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Fair Enough?
Fair For All Progress Report:
Analysis of Race Equality Schemes and Fair For All Action Plans

Findings and Recommendations

The overall context and methodology for assessment of the Scheme and Action Plan

Does the Scheme give a geographical background?

Whilst it was not a stipulation under the FFA guidance, the inclusion in most Schemes of some background information on the area and the population was helpful in providing a context for planning of work to fulfil FFA and RRAA requirements.

• Half of the Schemes provided at least some information on the geographical nature of their area for that purpose. (For the 5 national Boards this issue was clearly not applicable.)
• Very few Schemes gave an indication of the effect on their work of reaching out into rural communities or of local targeting in urban areas that indicated the impact of geographical considerations such as the particular isolation of black/minority ethnic individuals and families in rural areas.

Is the profile of black/minority ethnic communities discussed?

Only 6 out of the total 27 Schemes gave no feeling at all of the profile of black/minority ethnic communities in their area. Most of these were national Boards - but even for these some reflection on the population that they served would have been appropriate.

One rural Board gave otherwise very comprehensive information about the geography and demography of its area but with absolutely no mention of black/minority ethnic communities. However it stated that relevant information was published in its local health plan 2003 but this was not supplied with the Scheme.

Most of the data supplied made reference at least to the 1991 census and at least 5 Boards or Trusts had been able to update their information with the latest figures from the 2001 census by the time of submission of their FFA Action Plans.

Other Schemes referred to data from sources such as the National Labour Survey or a lifestyle survey showing initiative in fleshing out the bare bones of census information. Where supplied, such population data was a useful context for reviewing expectations and the actual history of race equality work in a particular area.

An area Trust and a national Board with responsibilities respectively outside their Board area and outside Scotland made no mention of the impact that these wider responsibilities would have on their planning for work in the areas of race equality and cultural competence.

A few Schemes mentioned communities such as asylum seekers and refugees and Gypsy/Travellers as a focus for work that was being undertaken or was being planned. However, it was disappointing that there was then little follow up within the Schemes or Action Plans regarding work that might be undertaken relating to these particular communities.

Several rural Boards mentioned that the small size of black/minority ethnic communities in their areas was not an excuse for inaction. This was a clear change from feedback obtained during the FFA stock-take and seems attributable at least in part to wide distribution of the Needs not Numbers study in the interim.

Is the Scheme owned singly or jointly?

In terms of ownership of Schemes, it was generally clear whether Schemes were of single or joint ownership. No schemes were multi-agency and jointly owned with other community planning partners though some were involved in development of the Schemes. The only separate Trust Schemes were for the Trusts in Greater Glasgow and Lothian. For these Trusts, there was a feeling of substantial co-ordination across the Board area between the different NHS bodies concerned. Greater Glasgow Health Board clarified that it had deliberately decided on separate Schemes in order to develop local ownership as well as the legal accountability of individual organisations.

Several Schemes had a good description of how Health and other partners would work together. The formation of joint racial equality groups in some Boards seemed a sound base for future work as well as for the preparation of the Scheme and FFA Action Plan.

In at least 2 of the Boards, it was not at all clear how the various components of the Board would work together to achieve change.

Is there any discussion of assistance from other bodies?

• Half of the Schemes mentioned assistance from NRCEMH - but for two thirds of these the assistance was to be obtained for carrying out future work rather than for work in development of the Scheme and Action Plan that had been submitted.
• A further 7 Schemes mentioned assistance from the CRE.
• 2 Schemes particularly mentioned assistance from local organisations in the development of their Schemes and Action Plans.

Given that so many Boards and Trusts said that they were short of experience in this area and needed external assistance, it was surprising that there was not more discussion in the Schemes (particularly the Schemes of rural Boards which often had the least experience) of other sources of external assistance that could be brought in to help develop their work.

Both the CRE and NRCEMH will be continuing to give guidance and support.

How are policies and functions listed, assessed and prioritised?

• The process of listing, assessment and prioritisation of functions and policies was covered fully in 12 of the Schemes where work appeared to have already been completed to a satisfactory level.
• In a further 6 cases work was still ongoing and another Scheme laid out a clear intention.
• The work had not been carried out to any significant extent in 3 cases whilst for another 4 Schemes it was not at all clear how much work had been done.
• A few Schemes mentioned consultation regarding this process that had already been completed or that was now being planned.

Is the context of the organisation and the community provided?

In around half the Schemes there was a fairly adequate effort to set the Scheme into context in terms of the organisation itself and its corporate priorities as well as in terms of the legislation and national policy context. In another 6 cases there was at least a partial attempt to establish a context but for 8 Schemes the context setting was either absent or very thin.

In a number of cases it was only the bare bones of the legislative framework that was provided giving no sense of where this would sit within the policy priorities and overall strategies of the organisation in question. Many Schemes would have given a more convincing sense of the commitment of the organisation if the issues involved could have been shown to be central to the overall aims and objectives of the Board or Trust in question.

Does the Scheme include all elements in the guidance?

Only 5 of the Schemes were assessed to have failed for the most part to have included all the elements in the guidance although inclusion was only partial in another 5 cases. This left around two thirds of Schemes as having included all or almost all elements of the guidance and values, aims and objectives were generally well laid out.

Is the Scheme original?

It was interesting that sharing of content or overall approach between Boards and Trusts was rather limited. This is despite feedback that some at least would have preferred a great deal more central guidance than was in fact provided. As a result the great majority of Schemes were original in their approach and generally took good account of local circumstances.

There was considerable sharing between 4 Boards and Trusts which borrowed from one very comprehensive Scheme - but this is not to say that such borrowing was a bad thing and it was generally combined with substantial local work. However, the main text was not always reflected in the Action Plan.

A number of Schemes mentioned substantial local consultation during the drafting process so that they were able to develop a real focus on responding to local needs and conditions. Other Schemes were the product of working groups with very wide membership from local organisations both within and beyond the health service.

Is there a clear distinction between race equality and cultural competence?

Evidence of real confusion was rare between race equality and cultural competence. In some cases, one approach was emphasised above the other and no one single Scheme laid out a clear distinction between the two to indicate a full understanding which could then be communicated more widely amongst managers, staff and users.

It is useful to be aware that cultural competence is more likely to relate to point of service issues whilst race equality covers this as well as strategic and societal dimensions. Clarity is therefore required to ensure all aspects are covered. The Joint Monitoring and Reporting Structure for FFA and RRAA developed by the CRE and the NRCEMH illustrates this overlap as well as some of the distinctions.

