Learning Disabilities, Autism and Neurodivergence Bill: consultation analysis

Section 1: Health and Wellbeing

Introduction

The consultation document highlighted that people with learning disabilities (including those with Profound and Multiple Learning Disabilities (PMLD)) and autistic people experience poorer health outcomes than the general population, are more likely to die earlier and from preventable illnesses. The current legislative landscape related to health was outlined, as well as current and ongoing work in the area - which included the development of the National Care Service Bill, as well as various targeted strategies and plans.

It was suggested that the LDAN Bill could help to create the right conditions for people with learning disabilities and neurodivergent people to access supports and services successfully when they need them, helping to prevent illness and improving overall health and wellbeing. To achieve this, five proposals were set out:

• Proposal 1: Neurodivergent and Learning Disabilities Strategies - require Health Boards, Integration Authorities and Local Authorities to set out in their local strategies how workforce and service planning has taken into account the needs of the neurodivergent and learning disability populations.
• Proposal 2: Mandatory training for the health and social care workforce - include in legislation a mandatory requirement for health and social care staff to be trained in learning disabilities and neurodivergence.
• Proposal 3: Inclusive Communications and Accessibility - (a) to legislate for people with learning disabilities and neurodivergent people to be able to request access to alternative means of communication where the offered means of communication is not suitable; (b) to provide better access to Easy Read versions of public facing communications and documents - this could be via a broad duty to make them available on request as well as an automatic duty to provide them in certain circumstances; (c) to legislate for an Accessible Information Standard for Scotland applicable to NHS Scotland organisations; and (d) to look at how far existing complaints systems meet the needs of people with learning disabilities and neurodivergent people.
• Proposal 4: Patient Passports - place a duty on Health Boards, HSCPs and Local Authorities to ensure that a person’s “passport” is able to follow them through whichever care pathways they are accessing, such as a hospital or care home admission. These passports would include important information about their needs and preferences, including how to communicate with them in an accessible way.
• Proposal 5: Annual Health Checks - consider including the delivery of annual health checks (currently being rolled out for all people with learning disabilities) as a specific legal duty in the Bill, and extending this provision to autistic people. Also consider extending this to those with Attention Deficit Hyperactivity Disorder (ADHD) and Foetal Alcohol Spectrum Disorder (FASD), subject to further evidence gathering.

Main Findings

In total, 578 respondents provided feedback at this section, with over half supporting all five of the proposals. There were calls, however, for the proposals to be implemented consistently across all areas in order to provide equal access and service provision across Scotland.

The most popular individual proposals, or those highlighted as the most important elements of the five options, were the patient passport (Proposal 4), closely followed by the Annual Health Checks (Proposal 5) and mandatory training (Proposal 2). Inclusive communication and accessibility (Proposal 3) was also popular among respondents, While strategies (Proposal 1) received the lowest levels of explicit support and discussion at this section, this was still well supported overall, albeit largely in combination with other proposals rather than as a standalone option.

It should be noted that several respondents simply pointed towards their views at the relevant overarching themes sections in relation to strategies, training and inclusive communication and did not provide any new information or sector specific feedback in this section.

Proposal 1: Strategies

This was the least explicitly supported proposal, with comments and feedback being somewhat limited. While strategies were generally supported as part of the full package of measures proposed, many respondents expressed a preference for a national strategy, either instead of, or to help guide and co-ordinate, local level strategies:

“There should be a national plan for Scotland and local plans should only add what is needed to make sure everyone gets the same service. Avoid a postcode lottery.” (LDAN Support/Representative Organisation - Learning Disabilities)

Consistent with the caveats and concerns raised at the overarching themes section in relation to strategies, respondents again stressed that strategies needed to be:

• Meaningful and effective, and should not be allowed to become a tick box exercise - it was felt there needed to be appropriate scrutiny and accountability around successful implementation of any strategies;
• Co-designed with people with lived experience; and
• Reviewed and evaluated regularly.

Those who disagreed with the development of neurodivergent and learning disabilities strategies generally did so for the same reasons outlined at the overarching themes sections (i.e. Part 2 Section 1). It was felt that strategies would be ineffective, that local strategies would lead to variation across the country, and that a single strategy for both learning disabilities and neurodivergence was inappropriate. It was also suggested that this proposal was “vague” and that more information was required.

