunities required
Better HR support required for staff members facing difficulties at work
More E&D training required
EIA should be given more priority
There were also two comments regarding car parking, with one specific reference to Medway Maritime Hospital.
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External Consultation External consultation was in two parts. First, there were two rounds of consultation and engagement with community groups. Secondly, there was a Rapid Engagement Event held in late May, to which members of the general public were invited. Community Groups In round one initial meetings took place with the following groups: Group
Equality Strand
Age Concern Chatham
Age
Churches together in Medway
Religion or Belief
First Steps Drop in Centre
Socio-Economic Status
Health Action Charity Organisation (HACO)
Race/Ethnicity
K Ying Chinese Elderly Association
Race/Ethnicity
Medway Access Group
Disability
Medway Ethnic Minority Forum
Race/Ethnicity
Medway Ethnic Minority Carers Forum
Race/Ethnicity/Gender
Shout Out
Disability
Health and Homelessness: Pier Road Projects
Socio-Economic Status
The groups that we met with recommended a number of strategies which would improve accessibility and equality of service provision: Medway Ethnic Minority Carers Forum The Medway Ethnic Minority Forum acts as the representative body for ethnic minority communities in Medway. It aims to promote understanding and awareness of the diverse cultural needs of ethnic minority communities in Medway. The group we met with specifically represented people who had caring responsibilities and specifically caring responsibilities for someone using health services. The group had specific recommendations for GP services as the primary point of service use including:
Providing information to carers in simpler language.
Ensuring GPs talked to carers about support resources rather than relying on brochures in the waiting room.
More focus on the carers health and well-being as well as the person they are caring for.
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Other feedback and discussion during this meeting focussed specifically on waiting times to access service and being kept informed of progress while their family member was receiving care. Additionally there was concern raised by families where treatment requests were not taken into account and no interpreter service was available. A number of participants confirmed that generally carers will not complain as they are concerned that raising issues will further impact the quality of care provided for their family member. Churches Together in Medway Churches Together in Medway is an umbrella body for street pastors and other projects. They represent approximately 60-70 Christian churches plus a variety of affiliated organisations. Each local church has its own priorities based on the local demography and issues and includes support to the elderly, youth services, ethnic diversity, poverty and deprivation. Their key feedback and recommendations were: Age and healthcare access: Older people are less likely to access health services early enough as they “don’t want to bother the GP”. The MedOCC service was recommended as a useful model, however due to the location meant that travel support was necessary to access it. There was also feedback that older people had limited knowledge of services that they could access and some further community education in relation to assessment for services is needed, as there continues to be concern in the older population about formal assessment processes. There was positive feedback in relation to the SOS bus in Rochester on Friday and Saturday nights in relation to supporting people with diminished mental health. There was a strong recommendation that MedwayPCT considers establishing a triage service (e.g. Norwich PCT’s service on the SOS bus). The street pastors often work with people who have a mental health issue and are not aware who to refer this to. Medway Access Support Group and Shout Out Previous consultation with The Medway Access Support Group and Shout Out identified healthcare provider attitude as the single biggest barrier for disabled people accessing services through NHS Medway. They also continued to raise issues of access with some services still needing to address additional physical access issues, specifically heavy doors, lack of ramps and lifts and high contrast colours. Just as importantly, they felt there were still services where communication issues, such as hearing induction loops and use of symbols, could be improved. Medway Access Support Group and Shout Out identified a number of recommended areas for action:
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A more standardised and shared assessment of service user’s access requirements when they initially use a service which was well documented and where appropriate shared with other healthcare providers.
A focus on staff development to ensure all staff are skilled in considering and responding appropriately to disabled service users.
Age Concern Two groups of older service users were consulted in relation to their experience with accessing service and for the most part their feedback related to four key areas of concern: The financial implication of accessing and using health services: This ranged from issues of car park charges, travel to healthcare services and phone bill charges due to lengthy wait times when they call services. Access to services: Reduction in pharmacy delivery services, access to procedures declined and perception that these are age related, not have funding available in care packages to access services. Communication: Issues in relation to cancelled appointments or clinics without notification, occasional communication difficulties due to cultural and language barriers of both the service user and service provider. Human Rights and Dignity: Participants shared a number of examples where they felt that they were not treated with appropriate levels of dignity e.g. being sent home from hospital in pyjamas when clothes were not available. Although some of these issues were general service level issues the participants expressed concerns about the greater impact that such service failures have on older people. Health and Homelessness: Pier Road Projects This meeting was held with a group of service users who had been or were currently homeless and using the support services available through the Pier Road Projects. The key issues that they raised for consideration: Communication about Service Access: Due to the nature of their living situation homeless people are clearly at higher health risk than many people in the community. A key concern raised by the group is that when someone becomes homeless it is very difficult for them to find out what if any mechanism exists for them to access health services other than the A&E departments. No one at the meeting understood how they could access primary healthcare. Access to GP services, dental services and so on all require a permanent address therefore homeless people experience a direct barrier to accessing primary healthcare.
