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Transcript
Consultation Response
A consultation on strengthening the NHS
Constitution (Department of Health)
28th January 2013
About us
Action on Hearing Loss is the new name for RNID. We're the charity
working for a world where hearing loss doesn't limit or label people,
where tinnitus is silenced – and where people value and look after their
hearing.
Our response focuses on key issues that relate to people with hearing
loss. Throughout this response we use the term 'people with hearing
loss' to refer to people with all levels of hearing loss and tinnitus,
including people who are profoundly deaf. We are happy for the details
of this response to be made public.
Introduction
Action on Hearing Loss welcomes the opportunity to comment on the
consultation on strengthening the NHS Constitution. Hearing loss is a
long term condition affecting over 10 million people in the UK – one in
six of the population. As our population ages this number is set to grow
and, by 2031, there will be more than 14.5 million people with hearing
loss in the UK1.
Contact details
Rachel Calton, Health and Policy Officer
Email: [email protected]
1
Action on Hearing Loss: ’Hearing Matters’ 2011
1
Summary
In the proposals for changes to the NHS Constitution we welcome the
commitments to equal access to services and improved public health
and wellbeing. We hope these will work in the interests of people with
hearing loss through increased communication support and equipment
where it is needed to access services and more proactive support for
people with undiagnosed hearing loss.
In summary, we support:
 Shared-decision making and that patients own and manage their
health.
 NHS organisations should welcome and act on feedback.
 It should be the role of all healthcare workers in the NHS to make
use of every contact with a patient, with the aim of improving the
public’s health and wellbeing and reducing health inequalities.
 Care should be coordinated and tailored around the needs and
preferences of patients, particularly in the interests of those with
long-term conditions.
 Staff working “towards providing fair and equitable services for
all… and helping to reduce inequalities in experience, access or
outcomes of differing groups or sections of society” to make clear
that services should be tailored to the needs of individuals, in the
way they access services and receive treatment.
 The proposed additions to principle 1 to accentuate that mental
health must be considered on a par with physical health.
 Staff aiming for dignity, respect and compassion.
 Local authorities taking account of the Constitution when
performing public health duties.
 The Constitution empowering patients.
We are calling for:
 Communication and inclusion standards running through all NHS
services, to ensure that patient communication needs are
consistently identified, recorded and met.
 Feedback processes that are accessible to people with hearing
loss, and on-going uptake of our Locate and Rate feedback tool.
 Healthcare workers in the NHS to encourage early diagnosis of
hearing loss through timely referrals and integrating hearing
2






checks into routine health assessments – particularly those
targeting older people.
Healthcare workers being aware of equipment available to support
communication and how to access it e.g. listeners
NICE quality standards around hearing loss that link public health,
clinical and social needs, and electronic patient records that
capture patient communication support needs.
An over-arching goal of NHS commissioning to make services
inclusive and accessible to the population as a whole, including
those with particular communication needs.
Staff training in deaf awareness and communication to appreciate,
understand and respond to communication barriers in a
compassionate manner.
Further details and guarantees as to how, structurally, the
Constitution will be implemented by Local Authorities when they
are performing public health functions.
The NHS Constitution to be made accessible to those who use
BSL as their first language.
Q1. What are your views on the proposed changes to strengthen
patient involvement in the NHS Constitution?
We support the emphasis on shared-decision making and the proposal
that the Constitution should reflect that patients own and manage their
health.
The age profile of people receiving NHS care means that they are likely
to have age-related hearing loss; over half (55%) of people over 60 and
90% of people over 81 have hearing loss.
Hearing loss often may not be obvious. Some people with hearing loss
may lip-read, others may wear hearing aids or have a cochlear implant,
and others may use sign language.
For patients to be at the heart of decision making, to exercise choice,
and to express their interests, communication and inclusion standards
must run through all NHS services, to ensure that patient communication
needs are consistently identified, recorded and met. Deaf awareness
and communication training amongst all staff is crucial to this. We would
support electronic patient held records/information.
3
Q2. What do you think about our proposal to set out in the NHS
Constitution the importance of patient and staff feedback towards
improving NHS services?
We welcome the proposal to clarify that NHS organisations should
welcome and act on feedback. All NHS organisations should champion
feedback processes and ensure they are inclusive.
In particular NHS organisations should take active steps to involve deaf
and hard of hearing people, and patients groups and representatives in
the development of giving good care. They should also ensure that
feedback processes are inclusive to people with hearing loss.
Information provided on how to give feedback should be in an accessible
format (large print, BSL video clips, plain English). A variety of contact
methods such as e-mail, text messaging and text phones for people with
hearing loss wishing to give feedback should be provided, and actively
offered to patients with hearing loss.
