CK999’s @RCRTRP consultation survey response says Keep both A&Es open!

Phew! Calderdale & Kirklees 999 Call for the NHS has celebrated the Summer Solstice by sending in our considered, collective response to the Right Care Right Time Right Place hospital and community health services consultation survey. The deadline for sending in survey responses is midnight today but anything with today’s postmark will be accepted.

Have your say survey ck999 response_lores

Our response is downloadable as a pdf here . It comes with an Appendix, here (also downloadable as a pdf). The Appendix  details the 38 Questions we asked the CCGs to answer in order to fix the Consultation Document’s errors and omissions; the CCGs’ responses – which didn’t answer our questions, and our comments on their responses.

The main point our survey response makes is:

We do not agree with the proposed changes to hospital and community health services

Here is a summary of  our reasons

  1. We don’t think that that the Clinical Commissioning Groups HAVE looked at all the alternatives.

We asked for disclosure of all documents related to this, including full planning data, and they failed to provide any.

We think they’ve missed: the views of frontline NHS Staff, including GPs and community health staff. And the views of the public – particularly those who’ve challenged and disagreed with the Clinical Commissioning Groups’ proposals.

We have no confidence in their so-called “pre-consultation engagement” with staff, patients and general public, during the time when they were considering alternative proposals. (See Appendix 1, questions 3, 15, 16, 17, 24, 25, 26, 27)

2. We think they’ve missed the opportunity to listen to and act on what thousands of members of the public were trying to tell them during the long drawn out pre-consultation engagement stage:

  • that we don’t accept their proposals, and
  • we expect them to stand up for the NHS and tell NHS England and the Sec of State for Health that their underfunded plans WON’T WORK, that cuts and privatisation are UNACCEPTABLE and that the 2012 Health and Social Care Act that is dismantling the NHS is TOTALLY UNDEMOCRATIC, as it wasn’t in any political party’s 2010 election manifesto.

They have missed the Royal College of Emergency Medicine’s proposals for A&E Hubs, co-located with A&Es, to divert non-emergency patients out of A&Es and so take the load off them.

3. We think it’s a bit late in the day to be asking what other alternatives the Clinical Commissioning Groups might have considered, and that they’re only asking it to show that they are undertaking the consultation with an open mind i.e. before taking a decision. Because consultations are meant to be done on all available options, at a formative stage.

It is very clear to us that this consultation has not taken place at a formative stage.

They need to consider fresh alternatives by going back and looking at what they missed first time round.

They also need to admit that what they’ve come up with is not a local alternative decided by local clinicians in response to a local problem. What they’ve come up with is a national model imposed on local situations across England.

4. We don’t like the Acute and emergency care proposals for life threatening conditions 

Each town needs its own A&E because of risks of increased patient deaths associated with A&E closure.

These are evidenced in peer reviewed studies that we have sent to the CCGs. They have not provided assurance that they have properly considered these risks.

We don’t trust the projected numbers of patients that will attend the single Emergency Centre

In the light of information from the Royal College of Emergency Medicine, we are worried that they are a considerable underestimate.

We asked the CCGs for the modelling data but did not receive it.

There are inconsistencies in the information they have provided about the data used in this modelling.

The importance of accurate projections and modelling of patient flows is shown by the overcrowding and decline in A&E performance at Ealing and Northwick Park hospitals London, following the closure of Central Middlesex and Hammersmith A&Es in September 2014 as part of an NHS reconfiguration in N.W London.

The Mansfield Commission has put this down to inaccurate projections and modelling for the other surviving full accident and emergency departments after the closure of Central Middlessex Hospital and Hammersmith Hospital A&Es.

They have failed to consult on changes to acute care.

This is a serious flaw in the survey design.

The acute care proposals involve cutting 78 hospital beds and around 900 hospital staff. This comes with serious risks. The CCGs denied this when we asked them about it.

