Appendix B - Key Stakeholder Views
1. Department of Health (England)
1.1 DH liked the Codes of Conduct and Practice for employees and employers, considering them effective and useful documents. They approved of the style and language.
1.2 Their biggest concerns lay with the induction standards. They considered that the principle behind the standards was good, but they may be too far-reaching for lower levels of staff, e.g. are HCSWs expected to seek information on health and safety, or should they take notice of information provided and check their understanding of it? Similarly, can they evaluate and reflect on their knowledge and skills when they may not have much at this level? The principle was felt to be good, but it may not match the level of staff.
1.3 Covering all levels of staff was their biggest concern, wondering whether it was possible to write standards which adequately covered all four levels. Something that covered level 4 could be considered too ambitious for staff at level 1, and equally something that covered level 1 would not be appropriate for the more advanced work of staff at level 4.
1.4 DH feared that lengthy induction processes could put potential recruits off, as it would be costly for employers, and burdensome for employees. One month's training was considered the most appropriate time-scale for training and induction.
1.5 DH wished for the greatest read-across between health and social care, as this would be most relevant to the nature of healthcare support workers' work. This needed to be reflected in the wording and the application of the standards and the codes of practice and conduct.
1.6 A number of regulation-based issues were also raised, such as who would be responsible for supporting workers through induction training, and whether or not the standards could be adapted to apply to employers and employees out with the NHS. Should the standards be adopted in England, DH would not be able to direct the KSF sub-group of NHS Employers to apply them, as governance arrangements are different in England.
2. The Department of Health, Social Services and Public Safety in Northern Ireland ( DHSSPSNI)
2.1 The Department of Health, Social Services and Public Safety in Northern Ireland ( DHSSPSNI) felt that the draft code for employees was too vague in places and not always presented in plain English.
2.2 The DHSSPSNI felt that some of the references in the code of practice for employers were unclear.
2.3 The organisation felt suggested that the code of practice for employers needs to be read in conjunction with employers' responsibilities with health and safety and pay and employment. The code raises the question as to what is hoped to be covered by these standards in addition to what is already in place?
2.4 It was felt that there is duplication between the code of practice for employers and what already exists, and that the area regarding supervision and assessment in relation to regulation would bring extra responsibilities.
2.5 The DHSSPSNI considered the draft standards to be overly comprehensive, but also that they were largely easy to understand for the employee. They were equally easy to understand for the employer, but links to KSF need to be made clearer.
2.6 In regard to the performance criteria, it was felt that the level of accountability expected of HCSWs appears too broad, and that the statements should be focused to the range of duties in which the HCSW will be engaged.
2.7 3 months was not seen to be a realistic timeframe for a HCSW to be able to achieve the standards in. It was considered that induction processes need to be strengthened and accompanied by ongoing training and development for staff. With this in mind, 6 months were suggested as more realistic.
2.8 The DHSSPSNI asked how the framework for the standards linked to KSF, and asked what arrangements would be put in place to address renewal of registration and notification cases. They considered that the Vetting and Barring scheme has the potential to cover the necessary safety considerations for people working in HCSW roles. The organisation also asked what added value the standards bring to the existing NHS standards covering public safety aspects under Clinical and Social Care governance?
2.9 Overall, the DHSSPSNI considered that yes, all three sets of standards should be mandatory, and should cover the private/voluntary/independent sectors also.
3 The Health Professions Council ( HPC)
3.1 The HPC welcomed the publication of codes of conduct for HCSWs, employers and induction standards for healthcare support workers.
3.2 In their opinion, simple, clear standards are vital for public protection, and standards are a clear demonstration that those involved in treating the public are committed to acting in their best interests. The standards allow the public to understand what they can expect of a HCSW, and allowed the HCSW to understand what is expected of them.
3.3 HPC considered the draft code of conduct for HCSWs to be written in clear, accessible English, which would be easy to understand for the target audience. The HPC feel it is helpful and appropriate for there to be one common code for all healthcare support workers.
3.4 The draft code of conduct for HCSWs includes many of the principles core to healthcare regulation emphasised by the HPC, and shares a strong common ethos with codes of conduct produced for professionals. In particular, it was felt that the key messages of personal responsibility and accountability were well expressed in the draft code of conduct for HCSWs.
