CPOL75 Accessible Infomation Standards Policy by Provide Community

Accessible Information Policy

Version: V1

Ratified by:

Quality Reference Group

Date ratified: 28/01/2025

Job Title of author:

Reviewed by Committee or Expert Group

Equality Impact Assessed by:

1. Introduction

The NHS Accessible Information Standard (AIS) sets out in detail responsibilities and standards that NHS organisations must meet in taking forward a consistent approach to identifying, recording, flagging, sharing, and meeting the information and communication support needs of service users and carers and with a disability, impairment, or sensory loss.

It is a fundamental principle that we must ensure that we provide equal access and experience for all users and potential users of our services, but this is also a legal duty:

• The Equality Act 2010 requires all organisations to make reasonable adjustments for disabled people and requires public organisations to ensure they do not discriminate and promote equality between Disabled people and those who are not disabled. Providing accessible information and communications ensures that this duty is met both in practice and in principle.

• Section 250 of the Health and Social Care Act 2012 is the legal provision by which organisations must comply with information standards, as such the Accessible Information Standard, as such the Accessible Information Standard is also a legal requirement

2. Scope and Purpose

This policy applies to all parts of the Provide Group. The policy sets out the principles of the Accessible Information Standard and provides information to health and care staff about how the standard should be implemented to improve the quality and safety of care received by individuals with information and communication needs, and their ability to be involved in autonomous decision-making about their health, care and wellbeing. It also sets out what we need to do to comply with the standard.

3. Responsibilities

• All health and care staff are expected to be aware of the standard and work to ensure the communication and information needs of service users, patients, carers and parents are clearly recorded and that action is taken to mee these needs.

• All Managers are responsible for raising awareness of this policy within their services and for ensuring that the requirements of the standard are being met in their services.

• The Director of IT and transformation will ensure that the Accessible Information Standard is met in IT procurement, contracting and training on systems across the Provide Group

• The Head of Contracts and Legal Services will ensure that all contractors and subcontractors are aware of their obligations to meet the requirements of the standard

• The Head of Quality and Safety will ensure that the customer engagement team are aware of the standard and can provide expertise and support to services who require communication professionals and interpreters for service users, patients, carers and parents

• The Group Chief Commercial Officer is the designated Accessible Information Standard lead for the Provide Group and is responsible for ensuring that there are systems and processes in place to enable staff to be aware of and fulfil the requirements of the standard and provide advice on this and the Equality Act 2010.

• The Group Chief Executive Officer has overall responsibility for the strategic and operational management of the Provide Group which includes ensuring that this policy & associated documents comply with all legal and statutory requirements.

4. What is the Accessible Information Standard?

The Accessible Information Standard (AIS) aims to make sure that people who have a disability, impairment or sensory loss get information that they can access and understand, and any communication support that they need from health and care services.

The Standard tells organisations how they should make sure that patients and service users, and their carers and parents, can access and understand the information they are given. This includes making sure that people get information in accessible formats.

The Standard also tells organisations how they should make sure that people get support from a communication professional if they need it, and about changing working practices to support effective communication.

By law (section 250 of the Health and Social Care Act 2012), all organisations that provide NHS care or adult social care must follow the Standard. Who does the AIS apply to?

5. Who does the standard apply to?

The AIS applies to all NHS and Social Care organisations. It applies to patients, service users, carers and parents and includes people who:

• Are blind

• Deaf

• Deafblind

• Have a learning disability

It will also support anyone with information or communication needs relating to a disability, Impairment or sensory loss such as people who have difficulty speaking or who may have Mental health conditions affecting their ability to communicate

6. What do we need to do to meet the standard?

The Accessible Information Standard means we have a legal duty to do five things:

1. ASK people whether they have any communication and information needs and find out how to meet their needs.

2. RECORD communication and information needs clearly and in a consistent way.

3. FLAG/ HIGHLIGHT/ ALERT the person’s file or notes so it is clear that they have information or communication needs and how to meet those needs.

4. SHARE communication and information needs when we refer to another team or service.

5. ACT and take steps to ensure that people receive information which they can access and understand, and receive communication support if they need it.

7. What does the Standard include?

The Standard says that patients, service users, carers and parents with a disability, impairment or sensory loss should be able to contact, and be contacted by, services in accessible ways. There are four methods we need to take account of:

• Contact Method e.g. via email or text message.

• Information format so we provide information and correspondence in formats they can read and understand, for example in audio, braille, easy read or large print.

• Communication support e.g. support from a communication professional at appointments if this is needed to support conversation, for example a British Sign Language interpreter.

• Communication professional Get support from health and care staff and organisations to communicate, for example to lip-read or use a hearing aid.

Where information is required in an alternative format e.g. audio, large print, braille or easy read contact the communications team for advice and support so that the information can be organised and provided without delay

Where communication support or a communication professional is required the customer service team can help arrange this.

8. Identifying Needs

Communication needs MUST be identified at registration / upon first contact with the service or as soon as is practicable thereafter.

In addition, communication and / or information needs MUST be identified proactively and opportunistically – the next time an existing patient / service user makes contact with / is seen by the service.

