The Clinical Commissioning Groups have published the final consultation document (with only tiny changes from the draft), and the final consultation survey, which has far fewer questions than the draft consultation questionnaire.
So all criticisms from Councillors, campaigners and members of the public still apply, as aired at two Joint Health Scrutiny Committee meetings on the consultation, in January and February.
Changes to consultation document from the draft version
On p 2, the Contents page, they’ve added “Proposed” in front of all the “new arrangements” headings.
There are many similar small changes: such as on page 7, they’ve changed “Why do we need to change?” to “Why we are proposing changes”. And at times they’ve used “would” rather than “will”
They’ve added a Glossary. Some of the definitions are a bit questionable, eg the Vanguard definition.
1. On p 5 – the Foreword, they’ve added:
“We need to understand the views of all patients, public, stakeholders and staff who live and work in Calderdale, Greater Huddersfield and others who for whom the proposed changes may have a direct impact (which may include patients, public and stakeholders in surrounding areas) about the wayin which Emergency and Acute Care, Urgent Care, Maternity Care, Paediatric Care, Planned Care and Community Health Services are provided in the future.
This is so that by the end of September 2016 both CCGs can make an informed decision on progressing the future shape of hospital services ensuring that these are high quality, safe, sustainable and affordable and result in the best possible outcome and experience for patients, as well as on which services should be provided in the community, closer to where people live.
These proposed changes would secure the future of health services for both areas for the next 20 years. They would make sure that our hospital services were in line with national recommendations and guidance. They would also mean that more services were provided in the community, including some outpatient clinics, so that people only needed to go to hospital when they really had to be there.”
Of course we know that there is no certainty that the hospital services would be high quality – the Clinical Senate’s review of the proposals said it couldn’t tell if the new clinical model would deliver the required standard of care. The Joint Health Scrutiny Committee asked the Clinical Commissioning Groups to make sure the Consultation Document addresses this Clinical Senate assessment – but it says nothing about it.
We also know it isn’t true that the proposed changes would secure the future of health services for both areas for the next 20 years.
The hospital Trust’s clinical revenue is set to fall over the next 5 years, the hospitals Trust Finance Director told the Joint Health Scrutiny Committee on 9 March, because the hospitals will be smaller, which means fewer patients, which means less income for the Trust.
This implies that the hospital Trust will no longer be providing community services, because if they were, they would earn clinical income for treating patients in the community.
Monitor, the hospitals regulator, told the Joint Health Scrutiny Committee on 9 March that even if all the proposed cost cutting measures were carried out by 2020, the hospitals Trust would still be in deficit by £9.5m/year.
At the Joint Health Scrutiny Committee Meeting on 9 March, Monitor said that
“Running a £9.5m deficit/year that can’t be funded by the Trust or the Clinical Commissioning Group, that’s not a sustainable position.”
And that at the end of the 5 year period of the proposed hospital cuts and changes, the hospitals Trust will:
“obviously be unsustainable in the longer term unless the government changes its funding policy.”
The Monitor rep continued,
“We’re heading into an unprecedented phase of the NHS, with many Trusts going into deficit this year. We’re looking at wider footprints now than individual Trusts.”
This is code for the fact that, as Monitor told the Hospital Finance Managers Conference last year, Trusts in deficit will be taken over by hospital chains. This has been confirmed by Simon Stevens, the privatising Chief Executive of NHS England. The Financial Times has reported that hospital takeovers represent the best investment opportunity for private healthcare companies.
Simon Stevens is now making all clinical commissioning groups produce a sustainability and transformation plan which will feed into a regional and whole country plan for the NHS, as part of its privatising, cost-cutting 5 Year Forward View. So another huge, cost cutting, privatising NHS redisorganisation is in imminent.
The Joint Health Scrutiny Committee asked for the Consultation Document to address the Clinical Senate’s statement that they couldn’t tell if the proposed hospital services clinical model and the care closer to home specifications would deliver the required standard of care. It doesn’t.
2. On p 12 , section 6 The alternatives we considered, they’ve added a bit more info:
“The total funding required, including the funding to develop CRH as the Emergency Centre would be £470m, compared to £501m if we were to develop HRI to be the Emergency Centre. These figures (£470m and £501m) include £179m that is needed to support the hospital deficit position. In the five years following the changes, if CRH were chosen as the Emergency Centre the cumulative deficit at Calderdale and Huddersfield NHS Foundation Trust would increase by £47.5m, if HRI were chosen the cumulative deficit would increase by £108m.”