3.5 The HPC felt the code of conduct for employers of HCSWs was comprehensive and appropriately focused on the responsibilities of employers to ensure the suitability of applicants, provide opportunities for training and development and have in place mechanisms for dealing with performance concerns.
3.6 The induction standards were seen to be comprehensive and easy to understand for both employers and employees. The principles expressed in the codes of conduct are helpfully built upon as clear induction standards and helpfully referenced against the core dimensions of the NHS Knowledge and Skills Framework ( KSF).
3.7 The HPC also considered that the induction standards provide a useful way for employers and employees to structure an induction period which meets their individual needs. It was felt that it was therefore useful that the induction standards are not prescriptive about how they might be met.
4. Nursing and Midwifery Council ( NMC)
4.1 The NMC found the language in the draft code to be, for the most, user friendly. However, it can sound patronising at times.
4.2 The NMC asked for an inclusion of an explanation regarding the standards that are also expected of NMC registrants in the exercise of their accountability and practice. The NMC is also unclear as to the accountability of the support worker following the delegation of the work that they are expected to undertake. Indeed, an emphasis on the need to fully explain to whom responsibility, accountability and liability falls to in any given situation at any given point in both draft codes and the draft standards was highlighted as imperative by the NMC.
4.3 The NMC considered some of the wording needed clarification, and at times strengthening, to fully put across what the employee is meant to understand from the draft code, such as the full implications of, for example, 'advocacy,' 'confidentiality,' or 'consent', could be in any given situation, in particular such as those concerning children and young people.
4.4 The NMC also underlined a need for record keeping to be established as a key element of regulation, and does not feel that this is not incorporated enough within the draft code for employees.
4.5 The NMC is pleased to see that the focus of the standards is 'primarily on public protection and safety.' However, the NMC would like to see further detail with regard to:
- what quality assurance processes around the mode of training that will be employed
- who will supervise the support workers who have not completed or are undertaking the programme, and equally who will mentor the support workers
- who will assess and 'sign-off' successful completion of the programme
- how those who are not achieving the standards will be identified
4.6 The NMC would like to highlight the importance of workforce planning linking with commissioners and Approved Educational Institutions so that clinical areas are not overloaded with students and support workers all requiring supervision.
5. The General Medical Council ( GMC)
5.1 The GMC considered that, given the stated aim for more formal regulation of HCSWs in the longer term the drafting of these documents is a good opportunity to develop a model which draws on common aspects of existing guidance/codes for other groups.
5.2 The GMC felt that given the existing obligations upon those involved in patient care to maintain consent and confidentiality, and the importance of these key areas, the code of conduct should place more emphasis on HCSWs' obligations and provide more information of these two areas.
5.3 The GMC felt that the draft code for employees seems to be trying to address a variety of purposes and there is therefore a lack of clarity about its status. As drafted, the code of conduct for employees does not make clear the thresholds at which behaviour would be called into question, nor do the induction standards provide an indication of thresholds for breaching the code and any consequences which may occur as a result. If the code is intended to be used in this way, then it is vital that this is clear.
5.4 Given that there is emphasis in these documents on working as part of a team, and what has already been said about consistency across other related professions, it would be useful to include a statement about individuals making themselves familiar with equivalent guidance/codes for their colleagues in other professions. This can be particularly important in multi-disciplinary team environments, or where care is delegated; as it would help the HCSWs understand the obligations upon the other members of the team. An indication in the code to this extent would therefore be helpful and it may be that it would sit well in the code for employers.
5.5 The General Medical Council ( GMC) felt that the code of conduct for employees is written in a way that is intended to be accessible to the majority of HCSWs regardless of where they work and what job they do. This was welcomed, and many of the examples such as 'advocacy', 'sensitivity', and 'consideration', for example, were considered to work well in this format. However, it trying to make the code accessible to all, it was recognised that there are some areas where there is the potential to oversimplify definitions. Particular examples of this are confidentiality and consent. The term HCSW encapsulates a wide range of individuals who will be performing at a variety of levels and will vary in their contact with patients. The code should therefore contain enough flexibility for this variation.
