EQIA for Improving Wellbeing and Working Cultures (IWWC)

This EQIA supports the Improving Wellbeing and Working Culture (IWWC) publication (2024). IWWC sets out the ambition to enhance working cultures across our social care, social work and health workforce.


The Scope of the EQIA

IWWC was published in July 2024. An initial EQIA screening, undertaken in March 2024, concluded that no EQIA was required for the IWWC publication on the grounds that it is not a policy or strategy. The Scottish Government has reviewed this position and concluded that an EQIA for the IWWC is necessary. This EQIA is therefore retrospective.

In the early stages of developing IWWC, we reached out to Stakeholders with drafts and sought their feedback on any potential issues/amendments – whilst we did not directly request feedback on Equalities issues, we did engage extensively.

• Groups and areas assessed (protected characteristics and the three PSED needs) Clearly define the protected characteristics and the three PSED (Public Sector Equality Duty) needs that were considered in the assessment.

N/A – As noted, we sought general feedback across the areas/policies. Our engagement followed confirmation that we did not require an EQIA so there was not a direct ask for feedback re protected characteristic s/PSED.

• Approach and methods used to assess impact Explain the methodology used for data collection and analysis, including any quantitative or qualitative methods.

N/A – Officials requested feedback on the draft versions of IWWC from a number of groups with vested interests and considered their comments accordingly. There was no specific EQIA input requested as part of this process. However, equalities considerations were gathered within the context of the “Equality” pillar under IWWC - no equality related issues were raised.

• Details of evidence gathering and engagement Describe the stakeholder engagement process, including details of consultations, focus groups, or other methods used to gather input from affected groups.

We presented IWWC in its draft to a number of governance groups for consideration and feedback and also wrote to interested stakeholders inviting their input. The below table encompasses all of the feedback we have received to date.

Forum/Group Date Feedback from Forum/Group
HRD Secretariat 02/06/23 Welcomed the shift away from a Strategy. Concerns raised on the proposal to introduce a diversity target and issues around the talent pipeline and impact on succession planning. Calls for the Staff Governance Standard to be updated and concerns that developing a Charter/Pledge would be confusing for NHS staff.
SPF Committee 06/06/23 Welcomed the shift to a Framework and Action Plan. Suggested including more on what we are doing to support staff with disabilities. Also suggested including the Anchors Workforce Commitment for health and social care. These are in hand. Also concerns raised about long term funding at national and local levels and the impact this could have on work to support staff on wellbeing, leadership and equalities.
Wellbeing Champions 08/06/23 Welcomed the Strategic board as it was felt more governance and assurance is needed. Felt a OfS approach is needed. Strong steer on the need for a standardised approach and resources on Peer Support and Reflective Practice. Will make this clearer in the action plan that this is something we are working on. Verbal feedback at a meeting
Wellbeing Champions 17/08/2023

SG colleagues provided an update on the Action Plan/Framework to members. Following this she agreed to share the document with the group in order to gather their feedback.

Members asked if there was a timescale for publication of the Action Plan/Framework. Colleague explained that there is no formal deadline for publication at this stage, however, the Action Plan/Framework feeds into the National Workforce Strategy which provides the governance structure of the work. The next stage of the Action Plan/Framework is to produce a charter that SG will be engaging with key stakeholders and staff groups across H&SC.

A&A have been planning to produce their own local strategy, as such, they wanted to know why the national strategy has been replaced with the Action Plan/Framework. Colleague provided the rationale for this change which included the threats of industrial action and significant changes in government including a new First Minister and Cabinet Secretary. This decision also allowed SG more time to reflect on the wealth of feedback that we have received by engaging with stakeholders.

Verbal feedback at a meeting

National Workforce Forum 13/06/2023

Feedback from SG colleague regarding union involvement.

Also need to consider the intersectionality with other statutory committees discuss these issues e.g. SWAG, SPF. Informed them that at the moment we are keeping all updated about change to strategy but will need to consider a clear and consistent governance route.

DD offered to discuss offline about use of the PMO in his Division to better coordinate reporting, governance and comms.