From the available evidence, it seems that the proposal to cut hospital beds and staff is not based on accurate data and evidence.

Staff implications

A single Emergency Centre won’t solve the national problem of recruiting and retaining A&E doctors.

The Royal College of Emergency Medicine position statement on A&E closures says that recruitment and retention of staff is often cited as a relevant factor. But in itself it is a poor justification for service reconfiguration… Longer term patient outcomes will be compromised.

There is no health inequalities assessment

This is despite the fact that the Royal College of Emergency Medicine’s position statement on Emergency Department closure and reconfiguration says that relocating services has a disproportionate effect on poorer and more vulnerable people.

We asked the CCGs about this and were given an unsatisfactory answer (Appendix 1 question 2).

Illusory cost efficiencies

The Royal College of Emergency Medicine position statement on A&E closures says the necessary increased capital and revenue expenditures at the receiving site(s) are seldom properly modelled.

We asked the CCGs about cost efficiencies and the proposals’ value for money. (Appendix 1, Questions 34, 35, 36, 37,38). The CCGs’ answers to our questions were as usual unhelpful. They repeated extracts from the Consultation Document that we had questioned, and avoided answering the questions.

The proposals will cut our hospital services, replace them with underfunded community health services and still end us up with the hospitals Trust having another massive deficit – and who knows what cuts to other parts of the local health system, imposed as a result of the Sustainability and Transformation Plan

Hospital size

The Royal College of Emergency Medicine’s Position Statement on Emergency Department closure demolishes the argument about sufficient size – that the current District General Hospitals each serve too small a population to justify each having an A&E. It points out that:

“Emergency departments in the UK are substantially larger than international comparators – even small UK departments are relatively large in relation to European, American and Australasian departments.”

Lendlease Consulting’s undeclared conflict of interest

The Hospitals Trust employed Lendlease Consulting  to advise on the Estates requirements for the hospital cuts/reconfiguration, to feed into the Ernst & Young (EY) 5 Year Strategic Plan for CHFT.

Lendlease Consulting’s advice reversed the Trust’s earlier decision, that the most cost effective option would be to make HRI the acute/emergency hospital and CRH the smaller planned care hospital.

Lendlease Consulting is part of Lendlease corporation, which is a major shareholder in the CRH PFI consortium/special purpose vehicle. It is clear from Ernst & Young (EY) 5 Year Strategic Plan for CHFT that Lendlease Corporation potentially stands to profit from this decision.

We asked CHFT if they had considered this conflict of interest when they employed Lendlease Consulting. They said no.

Yorkshire Ambulance Service capacity

Yorkshire Ambulance Service don’t know how they’ll cope with 10,000 extra hours/year of ambulance journey time. It would need 10.6 extra FTEs: 5 paramedics and 5 non clinicians plus back up – 5 week roster with 10 staff and back ups and 2 extra ambulances. At the 19.4.2016 JHSC meeting the YAS rep said that he would anticipate that the CCGs would continue a conversation with YAS about how to accommodate the change in service. It hadn’t been quantified in terms of cost – they will do more work on this.

5. We don’t like anything about the proposed change to Urgent Care for non-life threatening conditions
NHS 111 issues

We are not confident that proposals for urgent care patients to rely NHS 111 are safe.

Urgent care centre staffing issues

The Clinical Commissioning Groups are still not clear on urgent care centre staffing. We have learned this from public and Joint Health Scrutiny Committee consultation events. So how can we have confidence in the proposed urgent care centres?

Urgent care centres – patient safety

How will the Huddersfield Urgent Care Centre be safe for patients? GPs and Emergency Practice Nurses – if that is who ends up staffing it – will have to rely for support on a video link to the Halifax Emergency Centre. This is a particular worry for children (see 8, Paediatric Care, below).