5.6 Whilst the draft code is written to be very accessible, the draft induction standards are therefore less clear. Is there any intention to provide more explanation of these requirements and guidelines? This would make the standard more meaningful, and ensure that HCSWs who did face confidentiality issues would not fall foul of the code.
5.7 One option would be to include separate references to relevant documents regarding consent and confidentiality (relevant to Scotland) in section 5 of the code ('Want to know more?')
5.8 Within the code, there is also a mixture of high level principles, positive and negative statements and more concrete standards, which seems to be due to trying to be accessible whilst at the same time portraying a HCSWs' obligations in the same document. This is particularly evident in the difference between sections 1-3 which are fairly relaxed in tone and section 4 which is much more formal.
5.9 The GMC recognised that although many aspects of HCSWs' responsibilities to service users are covered (dignity, sensitivity and advocacy for example) in the draft code for employees, there is not really much that has been said in the code about public protection. There is more elaboration of this principle in the draft induction standards and it might be useful to incorporate some of this into the draft code.
5.10 The GMC considered the definition of good character to be reasonable.
5.11 In relation to the draft code for employers being sufficiently comprehensive to reflect an employer's responsibilities to service users and HCSWs in relation to public protection standards, the GMC did not consider that there was enough emphasis on public protection standards in the codes and that there should be more.
5.12 In regard to the standards' comprehensiveness, the GMC felt that it would be useful for the standards to include more about the requirements to seek consent and to respect confidentiality.
5.13 Concerning whether or not the performance criteria identified provide sufficient evidence for the achievement of the standards, the GMC considered that there was a mixture of approaches used in the guidance. Some of these are more comprehensive than others and it is unclear from these documents how the criteria should be applied where performance is called into question - do all criteria need to be breached; can a mixture of breaches lead to questions about performance; and are some considered more serious than others? The GMC felt that there should be some clear guidance on how these will be applied in practice. Whilst the GMC recognised that there are difficulties in defining specific thresholds, some indication of thresholds for breaching the code would provide more clarity.
6. Royal Pharmaceutical Society of Great Britain ( RPSGB)
6.1 The Society welcomes the intention for regulation on a Scotland-wide basis to dovetail arrangements with existing UK-wide frameworks such as the Knowledge and Skills Framework (as part of Agenda for Change) and Skills for Health products (for example, National Occupational Standards). The RPSGB consider that in most areas the draft generic standards for HCSWs in Scotland will complement its own existing policies. Whatever regulatory processes are put in place need to be manageable for the relatively large numbers involved in what may not be a stable working population.
6.2 As such, the Society supports the draft Code of Practice for employees, the draft Code of Practice and Conduct for employers, and the draft induction standards.
6.3 The Society sought clarification on whether or not it is intended that the obligation to adhere to the draft codes and standards would also apply to those contracted to provide services to NHS Scotland, e.g. community pharmacy contractors.
3.4 RSPGB commented that it is difficult to comment on the detail of the standards without specific information about who would be responsible for assessing that the performance criteria had been met and the required occupational competence of assessors
7. Scottish Social Services Council ( SSSC)
7.1 The SSSC found the draft codes to be written in a straightforward manner, though the tone could be found to be condescending. The SSSC felt that the code was written in a language different to that used in the induction standards and that having a similar register between the two would be more beneficial to the target audience for ease of understanding.
7.2 The SSSC however did express concern that the draft code was in danger of oversimplifying complex practice issues.
7.3 As the draft code for employees appears to sufficiently cover the conduct expected of HCSWs whatever the context of their practice, the SSSC felt that calling the draft code a code of conduct rather than a code of practice may make it easier to understand for the target audience.
7.4 The definition of good character was considered too subtle.
7.5 The SSSC expressed concern that the draft code for employers focussed more on the employers' responsibilities in relation to healthcare support workers than on their responsibilities to patients.
7.6 The induction standards were considered too dense and not readily accessible for employers or employees. The SSSC also worried how non- NHSHCSWs would be able to adopt the standards, and how these groups of HCSWs could be monitored and assessed. Indeed, it is not implicit in the standards how any HCSW will be assessed or measured. The SSSC consider it essential that the whole workforce grouping across this sector is subject to the same standards. As they currently are, the standards can only be read as aspirational or, at best, useful guidance.