Proposal 2: Mandatory Training

There were considerable levels of support for mandatory training across the health and social care sector. It was felt that training would be useful in its own right, and to support the implementation of various other proposals and measures. This included supporting: the use of appropriate communication options; the identification and treatment of learning disabilities and neurodivergent conditions, as well as other health issues; the delivery and use of patient passports; and in delivering effective Annual Health Checks:

“Mandatory training is in my opinion, a great way to upskill the workforce and ensure that all actions taken are in support of this target population. Knowledge is the best way to equip staff to deliver the best service to the people scoped within the act.” (Neurodivergent Individual)

Respondents mostly agreed that it was important to ensure training was not limited to just learning disabilities and autism, but should cover the range of neurodivergent conditions (with PMLD, FASD, and Down’s Syndrome mentioned specifically). Indeed, it was felt that training needed to be specific about learning disabilities and neurodivergence and treat these separately, as well as provide coverage of different neurodivergent conditions, rather than a more general consideration which could end up diluting the issues or usefulness of the training. This preference was not universal, however, and a few respondents suggested that training should only focus on learning disabilities, or learning disabilities and autism in the first instance.

In addition, it was recommended that training should cover intersectionality, unconscious bias, and be trauma informed. Training should also cover reasonable adjustments so health professionals/settings understand what is appropriate.

There were mixed views, however, related to the Oliver McGowan training used in England. Some supported the use of this or thought this sounded good, while others cautioned against using this training method/content.

It was felt that training needed to be tailored to different job roles and responsibilities rather than a single training course developed for blanket coverage. Further, it was considered important for all staff to receive training, including both primary and secondary care practitioners, managers, front line health practitioners (including dentists, paramedics, etc.), and reception staff. Several also wanted to ensure that education and training on learning disabilities, autism and other neurodivergent conditions was included as part of the university courses and other qualifications required to work in healthcare.

As noted in the overarching theme on mandatory training, respondents were again keen that those with lived experience were involved in designing and delivering this training.

A few were also concerned that better training could result in an increase in people being referred for diagnosis as health related staff will be able to identify possible conditions to a better extent than they did previously.

Proposal 3: Inclusive Communications and Accessibility

Again, respondents were largely in favour of the proposals around inclusive communications and accessibility, with only a handful explicitly stating they disagreed with this. It was felt that developing a greater understanding of communication needs and options, and delivering a more person-centred approach would have positive outcomes.

It was also suggested that clearer signposting to services and support options would be useful.

In terms of accessibility, respondents were in favour of being offered different ways to make appointments and have consultations. Different respondents noted different preferences. Some preferred phone contact while others found this challenging/saw this as a barrier, meanwhile some tended to avoid personal contact and preferred remote mechanisms, such as online, email, electronic forms, etc., while others (particularly people with learning disabilities) preferred in-person approaches/consultations.

A few respondents suggested that services should be required to proactively ask people about their preferred method of contact or communication needs and keep this information on file to ensure future contact is appropriate.

Alternative Communications and Easy Read

While respondents were generally in favour of the proposals, it was stressed that the interpretation of alternative communication needed to go beyond Easy Read, with a wider range of communication options being required to meet different needs. Similar to comments at the Inclusive Communications section in the overarching themes, it was highlighted that Easy Read may be patronising for some individuals, while others may require audio formats, use talking mats, Makaton, BSL, require information in other languages, or would benefit from different coloured paper.

It was also stressed that appropriate communication needed to consider more than just written information, with a need to offer alternative methods of arranging appointments, conducting consultations, the ability for individuals to provide information in a range of formats, and for practitioners to be aware and mindful of verbal and in-person interactions. For example, it was noted that closed and direct questions were often more suitable than open general questions, and that less importance needed to be placed on making eye contact:

“When thinking about inclusive communication, there needs to be access to a wide range of communication aides beyond verbal communication, e.g. talking mats and “teach me back” processes which offer a flexibility of approach to ensure understanding of information given, and the ability to communicate needs and wants.” (Other National Public Body/National Agency)

Further, it was stressed that any inclusive communication options available needed to be proactively offered to individuals and/or for these to be provided as standard throughout. It was not felt to be appropriate to require individuals to ask for these (again, consistent with comments in the overarching themes section).

Offering appointments via telephone and online were welcomed, with it highlighted that these options were both more suitable for certain conditions/needs, but also helped more generally to address geographical service gaps (e.g. for those in rural areas).

There was also seen to be a need to consider providing suitable information in alternative languages to people with learning disabilities and neurodivergent people where English is not their first language. This included BSL and Makaton, as well as for minority ethnic communities.