There have been problems with Urgent Care Centres that have been set up to replace A&Es that have been closed, eg in the reconfiguration of NHS services in NW London. A report by Michael Mansfield QC, commissioned by NW London Councils, found that there was “widespread confusion” among GPs, consultants and patients about what the urgent care centres could do and who should go there. The report said they should be co-located with A&E departments wherever possible to avoid “fatal consequences”

Possible urgent care centres privatisation

We are worried about Dr Steve Ollerton’s remarks at the Huddersfield Textile Centre consultation drop in, that the urgent care centres might “feasibly” be privatised.

We have heard from frontline NHS staff how walk in centres that have been privatised and are now run by social enterprises work far less well than they did when provided by the NHS.

An Emergency Nurse Practitioner working in privatised urgent care centres says that they make their money by not refusing any patient who walks through the door, even though they should be redirected to pharmacies where they would be treated far more quickly. She says it costs a ridiculous amount to staff privatised uccs to cover these numbers of patients who really don’t need to be there.

Yorkshire Ambulance Service See and Treat scheme

GPs are overloaded and underfunded, so will they be able to do the extra work that will result from the Yorkshire Ambulance Service “See and Treat” scheme, that is intended to treat urgent care patients at home rather than admit them to A&E?

Will YAS See and Treat paramedics be able to gain follow up if required from GPs after initial diagnosis / treatment? Is there a pathway into hospital if necessary?

At the Orange Box drop in, Dr Nigel Taylor said that paramedics will have much better access to primary care, through the CCGs’ “improving access to primary care” agenda.

We don’t know anything about this agenda, or where the money’s coming from to make it happen. So we can’t have confidence in this proposal.

6. Planned care – a procedure or treatment that is planned. You may have to stay in hospital to recover

We don’t really like anything about the proposed change to planned care, because

  • There is no consideration of how this will “negatively impact” users of planned care – athough the CCG’s own Equality Impact Assessment says it could
  • There will be no emergency services, such as Intensive Care Unit, on site in case things go wrong in, or after, planned care surgery.
  • We don’t think the economics of a new planned care hospital stack up – particularly if, as is possible, it is funded by PFI 2. We don’t think CHFT should embark on any more PFI projects. Wasting NHS money would have a bad impact on patient care – particularly since Calderdale & Kirklees NHS faces a £280m funding shortfall by 2020.
  • If the planned care hospital does go ahead, and NHS Improvement and NHS England then decide the economics don’t stack up, we fear the planned care hospital would be ripe for privatisation
  • The proposal to sell off the site of Huddersfield Royal Infirmary means that the valuable NHS estate would be lost forever.

7. Maternity services in the community

They don’t say how they’re going to resource improved community-based services for pregnant women, so what’s the point?

Maternity services were reconfigured some years ago, with the same aim of improved maternity services in the community. It didn’t work then, so how is it going to work now?

If the plan is to rely on the recent National Maternity Review, and its call for £3, 000 “personal care budgets” for all pregnant women – think again. This would result in fewer services, privately provided, and would undermine the NHS principle of universal comprehensive care. £3,000 won’t cover access to obstetric care when a woman has serious complications of pregnancy – so what happens then?

The real point of the National Maternity Review is to encourage midwives to leave the NHS and set up as local community providers. Women can then use their personal fund to pay them. But this would fragment care – there’s no evidence that a multiplicity of care providers are capable of co-ordinating care.

We are worried that the public “engagement” on the proposed maternity service changes was late, rushed and unethical. The online engagement survey was filled in by all kinds of people without the remotest interest in maternity services, who wished to support a cash-strapped community group that was promoting the survey, in exchange for a £5 payment from the CCGs for each completed survey.

8. Paediatric care- healthcare services for babies, children and young people.

We are worried by all aspects of the proposed change to paediatric services

We don’t really like anything about the proposed paediatric changes, except the idea of children’s care closer to home, if it is properly resourced.

NHS 111 problems

There are problems with depending on NHS 111 to determine if children need urgent or emergency care – most NHS 111 phone operators are not medically trained, they follow a script and often book call backs for parents to be contacted by a nurse in the centre.