Following identification of the existence of a communication or information need, the specific nature of the support and / or format required MUST be identified.

Patients, service users, carers and parents should be asked to self-define their information and / or communication support needs, and it is these needs (and not their disability) which should be recorded. This ensures that people with communication needs can receive information in a format that they can understand and can receive any additional support they may need.

Some questions which could be used to identify if an individual has any information and / or communication support needs, and the nature of these needs include:

• Do you have any communication needs?

• Do you have difficulty hearing, or need hearing aids, or need to lip-read what people say?

• Do you have difficulty with memory or ability to concentrate, learn or understand?

• Do you have difficulty speaking or using language to communicate or make your needs known

• How would you like us to communicate with you?

• Can you explain what support would be helpful?

• How do you prefer to be contacted?

• What is the best way to send you information?

• Do you need a format other than standard print?

Many people with a learning disability (and some people with other communication needs), have a ‘communication passport’ ‘communication book’ or ‘hospital passport’ or similar document which includes a detailed record of their communication needs and preferences – this can be a very useful source of information and advice where available

9. Recording and Flagging Needs

Communication /information needs MUST be clearly recorded in the service user record in a way that enables health and care staff to easily view them and should be highly visible to the health and care staff delivering care to the individual

The communication or information need MUST be recorded

On the front cover of paper records or files and be highlighted in a way to draw attention to the information as being of particular importance, for example in a larger or bold font, and / or a different colour.

On the front page of an electronic record as an alert or flag visible on the ‘front page’ of the electronic record so it is visible when the record is accessed

Across the Provide Group all health and care staff are responsible for ensuring that information needs are clearly recorded and flagged routinely as business as usual to ensure individual needs can be effectively met.

Once data is recorded about individuals’ information or communication support

needs, staff must ensure that, such data is regularly reviewed and if necessary updated.

10. Sharing of Needs

Having first obtained the relevant consent information about individuals’ information and / or communication support needs should form part of routine of referral, discharge and handover processes to ensure safe and effective continuity of care

Consent to the sharing of personal data should be obtained from the patient / service user wherever possible and clearly recorded If consent to share cannot be obtained, because the individual involved lacks the capacity to make the decision, and nobody has been formally appointed to make it for them, a decision to share information can be made in the patient / service user’s best interests in accordance with the Mental Capacity Act 2005.

11. Tips for clear face-to-face communication

• Make sure you have the person’s attention before trying to communicate with them. If they do not hear you, try waving or tapping them lightly on the shoulder.

• Identify yourself clearly. Say who you are and what you do – it may be more relevant to explain your reason for seeing the person rather than your job title.

• Check that you are in the best position to communicate, usually this will be facing the person, but consider whether seated or standing is more appropriate.

• Communication at eye level is usually easiest so if you are speaking to a wheelchair user consider sitting down if possible.

• Find a suitable place to talk, with good lighting and away from noise and distractions.

• Speak clearly and a little slower than you would do usually, but do not shout.

• Keep your face and lips visible – do not cover your mouth with a hand, your hair or clothing. If a member of staff is concerned about religious expression they should discuss this with their manager.

• Use gestures and facial expressions to support what you are saying.

• If necessary, repeat phrases, re-phrase the sentence or use simpler words or phrases.

• Use plain, direct language and avoid using figures of speech such as ‘it’s raining cats and dogs’ or euphemisms such as ‘expecting the patter of tiny feet’.

• Check if the person has understood what you are saying. Look for visual clues as well as asking if they have understood.

• Encourage people to ask questions or request further information. Ask if they would like anything in writing as a reminder or reference.

• Try different ways of getting your point across. For example, writing things down, drawing or using symbols or objects to support your point.

12. Tips for printed communication

• Use a minimum font size of 12 point, preferably 14 (which is readable by a significantly greater number of people).

• Use a clear, uncluttered and sans serif font such as Arial.

• Align text to the left margin and avoid ‘justifying’ text.

• Ensure plenty of ‘white space’ on documents, especially between sections. Avoid ‘squashing’ text onto a page and, if possible, include a double-space between paragraphs

• Print on matt and not gloss paper.

• Use page numbers.

• If printing double-sided ensure that the paper is of sufficient thickness to avoid text showing through from the other side.

• Correctly format Word documents and PDFs using styles and accessibility functions / checks. Ensure a correct and consistent heading structure, and that the cursor can move throughout all text.

• Use descriptions (‘alt. text’) to explain diagrams or photographs.

• Consider making all ‘standard’ printed letters / documents ‘easier to read’ –using plain English, highlighting important information, and supporting text with diagrams, images or photographs.

• Keep track of the electronic originals of documents you print out so you can reprint in larger font or convert to an alternative format when required.

13. Monitoring

Compliance with the standard will be reviewed annually as part of the annual record keeping audit by reviewing the electronic record systems to identify evidence Flags /Alerts are being recorded and that action has been taken to meet the needs identified.

Complaints and Friends and Family test feedback will be monitored for feedback on communication.