7.7 It is not clear how the performance criteria could evidence achievement of the standards.
7.8 It is difficult to see how induction training could be performing in a meaningful way given the density of the material. The achievement may therefore be superficial.
7.9 The language of the standards is not very accessible and seems to be at the opposite extreme of the language in the Code of Practice for Employees which is more simplistic.
7.10 There is no indication of what recognition will be awarded to staff that are deemed to have achieved the standards, i.e. what is the incentive for them?
7.11 Given all these points, the SSSC are concerned that these standards are not transferable, will have extremely limited value or 'currency' out with the NHS and will not facilitate workforce mobility. For these reasons, the SSSC would not advise that these standards be made mandatory. It is difficult to envisage how these standards will contribute to public protection.
8. NHS Education for Scotland
81 NES considered the draft code to be written in an accessible way and praised the approach used. However, to ensure that the target audience would find the document easy to understand, NES suggested it be 'road tested' by HCSWs before being accepted as a final version.
8.2 NES considered the draft code appropriately expressed, but suggested drafting amendments, in order to clarify meaning and ensure the document would be easily and fully understood.
8.3 NES highlighted the need to strengthen the definition of good character, as outlined on page 13 of the consultation, by adding ' at all times' to the end of the sentence ' someone who is capable of person-centred, ethical, safe and effective practice', to ensure that the requirements of 'good character' were fully understood and appreciated.
8.4 NES noted that the code of practice for employers referred specifically to employers in NHS Scotland and recommended that GPs and other independent contractors caring for NHS patients adopt the employers' code of practice.
8.5 With regard to the induction standards, NES suggested that more explicit reference be made to dignity, privacy and understanding roles within teams. Some of the response team at NES expressed the view that some standards go beyond what a HCSW could be reasonably expected to achieve. A clearer definition of 'supervision' was also called for.
8.6 NES did not feel the language was generally as clear in the induction standards as it had been in elsewhere, and disliked the inconsistency in terminology for patients. Some language was also considered to be confusing and/or complex in the Health, Safety and Security section. A clarification or expansion of what constitutes 'support effective group dynamics' was also called for.
8.7 With regard to the expected timescales considered appropriate for a HCSW to achieve the standards, NES felt that this depended upon the individual's capabilities, and upon the variability of available support. As such, NES suggested that 6-12 months was a more feasible timescale.
8.8 In general, NES considered that the induction standards should be more explicitly linked to the PIN Guideline on Induction. Other comments included suggested changes to wording to make the standards clearer and easier to understand.
8.9 NES considered that the standards should be made mandatory, as this would help them to be prioritised and therefore achieved. NES also believe that it would be advisable to ensure that non- NHS providers providing care for NHS patients are required to sign up to the standards prior to being commissioned to provide services, to strengthen the ultimate goal of public protection in Scotland.
9. Royal College of Nursing Scotland ( RCN)
9.1 The RCN felt the code was easy to understand for the target audience, though some aspects of the language needed to be made more explicit. Some areas of the language could be considered patronising, while in other areas it is too complex. Clarification and expansion on some points of the draft code for employees was also called for, for example in 1.6 there is a statement 'they will show you how…' - it is not clear who 'they' are. It was also felt that diversity and equality should be highlighted more. The appendix on the draft standard, in the opinion of RCN, was written in a different style to that to the draft code yet is expected to be used in the same way. Protection from abuse and identification of vulnerability and abuse also need to be explicitly highlighted.
9.2 RCN also expressed their concern over how the achievement of the standards was to be measured.
9.3 They felt the definition of good character was adequate.
9.4 The RCN were pleased that the draft induction standards tied in with the KSF, but expressed concern that the language was more complex than is in the draft code.
10. UNISONUK
10.1 UNISON does not support employer level regulation, though it is acknowledged that a pilot assessing this method is being undertaken in Scotland. UNISON does not believe that this will deliver public safety.