Accessible Information Standard and Complaints Systems

There was very little discussion of either the Accessible Information Standard or complaints systems.

Where mentioned specifically by respondents, the concept of an Accessible Information Standard was generally supported, but again, it was felt this should be designed in liaison with those with lived experience.

One Children's Organisation/Service, however, cautioned that the Standard applied in England was too prescriptive, and felt that practitioners should be encouraged to develop and use their skills to identify the best mechanisms for engaging with individuals.

Only a handful of respondents mentioned anything related to complaint systems, although those that did were supportive of reviewing these. Advocacy was also highlighted (by both individuals and a range of different organisation types) as an aspect that would support and enhance inclusive communication generally, and should be implemented throughout any complaints process.

Proposal 4: Patient Passports

Respondents were generally positive about the use of Patient Passports, with this being one of the most popular and well supported proposals. It was felt these would be highly supportive, although it was stressed that health and social care staff would need to be trained on the existence of, access to, and use of these to ensure they were effective:

“Having a health passport is just simple common sense. Not only will it be better for the patient (as they will not have re-tell their story at every appointment) but it will also benefit healthcare professionals who will be able to know, ahead of appointments, how to deal with patient they are about to see.” (Organisation for Other Disability/ Condition)

A few also suggested that a passport system would also provide people with learning disabilities and neurodivergent people with greater independence and autonomy.

While generally supportive of patient passports in principle, some respondents sought greater information around how these would work in practice. Respondents were keen to understand who would be responsible for the passports; what type of information they would hold; who would be responsible for updating these and how updates would be actioned; who would have ownership or control of these; how the information would be held and shared (e.g. electronically by services, or via an app or hard copy kept by the individual); etc.

There appeared to be confusion among respondents around what type of information would be contained in patient passports, and mixed preferences. Some discussed this in terms of it only containing information related to communication needs and preferences, and issues related to the presentation of some people’s conditions (e.g. how to calm them down if they become overwhelmed). Others felt this passport could also contain useful medical, treatment/medication, and care related information.

As such, it was felt that this passport could contain sensitive information, therefore careful consideration would be needed over content and access, and strict data protection protocols would need to be set out. As with training, it was suggested that those with lived experience should be involved in the design of patient passports.

It was stressed that passports (and annual health checks) should be voluntary with no individual forced to have one. Further, it was felt that individuals should either be able to complete this themselves or have input to the content of their own passport and be able to review, amend and remove information if they want. In addition, it was considered important that this remained a living document which could be updated to take account of changes and developing communication preferences.

A few respondents felt it would be important for passports not to be associated with mental health as it could be off-putting for individuals, however, it was suggested that mechanisms should be found to allow passports to be accessed by health, social care and social services. Several respondents also felt the passports could have wider applicability and should be accessible/usable in other sectors beyond health, including employment/workplaces, housing, social security, and the justice system. While a few highlighted IT systems challenges as a possible barrier to such information sharing between different services, others suggested passports held by individuals (either in hard copy or via an app) could be used to overcome this (although it was noted that this would introduce other issues as individuals/carers need to remember to carry and present this each time), or an online system where access can be granted to relevant services/professions.

Several respondents also felt it was important not to create a situation of ‘othering’ via patient passports. Rather than issuing passports to a small/limited population (which may create stigma or a sense of ‘othering’), a few suggesting that passports could be mainstreamed or made available to anyone who might find this useful. An example of another group that may find patient passports useful was children and young people from armed forces families as they may move around frequently.

Respondents who already had experience with a ‘passport’ system (either in healthcare, education or learning disability services, Promoting a More Inclusive Society (PAMIS)’s Digital Passports, or Advance Statements in mental health settings) were generally positive about these and the impact they can make. However, several respondents noted instances where they had been ignored by professionals, as it was either considered to be quicker/easier to ask for the information, or it was noted that passports were often out of date/not updated regularly enough to take account of changing needs and preferences.

In order to develop a more consistent national standard around the use of patient passports, some respondents felt it was important to introduce a statutory requirement rather than make this optional or best practice.

Concerns and Reasons for Disagreeing with Patient Passports

While only a small number of respondents explicitly disagreed with patient passports, the main concerns and reasons for disagreeing were related to these not being effective as they could be (or already were) ignored by health professionals, or would be burdensome or stressful for the individual to manage.