EQUALITY IMPACT ASSESSMENT

TEMPLATE: Stage 1: ‘Screening’

Name of project/policy/strategy (hereafter referred to as “initiative”):

Accessible Information Standard Policy

Provide a brief summary (bullet points) of the aims of the initiative and main activities:

To support staff to know what the requirements of the AI are and how to implement them for the benefit of service users, patients, carers and parents so that they can be communicated with effectively and can take a full and active part in their care

Project/Policy Manager: Director Nursing & Allied Health Professions

Date: January 2025

This stage establishes whether a proposed initiative will have an impact from an equality perspective on any particular group of people or community – i.e. on the grounds of race (incl. religion/faith), gender (incl. sexual orientation), age, disability, or whether it is “equality neutral” (i.e. have no effect either positive or negative). In the case of gender, consider whether men and women are affected differently.

Q1. Who will benefit from this initiative? Is there likely to be a positive impact on specific groups/communities (whether or not they are the intended beneficiaries), and if so, how? Or is it clear at this stage that it will be equality “neutral”? i.e. will have no particular effect on any group.

Implementing the AIS will have a Positive impact on people with sensory deficits or learning disabilities or other heath condition that may impact their ability to communicate

Q2. Is there likely to be an adverse impact on one or more minority/under-represented or community groups as a result of this initiative? If so, who may be affected and why? Or is it clear at this stage that it will be equality “neutral”?

Implementation will be Equality Neutral

Q3. Is the impact of the initiative – whether positive or negative - significant enough to warrant a more detailed assessment (Stage 2 – see guidance)? If not, will there be monitoring and review to assess the impact over a period time? Briefly (bullet points) give reasons for your answer and any steps you are taking to address particular issues, including any consultation with staff or external groups/agencies.

A more detailed assessment is not indicated as will have a positive impact and no negative impact has been identified.

Guidelines: Things to consider

Equality impact assessments at Provide take account of relevant equality legislation and include age, (i.e. young and old,); race and ethnicity, gender, disability, religion and faith, and sexual orientation.

The initiative may have a positive, negative or neutral impact, i.e. have no particular effect on the group/community.

Where a negative (i.e. adverse) impact is identified, it may be appropriate to make a more detailed EIA (see Stage 2), or, as important, take early action to redress this – e.g. by abandoning or modifying the initiative. NB: If the initiative contravenes equality legislation, it must be abandoned or modified.

Where an initiative has a positive impact on groups/community relations, the EIA should make this explicit, to enable the outcomes to be monitored over its lifespan.

Where there is a positive impact on particular groups does this mean there could be an adverse impact on others, and if so can this be justified? - e.g. are there other existing or planned initiatives which redress this?

It may not be possible to provide detailed answers to some of these questions at the start of the initiative. The EIA may identify a lack of relevant data, and that data-gathering is a specific action required to inform the initiative as it develops, and also to form part of a continuing evaluation and review process.

It is envisaged that it will be relatively rare for full impact assessments to be carried out at Provide. Usually, where there are particular problems identified in the screening stage, it is envisaged that the approach will be amended at this stage, and/or setting up a monitoring/evaluation system to review a policy’s impact over time.

EQUALITY IMPACT ASSESSMENT TEMPLATE: Stage 2:

(To be used where the ‘screening phase has identified a substantial problem/concern)

This stage examines the initiative in more detail in order to obtain further information where required about its potential adverse or positive impact from an equality perspective. It will help inform whether any action needs to be taken and may form part of a continuing assessment framework as the initiative develops.

Q1. What data/information is there on the target beneficiary groups/communities? Are any of these groups under- or over-represented? Do they have access to the same resources? What are your sources of data and are there any gaps?

Q2. Is there a potential for this initiative to have a positive impact, such as tackling discrimination, promoting equality of opportunity and good community relations? If yes, how? Which are the main groups it will have an impact on?

Q3. Will the initiative have an adverse impact on any particular group or community/community relations? If yes, in what way? Will the impact be different for different groups – e.g. men and women?

Q4. Has there been consultation/is consultation planned with stakeholders/ beneficiaries/ staff who will be affected by the initiative? Summarise (bullet points) any important issues arising from the consultation.

Q5. Given your answers to the previous questions, how will your plans be revised to reduce/eliminate negative impact or enhance positive impact? Are there specific factors which need to be taken into account?

Q6. How will the initiative continue to be monitored and evaluated, including its impact on particular groups/ improving community relations? Where appropriate, identify any additional data that will be required.

Guidelines: Things to consider

An initiative may have a positive impact on some sectors of the community but leave others excluded or feeling they are excluded. Consideration should be given to how this can be tackled or minimised.

It is important to ensure that relevant groups/communities are identified who should be consulted. This may require taking positive action to engage with those groups who are traditionally less likely to respond to consultations, and could form a specific part of the initiative.

The consultation process should form a meaningful part of the initiative as it develops, and help inform any future action.

If the EIA shows an adverse impact, is this because it contravenes any equality legislation? If so, the initiative must be modified or abandoned. There may be another way to meet the objective(s) of the initiative.

Further information:

Useful Websites www.equalityhumanrights.com Website for new Equality agency www.employers-forum.co.uk – Employers forum on disability www.efa.org.uk – Employers forum on age