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HEATH DEPARTMENT: HEALTH FOR ALL CHILDREN: DRAFT GUIDANCE ON IMPLEMENTATION IN SCOTLAND - ANALYSIS OF CONSULTATION RESPONSES

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EXECUTIVE SUMMARY

The 4 th Edition of "Health for All Children" (known as "Hall 4") was published in February 2003. Draft Guidance was subsequently developed on how best to implement the recommended core programme of child health surveillance, screening and health promotion in Scotland, and how to identify and target support for vulnerable children and families. The Scottish Executive published the Draft Guidance in December 2003 for consultation. The consultation closed on 31 st March 2004.

A total of 153 responses were received from a wide range of individuals and organisations. Most respondents only commented in detail on some parts of the Draft Guidance.

GENERAL COMMENTS

A large number of respondents welcomed the Draft Guidance, either in a general sense or in relation to its content. A small number of general criticisms were made, including that it:

  • Raised issues, but did not provide answers.
  • Focused too much on information giving.
  • Provided insufficient detail on how it should be implemented.
  • Was complex and contained jargon.

There were also criticisms of the process in relation to, for example, what was perceived to be limited involvement on the part of non-health agencies.

A small number of respondents identified gaps in the approach set out in the Draft Guidance, including the need to reflect the contribution of the voluntary sector and the multi-agency working and integrated service delivery which will be required, as well as to ensure that the role of community development is addressed.

Similarly, some respondents identified areas of work which were, in their view, either excluded or required more emphasis. These included equalities issues, domestic abuse, smoking, respiratory illness, accidental injury, physical activity, mental health, addictions, sexual health, obesity and the roles which can be played by men / fathers.

INTRODUCTION

A range of comments were provided on the introduction to the Draft Guidance.

Key principles

There was broad support for the principle of taking an integrated approach to the delivery of services and support to children, and for the incremental nature of the Draft Guidance. A wide range of suggestions were made identifying additional documents and policies which should form part of the context for the guidance.

There was a broad welcome among most respondents for the key principles underlying Hall 4. Although some respondents welcomed all of the key principles without comment or reservation, most identified areas either of a general or specific nature which, in their view, required amendment, clarification or amplification. Very few respondents were against the key principles underpinning the refocusing of the core programme.

A key area of concern for a number of respondents was that the Draft Guidance appeared to be based on the assumption that parents would cooperate with professionals and take part in the programmes set out.

A range of issues were raised about the proposal to target more resources towards vulnerable families. While many respondents supported this in principle, there were also concerns that, for example, the reduced levels of contact proposed would make it less likely that some vulnerable children would be identified. There were also concerns expressed about the impact of the refocusing of the programme on children receiving only the minimum core programme and the likelihood that issues would be identified. The observation was made that, in most areas, virtually any child could be vulnerable, and that families' circumstances change over time. There were also concerns expressed by some respondents that the proposals may be stigmatising.

Although not the subject of this consultation, there were mixed views about the Family Health Plan, referred to in the Draft Guidance. Some respondents welcomed this concept, while others had a range of reservations (including what was perceived as a lack of detail about the Plans, a lack of clarity in links to other documents, the nature of the ownership and location of the Plans, and the extent to which Plans could be completed within the timescales set out).

HEALTH PROMOTION

Many respondents welcomed the proposals relating to health promotion, although in most cases, qualifying one or more specific issues. Some respondents questioned the evidence base for the proposals, and were critical of some of the actions set out. A range of gaps were also identified in the proposed work, with some further areas identified as requiring more emphasis. Some respondents also suggested that more emphasis could be placed on work with very young children within the Draft Guidance. In terms of implementation, some respondents identified that there was, in their view, a lack of detail about the way in which the work would be taken forward. Although there was a good level of support for the recognition that the "primary responsibility for children's health rests with parents", a number of respondents identified issues with this, particularly relating to the extent to which this assumption could be taken to apply to all families.

