Health and social care - integration authority guidance: consultation analysis

4. Analysis of responses to Section 2 – Annual performance reports: statutory guidance

4.1 Structure of the guidance

The guidance is ‘statutory guidance’ by virtue of section 53 of the 2014 Act, which states those persons cited ‘must have regard to any guidance issued by the Scottish Ministers about its functions under or in relation to this Act’. This is communicated on page two of the draft guidance.

The draft guidance seeks to balance outlining the relevant requirements under the 2014 Act and related regulations with supplementary information intended to support integration authorities effectively perform the duties and draw links to wider supporting resources. The additional information is set apart, presented in boxes, throughout the guidance.

Chart 3 and Table 3, below, summarise responses to the initial question on the structure of the guidance. The majority of responses ‘mostly agree’, with ‘mostly disagree’ being the second most common response. Overall, with 50% of the responses ‘mostly’ or ‘strongly’ agreeing and 29% ‘mostly’ disagreeing, there appears to be, on balance, overall support for the approach taken in structuring the guidance.

Table 3. Do you agree that presenting supporting information in boxes throughout the guidance is a useful structure?

• Strongly agree
  • Total: 4
  • 14.3% total
• Mostly agree
  • Total: 10
  • 35.7% total
• Neither agree nor disagree
  • Total: 6
  • 21.4% total
• Mostly disagree
  • Total: 8
  • 28.6% total
• Strongly disagree
  • Total: 0
  • 0% total
• Total
  • Total: 28

Further feedback was received through the subsequent open-ended question, ‘If you have any further thoughts or suggestions on how the structure of the guidance can be improved, please tell us here’. The main points from the 17 responses included:

• some HSCPs noted that the additional supporting information is used to communicate both wider materials and other advice, which is unclear, and should be changed
• the additional information communicated in boxes could be shortened and refined
• the guidance could encourage HSCPs to evaluate their existing performance reporting arrangements
• the formatting to separate certain information in boxes is present in the PDF version of the document but not on the website version, which may be a barrier to accessibility

4.2 Balance of information within the guidance

The next questions centred on the balance of information between summarising the statutory requirements with wider supporting information throughout the guidance.

Chart 4 and Table 4, below, summarise the responses to the question on the balance of information. The majority of responses ‘mostly agree’ with the balance of information. Overall, with 79% of the responses ‘mostly’ or ‘strongly’ agreeing, there appears to be support for the balance of information within the guidance.

Table 4. Do you agree that there is an appropriate balance between information summarising the relevant statutory requirements in the Public Bodies (Joint Working) (Scotland) Act 2014 and wider information to support integration authorities meet these requirements?

• Strongly agree
  • Total: 3
  • 10.7% total
• Mostly agree
  • Total: 19
  • 67.9% total
• Neither agree nor disagree
  • Total: 5
  • 17.9% total
• Mostly disagree
  • Total: 1
  • 3.6% total
• Strongly disagree
  • Total: 0
  • 0.00% total
• Total
  • Total: 28

Further feedback was received through the subsequent open-ended question, ‘If you do not think that the balance of information in the guidance is appropriate, please tell us here what changes you would recommend and why’. The main points from the 14 responses included:

• the balance of information appears appropriate and reasonable
• the guidance is reflective of the legislation, but may benefit from further reflecting the complex environments that integration authorities operate within
• the wording used in the sections on accessible documents may need amended

4.3 Suggested improvements and other feedback

The final questions centred on suggestions on whether information can be improved or is potentially missing from the guidance, followed by the opportunity to provide any other feedback.

In response to whether information can be improved or is missing, the main points from the 19 responses included:

• some HSCPs reflected that the legislative requirements that the guidance communicates are difficult to achieve in practice
• some HSCPs questioned the role of the Scottish Government in analysing and reviewing performance reports, and feeding back good practice
• guidance on using local data would be helpful
• specific feedback on suggested updates to sections and wording of the guidance
• certain elements of the guidance were welcomed, such as aspects on reflecting on performance and taking action and encouraging practices to enhance accessibility

In relation to other feedback, the main points from the 21 responses included:

• the structure of the guidance appears appropriate
• issues with the performance report publication timing and the release of national data are not addressed by the guidance
• the addition of the checklist in annex A is welcome
• including a route for those using the guidance to provide feedback on broken links or outdated resources could be useful
• the guidance should be reviewed and kept up to date
• the legislative requirement for a comparison of financial information with the preceding five years is considered excessive