Child and Adolescent Mental Health Services

How are they going to cut the 1 year+ wait in Calderdale for Child and Adolescent Mental Health Services assessments and the sometimes 2 year+ wait in Huddersfield?

Children’s Community outreach clinics

If children are going to be seen in “community” outpatient clinics, will they see the same doctors each time and if not, how would doctors be up to speed with the child’s basic medical history and what’s been happening currently?

Also, if the CCGs want more paediatric services in the community, how are they going address the problems of our already overstretched and under-funded GPS and community services?

Risks of centralising Paediatric inpatient and emergency services

Huddersfield  families are not happy that they would have to come to Halifax, if their children need medical or surgical inpatient paediatric services, or emergency services.

The consultation document doesn’t specify anything about under 5s – but the Pre-consultation business case (p54) says all Huddersfield children under 5 would have to come to Halifax, since children under 5 will NOT be seen in urgent care centres.

Staff in Huddersfield would be deskilled if all under 5s go to Halifax Paediatric Emergency Centre; so urgent care staff would choose Halifax if they wanted the learning opportunities and the busier environment .

Sending all under 5s to the Paediatric Emergency Centre would have an impact on its capacity: a lot more children attend under 5 than over, so if all go to Halifax, the Paediatric Emergency Centre would be busier.

Rather than splitting A&E consultants over two sites, as at present, centralising paediatric hospital services means splitting surgeons and staff over two sites by patients’ age. Huddersfield staff will only treat adults. This has serious safety implications that the CCGs haven’t addressed as far as we can see.

For example, at the moment if a child comes into Huddersfield A&E with an appendix issue or a suspected torsion of the testicle, for example, the A&E staff can just bleep a general surgeon. The surgeon will make the call on whether they accept the referral / suspected clinical diagnosis.

With the proposed centralisation of all paediatric medical and surgical inpatient care at CRH, the Pre Consultation Business Case (p54) says such a child would be:

“quickly triaged, stabilised and transported to the Paediatric Emergency Centre”.

Does this mean an advanced practitioner nurse or GP could be in Huddersfield urgent care centre bleeping a surgeon in Huddersfield with the need to then transfer both the child and the surgeon to Halifax?

For Huddersfield children over 5, there is going to be a problem if they go to Huddersfield urgent care but then need admission or surgery and it’s urgent and they get sent to Halifax.

There is the likelihood that Huddersfield parents will take their children aged 5+ straight to Halifax, if they are unsure their children’s needs are urgent or not, because Halifax has both urgent and Emergency care.

9. Community health services

Everything about this proposed change to community health services worries us and we don’t like it.

Although it could be good for vulnerable patients to receive extra care at home so they don’t have to go into hospital in an emergency, we think this is all about cutting costs and privatising NHS services. So what could be good about it, won’t happen.

Instead, we think it is a recipe for denials and restrictions of care, de-professionalisation of health staff and the creation of a system ripe for takeover by private health companies.

We look at the meltdown in mental health services that happened when they were moved into the community 20 or so years ago and are very alarmed that history is about to repeat itself.

There is a big disconnect between the CCGs’ spin and the reality of the proposals.

There is a lack of evidence to support the CCGs’ claims about Care Closer to Home

There is a lack of evidence of local authority and hospitals Trust involvement in these proposals

There is a lack of GP support for these proposals.

Throughout the consultation, the CCGs have claimed that the GPs support their proposals. But at the 14 June Calderdale & Kirklees Joint Health Scrutiny Committee, GPs from Calderdale and Kirklees Local Medical Committees said that they have had NO input into the design of the Care Closer to Home proposal, or the design of hospital services.

The Kirklees LMC chair gave a long list of reasons why GPs in Kirklees and Greater Huddersfield are sceptical of the proposals for the future arrangements for hospital and community health services. The Calderdale LMC rep confirmed that they broadly shared this view.