Our online Locate and Rate service, launched this year, enables the
public and GPs to locate hearing services throughout the UK and
provides a platform for service users to review hearing services, based
on what is important to them.
It currently asks patients to rate a service according to factors such as
ease of access, clarity about tests and results, on-going support and,
finally, whether the patient would recommend the service to a friend.
We hope the rating tool will help to encourage the feedback process,
support patient choice and improve hearing services’ patient focus.
Q4. What are your views on including in the NHS Constitution a
new responsibility for staff to make ‘every contact count’ with the
aim of improving health and wellbeing of patients?
We welcome the proposal to include in the constitution that it should be
the role of all healthcare workers in the NHS to make the most of every
patient contact, with the aim of improving the public’s health and
wellbeing and reducing health inequalities, especially in a society that is
getting older and developing more complex needs.
4
In order to make every contact count, effective communication is
essential. Our recent research report ‘Access All Areas’ shows that
currently GPs do not always face the patient, speak clearly or check that
the patient has understood what has been said, in many cases leaving
patients unclear about diagnosis and medical advice2.
Currently, diagnosis of hearing loss is ad hoc and can take on average
10 years3, in which time people can become isolated from the work
place and from friends and family networks. This delay can also
exacerbate other health conditions. Evidence suggests that GPs fail to
refer up to 45% of people reporting hearing loss, for an intervention such
as a referral for a hearing test or hearing aids4.
Effective diagnosis and management of hearing loss is important in
supporting the independence and wellbeing of patients with hearing loss.
We would like to see healthcare workers in the NHS using contact with
patients to encourage early diagnosis of hearing loss through timely
referrals and integrating hearing checks into routine health assessments
– particularly those targeting older people.
Q5. Do the proposed changes to the NHS Constitution make it
sufficiently clear to patients, their families and carers how the NHS
supports them through care that is coordinated and tailored around
their needs and preferences?
We support the change to the NHS Constitution that care should be
coordinated and tailored around the needs and preferences of patients,
particularly in the interests of those with long-term conditions.
Person-centred integrated care is crucial to joining up the health and
social care sectors. Currently hearing aid wearers are not benefitting
from joined up health and social care; four out of five (79%)5 when fitted
with a hearing aid, receive no information about other services,
equipment or assistive technology, which can help to maximise
independence and wellbeing.
2
Action on Hearing Loss: ‘Access all areas?’ 2013
Davis, A. et al: ‘Acceptability, benefit and costs of early screening for hearing disability: a study of potential
screening tests and models’ (Health Technology Assessment 2007; Vol. II: No. 42)
4
Ibid.
5
RNID: ‘Annual Survey Report 2008’ p3
3
5
We welcome the announcement of NICE quality standards around
hearing loss. These should link public health, clinical and social needs,
and be delivered in a timely manner. We are calling for electronic patient
records to properly capture patient communication support needs.
We also call for:
 Health and Wellbeing Boards, Local Health and Wellbeing
Strategies to promote coordinated care for people with hearing
loss
 The NHS Commissioning Board and CCGs to actively disseminate
good practice around coordinated care for people with hearing loss
 Hearing service providers to demonstrate and meet a commitment
to service integration.
 All staff in NHS providers, irrespective of setting (i.e. primary
care/secondary care, tertiary care, intermediate care & long term
care) to be able to identify hearing loss through integrating hearing
checks within assessments; communicating effectively with
patients with a hearing loss and referring patients to appropriate
services and equipment to support them.
Q8. Do the proposed changes to the NHS Constitution make clear
how the NHS will safeguard and use patient data?
We support the Association of Medical Research Charities (AMRC)
position, in supporting the proposed changes (Section 2a). Improved
access to patient data for researchers is vitally important for translational
hearing research in order to further the understanding of the efficacy of
existing therapies and patient needs. Greater awareness and increased
provision of opportunities for patients to participate in research will be
critical in enabling the translation of recent scientific advances into new
treatments for hearing loss and tinnitus.
Q9. Do you agree with the proposed changes to the wording of the
staff duties and the aims surrounding the rights and
responsibilities of staff? What do you think about the changes to
make clear to staff around what they can expect from the NHS to
ensure a positive working environment?
6
We welcome the proposition that there should be a new responsibility
whereby staff work “towards providing fair and equitable services for
all… and helping to reduce inequalities in experience, access or
outcomes of differing groups or sections of society…” to make clear that
services should be tailored to the needs of individuals, in the way they
access services and receive treatment.
We believe an over-arching goal of NHS commissioning should be to
make services inclusive and accessible to the population as a whole,
including those with particular communication needs.