A few were also concerned about how passports would be perceived, i.e. that this might attract stigma. Others were concerned about data protection, particularly if sensitive personal information were to be included.

Several respondents also suggested the name of this product needed further consideration, or recommended that this should be changed. Both ‘patient’ and ‘passport’ were highlighted as potentially problematic terminology.

Proposal 5: Annual Health Checks

Respondents largely supported the use of Annual Health Checks as they perceived these to be more proactive and that they would tackle some of the issues that people with learning disabilities and neurodivergent people face in relation to accessing healthcare. It was suggested that appointments should be made automatically and sent out to individuals to avoid the need for them or their families/carers to take responsibility for this. The standardised nature of these checks also removed some of the stigma around asking for help or feeling like a bother or a burden on GPs/health services:

“Prompting is one of the primary support needs of ND people, even highly motivated ones, and these checks would go some way to prompting ND people.” (LDAN Support/Representative Organisation - Autism)

It was also suggested that these health checks needed to be conducted by well trained professionals, with a few caveating that this should not be implemented until after the mandatory training has been completed. It was also suggested that, ideally, the Health Check should also be conducted by someone who is familiar to the individual as this will work best when built upon a trusted relationship. Respondents did query, however, the scope of the checks and the nature of the professional(s) who would be responsible for undertaking them, as this could make a big difference to the quality and depth of the check.

It was felt that more information on the practicalities and processes for this proposal was required, including who would deliver this, what would happen in cases of unmet need (i.e. where health concerns are raised that cannot be tackled locally), does such a system rely on a medical rather than social model of disability/need, and how capacity and resource challenges will be addressed to meet demand.

As well as training, it was felt that this proposal also needed to take on board the proposals around accessible communication, and ensure that appointment information was provided in a variety of formats. It was also suggested that easy mechanisms would be needed to allow individuals to rearrange appointments which were unsuitable, for venues to be easily accessible, and for information to be provided in advance about what would happen at the appointment and any tests that would be carried out.

Respondents also indicated a desire for these health checks to cover mental health (mentioned repeatedly by mental health organisations as well as others), dental and oral health, sight and hearing (ophthalmology and audiology). It was noted that all these issues contribute to overall health and were settings that can be difficult for people with learning disabilities and neurodivergent people.

Respondents also generally agreed with the proposals to introduce a legal duty on Health Boards to implement Annual Health Checks, and also called for any new accountability mechanism introduced by the LDAN Bill to seek reports on implementation and impact. A few of those representing people with Down’s Syndrome also sought a full evaluation of the programme, along with a statutory requirement to review and update this every five years.

Extending Annual Health Checks to Others

While many respondents simply expressed support for the proposal without reference to the potential for expansion to specific groups, those who mentioned autism were generally in favour of including this group within the Health Checks. This was considered particularly important due to the lower life expectancy, high instances of mental health problems and high rates of suicide:

“Please do include autistic people in annual health checks. I face enormous barriers to healthcare as a result of my autism and almost always miss out on accessing care. I would really appreciate this as it takes all the difficulty away and presents a ring-fenced opportunity to speak to a medical professional.” (Neurodivergent Individual and Family/Friend/Carer)

Several respondents argued, however, that if Annual Health Checks are extended to autistic people, then they should also be extended to those with ADHD. This was due to the health challenges faced by those with ADHD and because ADHD and autism are known to frequently co-occur. Others felt it was also important to include those with FASD in the Annual Health Checks, again due to poorer health outcomes. Similarly, cerebral palsy was another condition specifically highlighted for inclusion. Yet others felt that all types of neurodivergence should make a person eligible for an Annual Health Check.

There was a sense among some respondents, however, that not everyone with specific conditions (e.g. autism, ADHD, etc.) would want or need an Annual Health Check. While they generally felt this was a useful and important programme, it may need to be implemented flexibly or on an opt-in basis and based on need rather than solely on condition. These respondents were typically in support of greater evidence gathering ahead of widening the scope of Annual Health Checks.

In addition to neurodivergence, a few respondents suggested that health checks would also be helpful for/should include a much wider range of conditions, including rare conditions and genetic syndromes, those suffering from poor mental health, and people who have addiction issues. Others suggested that annual health checks should also be offered to unpaid carers due to the stress and strain they experience and how difficult they find it to look after their own health needs when there is little respite care available to allow them to attend appointments for themselves.