There is a hidden NHS privatisation agenda.

The Consultation Document is entirely silent about privatisation. But steps towards privatisation of community health services are clear.

First, Clinical Commissioning Groups will have to procure community health services through competitive tender.

The Care Closer to Home contract will be big and attractive to private health companies like Virgin Health, which has been hoovering up community health service contracts in other parts of England.

Even without privatisation, procurement brings problems. The CCGs have not explained to the public how a contract for “managed (accountable) care” is awarded to a Lead Provider who then subcontracts to numerous other providers – or that many of them will be voluntary sector organisations with no skills on providing health care. This leads to fragmentation and loss of quality control.

Or how the care is paid for on the basis of capitated payments – an average amount per patient, depending on their estimated level of need. The idea is that capitated payments will drive efficiencies, as doctors find ways to deliver the managed care more cheaply than the capitated payment, so they can make a profit.

But in the USA, as practiced by Kaiser Permanente, this system has led to denial of care to sicker patients who would cost a lot to treat.

We are gobsmacked by the CCGs’ refusal to say how they are going to get from the current situation – where they say they have not designed the the Care Closer to Home Phase 2 model – to procuring these services in the autumn this year.

They were evasive when faced with this simple question at the 14 June 2016 Joint Health Scrutiny Committee.

We think this is because they didn’t want to admit they HAVE designed the Care Closer to Homes Phase 2 model, because they are afraid this could be seen as predetermining the outcome of the consultation.

Second, we are very worried by the prospect of Calderdale community health and social care services being run by an Accountable Care Organisation.

At the March 2016 Calderdale Health and Well Being Board, Calderdale CCG said the Calderdale Vanguard Care Closer to Home scheme will be run by an Accountable Care Organisation.

Despite Matt Walsh saying at the Greetland drop in that this is not a preparation for privatisation, it would open the door to NHS privatisation on a scale not yet seen, with damaging effects on patient care and the workforce.

With the CCGs’ unwillingness to explain what an Accountable Care Organisation is and how it is a vehicle for privatisation, we have had to dig out what information we can.

Jeremy Hunt recently told the House of Commons Health Select Committee, that Clinical Commissioning Groups should set up Accountable Care Organisations. He referred to Valencia’s model of Accountable Care Organisations, which are public private partnerships – kind of like PFI, but for NHS services as well as NHS buildings.

For example, the city of Alzira ACO is a public-private investment partnership where the public healthcare insurance system pays a private health company to provide primary care integrated with specialized and hospital services to a catchment area of around 250,000 people.

This is a “full service” model for the entire range of health services including mental health. The contract for the “concession” term is 15 years (extendable to 20 years). The private health company consortium makes a profit.

Accountable Care Organisations are used in the USA by private health insurance companies to provide “managed care” that follows specific protocols.

This means that insurance companies control exactly what they’re paying for, and it also means that low-qualified staff such as Physician Associates, who only have two years training, can deliver care without having to rely on knowledge and skills they don’t have.

The CCGs have not explained any of these issues to the public.

We asked the CCGs about all these issues, in an attempt to fix the Consultation Document’s misleading and lacking information. (Appendix 1, Questions 2, 16, 17, 18, 19, 20, 21,)

As usual, their responses were evasive, denied our points, didn’t answer our questions and failed to produce evidence to back up the claims they make in the Consultation Document about Care Closer to Home.
Integrating health and social care

The survival of the NHS is threatened by the Care Closer to Home proposal to merge NHS services with cash-strapped, means-tested, largely privatised Council social care and leisure services and a wide range of other local authority and central government public services.

What happens to the NHS principles of a comprehensive, equitable health service for everyone who needs it, free at the point of need, when merged into this system? Particularly come 2020, when it is predicted that central government grants to local authorities will be £0. Where is the money for social care going to come from then?