Is there an Action Plan that answers FFA guidelines?

• In 3 cases there was no substantial Action Plan to answer FFA requirements.
• In 1 case the Action Plan supplied was very thin and preliminary in nature.
• Another Scheme contained no Action Plan as such but it was apparent that a great deal of work was now being undertaken in terms of planning for action required for FFA.
• One Action Plan was very comprehensive in terms of FFA but seemed to have taken little if any account of RRAA requirements.

Many Action Plans could have been more explicit about outcomes rather than outputs. (For instance, there was very little mention of the final aims of training and what it might achieve in terms of organisational and cultural change.) This would provide a clearer basis for monitoring of progress in achieving objectives and effecting real change.

In 6 of the Action Plans submitted by end March 2003, the costings had not yet been established to a full or satisfactory extent. One Board explained that gaps in terms of cost were the result of the mainstreaming approach that had been adopted. In this case, other indicators need to be particularly clear to monitor that the objective has been met. For another the problem in including costs was the timing of its budget process.

In the case of the 2 Boards (the former Health Education Board for Scotland and the former Clinical Standards Board for Scotland) that submitted Schemes and Action Plans but that were themselves undergoing reorganisation over the last few months, it is noted that Schemes are being revised and Action Plans prepared to include all parts of the new organisations that have been created.

Several Schemes recognised that the low level of past work meant that there was now much to do. One Scheme recognised the need to work with community planning partners. Few schemes considered how community planning and joint futures work might contribute to integrated working on areas such as transport and social services.

At least 2 Schemes mentioned a strong effort directed at mainstreaming which is also the intention of both RRAA and FFA.

In at least 2 Schemes there was a stated intention to cover a much wider equality agenda than just race equality: however in both cases this intention was not delivered in the body of the Scheme and generally created uncertainty as to whether the specific demands of RRAA and FFA would be met. Whilst it is laudable to work on a range of diversity aspects - since all inequalities need to be addressed - a minimum requirement must be that attention be paid to meeting legal and policy requirements in each area.

Project leadership and planning, partnerships and procurement

Is there a statement of organisational intent?

An adequate statement of organisational intent was included in 17 of the Schemes reviewed. 8 Schemes either included no such statement or a statement which fell far short of what was required. Sometimes, much of the material that would have made a satisfactory statement was present in the Scheme but had not been brought together in a proper statement which could be published and disseminated as required by the guidance. Another 2 Schemes seemed to be well on the way to creating a satisfactory statement although they still had some work to do to achieve this.

Many statements included the definition of institutional racism carried in the Stephen Lawrence Enquiry Report. Some statements needed strengthening particularly in the approach that would be taken to tackling racist incidents and/or to the mainstreaming of issues and practices.

There was very little detail in most Schemes on how statements had been (or were to be) consulted on and disseminated. A few Schemes mentioned that the statements had indeed been

developed very much in consultation with black/minority ethnic community organisations or joint working groups or that staff had been involved in the development process.

In some cases, it was not clear whether a Strategic Action Plan or a Race Equality Policy referred to in certain Schemes might either constitute or include a statement of organisational intent that might meet the requirements of the FFA guidance. If so, then this needs to be made explicit and evidenced. Members of the public should not have to go searching to identify the intention of the organisation.

Is there evidence of a commitment to race equality?

All Schemes were judged to have shown a reasonable level of commitment. This is not surprising given that all Boards and Trusts have signed up to the CRE Leadership Challenge, and that this work is being driven by legislation. Such commitment was measured through criteria such as the effort invested in preparation of the Scheme and Action Plan, the amount of past or current work being undertaken in the area and the description of CRE Leadership Challenge and action taken in fulfilment of that Challenge. Nearly half of the Schemes indeed mentioned the Challenge although many failed to mention specifically what action was being taken to fulfil the Challenge.

Six of the Schemes included either no or very little discussion of past work: whilst nowhere required in the guidance (and recognising that some organisations felt their focus should be on the future) description of past work helps to give a sense of commitment and a context for assessing whether current planning is indeed realistic and likely to result in real progress. This is particularly useful when the action planning is less detailed and commitments to action are therefore having just to be taken at face value.

Commitment was also shown by a few Boards and Trusts through allocation of the remit to an existing member of staff (with time allocation for the task and building of relevant skills and knowledge) or by the appointment - whether actual or just planned at this stage - of a race equality adviser or co-ordinator. Several organisations with such officers in place appear to have been able to move their race equality agenda forward with greater speed. Such an officer can devote adequate time and attention to moving action forward as well as providing some expertise to guide the direction that is being taken.

The formation of strong working groups and partnerships around race equality was another indication of strong commitment in some Schemes. Another indication was a wide agenda on equal opportunities beyond race equality. In some cases this was in the form of an active Equal Opportunities Policy with related training taking place throughout the organisation. Action in such respects in some rural Boards was particularly valuable in showing commitment to change even though real action was only just getting underway.

Is senior responsibility for implementation clearly allocated?

The great majority of Schemes were generally satisfactory in terms of allocation of senior responsibility for implementation and the FFA HDL requirement for nomination of a lead officer at senior level.

• Only 6 Schemes were found to be less than satisfactory, in some cases because of a lack of clarity about the arrangements that were being proposed.
• In a further 5 cases the allocation of responsibilities within Action Plan was either missing altogether or less than satisfactory.

There needs to be confidence in the ability of Boards and Trusts to implement their Schemes and Action Plans.

Are there arrangements for working with external partners?

• In 18 Schemes there was a feeling of real planning and/or action and progress in terms of partnership working. Some of the new partnership forums are clearly dynamic and energetic and seem likely to deliver change across a wide equalities agenda.
• Only 5 Schemes contained no substantive discussion or even a clear commitment to working with partners in the pursuit of race equality and cultural competence.
• Two Schemes mentioned the formation of partnerships with local academic institutions for the development of culturally competent services through mentoring and training.

For rural and smaller Boards, where local partnerships may be harder to develop, consideration may be given to building partnerships at a national level. This is not to say that larger Boards can neglect this area - length of experience does not necessarily indicate good practice. Schemes also need to show how the General Duty is being met in any partnership arrangement that may be formed as this is a requirement of RRAA. National Guidance on partnerships will be forthcoming from the CRE in autumn 2003.

What are the arrangements for equal opportunities in procurement?