Evidence from our 2011 Annual Survey found that 44% of respondents
felt that they had experienced difficulty relating to hearing loss when
visiting their GP surgery. Our recent research report, ‘Access All Areas’
shows that barriers can include contacting and visiting the GP surgery
and being left unclear about a diagnosis or health advice after a GP
consultation because of poor deaf awareness6.
The research shows that poor access to health services for people with
hearing loss causes health inequalities in terms of access to, and
outcomes from NHS services.
Our recommendations include: deaf awareness and communication
training for all staff; a range of ways for patients to contact their GP
surgery; the use of technologies such as loops systems and visual
display systems; patient records that clearly indicate a person’s
communication support needs and policies and procedures in place for
booking communication support.
In order to reduce inequalities and ensure that equal health outcomes
are achieved, a focus on hearing loss is needed, to help encourage
measures such as integrated r care records, the use of qualified
interpreters in healthcare settings and deaf awareness amongst staff,
that could help to remove barriers and create equal access to healthcare
for people with hearing loss.
Q10. Do you agree with the wording used to emphasise the parity of
mental and physical health? Are there any further changes that you
6
Action on Hearing Loss: ‘Access all areas?’ 2013
7
think should be made that are feasible to include in the NHS
Constitution?
We welcome the proposed additions to principle 1 to accentuate that
mental health must be considered on a par with physical health.
Hearing loss often compounds barriers to inclusion and feelings of
isolation. It can cause anxiety and depression and exacerbate other
conditions, including dementia. In turn, effective diagnosis and
management of hearing loss can work to minimise these impacts on
peoples’ mental health.
Q11. What are your views on the wording used to highlight the
importance of ensuring that the tenets of dignity, respect and
compassion are sufficiently represented in the NHS Constitution?
We welcome the new wording in the values section of the Constitution
and the incorporation of dignity, respect and compassion into the aims
for staff.
Knowledge and understanding of a person’s hearing loss is key to staff
being able to demonstrate underlying compassionate values. Staff need
training in deaf awareness to appreciate, understand and respond to
communication barriers in a compassionate manner.
People with hearing loss rely on the communication skills and patience
of staff, and the forethought of those managing services, in order to have
a safe and welcoming hospital experience.
Deterioration in performance around dignity, for example shouting
unnecessarily at patients who cannot hear, ignoring the need for
communication support for a BSL user or failure to identify and support
patients who use hearing aids may signal a lack of staff deaf awareness
and should be addressed immediately.
Q13. Do the proposed changes to the NHS Constitution make it
clear what patients, staff and the public can expect from local
authorities and that local authorities must take account of the
Constitution in their decisions and actions?
8
Under the new health reforms Local Authorities will be performing
important public health functions.
Hearing loss is a widespread public health issue that demands urgent
action. It can impact on health, wellbeing and employment. Noise
induced hearing loss is preventable, and, on average, there is a 10-year
delay in people seeking help with their hearing loss.
We welcome the technical amendments in the new Constitution to make
clear that to local authorities that the Constitution applies to them.
However we seek further details and guarantees as to how, structurally,
the Constitution will be implemented by Local Authorities when they are
performing public health functions, especially in terms of letting patients,
staff and the public know what to expect.
Q17. How can we ensure the NHS Constitution is accessible and
useable to individuals from different backgrounds and to different
sections of society?
As the Constitution is designed to empower patients, alert them to what
they should expect to receive, and strengthen patients’ rights in relation
to involvement in their health and care, we hope it will be made available
in a range of formats, so it can be used by those who use BSL as their
first language.
We also welcome that the Constitution recognises that NHS services
should be tailored to the needs of individuals, in the way they access
services and receive treatment.
We believe an over-arching goal of NHS commissioning should be to
make services inclusive and accessible to the population as a whole,
including those with particular communication needs.
Evidence from our 2011 Annual Survey found that 44% of respondents
felt that they had experienced difficulty relating to hearing loss when
visiting their GP surgery. Our recent research report ‘Access All Areas’
shows that barriers can include contacting and visiting the GP surgery
and being left unclear about a diagnosis or health advice after a GP
consultation because of poor deaf awareness. The research shows that
poor access to health services for people with hearing loss causes
9
health inequalities in terms of access to, and outcomes from NHS
services.
In order to reduce inequalities and ensure that equal health outcomes
are achieved, a focus on hearing loss is needed, to help encourage
measures such as integrated records of care, the use of qualified
interpreters in healthcare settings and deaf awareness amongst staff,
that could help to remove barriers and create equal access to healthcare
for people with hearing loss.
10