Two big risks are already evident, from Better Care Fund Phase 1 Care Closer to Home schemes:

  • perverse incentives to cherry pick patients who will improve “bottom line” outcomes (ie reduced hospital admissions and the financial rewards for this)
  • Councils’ responsibility for propping up a dysfunctional, profit-making care “market”

We think this is a total mess, and social care should be renationalised. Public services should be publicly funded, managed and provided.
GP Federation process

This is galloping ahead in both Calderdale and Kirklees. All the Calderdale GP practices – bar one – have formed themselves into this federation so that they can bid for contracts.

This gives rise to a conflict of interest, since the GPs in the GP federations are bidding for contracts that are awarded by the GPs from those federations that are on the CCGs Governing Body.

A Dorset GP has written to his LMC that the GP federation process is clustering GPs into manageable groups in line with future Kaiser permanente type models – an aim now openly voiced by Jeremy Hunt. And that Doctors will lose their autonomy and freedoms, though working on short term salaried contracts within strict guidelines, with the result that many will opt for a private service in order to retain their independence.
Staffing

We are very unhappy about the CCGs’ proposals to staff Care Closer to Home with new grades of less qualified health workers and to make patients responsible for their own “self care” with help from 3rd sector workers, carers and IT.

In public, the CCGs spin this as “empowering” patients to become more “resilient” by “taking care of themselves and control of their health needs.”

In private – as we found out from the record of a meeting we obtained through a Freedom of Information request – they say this is a “big challenge” that requires:

“Realigning the mindsets of individuals, their carers and their health professionals to this vision.”

If the CCGs think we are going to let them realign our mindsets to this “vision”, they can think again. “Resilience” and “enabling and empowering people” are code words for cutting public services, making patients and carers take the burden of care, and radically downgrading clinicians’ working practices, terms and conditions.

For example, Greater Huddersfield CCG Care Closer to Home – Plans and Phase 2 – Long term conditions – adults at risk of harm due to their frailty – says:

“we believe that there is additional capacity to manage cases out of hospital, in addition there is the potential to deflect another 50% of people from the formal pathways of care”

What? Where are they going to be deflected to? Are they proposing that this extra 50% of frail adults will basically be told to sod off and look after themselves?

This is a desperate attempt to ram through a proposal without the resources to deliver it properly.

It is not that there isn’t an element of possible improvement to be gained via inventing new ways to work and bringing these things into the community, but with a purely business based focus the results are catastrophic.

The CCGs use waffle to disguise this, eg the Pre-consultation Business Case says putting hospital services into the community will require:

“Enhancing generalist and collaborative skills for the Trust’s workforce across primary and secondary care to support delivery of the Commissioners’ QIPP requirements”

We know QIPP requirements are to cut spending or deliver more services for the same money – but who knows what the rest of that sentence means? When we asked at the Lockwood drop in, the CCGs and Calderdale and Huddersfield NHS Foundation Trust staff didn’t know either.

Dr Bob Gill, a South East London GP and member of the National Health Action Party, told us it is about down-skilling. GPs will have a new title of consultant generalist and be supervising a less qualified team, so that the system will need fewer GPs. Those GPs prepared to work in the system will be providing medico – legal cover for a vastly lower quality service.

Dr Gill said that outcome would be:

“A skid row NHS to drive us to take out private health insurance.”

Changing GP contracts

Our alarm bells are ringing since Dr Ollerton told the 14th June JHSC meeting that part of the GH CCG primary care strategy was to address a “problem” with the GPs’ General Medical Service (GMS) contracts. This is: what is core general practice?

They are trying to get consistent core offer from all practices. Then GHCCG would pay practices on top of that for additional services.

But if GH CCG’s primary care strategy were to mean some GP practices only end up offering core services, where would their patients go if they needed an “additional” or “enhanced” service?

This would not be Care Closer to Home, it could be Care Somewhere Halfway Across Greater Huddersfield – with all the problems this could bring for people who are poor or have mobility problems.