Whilst only a few of the Schemes submitted in November 2002 contained any real coverage of procurement issues, the situation has improved considerably since then, in the light of the first analysis, either through revisions to Schemes or in the detail provided in Action Plans. Almost half (13) of the Schemes included some discussion of procurement issues with a number of Boards having already made real progress in this area. Of these 13 there are, however, a number where a commitment to change has yet to be matched by detailed planning for action. A few Boards mention that it will take a few months to complete reviews of contract and tendering procedures which is understandable.

Procurement issues do need to be addressed quite urgently as many organisations will need to contract out to meet the requirements of RRAA and FFA (for instance in terms of training) and procurement is itself part of the requirements of the RRAA. There is substantial scope for partnership working in terms of procurement, particularly between Boards.

Demographic profile and the assessment of needs

What are the systems for gathering information?

The analysis of Schemes and Action Plans looked at the systems that Boards and Trusts mentioned for the gathering of information on staff, users, the general community and wider health issues. The intention was to see whether there was a real effort to gather information as widely as possible - i.e. from research, library materials, complaints, and consultation - rather than from only one rather narrow source such as the census data.

The analysis found that the split was about 50/50 in terms of the detail supplied in Schemes on systems for gathering information. A clear exposition in terms of information gathering systems would tend to give the reader the impression that the organisation was proceeding on the base of the best possible evidence rather than on a rather partial or subjective basis.

• Several Schemes mentioned that information would be gathered in partnership with local bodies such as regional consultative forums.
• There was evidence of major initiatives in information gathering in a few organisations: one example was a health and well being study undertaken with partners which was to be repeated in 2002/2003.
• Other organisations mentioned that systems would be developed in consultation with local black/minority ethnic communities.
• For national organisations, it would be encouraging to see evidence of work in partnership with other national bodies for the gathering and analysis of national information.

What are the arrangements for getting local population information?

A third of the Schemes did not provide adequate information on plans to gather local population information. Two of these were national bodies which also need to deal with population issues. Most Action Plans included at least a mention that 2001 census data would be included and a number of organisations committed themselves to partnership working in the gathering and analysis of census and other demographic information. (Partnership approaches to demographic information were particularly apparent amongst the Lothian and Greater Glasgow Boards and Trusts.)

Very few organisations mentioned how they would publicise local population information. (Whilst not a specific demand of the FFA guidance this could help external parties to understand the evidence base upon which action was to be planned and executed. It is also an action that accords with the spirit of the RRAA in terms of public access to information.) A few just stated that it would be included in their annual reports.

What are the arrangements for assessing local health needs?

One Board mentioned that GP registration would be examined in the course of its demographic survey work. Another Board suggested that the development of a consistent national approach on how population data could be analysed should be led by NRCEMH. There was generally very little detail on how information might be further disaggregated for wider equality issues, e.g. in terms of disability and gender.

Boards and Trusts with responsibilities outside their main geographic focus areas failed to consider the consequences of their wider geographic remit (for example, the State Hospital has responsibilities in Northern Ireland and Yorkhill NHS Trust and the Southern General Hospital in Glasgow both have responsibilities outside Greater Glasgow).

18 Schemes mentioned either planning or existing work for a local health needs assessment. The FFA guidance in this case states clearly that the assessment is to be made publicly available.

One urban Board proposed a national strategy on local health needs assessment to be developed in partnership with the NRCEMH. In other Schemes there was a fair amount of discussion concerning commitments to undertake assessments in partnership with local organisations and in partnership with relevant communities. One rural Board used its initiative in identifying a suitable health needs assessment process adapted from a book dealing with black/minority ethnic health needs which was fully credited.

Are there arrangements for further relevant research?

The majority (16) of Schemes mentioned at least a commitment to further research or to further analysis of existing research. However a further 11 Schemes either did not mention the issue at all or else failed to give a satisfactory response to meet the FFA guidance (which gives some detail on what might be included in such research within systems for gathering relevant information on an ongoing basis).

One rural Board was committed to producing a Minority Ethnic Group Research Strategy and to start the research process after completion of the initial needs assessment.

In one or two Schemes there was a tendency to confuse research on health needs with analysis of the monitoring that would be undertaken to assess progress made with the Scheme and Action Plan. A number of organisations which had not produced or committed to a research plan nonetheless had produced much input for such a plan either from consultation on needs with the local black/minority ethnic communities or past health assessments.

Given that research is an issue common to all Health Boards and Trusts, a few Schemes referred to discussion through NRCEMH as the best approach to be adopted.

Communications: publication, consultation and community development

Does the document meet the publication requirements of the RRAA?

For over half (15) of the Schemes reviewed, it appeared that publication had taken place on or around the due date of completion (i.e. 30 November 2002). However, in very few cases only was it absolutely clear if and when publication had indeed taken place.

In this regard it is fair to say that there were no clear stipulations in the specific duties under the RRAA as to how publication was to be notified and who the Scheme was to be submitted to after it had been completed. All that was said was that 30 November was the deadline for publishing the Schemes. In retrospect, it might have been helpful for Boards and Trusts to have been given clear guidelines on the manner of publication and distribution.

One Board which should have produced a Scheme appeared not to have produced anything on schedule beyond drafts. It is worth noting that the CRE has issued its first compliance notice to a public authority in England and Wales for failure to comply with the General Duty to produce a Scheme. ( http://www.cre.gov.uk/media/nr_arch/2003/s030515.html ) Five organisations seem to have published their Schemes somewhat after the deadline and in another 5 cases it was not at all clear if and how publication had taken place. Very few organisations gave a clear picture as to when and how their Schemes had been published.

A number of Schemes stated that there would be further revision and/or that Board approval (in one case by as late as June 2003) was still to be obtained before publication could proceed. A few stated that the version submitted for this analysis was a draft - although such a stipulation was clearly not compatible with the RRAA requirement for production of a Scheme by 30 November. Overall there was an impression of Boards and Trusts having frequently started very late with their work on production of a Scheme with the result that they were still involved in fine tuning or consultation or in seeking approval at the time of the production deadline.

Most organisations had made or were committed to making arrangements for their Schemes to be available in a variety of languages and formats and/or in summary form. In a number of cases it was evident that the Scheme had developed with substantial local consultation along the way rather than just at the last minute on a final draft.

• One Scheme was formally launched in January 2003 with advertisement in a local newspaper and circulation to community groups and to all members of staff.
• A third Board said that a summary leaflet would be published for general distribution by May 2003.
• A Trust was making its Scheme available on its website with a feedback page for comments or suggestions.
• Another Board was planning a seminar in the first part of 2003 to launch its Scheme.