There was widespread support for the view that additional support should be provided to parents. Concerns were, however, expressed about the means of delivery of information.

There was qualified support for the view that staff in a range of settings are well-placed to identify problems and to deliver advice. There was clear support, however, among some respondents for the approach of identifying a named practitioner who would liaise with each establishment and would have a highly visible role supporting other staff.

A number of respondents specifically welcomed the focus on Health Promoting Schools although suggesting that there should be more focus on this throughout the Draft Guidance. As with other proposals, there was concern that some children could be missed. There was also a concern that the number of Public Health Nurses available would not be adequate.

Oral health

A range of suggestions were made by respondents about developments in current provision. It was also suggested that more could be done to encourage dentists to take on NHS patients. As in other areas of the Draft Guidance, respondents also expressed some concern that the proposals would run the risk of failing to pick up on the risk factors for some children.

Diet and nutrition

There was support for the inclusion of diet, nutrition and exercise within the Draft Guidance from a number of respondents. Some respondents also identified the relationship between inequality and diet, nutrition and exercise as a wider issue which would also have to be addressed.

SCREENING AND DETECTING PROBLEMS

There was a general acceptance of the screening programme among a range of respondents, although some respondents identified gaps and areas requiring strengthening. As with other areas of the Draft Guidance, a concern was expressed by a small number of respondents that some children would not be identified by the means suggested.

There was support expressed by some respondents for the principle of care pathways. A number of respondents suggested that there would be benefits to having a national approach.

Hearing screening

There was a general welcome for the proposals set out in relation to hearing screening, although some reservations about their implementation were also expressed. There was strong agreement for the ending of distraction testing and its replacement with universal newborn hearing screening, although mixed views were expressed about the school entry hearing sweep test.

Vision screening

There were similarly mixed views about the proposals for vision screening. While some respondents welcomed these unequivocally, others expressed reservations. The main reservation relevant to the consultation related to the timing of screening. There was criticism of the proposal to offer screening only in the pre-school year. A main area of concern expressed was the perceived shortage of orthoptists and the impact of this.

Developmental disorders and disabilities

While there was broad agreement that routine screening for disorders should cease, there was also a strong view that there needs to be vigilance among staff in order that disorders are detected as early as possible. The main concern with the approach reflected in the Draft Guidance was in relation to the overall volume of core contacts.

Information for parents about screening and responding to parents' concerns

There were mixed views about the standard form of words recommended in Hall 4 and reproduced in the Draft Guidance. There was, however, a strong view that there will be a need to provide information to parents and carers about a range of issues. There were varying views expressed about the role of parents in relation to identifying disorders, and whether or not the assumptions underpinning the guidance were tenable.

CHILD HEALTH SURVEILLANCE - INFANCY AND PRE-SCHOOL YEARS

A range of comments were provided on the child health surveillance proposals for infancy and pre-school years.

The core programme of contacts

There were mixed views about the core programme of contacts as reflected in the Draft Guidance. While some respondents welcomed the changes, others were concerned about the reduction in contacts proposed for some children. A number of respondents identified that there may be children whose needs are undetected and there were comments about the difficulties in tracking changes in family circumstances. There was also concern expressed by a range of respondents that some dental checks do not appear in the core programme. Similarly, there was also a concern that the notification visit, seen as valuable by some respondents, does not appear in the core programme. A number of respondents suggested that there should be specific mention of mental health issues.

There was also a view among some respondents that the Draft Guidance is unrealistic about what could actually be achieved in, for example, the first 24 hours. There was also specific concern raised about the impact of the new GPGMS contract on the programme.

Contact at 7-9 months, 22-24 months and 39-42 months

There were mixed views expressed about the proposals made in relation to the contacts at these stages. While some respondents noted their satisfaction that these were to be reviewed or phased out, others were concerned about the lack of frequency of contact, the perceived difficulties in forming relationships with families and the concern that some children would be missed. Similarly, there were also concerns expressed about the reliance on parents and non-health professionals to detect problems. Although there was support for the Universal Health Promotion Point at age 2, there was a view that this should be part of the core programme.