Additional or enhanced services are more about Box ticking instead of making a real difference. The arbitrary standard setting in Quality and Outcomes Framework (QOF)  and money available for enhanced services such as the pre-diabetes targets in referral to diet and exercise are too removed from what will actually provide improvements in patients’ health.

We have no idea what the answer is, but we hear from primary care clinicians that it is very frustrating to be ticking boxes instead of making a real difference and being allowed to use their professional skills to come up with the best diagnosis and treatment for each individual patient.

In North West London a big NHS and social care “reconfiguration” – similar to the one proposed here – includes messing with GP contracts with the aim of trying to sell off GP family doctors’ practices to the likes of Virgin Health and Care UK, by putting them out to competitive tender as short term GP Alternative Provider of Medical Services contracts.

Patients are petitioning to stop this.

The public will need to look carefully at any proposed changes to GP contracts in the GH and Calderdale CCGs’ primary care strategies. But these do not seem to be publicly available.

Section 3 About all our proposed changes 

10. We do think we will be negatively affected by the proposed changes

We think the proposed changes are contrary to the health needs of Calderdale & Kirklees people.

Our health needs are for evidence-based, comprehensive, universal, equitable and value-for-money health care. These proposals offer none of these things.

Elsewhere, the combination of the proposed hospital services clinical model and the out-of hospital services/Care Closer to Home specifications have led to large-scale NHS privatisation – indications are that this will also be the case here.

Such NHS sell offs erode the values of a universal healthcare system – as shown by a recent Independent Healthcare Commission, chaired by Michael Mansfield, QC and initiated by NW London Local Authorities. It found that the impact of fragmentation through privatisation, in a hospital and community care shake up like the one proposed for Calderdale and Kirklees, is slowly eroding what was our National Health Service.

These proposals will funnel increasing amounts of public money into private companies, where money will be wasted on shareholder profits and staff bonuses.

And the increased NHS marketisation and privatisation implicit in these proposals will increase the waste of NHS money on the market bureaucracy needed to tender and procure services and manage the resulting contracts.

None of this is acknowledged or costed in the Consultation Document.

The hospital cuts and community care proposals are driven by the need to cut NHS services in order to fill a projected £280m funding gap in Calderdale and Greater Huddersfield NHS by 2020.

The cost cutting proposals are not evidence based and we have no confidence that they will deliver safe, high quality patient care – or safe, fair working conditions for NHS and social care staff.

The proposals are designed to conform to NHS England’s Five Year Forward View plans for the final stages of dismantling the NHS, though the introduction of new “care models” and a “modern workforce” that are both based on private American health care companies’ systems.

The proposals would carry out the government’s plan to de-fund, run down and privatise the NHS. This is going to damage both patient care and frontline NHS staff – none of whom have been involved in preparing these proposals, apart from senior consultants.

11) Please tell us if there is something that you think we could do to improve travel, transport and parking

The Clinical Commissioning Groups should push for far better public and community transport for patients and their friends and families.

They should recognise that Yorkshire Ambulance Service is overstretched and underfunded and push for it to be better funded.

We asked the CCGs to provide adequate information about how people who rely on public transport would be able to cope with having to travel further for planned care and to visit family and friends in either the planned care or acute/emergency care hospital. (Appendix 1, question 31)

We asked them to explain to the public that Neil Wallace, Bus Services Manager for West Yorkshire Combined Authority has said that he had had no involvement in plans for transport between the 2 hospitals and there had been no consultation from the CCGs on the issue.

The 2014 transport document by Jacobs identified a disproportionate effect on public transport users, but Mr Wallace said that he doesn’t know what to do to improve this because that would depend on the issues and but the CCGs haven’t consulted him, so he doesn’t know what the issues are. He wants to talk about the options, but the CCGs need to talk about where the money would come from.

We also asked the CCGs to say if they have money to commission bus services to improve travel for people who will have to travel further to hospital using public transport and if so, how much.