When Schemes were initially sought after 30 November 2002, several schemes were unavailable, not provided or difficult to access. Whilst this situation has improved, it points to the question of whether the intention of the RRAA was fulfilled about accessibility. Perhaps all public authorities can revisit this question in future in relation to publication of the Scheme and associated documents.

Is the document well produced and easy to understand?

The documents were generally assessed as being well produced. The criteria for this assessment were based on considerations as to how accessible the Schemes would be to external readers as well as considerations of the actual information included. In several cases, a tremendous amount of time and effort had clearly gone into the production of a comprehensive Scheme.

Schemes were mostly clearly presented with contents pages.

• In some cases, the documents received for analysis lacked a contents page or a foreword but organisations then responded that these elements were present in their final Schemes.
• Several Schemes included a glossary of terms used
• There were few diagrams or tables beyond basic tables for Action Plans. Sometimes, diagrams could have helped to demonstrate matters such as the lines of responsibility for implementation of Schemes and the relationships between partners involved in the development or implementation of a Scheme.

The best laid out Schemes had new pages for new sections so that the Scheme was easy to navigate.

• On the other hand a few Schemes seemed to have been finalised in a hurry and there were errors in numbering of sections and so forth which made it hard to keep track of where you were in the text.
• Sometimes there was no page number or sub-heads to help the reader find the way.
• A few Schemes started with an outline of the purpose and content of the document which was very helpful in giving a sense of what would follow.
• Some Schemes set out the requirements of the RRAA and FFA which would be helpful to readers not familiar with these, including staff.

Some Schemes were admirably brief and concise whereas others were very bulky. However, the bulkiest ones generally included a lot of background and other detail and summaries either had been produced or were to be produced. One Scheme included great detail about the RRAA requirements but very little detail on action that was planned to address those requirements.

Some Action Plans did not include milestones and targets. Sometimes the outputs from actions were not clear and outcomes were sometimes described in a very general way. One action plan was divided into sections for patients, staff and partners which gave a clear sense of purpose and vision to the planning.

Was there consultation on the Scheme before publication?

• For 12 Schemes there appears to have been consultation with black/minority ethnic communities before finalisation and publication of the Scheme.
• A further 7 organisations were committed to consultation after the November 2002 production deadline.
• Eight Schemes either did not seem to have planned for consultation or provided little or no information on this matter.
• A number of Schemes mentioned that they were made available to staff, through an intranet or otherwise, but this did not always mean that there was a real intention to seek staff views. It was frequently not clear if or how staff had been consulted on a Scheme.

Consultation prior to publication of the Scheme was not specified in the RRAA although it is consistent with good practice that the RRAA requires public authorities to develop. A hard line that consultation after the November 2002 deadline should be regarded as inferior to consultation before that deadline does not seem appropriate: the bare figures do not reveal the approach taken to consulting communities or the degree of flexibility or otherwise in responding to views and amending Schemes accordingly.

• Some Boards were planning major launch events in early 2003 which seem more useful than a superficial exercise involving mailing around a draft to relevant organisations just in advance of the production deadline.

What are the usual arrangements for consultation?

Schemes were also required to lay out the usual arrangements adopted for consultation. It is important that consideration is given to the inclusion of black/minority ethnic people in general consultations as well as using specific mechanisms or consulting on issues deemed to be of particular relevance.

• Ten of the total provided adequate details of such arrangements whilst another 14 Schemes were found not to be adequate - either there was no significant discussion of such arrangements or the arrangements were at a very preliminary stage of development only.
• For a further 3 Schemes, the arrangements for consultation were well under development although they were not yet operational.

Some Schemes presented a good awareness of some of the issues involved in planning consultation: i.e. issues of consultation fatigue and of ensuring that organisations and individuals were truly representative of communities. One urban Board with considerable experience of consultation on health policies voiced an awareness that what had been adequate in the past might not necessarily serve in the future: therefore it was currently reviewing its arrangements for consultation. Indeed a number of organisations seemed committed to a thorough review of their arrangements for consultation so that best practice could be established. Sometimes the responsibilities and functions of the various consultation mechanisms were not laid out very clearly.

In addition, it is worth considering that consultation falls short of real power-sharing, as demonstrated in the Ladder of Participation, (Sherry Arnsteim, Journal of the American Institute of Planners 1969)

A higher aspiration must be to have consultation as the minimum, and real engagement with staff and communities as the objective.

What arrangements are in place for a consultative forum?

The establishment of a consultative forum was a clear requirement of the FFA HDL (which gave fairly full details of what was needed) and a majority of organisations producing Schemes (16) had either established what seemed an appropriate forum or were at the least well on the way to doing this.

• Six Schemes did not discuss a consultative forum whilst a further 3 Schemes were not clear what action was being planned with regard to such a forum (i.e. it was not clear what body would constitute the required forum).
• Some action was underway at another 2 organisations although there seemed to be still a fair way to go.
• For the national Boards, in particular, it is suggested that partnership working in establishment and operation of a consultative forum might well be appropriate to avoid duplication and consultation fatigue.

Whilst the FFA HDL is prescriptive in this regard, the consultative forum should be seen as one mechanism for consulting black/minority ethnic people as well as potentially including representatives of other aspects of diversity. It does not preclude and in fact should improve the development of other mechanisms. The spirit of the HDL encourages wide and regular engagement with community individuals who are supported to grow in experience and capacity.

What arrangements are there for consultation and engagement of staff, including black/minority ethnic staff?

• Treatment of issues around consultation with and wider engagement of staff had improved since the production of Schemes in November 2002.
• Twelve Schemes gave at least fair coverage of this issue even if the depth of engagement was not always very deep (i.e. there were plans for briefings to staff rather than a real attempt to involve them in the development of policy and practice).
• In the remaining 15 Schemes, there was either very little or no discussion of how staff might be involved in taking forward work on race equality and cultural competence.
• One national Board went further than most in committing itself to fully involving staff in reviewing and revising its Scheme.
• An area Board stated that the Area Partnership Forum Staff Side would be involved but without giving any clear indication as to what would be included in 'involvement'.
• An urban Board stated that there had been considerable involvement by staff but without giving any indication of what that involvement had entailed.
• A small rural Board noted that it had a rather high number of black/minority ethnic medical staff: however it failed to consider how these staff could help the Board to move forward with its agenda for race equality.

What arrangements are there for wider engagement with black/minority ethnic communities?

Nearly half (12) of the Schemes had some discussion at least of planning or actual initiatives for wider engagement with black/minority ethnic communities, i.e. beyond the basic consultative framework.