10.2 UNISON supports the call for a code of conduct; indeed the organisation launched its own code last year. UNISON would be happy to help develop the draft code. UNISON also believes that irrespective of the occupation or profession, all members of the healthcare team should be working to one single standard. UNISON would welcome the involvement of the Council for Healthcare Regulatory Excellence take a lead in bringing all of the regulators to facilitate this in conjunction with representation from the trade unions and four countries.
10.3 UNISON would insist every organisation should have a nominated manager responsible for ensuring that standards and the code of conduct are adhered to and that sufficient training is provided with the appropriate amount of paid time off in order to ensure that new registrants are fully conversant with their responsibilities.
10.4 UNISON supports the use of the electronic Knowledge and Skills Framework across all employers, and would urge a national approach to this in line with the Agenda for Change agreement. Also the establishment of appraisal competencies complementary to the KSF
10.5 UNISON supports the use of the KSF in establishing standards in the draft code of practise for employees. However the standards have to be relevant to their role and the level of responsibility that they work to.
10.6 UNISON would argue for a single standard for good health and character in the code for HCSWs. However the organisation would again argue for a single standard across the regulators and that the standard must be reasonable and reflective of society.
10.7 UNISON calls for the introduction of a qualification escalator to support the code of standards based upon a programme that progresses from level 1 to 4 of the higher education standards.
10.8 UNISON calls for NVQ two to be the minimum standard for all HCSWs at the point of renewal. The feedback and surveys Unison have undertaken across the countries relating to this issue has indicated less than 50% of HCSWs have had appraisals and NVQ/ SVQs, also individuals indicate that their NVQ/ SVQ programme is regularly delayed as their organisations have too few assessors. Based on this UNISON would reiterate that as an interim measure in order to prioritise patient safety induction should be the minimum standard for entry and that the link to vocational qualifications should be at the point of re-newel. This would give the services adequate time to deliver the education pathways and improve the safety of patients/service users. In the longer term UNISON would like to see consistency with the social care council which requires vocational level 2 at the point of entry, given the numbers of HCSWs throughout the UKUNISON believe that this is more realistic in the longer term.
10.9 UNISON calls for the introduction of an independent registrar who will develop and supervise the employee and employer codes of practice.
10.10 UNISON believes that as an initial stage, the voluntary system of registration similar to that adopted by the HPC when a new profession is entering it should be used.
10.11 UNISON calls for this voluntary register to be replaced by registration by the HPC.
10.12 UNISON calls for equality in the registration process in line with other health professionals.
11. UNISON Scotland
11.1 UNISON Scotland recognises the need for public protection and that all staff whose work impacts on the care of patients should be subject to proper regulatory arrangements. UNISON highlights the need for the Scottish Executive to fully fund any additional training programmes in order for the relevant staff to achieve any new set of regulation, and add their concern that such costs should not fall on staff, many of whom are low paid, working part-time and employed on temporary contracts. It is a concern to UNISON that this issue is not addressed in the consultation.
11.2 UNISON Scotland believes that the regulations should be on a Scotland-wide basis. For this reason, UNISON Scotland would not support employer-level regulation. UNISON Scotland considers that this would create a conflict of interest between the employer, who has its own interests to preserve, and the interests of the individual employee. UNISON would recommend that there is an independent regulator, as they consider an employer cannot fulfil that criterion.
11.3 UNISON Scotland also deem as essential the monitoring of standards and codes of conduct, for regulators and employers, for consistency of application and to be equally applied to all healthcare staff.
12. The KSF sub-group of NHS Employers (England)
12.1 The KSF sub-group of NHS Employers welcomed the links made with the NHSKSF, and considered the public protection standards workable and appropriate from both an employee and employer viewpoint. However, they considered the performance criteria long, detailed, and therefore less workable.
12.2 The KSF sub-group of NHS Employers welcomed the links that had been made between these proposals and existing staff governance arrangements to ensure that staff are well informed and appropriately trained, and that employers are legally accountable for this.
12.3 The KSF sub-group of NHS Employers particularly praised the emphasis that had been placed in the proposals on the need for an effective means of supervising and assessing HCSWs' practice, for the provision of appropriate induction training; the need to recognise and use the workplace as a key area for individual development, and to link development opportunities with team and individual learning plans.
