National Care Standards Review: Consultation Analysis

8 Additional Comments

8.1 Respondents were invited to submit any further comments over and above those already provided in response to the previous specific questions. General themes to emerge from many responses were:

• The new standards should be meaningful, widely publicised and enforced.
• The level of detail of the standards will need to be pitched appropriately in order to avoid being vague, yet be generally applicable but not prescriptive.
• Complaints procedures including appeals processes and protection for whistle-blowers should be addressed alongside establishing the new standards.

8.2 Much support was provided for proposals for further consultation but calls were made across sectors for this to be inclusive in order to get views from a variety of perspectives. Some felt that the consultation made little reference to the Adults with Incapacity (Scotland) Act 2000 and recommended that more thought is given to seeking the views of those with incapacity. A small number of respondents criticised the easy-read version of the current consultation stating that it had not been easy for some service users to understand and respond to:

"The easy read document does not satisfactorily explain the changes taking place. The questions in the easy read document are repetitive, too long, not in simple enough language and therefore requiring considerable explanation and interpretation" (Ind).

"This form was far too complicated for a learning disabled service user to comprehend. X understood very little and was unable to make any comments of her own" (Ind).

8.3 Many respondents urged that that the new National Care Standards be produced in a wide range of formats including pictorial and in short leaflet form.

8.4 A recurring view was that the new standards should be widely and systematically publicised using a variety of media including radio, TV and social. Other ideas were deploying theatre, DVD and videos to help publicise the standards. Adverts on buses were envisaged. Several respondents commented that the current standards are not widely known about, or understood. One remarked:

"I train staff on meeting the care standards and how to improve the service and still find staff (not managers usually) have not even read the document let along know and understand the impact they have on practice and the service" (Ind).

8.5 One local authority criticised the images used on the front of the consultation document for what they considered to be stereotyping (no male carers depicted) and inappropriate (all laughing and having fun), emphasising that providers deliver services in situations which can be emotionally charged and challenging.

8.6 Some respondents raised the issue of implementation of the new standards, with a few criticising the proposed date of April 2015 as ambitious. One respondent (Reg) recommended a phased approach to implementation; three respondents advocated piloting the system before national roll-out.

8.7 Three respondents suggested that users and carers are provided with information about the new standards in an incremental fashion, bit by bit, in order for them to become familiar with them and not feel overwhelmed.

8.8 Several respondents praised the proposal for the standards to be outcome-focused, viewing this as making them more meaningful for providers and users. There were calls for the standards to contain many examples of good practice. One respondent remarked:

"Any standard proposed must carry clear information on how it is to be practised within a care service. Without this, care providers will waste precious time deciphering vague statements, only to face their inspector who happens to have a totally different interpretation of the same statement" (Ind).

8.9 Two respondents suggested that the word "care" in the title of the standards could create difficulties as all providers may not see themselves as providers of care and some users do not seek or receive this.

8.10 A recurring view was that quality of delivery of service does not take place in a vacuum but is very much linked with resourcing. Several respondents felt that procurement should take this into account and that delivery of standards should be supported by a level playing field with regards to funding. Comments included:

"We would suggest a separate set of standards is developed around Commissioning & Procurement. The ability of providers to deliver high quality, responsive and personalised services is very much linked to commissioning and procurement practice" (Shared Care Scotland).

"Currently, service managers experience frustration at the lack of connection between the inspection of services and the commissioning of those services. It was felt that there needed to be recognition within the National Care Standards and the inspection process of factors outwith the control of providers of services that impact on service standards, i.e. an insufficient individual budget for a person may compromise them Reaching Potential; similarly insufficient contract values..." (Capability Scotland).

8.11 Concerns were raised that a gap may develop between what providers aspire to and what they can afford with inspectors' remarks being out of step with what commissioners are willing to resource.

8.12 Another relevant tension identified by a small number of respondents was what they perceived to be the imbalance between healthcare, which is free at point of delivery and is regulated tightly, and social services which differ on these counts, being perceived as less strictly regulated. It was felt that these imbalances should be addressed as part of consideration of the new standards.

8.13 A recurring theme was that the new standards will need to be systematically enforced with transparency about actions taken where services are deemed to be failing to achieve. Calls were made for inspectors to ensure they listen to different voices when making their inspections.

8.14 A few respondents advocated clear timings for reviewing the standards be put in place from the start.

8.15 Other significant issues (which had not already been covered in detail in response to previous consultation questions) were raised by only a few respondents:

• Clarification is required on how the new standards will apply in relation to self-directed support.
• It may be helpful to examine international evidence on related standards, their implementation and effectiveness.
• The training needs of inspectorate staff should be identified in relation to the likely greater need for specialist knowledge.
• There needs to be a clearer link between the registration process for social work and social care staff and the National Care Standards. This is currently perceived to be unclear and confusing.
• The place of self assessment within the new standards needs to be addressed further.

Summary of main findings

• Support was expressed for further consultation on the new standards before they are finalised.
• Many respondents called for the new standards to be widely publicised using a variety of media.