14. Any other comments or suggestions
Question 14: Any other comments, suggestions.
14.1 The final consultation question invited any further comments or suggestions. Many respondents took the opportunity to reiterate their main points already made in relation to previous questions. Some provided background information on their organisation. Several described how they had consulted across their organisation in preparing their response, demonstrating a wide engagement over and above the 499 responses submitted.
14.2 Amongst the responses to the full consultation and the easy-read version, emerged a number of broad themes, outlined below.
Support for the Standards
14.3 There was considerable support for the Standards as drafted and an appreciation of what was viewed as the thorough and thoughtful development work which had led to this stage.
14.4 The Standards were perceived to be a potential tool for partnership working, underpinned by a shared understanding between partners of expectations of provision. They were seen as helping to highlight where services need to join and work together for the benefit of service users. One respondent commented that the Standards provided a reference point for continual improvement.
Views on further refinements
14.5 The Standards were viewed by some respondents as requiring further editing to make them shorter and more streamlined. They were perceived to be overwhelming in detail in places, which some felt was off-putting.
14.6 A small number of respondents considered that some of the statements could appear patronising; one respondent suggested that the text be proofed for potentially discriminatory language.
14.7 A few respondents highlighted what they perceived to be inconsistencies in the Standards. These included:
- Broad statements along with relatively prescriptive statements.
- Mix of "hard" and "soft" aims.
- Focus alternating between outcomes and processes.
- "Jargonise" mixed with "easy-read" text.
- Lengthy statements mixed with concise, short statements.
- Mix of what were perceived to be minimum Standards with aspirational Standards.
- Word "care" used inconsistently, sometimes with "health", sometimes with "social" and sometimes by itself.
14.8 Respondents emphasised the need for definitions in the Standards to be consistent with those used in related contexts, with the term "early years" highlighted most frequently in this regard. Suggestions were made for the glossary to include definitions of "person-centred", "wellbeing", "transitions" and "compassion".
Views on linking with broader contexts
14.9 A few respondents emphasised the need for the Standards to acknowledge broader, related contexts which may have their own regulator and prioritites. An example was provided of pharmacists who have their own new Standards and a different regulator.
14.10 One respondent highlighted the need for those working in related areas to recognise that the new Standards are relevant to them. The example given was forensic medical examinations for victims of sexual assault which may be done in police or other multi-agency premises, and at which healthcare professionals and others must recognise that the Standards are applicable.
14.11 Many respondents identified related guidance and legislation which they considered should be referenced explicitly in the Standards: Excellence in Care; Quality of Care Reviews; Quality Assurance programmes; health and safety legislation and risks; Carers (Scotland) Act to be implemented in 2018; Patient Rights (Scotland) Act 2011; and the current review of health and social care targets and indicators.
14.12 A recurring theme was that implementing the Standards should be assessed against the backcloth of limited resourcing and different financial priorities across different regions.
Views on balances and tensions
14.13 There were contrasting views on the universal approach adopted by the Standards. Whilst a few respondents welcomed this as simple and comprehensive, others considered that this was too broad-brush and masked the complexities of the "diverse landscape" of health and social care provision.
14.14 Several respondents remarked on the balance of focus on health care and social care in the Standards, with a recurring view that they appear weighted towards social care. A few respondents suggested that the Standards should be aligned with the Health and Social Care Delivery Plan (Dec 2016).
14.15 Views emerging from a few of the engagement events were that there may be some conflict of interest between professional guidance and the Standards. The example of infection control vs child protection was given. Questions were raised over how the Standards would fit with various Codes of Practice.
14.16 One respondent considered that the Standards were a mix of Guidelines and Standards, and sought clarity on this.
14.17 The person-centred approach, and in particular the drafting of the Standards in the first person, led a few respondents to suggest that a key gap in the Standards is reference to supported decision-making for people with dementia, incapacity, and those with learning disabilities.
14.18 A related issue was raised by one respondent from the voluntary sector, who suggested that gathering evidence to demonstrate compliance with the Standards may be affected by individuals' capacity and the various safeguarding issues that surround them.
14.19 A common view was that the Standards are generally applicable, but will need to be implemented in a meaningful and systematic way to ensure effectiveness. Effective implementation was viewed as including high quality commissioning, high quality monitoring of provision, and robust inspection approaches.
14.20 Several respondents raised issues of future inspection of services and provision, with recurring views being that inspectors will need to update their training and methods to accommodate the new Standards and their universal approach; there will need to be a process for agreeing which Standards are relevant to which service; and some Standards will need further description to make them measurable.
14.21 Many respondents emphasised the need for thorough preparation before the launch of the new Standards. The challenges ahead were acknowledged with requests made for an adequate lead-in period and robust implementation strategy.
14.22 A recurring view was that the Standards need to be accessible and "portable". Different formats were envisaged to enable inclusive access, along with the development of appropriate educational resources to underpin and support implementation.