• A further 14 Schemes provided no real discussion in this area.
• A Trust plans to involve black/minority ethnic groups in the planning, evaluation and operational delivery of services.
• In a few cases it was mentioned that action would be taken forward under the umbrella of a wider public involvement strategy.
• In a small rural Board, a development worker had been specifically allocated to the task of building links with black/minority ethnic communities.

Has a directory of individuals and agencies been prepared?

The preparation of a directory of individuals and agencies was mentioned in 15 of the Schemes. In only 6 cases out of this 15 did it seem that the directory in question was either already available or preparation was well underway. In a further 12 Schemes there was no mention of such a directory. This is an obvious area for partnership working at both local and national level and is an area the National Resource Centre for Ethnic Minority Health could consider developing. Indeed the danger of duplication of effort is illustrated in the report by one urban Board that it already had reference to 3 separate directories. A Trust has already had a directory available online for over a year, giving immediate access to all parties wishing to use this resource.

What steps are being taken to build the capacity of communities to engage?

For strategies for public involvement and consultation to be implemented effectively it is necessary for Boards and Trusts to address issues of capacity building and community development. It may be useful to give some examples of what is meant by capacity building and community development as commitment to this has historically been patchy in Scotland, and health organisations have different levels of expertise in these aspects. The Patient/Public Involvement Strategy sets out some of the principles though not specifically in relation to black/minority ethnic communities.

• Sixteen of the Schemes made some effort to address such issues.
• A rural Board planned to use the principles of its new Patient/Public Involvement Strategy to develop the capacity of communities. It would seek to bring less organized groups into the process in part by training frontline staff on principles and practices of community development.
• Another rural Board was establishing a black/minority ethnic volunteers scheme as part of its community development strategy.
• An urban Board had been investigating capacity building issues through a series of consultation exercises.
• A rural Board had created a Gypsy/Traveller Partnership Group with a designated development officer and was also appointing outreach workers.

A number of Boards which were still preparing their strategies for consultation and public involvement needed to include capacity building within that planning process.

What are the arrangements for supporting local carers?

• Only 10 of the 27 Schemes under review gave a satisfactory description of plans that they had or were developing for support for carers from local black/minority ethnic communities.
• Another 15 Schemes had no discussion of this area of work which is specified in the FFA HDL whilst for 2 national Boards this is not a relevant issue.
• For those Schemes which made some response on this issue, detail was generally lacking and further planning is still required.

Is there a communications strategy?

Schemes were required to show a strategy for communications which took into account the information needs of different communities. Such a strategy should discuss how these information needs were assessed and how they would be satisfied. Neither RRAA nor FFA specified a strategy; however, whilst a strategy need not be a single document or statement, only a strategy can take account of the co-ordination required in meeting the various aspects of information, dialogue, consultation and involvement included within this section and laid out in the legislation and policy. It is also linked to interpreting and translation needs.

Ten of the Schemes did not provide a satisfactory response either detailing such a strategy or committing to the development of a strategy for communications.

• In the 17 Schemes which recognized the need for such a strategy, the work of developing was generally still to be carried out or completed.
• On the other hand, two Boards were now taking their communications strategies out to consultation.

Needs in terms of translation and interpreting were generally quite well covered and there was much recognition of the barrier that could be created by a poor service for translating and interpreting.

However, in some Schemes translation and interpreting was the only communications issue to be covered. Communities have varying language and literacy profiles and poor access to information can create barriers for accessing services and complaints procedures. Whilst addressing the specific needs of asylum seekers and refugees, the opportunity exists to ensure that resident black/minority ethnic populations are served well by mainstream provision of translation and interpreting.

Access to services and delivery of services

Have services been clearly prioritised?

For the most part, a framework for assessment has been provided. Prioritised services are also reflected in the FFA Action Plan: in some instances this issue was covered in the Action Plan although it had not been included in the Scheme document.

• Twelve Schemes have prioritised their services satisfactorily through needs assessment and consultations, working through a scoring grid according to relevance, etc.
• Most of these 12 Schemes have listed services in full, though sometimes along with policies and functions, and the services are prioritised for each year of the Scheme.
• Fourteen Schemes have not assessed and listed their priority services at all, or for each year, or they have only discussed a limited range of services.
• At least 1 Scheme has given a very full picture of the exercise of setting priorities.

In those Schemes which have not assessed or prioritised functions and policies satisfactorily or not done this at all, there is a need to give a full list of functions and policies and to relate these to services as required by RRAA. However, services are distinct from policies and functions (though they do relate to each other) and priorities should obviously reflect most relevance to the General Duty.

What are the arrangements for identifying barriers to change?

Most of the Schemes (23) have mentioned the arrangements and the approach to ensure a systematic review of functions and policies through different mechanisms such as access audit, needs assessment, consultations, impact assessment, etc.

There is also an indication of arrangements for a review of new policies and functions and in some instances a working group has been formed to manage this assessment and to monitor the effects of changes. In a few (4) Schemes, however, no specific details have been given of either the approach or of an assessment for ensuring a systematic review of policies and functions

In those Schemes where there is no evidence of appropriate arrangements, there is a need to specify how new functions and policies will be assessed.

Is there evidence of progress and commitment to change?

Twenty Schemes showed at least some evidence of commitment to change through, for example:

• demonstrating leadership
• completion of the full action planning process (including the development of a timetable for achieving targets)
• discussion of past work and progress already made
• development of monitoring procedures
• review of service areas and developing appropriate quality standards
• commitment of rolling programme
• amendment of policies based on consultations, assessments and ongoing work.

In a few (5) Schemes evidence of progress and/or commitment to change was not very apparent and compliance with the letter of the RRAA and of the FFA guidance seems the objective rather than there being genuine commitment to change or progress. One wonders what level of hidden barriers may exist if this is the overt position. At least 2 Schemes showed evidence of much work underway including a thorough listing of functions and a planned audit of service accessibility.

Commitment needs to be demonstrated in measurable action points. It also needs to be matched by reflecting and meeting legal and policy requirements. In some cases, RRAA and FFA were not met adequately though other work was illustrated. Whilst supplementary work is helpful, it cannot replace actions to meet those requirements. Consideration of encouragement of uptake, monitoring across service areas, and measurement of satisfaction will all support progress and the achievement of real change.

What are the arrangements for personal care?