CHILD HEALTH SURVEILLANCE IN SCHOOL AGE CHILDREN AND YOUNG PEOPLE

A range of comments were provided on the child health surveillance proposals for school age children and young people.

The core programme of contacts

There were mixed views about the proposals. While some respondents welcomed these without reservation, others made a series of comments, many covering broadly the same areas as those made in relation to the pre-school programme. The most commonly expressed concern was that the Draft Guidance does not deal with the issue of children who do not attend school, or whose parents do not engage with either the school or the health system. A number of specific concerns were expressed about the role of GPs.

Identifying problems and providing support

A number of respondents expressed support for the provisions of the Education (Additional Support For Learning) (Scotland) Bill, particularly the change in terminology.

The role of school nursing

A number of respondents offered general support for this section. Some respondents suggested that the school nurse could play an enhanced role in relation to both the detection of domestic abuse and in working with school travel and active school coordinators. There was also some support for the Scottish Framework for Nursing in Schools although concerns were expressed over capacity issues.

Transition

A number of respondents actively welcomed the inclusion of a section on transition.

Independent schools

A small number of respondents specifically welcomed the references to independent schools. It was also noted that some independent schools are registered with the Care Commission and are already covered by the National Care Standards. It was also noted that these schools should be included in the circulation of information and guidance.

TARGETING SUPPORT FOR VULNERABLE CHILDREN

Most respondents agreed with the principle of targeting support to vulnerable children, but most also had some reservations either about how this would work in practice, or about the impact on, for example, those receiving only the minimum core programme, or those whose circumstances changed over time.

It was suggested that there would be a need for a mechanism for the allocation of resources which is seen to be fair at a national level, although respondents from Glasgow and from rural areas made a range of points in relation to the difficulties facing service providers in these areas.

Some respondents expressed concern that the proposals imply a relocation of Health Visitors / Public Health Nurses from a medical to a community setting and a corresponding change in the roles of other professionals, such as practice nurses (although this is not, in fact, suggested in the Draft Guidance). A common concern expressed by Health Visitors and other respondents was in relation to workloads, with some suggesting that they did not agree with the assumption that resources could be saved by undertaking less routine screening.

Assessing vulnerability

A range of comments were provided on the issues raised in the Draft Guidance relating to assessing vulnerability.

Many respondents welcomed the development of a common approach to the definition and assessment of vulnerability and need. A number of respondents were critical of the defined list of groups of children, some taking specific issue with "children of troubled, violent or disabled parents". A number of respondents suggested other groups. A number of respondents took issue with the concept of using geography as the basis for prioritisation, and raised technical issues about the way in which this is done.

Some respondents explicitly welcomed the proposed multi-agency nature of the assessment framework and the recognition that information would be required from many sources, although some made cautionary points about information gathering and joint working.

A point made by a number of respondents was that, in their view, there is currently a lack of tools for the assessment of vulnerability and need (or that tools have significant weaknesses), and that tools are not necessarily used across Scotland, or used consistently, or used by all relevant services in an area. The need for national consistency was raised by many respondents.

There were mixed views expressed about the Family Need Score. While some respondents welcomed the implied use of this within the Draft Guidance, others were more cautious.

Support for families

Relatively few respondents chose to comment on support for families. Among those that did, there was some support for a national approach, although others expressed the view that there is a need for flexibility, and for local discretion.

Child protection

There was a significant difference of opinion among respondents about the impact of the Draft Guidance and the implementation of Hall 4 on child protection. While some respondents considered that the focus within the Draft Guidance on vulnerable children would have a positive impact on child protection, others were concerned about the impact of the reduced frequency of contacts.

Scottish Women's Aid expressed concern that, in the Draft Guidance, domestic abuse was located only within a section dealing with child protection. A number of respondents identified the need for both training and awareness raising, and for the national definition to be adopted.

