The Scottish Government

The Reference Group membership is made up of key stakeholders from ADSW, Audit Scotland, CCPS, COSLA, NHS Chief Executives, Scottish Care, the Scottish Housing Regulator, SOLACE, and Scottish Government policy interests. It meets bi-monthly to represent the broad internal and external stakeholder groups and provide considered reactions to the Change Delivery Group/Project Team proposals.

This page will provide details of the comments made by the reference group on the various pieces of work that they have considered.

If you would like to know more about the Reference Group or if you are interested in becoming involved in the group please contact us at NSB2011@scotland.gsi.gov.uk. Also, if you have any comments on the Task Team reports or on the Reference Group's comments we would be happy to hear them. Please e-mail any comments to NSB2011@scotland.gsi.gov.uk.

Task Team Interim Reports

The Reference Group commented on the interim reports that had been produced by the five Task Teams that are taking forward various parts of the project.

These comments will be considered by the task teams when they are producing their final reports.

• Commissioning New Scrutiny | Interim Report | Comments
• Implementing Scrutiny Improvement | Interim Report | Comments
• Linking Scrutiny and Improvement | Interim Report | Comments
• Standards and Outcomes | Interim Report | Comments
• Working Collaboratively | Interim Report | Comments

• Is it the case that HIS will look at improvement for the NHS and only regulation for independent healthcare?
• There are no clear links between NHS QIS Standards and Scottish Government performance targets. This can bring challenges for NHS improvement focus.
• We need consistency of approach and a level playing field across the sectors. We need a debate on the balance of scrutiny versus improvement in the future. What are we aiming for? Would like to see more emphasis on improvement as we move forward (without losing robust regulation where it is required).
• What do we mean by 'support for improvement'? There are different ways of doing this from issuing guidance to 'hands-on' support.
• There is still an expectation that resources will be moved (from scrutiny work to local authorities). Is there a danger that moving from a regulatory agenda to an improvement agenda means that resources are just moved within the scrutiny bodies (and there is effectively no change in the scrutiny bodies)?
• There are a lot of improvement agendas impacting on the NHS in Scotland and not all of them are the responsibility of NHS QIS. Is there a risk we just add more initiatives to this agenda?
• The recent joint CC and MWCS report had a different impact on different sectors. There were recommendations in the report for a range of agencies (NHS QIS, doctors and pharmacists, local authorities etc) but it seemed as though only Care Homes were identified as being unsatisfactory.
• There is an issue about the capacity in NHS boards to cope with both preparing for scrutiny and releasing people to undertake peer review/scrutiny work. Some units have a relatively small number of people and lack capacity for all this work.
• We are not yet seeing a reduction in the burden of scrutiny so how do we support organisations to be become more self-aware and not miss the obvious?

• Scrutiny should be a positive issue , it should be able to look a the 'holistic' nature of the service user's experience the whole journey. We should not compartmentalise parts of it.
• Providers are not yet feeling the reduction in scrutiny.
• There should be a process for review of scrutiny improvement to help us understand if it has worked.
• Different models of self-assessment used might make it continuity and collaboration difficult to achieve.
• Local authorities can see that they have moved on in the last few years.
• I can't really get a feel for what the new scrutiny bodies will be going in the future which is any different from now - e.g. how will the role of what is currently NHS QIS change?
• Clarity is needed about the role of the new scrutiny body and understanding is required of this role between regulation and inspection/audit and improvement.
• The robustness of the self evaluation the local authority is doing that is important, not what the scrutiny body's self assessment format is like.
• There is too much focus on self evaluation/self assessment and that lots of different models will emerge, leading to a loss of focus on improvement.

• All the work being undertaken needs to be joined up to provide an overall picture of the direction the work is going and to provide assurance that there is cohesion/shared understanding of how the 5 work streams fit together and how they will all deliver.
• There appears to be a mixed 'commitment' to the approach to risk, based proportionate scrutiny which will lead to the overall reduction in activity and cost.
• There is no clear view emerging from the papers about how and when key stakeholders will be engaged in a systematic way; and more specifically who the key stakeholders are?

• We need to fit in to the Scottish Government's objectives for bodies, corporate objective and outcome for individuals.
• The issues are common for NHS and care services but how does scrutiny fit with other performance management arrangements?
• Community Planning Partnerships with Local authorities and NHS partners add further complexity to the landscape.
• An outcomes-based approach will take longer to achieve . It requires different scrutiny methods including more listening to service users. It will need a major shift which will take time to achieve.
• Having minimum frequency of inspections doesn't leave time between inspections to demonstrate improvements.
• Whose role is it to demonstrate the achievement of outcomes - the regulator or the commissioner of services? If it is the commissioner's job then the regulator should not need to do it.

• Local authorities and regulatory bodies need to co-operate too. LA have a regulatory role in commissioning services but LAs are NOT in the list of bodies under a duty to collaborate.
• Will duty to co-operate extend to other bodies and then to service providers?
• Providers are required to give similar information to both Local Authorities and the regulatory bodies. Are LAs duplicating regulatory action for their own reassurance? Does it indicate a duplication of functions? Could it be addressed? would that need regulation or just new ways of working?
• Was this an issue in Crerar that has not been followed up?
• Care of older people will straddle health and care sectors in future. Points to need for more joined up scrutiny.
• We need to see the changes bringing benefits (rather than ore of the same) to make these changes (from the Bill) worthwhile.
• Could we have a goal to reduce scrutiny (but not to start again to establish baselines).
• The financial pressures in the next few years will focus minds.
• We need to focus on service users and consumers. We need to ensure that they are also best serviced by these changes.
• If providers can't afford to improve services because of financial pressures does that mean there is a danger that scrutiny/regulation might increase?
• The potential for an integrated approach to inspection across services and sectors is a positive development and will be welcomed.
• What is happening on complaints - will new bodies simply replicate systems used by existing bodies?
• The future financial challenges will potentially constrain councils and partners ability to improve or even maintain services.