• Fewer than half (12) of the Schemes have satisfactorily considered and assessed personal care provision as a priority service through consultation with local community groups, staff/ departments, etc.
• Most of these 12 Schemes have either included plans surrounding the issue, including training to staff, or have described their intention to carry out a review of current service provision in order to develop service plans.
• In contrast, an equal number (12) of Schemes have either not addressed the issue in detail, have failed to address it in the Action Plan, or have not made clear what steps will be undertaken, including how staff and users will be informed.
• For 3 of the Schemes the issue is not entirely relevant due to the nature of their operational responsibilities. However, the matter still needs to be considered for staff and visitors.

What is the planning to address dietary needs?

• Over half (14) of the Schemes have assessed and included dietary/catering services in their list of functions. They have also made plans to address the issue through appropriate provision consistent with the needs of people of different black/minority ethnic groups. In some cases they have undertaken to carry out a review of current policies, consultations, and training.
• In 10 Schemes the issue needs to be addressed specifically as either they have not detailed their plans surrounding dietary needs or not addressed the issue at all.
• At least 2 of the Schemes have shown evidence of progress/good practice by planning an interim review (including measurements of satisfaction, visits to other organisations having a reputation for providing high quality, culturally sensitive catering, identifying areas for improvement and plans for changes, and planning actions with different communities on their needs).
• Three of the Schemes have not included discussion of dietary needs, as the issue is not relevant to the services they provide.

Most of the Action Plans will need to provide information on how awareness will be ensured both for staff and users and how needs will be met. There is scope for national guidance in this area, supplemented for local needs as necessary.

What steps are being taken to address issues of spiritual care?

• Nineteen Schemes have addressed spiritual care provision and have listed in their functions. Many of them have provided specific details with plans e.g., service review audit, access to facilities, appropriate counselling and support, training to staff, etc.
• However, in 6 Schemes there is either a general statement with no reflection in Action Plans or not considered at all.
• The issue is not relevant for 2 Schemes and therefore is not considered.

There is a need in the Action Plans to elucidate on provision, ensure awareness, and to meet needs. Reference can be made to the spiritual care HDL 2002(72) for guidance.

What plans are there for translating and Interpreting services?

Overall there has been a good response to this aspect as all Schemes have responded to the issue in some or other form.

• 14 Schemes have made satisfactory arrangements/ plans to deal with, e.g. the provision of information in appropriate languages and ensuring sufficient translation services, service review audit, monitoring use and update, staff training, etc.
• 7 Schemes have shown evidence of progress through strategies to improve service and provisions, identifying needs, development of directory of products and services, and staff training.
• The remaining 6 Schemes have committed to deal with the issue though they have not given much detail about their plans and implications and therefore will need to give further thought to the matter.
• Following initial analysis all references to using relatives and staff to act as informal interpreters had been removed. Trained interpreters can avoid embarrassment and conflict of interest, and are more likely to give objective interpretation. They may also have expertise in the jargon e.g. medical terminology.

What are the arrangements for providing advocacy services?

• Over half or 15 Schemes have covered the issue of advocacy satisfactorily. They have detailed their intentions and reflected this in their plans about access to advocates, service audit review including investigating satisfaction of black/minority ethnic users, and staff and community awareness-raising.
• For 1 of the Schemes, the issue is not relevant and, therefore, is not included.
• In one locality, a major project is being funded along with the local authority to provide specific advocacy services for black/minority ethnic people.
• For the remaining 11 Schemes there is a need for improvement in developing this area as it is one of the requirements of the FFA guidance. These Schemes have either committed to action but not reflected this in their Action Plans or have not included detailed planning on top of a general commitment.

Generally, there is a need to discuss the service in Action Plans and to show a mechanism for measuring service provision and uptake. Advocacy services, which should already be available in all LHCCs, need to be inclusive of black/minority ethnic needs.

Have gender issues been taken into consideration?

11 of the Schemes have specified gender issues in relation to patients, staff and visitors and considered provision of choice of gender of health professionals. These Schemes have also planned a service audit review and actions surrounding the issue including awareness raising. The remaining 16 Schemes have either not considered or made a general statement without any specific details or plans.

Steps need to be taken to cater for gender preferences in the Action Plan, which also needs to show steps taken to assess needs and to measure awareness and uptake of provision. Schemes should consider the options for action under the Sex Discrimination Act as well as the RRAA.

Are there any other notable factors that have been considered as regards access to services and delivery of services?

Twelve of the Schemes have considered other factors in their service plan, including plans for asylum seekers and refugees. Gypsy/Travellers, homeless persons, and drug addicts. Some have also considered strategies towards domestic abuse services, transport services, mental health, out of area treatment procedures, child protection, health education in schools, etc. One Scheme has shown evidence of progress through taking on and addressing issues arising from REC casework and shown evidence of attempts to mainstream. The rest of the Schemes have generally not contributed anything significant.

There is a need for the Schemes to include a strategic and long term view and it is appropriate for Action Plans to include measures directed towards health improvement on a wider basis e.g., covering social work, transport issues, long term care issues, etc.

NHS Argyll and Clyde - The Action Plan includes taking on and addressing issues arising from the local Race Equality Council. Planning and Provision for Training

Has responsibility for the planning and delivery of training been allocated?

A majority of the Schemes (19) have identified and mentioned lead responsibility, mostly in their Action Plans. In the other 8 Schemes, a department or person responsible for planning and delivery of training has not been identified or specified. There is a need to be explicit about the responsibility for planning and delivery of training, thereby providing evidence that training programmes are planned.

What are the arrangements for ensuring appropriate and relevant training?

• Most of the Schemes (22) have showed an intention to train all staff on the General Duty, equality and diversity, and/or cultural awareness.
• Many of those have target timescales and their plans reflect details of training. In addition, awareness of the implications of RRAA has been considered.
• Some Schemes have plans to identify and train managers with special responsibilities to fulfil obligations under the General Duty and Specific Duties.
• At least 2 of the Schemes have given comprehensive information covering different aspects e.g., induction, range of staff to be included and prioritised, annual programme, and range of areas to be covered in training programmes.
• The remaining 5 Schemes need improvement in this area as they contain only a general statement or commitment but with little evidence of addressing training issues in a holistic way.

The National Resource Centre for Ethnic Minority Health has a Training and Development Network which is considering guidance for the Health Sector, focusing currently on FFA and cultural competence.

Are there any arrangements in place for the evaluation of training?

Generally, consideration of evaluation of training has remained a weaker area, as 14 of the Schemes have not considered the matter at all or have just given a general statement that they will review training. However, 12 Schemes have given some impression of considering evaluation through plans for review, and of further refinements and improvements in training strategy based on review results. One of the Schemes intends to commission an external evaluation to avoid bias.