They haven’t explained that Monitor has, with “some caveat” put in an application to the Department of Health for “extraordinary funding of £470m for a single Trust reconfiguration” – extraordinary in that it compares with £300m that it cost for a Northern Trust to build a whole new hospital.
Monitor told the Joint Health Scrutiny Committee on 9 March that the Department of Health is liaising with the Treasury and that there is no indication of the time frame “or what they’ll stomach”.
Monitor are working with the hospitals Trust to review in detail the work that Ernst and Young did to come up with the cost of the “reconfiguration”. This is to reassure themselves and the Treasury that all that money is needed and will increase quality and safety.
The hospital Trusts Finance Director said that if they can’t get the capital to rebuild the hospitals, the proposed changes can’t happen and the big current deficit will be ongoing.
Dr Brook, the Chair of Calderdale Clinical Commissioning Group Governing Body, told the Joint Health Scrutiny Committee on 9 March no one will fund it without the consultation results.
So the consultation is the hoop the Clinical Commissioning Groups and Hospital Trusts have to jump through to have a chance of getting £470m – although Monitor doesn’t seem to think this is such a good an idea.
3. On Page 19 there is more info about car parking.
4. On P 20, in the section What would be the impact of our proposed changes? they have taken out “There would be no A&E in Huddersfield” and replaced the the rest of that paragraph with:
“Both current A&E departments would be replaced by Urgent Care Centres for those people who make their own way to hospital, but there would be no facilities for emergency admission at the new hospital on the Acre Mills site at Huddersfield.”
On Page 20, in the section Impact of travelling further, they have added this para:
“The impact of additional ambulance journeys would be taken into account during contracting discussions with the ambulance service.”
And this sentence:
“We recognise the need to improve car parking and have taken into account the costs of providing multi-storey car parks on both sites. Clearly this would need further discussion with the planning authorities.”
5. Page 26, section 10 on proposed planned care arrangements
“Patients requiring complex planned surgery, who may need intensive care afterwards, would have their operations at CRH.”
6. On page 30, Section 11 Strengthening maternity services in the community, there is an additional sentence:
“The midwifery-led units would remain as they are on both sites.”
7. On page 35, Section 13 Strengthening community services – what this means for patients, there is new info:
“Mobilisation of Phase 1 of Huddersfield Care Closer to Home services started in October 2015 and includes a range of general community services as set out below. Improvements have already been made and more are expected.
Long term conditions – Respiratory services for adults, with chronic problems. Cardio vascular disease, including services for people with heart failure, angina and atrial fibrillation. Diabetes services, including specialist nursing and supported self-management programmes to support and prevent people with diabetes becoming unwell.
Musculoskeletal – planned orthopaedic care, rheumatology, physiotherapy.
Dermatology – provision of specialist/acute services.
Older people’s mental health – services include the dementia diagnosis service and community mental health teams.
Other services – introduction of a single point of contact into community services – integrated with the local authorities’ ‘Gateway to Care’, end of life care, specialist nursing and some therapy services.
Phase 2 would include the re procurement of some additional existing community based services including:
Pain management service.
Ophthalmology – vision screening, community based optometry, cataract assessment and follow-up, ocular hypertension (OHT) follow-up.”
8. On p 36 they have added Diagnostics – radiology and pathology as a Huddersfield hospital service that they are looking at moving out of hospital into GP surgeries and health centres.
9. On p 40 in the section on Consideration of travel, transport and parking issues, they have added:
“A supplementary report is also available (www. rightcaretimeplace.co.uk) which examines journey times in the event of changes being made to emergency services at Dewsbury District Hospital.”
In the event! Dewsbury District Hospital A&E is being downgraded to an urgent care centre in September 2016.
They have also added, “such as Kirkburton, Shelley, Shepley, Denby Dale, Skelmanthorpe and Scissett”: after “ Several areas including the south of Huddersfield…”
10. On p 40 in Section 15 Next steps and decision making after the consultation, they’ve added:
“Calderdale and Kirklees Councils have set up a Joint Scrutiny Committee to consider these proposed changes. The Joint Committee will take a view on the consultation process. Legislation also allows the Joint Committee to make recommendations on the proposed changes to the CCGs, which it may choose to do after it has examined these in detail.”
“As indicated elsewhere in this document we would need to seek funding from HM Treasury to enable the proposed changes to the hospitals to take place. There would also need to be discussions with the ambulance service to take into account the impact of increased journeys. If we gained all of the necessary approvals, implementation could begin quickly but would take up to five years to complete.”
11. On p 41, Section 16 How you can make your views known, they’ve added:
“A copy of the consultation survey is attached to this document or can be completed on line (see opposite).”
The consultation survey isn’t attached to this document anywhere I can see.