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This results in them not attending to minor complaints which can progress into more serious conditions. Human Rights and Dignity: There was a clear sense from this group that their homeless status had a direct impact on the way that they were treated by service providers and in particular when they attempted to access services to address a mental health issue. They communicated that there is a common perception that a homeless person who tries to access mental health support is actually attempting to access drugs and is treated as such. The group contributed a number of useful suggestions which included:
Access to primary healthcare services through the charities and hostel services that they already access would be a useful mechanism to accessing care in a more timely and useful manner e.g. a healthcare visitor programme as an outreach service.
Placing health promotion information in places that homeless people are more likely to see it such as public toilets or bus stops.
Medway Ethnic Minority Forum Medway Ethnic Minority Forum was formed in 2001 and a meeting took place with one of the key founders. The Forum is an umbrella organisation for local BAME community groups and its current membership consist of 26 groups. The key issue raised for consideration:
Diabetes is a key health issue for BAME communities and the need to improve the various pathways and analysis rates
First Steps Drop in Centre The Centre is funded by a local Quaker Church and provides a local meeting point for predominately homeless and low income men. It provides breakfast and lunch on a Tuesday and Thursday to between 50 to 60 people. A meeting took place with about 20 of the users who commented as follows:
Needs to be an increase in the number of clinics catering for people with alcohol related illnesses
The waiting times for CAT scans need to be reduced
During the second round of consultation we invited 175 community groups and key stakeholders to comment about our priorities in the Scheme. The community groups and key stakeholders we consulted are contained in a separate document and can be found on the Internet. We also engaged with staff of Medway PCT, local councils, primary care trusts in the South East and also consulted with Stonewall and The Gender Trust. We received a 21% (36 responses) response rate on feedback. The priorities they
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identified were nearly all signalled in the first round of consultation. Additional issues flagged up at this stage were:
Interpreting services for BAME mental health service users.
Reaching out to those with no ‘voice’.
Appointing people from under-represented communities to NHS posts.
Groups were also asked the following questions: 1 Is our Scheme easy to understand? 2 Do you think we have covered your priorities adequately? 3 Do you agree with the key actions outlined in the Action Plan? The answers to these questions were almost all positive. They were also asked if it was clear who was accountable for actions in the Scheme, and about half said no. The Action Plan in the final version gives the accountable Lead Director. We asked if there was more we could do to eliminate discrimination, and responses included:
Constant awareness of change.
People are afraid to complain.
Staff need more training.
Staff should listen better to user groups.
People offered the following ideas about what more we could do to involve people in our work:
Go to venues that people already use (e.g. bingo halls).
Locate groups and go to listen to them in their context.
Head hunt knowledgeable people.
Make sure there is representation from all communities.
Ideas about promoting positive attitudes towards disabled people included:
Basic training for staff.
Anti-stigma training and materials.
Education.
Promote active community groups.
Build the confidence of disabled people in approaching the NHS.
Rapid Engagement Event On 25 May 2010 we hosted an engagement event where we invited 30 members of the community to comment further on the recommended actions in the Single Equality Scheme. A total of 21 people attended the event (70%) to provide their invaluable
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input. They were asked to prioritise their main concerns and these have been summarised below.
Issues identified as Priority 1 Communication with people – those with learning disabilities. Mental health needs and autism often feel they are unheard/misunderstood. GP appointments being easily accessible. Involve all groups in what the organisation does. Genuine willingness to implement equality and diversity. Importance of networking between organisations. To develop a better and working mechanisms for engaging minority groups and monitoring the career progression of BAME. Consider use of Language Line or similar at triage, A&E and on the wards. Availability of information. Continued involvement. Communication is vital. Language barriers – staff to make sure that all users understand what they are being told. Easier links to all services. To really LISTEN to participants. Better understanding of PCT and NHS. Availability of information. Issues identified as priority 2 NHS Medway works with the voluntary sector to improve the service they provide. Language barriers addressed so that staff and patients can understand each other. Take into consideration diversity in commissioning and recruiting providers. Develop appropriate monitoring to ascertain service use. Value of voluntary organisations and recognition of their contributions. Give training to NHS staff in understanding how to communicate effectively with service users generally. Training of staff across the board. Training Specialist information for specialist groups. Mentoring. Accountability. Ethnic groups – ideas on how people can reach all services (inc. voluntary groups). Disability access to healthcare i.e. nearby parking for walking disabled. Mental health services – why are they being closed? To support voluntary organisations financially. That the NHS work with the voluntary sector to improve the service they provide.
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Issues identified as Priority 3 Provide training for all. Helping NHS staff be able to communicate/understand patients. Hopefully leading to higher usage. Patients stay in hospital is a pleasant experience and they get the care and respect they deserve. After care support and care for mental health patients. Focus group developed and supported to review and refresh the Single Equality Scheme. Being able to convince me that the PCT will be able to act on the recommendations. More communication with charity groups. Appointments with GPs made easier. Training. Relevance to the community. Ethnic surveys – should remain a matter of choice to each individual. Training – including from services purchased. Positive follow-ups.