It was noted by a few respondents that Annual Health Checks are not currently extended to those under the age of 16, with organisations representing children and young people uncertain of the reason for this, and stressing a desire/need for their inclusion.

Concerns and Reasons for Disagreeing with Annual Health Checks

While in support of Annual Health Checks in principle, several respondents highlighted delays and problems with the implementation and current roll out of these for people with learning disabilities. In particular, respondents representing people with Down’s Syndrome noted challenges and a lack of access to an Annual Health Check, despite the consultation paper stating that “a health check will be offered to everyone who is eligible by end March 2024”:

“…the roll out of the annual health checks for people with LD has been terrible. Slow, disparate, inconsistent, no urgency, mis-understood, and no accountability from any of the health boards or Scottish government… Hardly anyone with LD has had an annual health check despite the end of March 2024 meant to be the roll out date.” (Family/Friend)

Respondents were also concerned about how the Annual Health Checks would be resourced, particularly if rolled out beyond people with learning disabilities. As well as the capacity to deliver this, respondents were worried that wider delivery of Health Checks could put stress on the health system to the detriment of other patients in need.

A range of other concerns were also expressed in relation to Annual Health Checks, as detailed below:

• These could result in added stress for individuals around remembering the appointment and any paperwork, as well as anxiety around the consultation itself;
• That Health Checks may be intrusive and unnecessary;
• That these would not be well attended and could therefore be a waste of resources;
• That the checks would not be detailed or in depth enough to be meaningful;
• Cuts in social care could impact people’s ability to attend these checks and other healthcare appointments; and
• Suggestions that the delivery of Annual Health Checks did not require primary legislation.

Other Comments and Considerations

Diagnosis Issues

One of the main issues discussed at this section was diagnosis and the current problems and delays in accessing assessments and support. This included apparent gatekeeping, prioritisation and restrictions currently placed on access to assessment systems in certain areas. Diagnosis delays were discussed at length as posing a significant problem for health and wellbeing in their own right, but were also noted to complicate the proposals set out in this section. As such, respondents sought clarity around whether or not a diagnosis would be required for accessible communication options, to hold a patient passport and to receive an Annual Health Check. It was suggested that the due to the current problems and limitations in the diagnosis system, all provision should be based on need and available to those who self-diagnose.

Respondents noted the absence of a dedicated section on diagnosis and pathways to diagnosis, and saw this as a missed opportunity. It was felt this was an area which required considerable attention and urgent action.

It was also suggested by several respondents that the LDAN Bill should make provisions for the maximum waiting times, not just for an initial assessment by diagnosis teams, but with regards to the time taken to be assessed and to receive effective treatment or support (where appropriate).

Shared Care Arrangements

Linked to difficulties with diagnosis, a few respondents discussed the difficulties that private assessments and diagnosis can create in the provision of healthcare going forward. It was noted that some people, who can afford it, choose to get an assessment and diagnosis privately due to the significant challenges and delays in the NHS system. However, it was highlighted that, while some can then go on to receive appropriate care and medication from the NHS via shared care arrangements, others cannot access this as their GP does not support this arrangement. A “postcode lottery” situation was described, with arrangements said to vary by GP practice. In situations where shared care arrangements are not provided, respondents said they were required to be assessed by the NHS Community Mental Health Team (CMHT), thus sending them back to the long waiting lists and duplicating assessment effort, or they need to fund their own treatment through the private sector.

Specialist Providers

Some respondents called for greater use of Learning Disability Liaison Nurses, and for such provision to be expanded to autistic people and neurodivergent people. It was felt these professionals were highly beneficial across a range of different roles, including supporting the individual, assisting both the individual and other professionals with communication needs, and developing learning among other professionals.

Several also suggested that specialist clinics, hubs or healthcare providers who specialise in learning disabilities, autism and neurodivergent conditions would be helpful and supportive of development. Other options discussed included having a main lead professional/service in each local authority, or specialist staff located within each service:

“We need people who are focused on just treating ND's [neurodivergence] as they will be able to do a much more effective job and this will lead to a step change in support.” (Individual with a learning disability)

Others suggested peer support roles, or promoting the use of a “chaperone” for support in medical appointments and interventions. Again, it was felt that having a trusted person present helped to reduce anxiety, aide communication, and delivered better outcomes. Similarly, a few suggested that having someone who could help with making appointments and reminders about these would be useful.