12.4 However, it was not felt that it was clear from the proposals whether there is a plan to assure the quality of employer arrangements, something the KSF sub-group of NHS Employers would recommend.
11.5 It was agreed that a centralised, mandatory, occupational register would contribute to public protection and help raise the profile of the existence of, or in some cases the need for, statutory professional regulation.
13. The Care Commission
13.1 The Care Commission welcomed the standards, but considered they should also be required for the independent and voluntary healthcare sectors, as well as the NHS. The Care Commission also considered that the standards should also consider that integrated service delivery is appropriate where social care and healthcare and jointly provided within the same care settings. As such, provisions for the regulation of social care must be taken into consideration, as well as the regulation of healthcare. The Care Commission thus consider that the standards should be extended to cover health and social service support workers and staff.
14. The Society of Chiropodists and Podiatrists ( SCP)
14.1 The SCP welcomed the creation of national standards for healthcare support workers, as it believes that this will help ensure that the public have confidence in the full range of staff working for NHS Scotland.
14.2 The SCP feels however that the definition of healthcare support worker is not generic enough, and feels it could be re-worded to clearly show who is and is not included in the definition of healthcare support worker. A list of the types of workers included in the definition is suggested as a possible way of dealing with this.
14.3 The SCP also echo previous comments received that the draft codes and standards should be expanded to cover more than simply those employed by NHS Scotland, but those employed in the independent and voluntary sector also.
14.4 Also echoed is the common sentiment that the induction standards document, in particular the section relating to performance criteria, is too lengthy to be easily digestible, and ought to be made more concise and user-friendly.
15. The Chartered Society of Physiotherapy ( CSP)
15.1 The CSP welcomes the introduction of common standards to which support works and managers will work and agrees with an approach that seeks to ensure all support workers achieve a recognisable minimum standard, transferable across employment settings.
15.2 As the CSP has had a Code of Conduct for Physiotherapy Support Workers in place for a number of years, the Society feels that the regulatory standards detailed in the consultation should signpost these to help workers recognise that good practice emanates from adherence to both the regulatory and the professional codes.
15.3 The CSP also echo the sentiment that the standards, and any centralised mandatory register, should be applied to all healthcare sectors and not simply the NHS. The CSP state their concern that simply regulating those working within the NHS could lead to two-class system of support worker.
15.4 The need to resolve who will assess if and how healthcare support workers have achieved the standards must be addressed. Equally, whether monitoring of employers' compliance with its own code of practice will take place, and by whom, needs to be established.
15.5 The CSP also consider that the codes and standards should be checked for compliance with the Plain English Campaign standard.
15.6 The CSP considered that 3 months was sufficient time for a healthcare support worker to achieve the standards by. However, it was recognised that the time needed to achieve the standards will vary from person to person, depending on their existing knowledge, previous experience and capability. As such, it might be possible for some workers to achieve the standards sooner than 3 months whilst others may require longer.
15.7 The CSP agreed that all three sets of standards should be made mandatory, though it will "require considerable attention to detail when devising systems and procedures for monitoring and for taking actions against those who do not meet the code or standards."
16. The Office of the Chief Nursing Officer, Welsh Assembly
16.1 The office of the CNO of the Welsh Assembly queried as to who would monitor and police the draft codes and standards - in the absence of a National overarching body the code will be open to employer interpretation and implementation.
16.2 Provisions in the standards should be given for employers regarding staff members who are considered either to have broken the code of conduct or be incompetent, and resist or fail to improve, who resign from their posts before any disciplinary measures can be brought against them. The office considered this a serious loophole that would need closing.
16.3 The office queried how support staff will know if they are acting outside their area of competence? Also highlighted, as in many other comments, was the need for a clear indication wherever necessary of the accountability of employees and/or employers in any given situation.
16.4 Acknowledgement of and adherence to the Disability Discrimination Act was called for.
16.5 The office of the Welsh Assembly suggested induction should be done in 3 months.
17. Association for Perioperative Practice ( AfPP)
17.1 The AfPP welcomed the draft codes and standards, recognising their value in attempting to safeguard patients and uphold public safety by informing all professions, employers and the public of the standard of conduct required of support workers when providing care.