How have we addressed this feedback? Many of the issues raised during the engagement and consultation period reinforced our views of what should be and had been included in the Single Equality Scheme, and this was very encouraging. The input from various groups we engaged with has directly influenced the priorities and Action Plans included in the Single Equality Scheme in a number of ways:
The identification of key areas of attention of the Equality Impact Assessment programme, for example feedback from the Medway Ethnic Minority Forum confirmed the need to conduct an EIA on Did Not Attend (DNAs) in relation to minority ethnic communities.
Feedback from the Medway Access Forum further highlighted the need to have a rigorous analysis of access issues in service development which is also highlighted in the Action Plan.
Other issues have been given a higher priority in the final draft of this Scheme or in the Action Plans, for instance
Mental health.
Interpreting services for BAME mental health service users.
Physical access to premises, and related issues such as car parking.
Much of the feedback through the engagement phase has been in relation to specific service issues, e.g. wait times for CAT scans, cost of parking at hospitals. Some of these issues are captured under headings in the Action Plans.
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We completely acknowledge that for members of the community service access is their priority and in this Single Equality Scheme have endeavoured to further develop the structures that will ensure that our community can access the best services possible. Our priority in the Single Equality Scheme at this stage is ensure a rigorous process within our organisation to effectively identify needs and ensure service delivery is conducted in a way that respects difference and individual dignity. In commissioning we are improving our Equality Impact Assessment process to ensure services are designed and delivered in a way that addresses the needs of all community members and will include specific consideration of the needs of carers and homeless people in addition to the core protected groups already identified. We will continue to ensure our staff have effective induction and training in relation to the kinds of behaviours we consider appropriate in service provision and our financial mechanisms which will include levels of customer satisfaction we hope will go some way to addressing these issues. Some of the larger legal and regulatory changes will also have an impact on issues in relation to potential age discrimination. Both the passing of the Equality Act and the move to personalised budgets, will have an impact on all of our decisions in relation to service planning and delivery which we will continue to improve.
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Appendix 3: The Medway PCT Single Equality Scheme Relationship with the CQC Regulation Framework Where in the Scheme this is addressed
Key Area
Outcome
Involvement and information
Respecting and involving people who use services
Theme 1 Commissioning, contracting and procurement Theme 2: Patient experience
Consent to care and treatment
Theme 2: Patient experience
Care and welfare of people who use services
Theme 2: Patient experience
Cooperating with other providers
Theme 1; Commissioning, contracting and procurement
Personalised care treatment and support
Safeguarding and safety Safeguarding people who use services from abuse
Suitability of staffing
Theme 2: Patient experience Theme 3: Workforce
Safety and suitability of premises
Theme 1: Commissioning, contracting and procurement
Requirements relating to workers
Theme 3: Workforce
Staffing
Theme 3: Workforce
Supporting workers
Theme 3: Workforce
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Quality of management
Suitability of management
Statement of purpose
Enabling theme Leadership and governance
Assessing and monitoring the quality of service provision
Enabling theme: Building the evidence
Complaints
Theme 2: Building the evidence
Requirements where the service provider is an individual or partnership
Theme 1: Commissioning, contracting and procurement Enabling theme: Leadership and governance
Requirements where the service provider is a body other than a partnership
Theme 1: Commissioning, contracting and procurement Enabling theme: Leadership and governance
This table will be refreshed and updated when the new regulatory framework comes into practice.
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Appendix 4: Acknowledgements We take this opportunity of acknowledging our gratitude to the staff of Medway PCT, Age Concern Chatham, Churches together in Medway, First Steps Drop-in Centre, Health Action Charity Organisation, K Ying Chinese Elderly Association, Medway Access Group, Medway Ethnic Minority Forum, Medway Ethnic Minority Carers Forum, Shout Out, Health and Homelessness: Pier Road Projects, Alzheimer's and Dementia Family Support, Medway Pensioners' Forum, St Nicholas Day Care Centre, Welcome Day Centre (EMSCA), Arthritis Care (Chatham & District Branch), Fibromyalgia Support Group, Motor Neurone Disease Association, Depression - Anxiety Self Help, Kent Multicultural Community Association, Macmillan Cancer Support, Medway Asthma Self Help The Stroke Association, Sure Start – All Saints Children’s Centre, All Saints Community Project, Cerebal Palsy Care, Stonewall and The Gender Trust in writing this Single Equality Scheme.
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NHS Medway Fifty Pembroke Court North Road Chatham Maritime Chatham Kent ME4 4EL
Share your opinion and help us make services better for you. email: itsyournhsmedway@nhs.net phone: 01634 335173
01634 335020
Patient Advice and Liaison Service (PALS) PALS is here to help when you need health advice, have concerns or don’t know where to turn. email: pals@medwaypct.nhs.uk freephone: 0800 014 1634 Customer Care Listening and acting on your comments, compliments or complaints. email: nhsmedwaycomplaints@nhs.net freephone: 0800 014 1634
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