The CCGs’ response failed to address the key points raised in our question.

12) Overall after reading the document we disagree with your proposed changes.
Some of the reasons why we disagree with the proposed changes:

  • They are not based on evidence.
  • The claims that the Consultation Document makes about the proposed changes are specious  and often misleading. When we have asked the CCGs for the missing evidence, they have not provided it. (Appendix 1)

Two of the worst examples of the Consultation Document’s false claims about the proposals are that they:

  • are high quality, safe, sustainable and affordable and [would]result in the best possible outcome and experience for patients
  • would secure the future of health services for both areas for the next 20 years. (Consultation Document, page 5, Foreword)

There is no certainty that the hospital services would be high quality

The Clinical Senate review of the proposals said it couldn’t tell if they 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 they ignored this request. It doesn’t.)

It isn’t true that the proposed changes would secure the future of health services for both areas for the next 20 years.

Even if all the proposed cost cutting measures were carried out by 2020, Calderdale & Huddersfield NHS Foundation Trust (CHFT) would still be in deficit by £9.5m/year. The hospitals regulator, Monitor, has said this is not a sustainable position and that at that point the Trust  will “obviously be unsustainable in the longer term unless the government changes its funding policy.”

The hospital Trust’s clinical revenue is set to fall over the next 5 years, because the hospitals will be smaller, which means fewer patients which means less income for CHFT. 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.

The Consultation Process has been unfit for purpose

First, the Have Your Say survey is badly designed to the point of being unfit for purpose. Members of the public have said that they have looked at it and given up any intention of responding to it, because they can’t get their heads around it.

We have been unable to identify if the Survey asks the public to say whether or not we agree to the proposed new clinical models for hospital and community services or, if it is asking us to say how these proposed changes would affect us.

We have said this at Joint Health Scrutiny Committee meetings, but the CCGs have not offered any clarification. Our confusion has been intensified by contradictory statements by the CCGs.

At the 14 June JHSC meeting which looked at the care closer to home proposals, Carol McKenna explained,

“The purpose of the consultation is about getting people’s views about whether or not they agree that those services that we have set out in the consultation document are the sort of services that could be delivered in community settings.”

This is countered by Matt Walsh’s statement at the 6th June Huddersfield public consultation meeting, where he said:

“We will listen to you to some extent. There are some limits. The limits in relation to clinicians is that we think we can deliver something better [than the present system]. Public input will go into the business case and how this will affect our plans.”

And elsewhere he has said that the CCGs may “flex the details” of the proposals, in the light of the consultation responses.

Second, As well as the poor design of the survey, the Consultation Document does not provide adequate information for the public to make up their minds about the proposed future arrangements for hospital and community health services.

We asked the CCGs to clarify 38 questions (Appendix 1). Their responses did not answer our questions.

Third, we believe there is strong evidence that the CCGs have been fundamentally deceitful in their conduct of the pre-consultation engagement and the consultation process.

From the very start they have disrespected the role of democratically elected Councillors in scrutinising their Consultation process.

The CCGs have come up with inconsistent, evasive, inadequate and patronising replies to people’s requests for information during the consultation – whether these have been by email or face to face in drop in sessions and public meetings.

Fourth, this has made it hard for the public to communicate their views to the CCGs during the consultation and we have no sense that the CCGs have any interest in listening to what people say.

Members of the public have told us they have been reduced to tears in drop in sessions, through being patronised and feeling intimidated.

The evasiveness that has been a feature of their responses to public and Councillor questions, has corroded public trust in the people who run our NHS and who are also our GPs. This is unforgivable.

Last but not least, the Consultation Document and the consultation events have misleadingly presented the proposals as the outcome of decisions by local clinicians, and have consistently failed to clarify how the current political and NHS England policy contexts have formed these proposals.

Statement to the Consultation Institute

We are making a separate representation to the Consultation Institute about these issues.

This will include evidence to support the points just made – and others

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