17.2 The AfPP felt positively about all aspects of the draft code of conduct and practice for employees. Its only comments were to change wording to be more consistent, specific or clear. Clearer definitions of terms used such as 'advocacy' and 'accountability', etc, were asked for and a glossary of such terms was suggested.
17.3 Regarding the draft code of practice for employers, the AfPP also responded very positively. It suggested mentoring and adequate support for a HCSW's induction period, with sufficient time dedicated to the achievement of the codes and standards. The workplace as a learning environment was championed.
17.4 The AfPP felt the draft code of practice for employers to be concise, and highlighted the employer's responsibilities and duties as stated by existing systems of healthcare governance. AfPP recommended that each organisation identifies a Board or Human Resources Lead to assess, implement, monitor and evaluate the implementation of the code of practice. The Lead person will then be able to report centrally to NHS Scotland whether the piloted system is effective.
17.5 With regard to the standards, the AfPP are supportive of the idea that all assistants and support staff are regulated as a single group within a single framework based on KSF dimensions. However, AfPP recommend there is recognition of discipline specific standards which could be formulated locally to enhance the code of practice.
17.6 When answering whether or not three months was sufficient time for a HCSW to achieve the standards, the AfPP recommended that six months may provide a more realistic time-frame, allowing for greater flexibility towards available resources and the need to identify learning needs adequately. The AfPP also established that there is a need to link support workers development and assessment to their completion of the Health Awards where employers are committed to their employees pursuing a national standard/benchmarked programme of study.
17.7 With regard to general comments, the AfPP considered that the terminology relating to patients changes throughout the document, and should be changed to one consistent term.
17.8 AfPP also recommends that induction assessment criteria and results be made available to all Health Boards, to facilitate worker migration and prevent duplication of the generic elements of the induction programme. This would also enable both the HCSW and their new employer to identify the specific learning needs for the new post.
17.9 The AfPP considered that yes, the standards should be mandatory, but whether or not the standards will involve a contractual arrangement between employer and employee needs clarification.
18. "Fair For All"- Disability
18.1 "Fair For All" welcomed the development of standards to enable and support healthcare support workers to promote good practice in carrying out their work. The organisation was pleased to note that equality and diversity had been recognised in some of the standards.
18.2 With regards to section one; the draft code for employees, "Fair For All" agreed that the language and format of the guidance was appropriate for the target audience. With regard to the presentation, it was recommended that the text should be produced in Ariel font size 14 to make it accessible to a wider audience, and an easy read section should be produced to enable access to those with learning disabilities.
18.3 It was felt that the standards in the draft code for employees did not refer to equality and diversity beyond the standards on objectivity and dignity. Consequently the standard on objectivity requires to be rewritten instructing healthcare support workers to provide equal treatment to all, irrespective of their race, disability, gender, sexual orientation, age, or religious belief. Furthermore, "Fair For All" recommended the addition of a footnote, in which it was explained that the law stipulates that disabled people receive equality with respect to goods and services, a law which applies to the NHS.
18.4 In section two, on the draft code for employers, "Fair For All" praised the inclusion of guidance that requires healthcare support workers to be cognisant of relevant legislation as this could allow for the NHS to provide workers with information on the Disability Discrimination Act. It was felt that the guidance in this section should require the NHS to use the Scottish Executive Equality Impact Assessment Toolkit ( EQIA) to ensure that their recruitment policies are not excluding disabled people from accessing work. This section of the standards should also alert employers to the need to monitor its workforce of healthcare support workers to ascertain the extent to which it is diverse and reflects the community.
18.5 In reference to section three on the induction standards, "Fair For All" were pleased to see the list of criteria listed under the heading of equality and diversity. The standards were considered to be comprehensive and extremely welcome. It was of concern however that the language only seemed to reflect race, as seen through the repeated use of words such as 'culture', 'beliefs' and 'values'. In the interest of clarity Fair For All ask that it is ensured that the standards are applied to all strands of equality and diversity groups.
18.6 "Fair For All" recommended that all healthcare support workers receive equality and diversity training. The recruitment and retention of disabled employees should be monitored and any barriers removed, and the Equality Impact Assessment Toolkit should be used to assess the impact of NHS policies and practices on disabled healthcare support workers.