Schemes and Action Plans should consider evaluation of their training programmes, especially in terms of the overall impact that may eventually result. Possible focus areas for the evaluation of training include consideration as to whether the contents meet legal and policy requirements, cost effectiveness, measuring change in behaviour and attitude and measuring the change in organisational culture.

Planning for employment monitoring and human resources issues

How will the requirements of RRAA and FFA be made known and implemented?

A majority of the Schemes (19) have specified training programmes/orientation for managers and staff for understanding and implementation of the General and specific duties. Most of them have included plans with target timescales with some even one step ahead in mentioning that work has already started. In contrast, in 8 of the Schemes either it is not mentioned explicitly or it is not clear whether their training programmes will cover the requirements of RRAA and FFA.

There is a need under the RRAA to be explicit and ensure that awareness of the requirements of the General Duty under the RRAA and of the FFA is increased through training. In addition to this, staff must be able to fulfil their duties e.g. in providing culturally competent services, understanding differences in morbidity and aetiology in different racial groups, conducting adverse impact assessments, collecting and interpreting monitoring data. There is little evidence that the implications of this part of the RRAA have, as yet, been fully understood.

Is there an Equal Opportunities Policy and if so how is it disseminated and implemented?

All organisations were required to have an Equal Opportunities Policy (EOP) in place by FFA guidance and indeed by earlier guidance.

• Fewer than half of the Schemes (10) have indicated that each Board and Trust has its own EOP, with plans for review and readjustment according to current requirements, as well as arrangements for proper dissemination.
• Very little evidence of harmonising of policies could be found in the Schemes.
• An equal number (10) of Schemes have either not provided evidence of an EOP in place or not given much detail of a policy/strategy or just given a general commitment of developing policy/strategy.
• Three Schemes have, however, shown evidence of progress/good practice by harmonising the policies, appointing senior managers with responsibility for the policy, training of staff for supporting as internal advisors, planning development of a comprehensive policy and ensuring awareness to all staff.

There is a need to provide details in the Action Plan on arrangements for development, update for legislative changes, dissemination and implementation of Equal Opportunities Policy.

Is there a Bullying and Harassment policy and if so how is it disseminated and implemented?

Almost two thirds of the Schemes (17) have provided satisfactory evidence for the existence or at least the current development of a policy relating to bullying and harassment/Dignity at Work or of arrangements for receiving complaints. These Schemes also include plans for review, implementation, and relevant training to staff. However, most of these Schemes lack detailed mechanisms for dissemination.

At least 1 of the Schemes has evidenced good progress through developing training and awareness raising programmes for its Dignity at Work policy and scheduling monitoring. Nine Schemes, however, have not mentioned the existence of a detailed bullying and harassment policy. It is worthy to note that as a result of European Directives, harassment will be included formally in the Race Relations Act from July 2003, and in forthcoming legislation on discrimination on grounds of religion, sexual orientation and age.

There is a need for the Schemes to demonstrate how Dignity at Work will be disseminated and implemented, details on monitoring and use of results and the comments in the section on Equal Opportunities Policies about case law are also relevant here. Schemes would benefit from referring to the Partnership Information Network (PIN Guidelines on Dignity at Work).

What are the arrangements for employment monitoring?

• Half of the Schemes (14) have either provided evidence of currently monitoring their workforce or have plans to monitor staff by ethnic groups.
• Most of these have also provided details on areas of monitoring e.g., staff in position, applicants for employment and staff leaving employment.
• 5 of the Schemes have also shown evidence of good progress/practice by providing considerable detail of their plans, including the development of arrangements for computerised database systems and publishing.
• In contrast, almost one third (8) of the Schemes need improvement in this area, generally because there is only a commitment to monitoring but without any details on arrangements or the areas to be covered as required by RRAA. Also these Schemes have not reflected measures for the development of an employment monitoring system in their Action Plans.

There is a need to provide detail on each aspect of monitoring i.e. work profile and recruitment and selection, staff leaving employment and to include this in the Action Plan. It will no longer be sufficient to have gross figures e.g. total numbers of staff in each ethnic group. Full monitoring requires that more detail is available to identify where processes may be discriminatory e.g. at what stage in a recruitment and selection process, in what part of the organisation, and at what grades.

Also, if monitoring is stated to be in place, there should be information from that monitoring in the Scheme. There is also a need to be more explicit on reporting of monitoring information, i.e., to whom, how, and how often. Under the RRAA, Schemes are required to detail arrangements for monitoring which covers these categories. Schemes could provide target dates on when monitoring data was to be published if it is not already available: this would give a sense that there was more than just a general commitment to action in this area.

The CRE Guidance on Ethnic Monitoring is detailed and also covers the interpretation of monitoring information.

What are the arrangements for other human resources monitoring?

• In 12 Schemes, there is both recognition of the requirement and concrete planning to ensure monitoring in the areas required. Some plans are also made for recording and reporting. Some of these Schemes have also mentioned their intention of taking the elements as equality indicators.
• 3 of the Schemes have given considerable detail and have mentioned the development of a system with arrangements for analysis and publishing.
• In 10 Schemes, this is a weak area, with most of them having failed to provide detail as required for fulfilling the Specific Duty.

There is a need to be more specific about each aspect of human resources monitoring and to include in Action Plans. Under the RRAA, Schemes are required to detail arrangements for monitoring under all the categories, i.e., applicants for training, and promotion, staff receiving training, results of performance assessment procedures, grievance procedures, and disciplinary procedures.

Are there any positive action measures in place or under consideration?

Much improvement has been observed in this area following the initial assessment, as 17 of the Schemes have evidenced awareness of potential need and, therefore, now have plans to consult and to review recruitment processes to reach black/minority ethnic groups, to offer training to encourage equal skills competency, or to provide positive action work placement and volunteering opportunities. The remaining 10 Schemes have either not mentioned positive action or have not provided any detailed plans.

Are there measures to ensure that staff from different groups can participate fully?

For the most part, this has been a very weak area, as 24 of the Schemes have shown no evidence of arrangements made for participation of under-represented staff in consultations, decision-making, and/or implementation process. Only 3 Schemes have shown some commitment in relation to consultation and reflected this in their Action Plans.

This aspect of the assessment considers the difficulty minority ethnic and/or disadvantaged staff have in participating fully. Examples of mechanisms include networks, open communication processes which bypass hierarchical lines such as suggestions schemes and representative or weighted staff surveys. The issue applies to different types of minority - both numerical and in terms of power and influence - so it may be necessary, for example, to consider ways of involving women, and black/minority ethnic women separately.

