Department of health
17 February 2012
Introduction to our response
Good health matters because it enables people to work and further their careers, to look after their families, and to pursue social and leisure activities to the full. However, evidence from the Commission’s Triennial Review shows that people with some protected characteristics find it difficult to access care and support that meets their particular needs and some are more likely to experience 'poor' health.
Joint strategic needs assessments and joint health and well being strategies will lay the foundations of the planning and commissioning process in the new health and social care system in England. It is therefore vital that the statutory guidance being developed by the Department of Health supports local authorities (through Health and Wellbeing Boards) and Clinical Commissioning Groups to embed equality and human rights into the way they develop their assessments, strategies, commissioning plans, service provision and its evaluation.
Summary of our response
The Commission recommends that the statutory guidance responds to the recommendation of our policy paper on health by setting out an expectation that local authorities (through Health and Wellbeing Boards) and Clinical Commissioning Groups need to:
- Improve the quality of the information used in the development of JSNAs to include all protected characteristics and ensure involvement of people in the development process across the range of diversity.
- Produce JSNAs that explicitly outline the needs, experiences, outcomes and aspirations include those from people across all protected characteristics. If this is not achieved, JSNAs should outline the steps that will be taken to address these gaps in evidence.
- Ensure that this assessment of needs, experiences, outcomes and aspirations is reflected and addressed in joint health and well being strategies; commissioning plans and subsequent service delivery and evaluation.
- Ensure that joint health and well being strategies and subsequent; commissioning plans move away from process-based objectives to objectives that are outcome-focused, measurable and reduce health inequalities experienced by people including those with different protected characteristics. Aligning objectives with equality objectives published to meet the specific duties will help these to be mutually supporting whilst reducing the duplication of effort.
- Increase transparency and accountability to local people, both about what is being done to tackle health inequalities experienced by people with protected characteristics and what outcomes are being achieved. Different solutions may be required to address pre-existing health inequalities and prevent new ones. Data is a key tool to facilitate the monitoring of progress as well as an early indication of areas of concern.
Our response also responds directly to the questions posed by the DH by:
- making a range of specific recommendations to the draft statutory guidance. These are aimed at helping local authorities and CCGs implement the recommendations from our policy paper; comply with the law and mainstream equality within their work to develop JSNAs, joint health and wellbeing and subsequent commissioning plans.
- providing feedback on the equality requirements of the wider suite of guidance being produced for the health sector
- providing technical feedback on equality information in data sources
- highlighting the potential for partnership working with the Commission
- highlighting a range of useful existing resources
- highlighting our expectation that the DH publishes its equality analysis of the development of the statutory guidance as soon as possible.
Download the full consultation response (Word)