INFORMATION COLLECTION AND SHARING

A number of respondents suggested that there will be a need for cultural change across services in relation to information sharing. At a more practical level, a number of respondents identified the need for the development of effective protocols.

Respondents identified that staff lack confidence to share information, and suggested that there may have been barriers placed in the way of effective sharing in recent years. Some respondents suggested that there will be a need for national guidance. The importance of communicating policies and practices in relation to confidentiality and data sharing to staff and parents was stressed by a number of respondents.

There were mixed views expressed in relation to consent. Some made the general point that there is a need for "clearer" thinking on the issue of consent, and the need for guidance to be developed, particularly to take account of situations where parents withhold consent.

Child health information

A number of respondents specifically welcomed the establishment of a Children's Information Strategy Group. There was support expressed for the involvement of parents and carers in information about children's health. Some respondents expressed a concern that the suggestions may have the effect of making children's information systems more complex. One of the key issues identified was the need for investment in information systems' development and implementation.

Concern was expressed by a number of respondents about the current lack of information about children, and a wide range of practical and technical issues were raised. There was also a series of concerns expressed about how information would be recorded and shared. As might be expected, a number of respondents raised the issue of the quantity and reliability of data for some children, given the reduced levels of contact proposed.

Effective monitoring

There was some support for the suggestion that standardised records could make monitoring more effective.

The Parent Held Child Health Record

There was support from a number of respondents for a review of the Parent Held Child Health Record. A number of respondents identified the need for both parents and staff to be made aware of the current plan, and for them to be involved in any future development. Specific issues in relation to looked after and accommodated children were also identified.

DELIVERY

A range of general observations were made about the implementation of Hall 4, including the need for adequate resources, flexibility, investment in research, piloting, delivery to be in partnership, training, monitoring and evaluation as well as the need to keep all stakeholders (including parents and carers) informed of developments. There were also concerns expressed about timescales, the impact of low morale, the impact of current staff shortages in key services, and the need to take more account of the disruption which would be caused during the transitional period.

A number of respondents identified that, although delivery is a local issue, there is a need for leadership at a national level.

There were a wide range of comments made in relation to joint working. Among the most common was a general agreement that there was a need for joint working. A number of respondents identified the need for a clear definition of partners' roles and responsibilities, and for parents to be provided with more information about what they should expect from health and other services. There were also suggestions made about the need for guidance about the relationship between the various coordinating bodies active at a local level.

A wide range of respondents also stressed the need for all partner organisations to work closely with parents.

There was general agreement that there would be a need for multi-agency planning to implement Hall 4, although there were mixed views as to whether or not the approach set out in the Draft Guidance was clear and appropriate.

Community Health Partnerships

A number of respondents suggested that it was perhaps too early to judge the potential impact of these on the implementation of Hall 4. A number of respondents suggested that there was a general need for clarification of the role of Community Health Partnerships.

Resources

There was a high level of agreement that more funding would be required to implement the changes set out in Hall 4. Some respondents also suggested that some reallocation of resources would be required between areas and there was also concern about the basis for prioritisation and allocation decisions. Some respondents also identified that there would be costs for partner services, as well as a need for investment prior to the implementation of Hall 4, particularly in relation to technology. The need for additional resources for a wide range of individual services was also noted.

One of the key concerns was whether a reduction in the number of routine contacts would free resources to allow targeted work with vulnerable children and families as presumed.

Workforce development

Many respondents identified training and awareness raising as key issues. The issues raised covered virtually every aspect of the implementation of the Guidance, and virtually every professional group. A number of respondents suggested that there will be a need for national coordination of training and awareness raising. It was also identified that it would be important to ensure that effective training is delivered to non-health staff.

Quality assurance

Only a very small number of comments were made about quality assurance. Some respondents simply welcomed this, although a small number of additional suggestions were made.

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Page updated: Friday, April 8, 2005