Capacity, Resources and Funding

One of the main concerns expressed at this section was around the current staffing, capacity, resourcing and funding of the NHS and other public healthcare systems. This was commonly voiced by a wide range of individuals, third sector and public sector organisations. It was stressed that, whilst the proposals were positive in principle, these would need to be fully funded to support successful implementation as the current system was not perceived to have the capacity to deliver them:

“…many of the rights and removals of barriers outlined here can only be fully implemented if health and social care systems neurodivergent people and people with learning disabilities use are adequately resourced and funded. This is not, to say the least, currently the case.” (Neurodivergent Individual and Family/Friend)

It was noted, however, that funding was not the only issue. Staffing levels would also need to be addressed in order to boost capacity.

There were concerns that the proposals might raise expectations which cannot then be supported or delivered. Without greater capacity in the health and social care system generally, it was felt that service delivery and health outcomes would be unlikely to change. Respondents were concerned that this could exacerbate the implementation gap, generate increased levels of unmet need/demand, and potentially worsen outcomes for individuals.

It was also suggested that healthcare services, and services for people with learning disabilities and neurodivergent people needed greater levels of funding generally in order to deliver significant improvements to health and wellbeing outcomes.

Other Issues/Comments

A wide range of other comments or issues for further consideration were outlined. These are detailed below:

Comments related to service provision:

• A stronger focus is needed on mental health, as well as better access to suitable mental health services;
• Seek to understand and tackle ‘diagnostic overshadowing’ (i.e. the misattribution of symptoms of one illness to an already diagnosed comorbidity) which was said to be common for people with learning disabilities and neurodivergent people;
• Greater access to effective treatment and care is required:

“Even if health services can be accessed, the types of services offered are often not neuro-affirming, lack efficacy and a proper evidence base, do not align with human rights and their harms for autistic and other neurodivergent people (regardless of the presence of a learning disability or not) are not understood or dismissed, e.g. therapies offered through a neurotypical lens and Positive Behaviour Support.” (LDAN Support/Representative Organisation - Autism)

• Greater focus is needed on integrated care models, e.g. social care staff trained in the health needs of people with learning disabilities and neurodivergent people. There was said to be a current lack of multidisciplinary and integrated care, particularly related to drug use among young people and adults with learning disabilities and neurodivergent young people and adults; and
• Strengthen early intervention and support.

Comments related to specific communities included:

• Specific consideration was needed for both Down’s Syndrome and PMLD in both the consultation document and the Bill in relation to health and wellbeing; it should not be subsumed within wider labels/communities and their unique needs should be taken into account;
• Issues in older age need to be better understood and supported, including autism in older age, as well as the prevalence/challenges of dementia in people with learning disabilities and neurodivergent people. It was felt important to provide dedicated training and to develop greater oversight of services for this age group;
• Improve intersectional understanding around differences in presentation/ masking^[1], and around barriers to accessing healthcare, for a range of different personal/protected characteristics, including gender, ethnic minorities and the LGBTQIA+ community;
• This section of the consultation was perceived as very adult focused - proposals need to extend to and include children and young people’s health and wellbeing, covering both physical and mental health and wellbeing, and be mindful of additional barriers that children and young people face; and
• Greater consideration of, and a more joined up approach was needed to transitions, and moving from children and young people to adult health services.

Other comments:

• The neurodivergent community needs to have trust in the health service, individuals (and their families/carers) need to be believed and understood, and not dismissed or made to feel like a burden;
• Longer appointment times are needed so people with learning disabilities and neurodivergent people are not rushed and communication needs can be accommodated;
• It was noted that health settings were problematic and needed to be designed in liaison with people with learning disabilities and neurodivergent people;
• Implementing a requirement for employers to consider and make reasonable adjustments for the health and wellbeing of their neurodivergent staff;
• Behaviour modification approaches such as Positive Behavioural Support (PBS) and Applied Behavioural Analysis (ABA) should be banned;
• Greater input should be sought from Allied Health Professionals (AHPs) in relation to tackling health and wellbeing. They should also have a role in supporting the proposals set out in the consultation document, particularly speech and language therapists and occupational therapists; and
• It was felt that ‘wellbeing’ was not addressed in this section and that more focus was needed on this. This included greater consideration and development of other aspects to support health and wellbeing, including:
  • physical activity and access to sports and sports therapy;
  • community based infrastructure changes and creation of high quality green/outdoor spaces (again to involve those with lived experience in the design process);
  • tackling isolation and social inclusion, and offering better access to social activities; and
  • support related to sleep and diet.