Where a staff profile includes some staff from smaller groups, the Schemes could consider action that may be taken to include such staff. Existing barriers for participation should be considered; as there may be special support needs to be catered for.

What are the arrangements for internal partnerships to involve workers and their representatives in race equality matters?

This has been another of the weakest areas of the Schemes. In 20 of the Schemes, there is no evidence at all, or very meagre details only, to judge on mechanisms for internal partnerships. The remaining 7 Schemes have, however, shown either a commitment or actual work for involving a local partnership forum, and have indicated work with recognised trade unions, staff associations or other networks.

It is also important to consider workers as distinct from employees and how they will be involved. This may include contractors (such as GPs and research consultants) and volunteers as well as people on placement.

There is value in involving staff more in discussion of issues and finding more ways of getting feedback that can help to ensure the successful implementation of work under the RRAA. It serves to increase awareness, and demonstrates that commitment is neither short-term, nor superficial and that all staff are expected to uphold the values in any scheme.

Monitoring Arrangements for progress & outcomes under the Schemes

What are the arrangements for monitoring progress?

More than 2/3 of the Schemes (20) have committed to develop a framework for monitoring progress complying with PIN guidelines and FFA requirements, and have stated an intention to review functions and policies according to monitoring results. Some of these Schemes have also planned qualitative and quantitative methods for monitoring progress.

An audit of monitoring arrangements for policy development is described in 1 Scheme. The remaining 6 Schemes have either not provided specific details or the arrangements mentioned are general.

The legislation requires that plans for progress monitoring be properly laid out in the Scheme and the FFA HDL makes clear that progress will be monitored via the NRCEMH. The CRE has published a framework guide for Inspectorates to use in their audit work of public authorities. In addition, the Scottish Executive is including progress on race equality and cultural competence in the Performance Assessment Framework from 2003. In England and Wales, equality indicators are a formal part of Best Value legislation and in Scotland, whilst less formal, equality is to be considered part of Best Value. Given Community Planning and Joint Futures work, this may be of relevance to Health Boards and Trusts too.

Are there plans to make real use of monitoring information?

Nineteen Schemes have provided evidence of awareness that monitoring information will help to develop and plan services and products. These Schemes have also shown indications that monitoring results will be translated into project planning, into recommendations made for the allocation of resources, and into results fed back into policy development and review, and/or preparation in cooperation with other partners. In the remaining 8 Schemes, broad statements are given and it is not clear as to how monitoring information will be used to effect change.

This area will need more detail and thought in many of the Schemes to show or plan the practical use of monitoring information.

What are the arrangements for making race impact assessments?

• Around half of the Schemes (14) have shown evidence of an intention to develop an assessment framework for assessing race impact.

• Some of these Schemes have also proposed a combination of methods to assess impact, including consultations, and have developed checklists of 'equality indicators' which may influence both race equality issues and other equality issues.
• Occasionally, it was observed that groups have been formed with a responsibility for assessing the potential impact on the promotion of race equality. However, few details have been provided on specific approaches for assessment.
• The remaining 13 Schemes need improvement in this aspect as either they have not mentioned race impact assessment at all or else they have not provided adequate detail on their plans for assessment.

The RRAA requires the arrangements for race impact assessments to be set out in the Scheme and consideration should be given to the resource and practical implications. This area, therefore, needs detail in many of the Schemes. It is also an appropriate area for work to be carried out on a national basis.

How will the results of monitoring be published and disseminated?

• Though most of the Schemes seem aware of the need to publish monitoring results, only 14 Schemes are clearly committed to publishing results, mostly in the form of an annual race equality progress report.
• Many of these Schemes have given undertakings to review the publication process and then to ensure that information will be freely accessible.
• The other half (13) have either not mentioned or have only given a general statement without much detail on this matter.

There is a need to consider and be more specific on the issue of publishing monitoring results and details provided on dissemination and access. Publication only in the annual report will not be adequate.

What are the arrangements for publishing the results of assessments?

Fewer than half of the Schemes (12) have provided evidence of publishing results of assessments, mostly through the annual race equality progress report. Many of these are also committed to its proper dissemination. There are also mentions of consultations on mechanisms to publish results. Very occasionally, however, Action Plans contain details of how these commitments will be implemented. 15 Schemes will need improvement in this aspect as either they have not specified plans for publication or there is a general statement only or there is no demonstration of the mechanisms for publishing and reaching diverse communities, including the use of accessible formats.

There is a need to be more specific on the issue and provide details. Again, publication only in the annual report is not adequate.

What are the arrangements for publishing the results of consultations?

Only 11 of the Schemes have mentioned their intention to publish results of consultations, mostly through a race equality annual progress report. Some of these are also committed to feedback the results in planning and decision-making process. However, a majority of the Schemes (16) have not specifically mentioned the issue or have given general statements without much detail on the method/process of publication and of reaching diverse communities in accessible format.

Most of the Schemes need to be more specific on the issue and provide details on dissemination and access. Publication only in the annual report will not be considered adequate.

What are the arrangements for publishing the results of race impact assessments?

Generally, this has remained an area of weakness, as 18 of the Schemes have not specifically mentioned the issue or have given a general statement only without details of arrangements. Only 9 Schemes have shown some evidence of commitment to publishing and there is a need to detail plans for dissemination and accessibility.

There is a general need to be more specific on the issue and to provide details on dissemination and access. In this regard, publication only in the annual progress report cannot be considered adequate.

What arrangements are there for a 3-year review?

Although most of the Schemes have expressed an intention to review either at the end of year 1 or each year, 19 Schemes have also expressed an intention of reviewing at the end of year 3. Another 8 Schemes have either not specified the issue of review or have not given explicit detail on what will happen at the end of year 3, i.e., a full review.

Schemes need to consider the issue and be clear that at the end of year 3 a full review is required under RRAA. Annual reviews are good practice.

Have outcomes and benefits been identified across stakeholders?

This remained another of the weakest areas, as only 4 of the Schemes could provide some evidence of identifying outcomes and wider benefits in their Schemes. These have recognised further work on specific areas to meet the health needs of black/minority ethnic communities and to promote good race relations, including in employment, and benefits in relation to policy development and service delivery. The remaining 23 Schemes provided no explicit discussion as to how changes may benefit wider groups and contribute to equality and good relations between persons of different racial groups.

Most of the Schemes could consider outcomes and benefits for the whole population and staff in more depth. This will also assist in promoting good relations between people from different racial groups which forms part of the General Duty.

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