Verbal feedback at a meeting

HRDs 27/072023

Targets on EDI a big issue for the majority of HRDs

Boards feel like they will be measured against something they cannot delivery on , don’t want artificial target – would rather have something to aspire to and sustain rather than unrealistic target. Seen as a crude measure if singular target for all boards, rather than varied big/small/city/rural – keen with comments from SG colleague about reflecting community that boards serve. Also keen to understand what this means for wider protected characteristics

Concern about ‘hitting the target and missing the point’ – query if focus on singular characteristic is inclusive?

Interest in general principles, approaches, allyship interventions and mainstreaming/baselining

Action plan over strategy seen as a positive move – strong agreement from all speakers

Some asks about other SG work and how that links such as now concluded Collective Leadership Scotland interventions

Ask around what we are targeting in EDI space – eg gender pay gap issues

EMF member – disagreed with general feel on targets , fed back EMF views on career advancement issues so sees greater issues that mean targets needed . Opportunities to learn from organisations like RAF where positive action has been both good, and seen as positive discrimination

Lessons from orgs like SAS and the 50/50 by 2020 target – SAS was very male 10+ years ago, now more balance, more age inclusive. What good practice is in the boards already in different areas, EDI not new, but what can we learn from and improve?

See EDI not a case of not doing anything – but there are places we all need to do better so like mentions of existing good practice.

Chief Executives – CE Leads 03/08/2023

Framework itself doesn’t necessarily talk to the audience – it feels quite corporate and jargonistic. Is there a way we could frame it at each section for the workforce ie what this means for me / what this means for teams / what this means for organisations? Colleague at NES can share an example of this type of style if that would be helpful.

How confident are we that the IWWC Framework and action plan reflects the current wellbeing support needs of our h & sc workforce? Feedback from staff suggests that what would improve wellbeing is properly staffed teams.

How does Safe Staffing fit in with supporting wellbeing and culture?

The pledge is welcomed however if we are pledging as organisations and employers to meet staff needs there may be times when we cannot do that – how do we manage expectations?

I am keen to understand more about the pledge/charter – as the reality is for staff to buy into it for it to fly, it has to be meaningful locally

What are the opportunities for the charter to read across to any future revision of the Health & Social Care Standards?

How do we encourage staff under their individual responsibilities to raise concerns where practice is not of standard?

We talk about team (which is important) but we need to recognise that MDTs will have multiple professional disciplines, identities and potentially employers – how do we ensure there is consistent and equitable approaches to wellbeing, culture and support?

Action plan sets out clearly what is in progress/planned re: to take forward the national deliverables – there is something about what is expected of each Health Board, what’s for local discretion and what’s the minimum standard that is expected to be place (recognising all organisations start from a different place) in each of these important areas – wellbeing, leadership and equality

The attachments reference sharing good practice and innovation and it would be really helpful – given there is so much of this across Scotland – to more clearly signpost to this learning, innovation and good practice so it is easily accessible to us all.

HSCMB 13 September deadline for paper

“Is the paper going to HSCMB for noting only? I suppose the question is do we know if any specific directors have a particular interest. Is there anything we might want to note about timeframes? Would anyone have any particular objections to splitting up as you propose? How does the subject matter relate specifically to the work of HSCMB and directors - so is there a link here with Directors commitments to have anti-racist objectives etc? Anything on leadership and culture that is relevant to current system challenges – NHS FV etc? What’s the key selling point in terms of the contribution the framework etc will make?”

Formal, written feedback

Joint HSC Steering Group N/A

Good to see that excellent leadership is acknowledge as a key component of staff wellbeing in the workplace.

Excellent to see SG take a lead in driving improved equality within the workforce including for minority ethnic staff and staff with disabilities who we know have poorer experiences of working in, and advancing in the NHS.

Delighted to see the commitment to all of the National wellbeing initiatives being re-affirmed. This reflects the good outcomes and excellent feedback that NES has been able to report to SG for the Workforce Development Service (now known as Psychological Therapies for the Workforce) and the ongoing need to expand this service.

By continuing to fund the National wellbeing initiatives SG has modelled a clear understanding of the importance of staff wellbeing and the importance of providing excellent evidence-based services for staff who are struggling with their mental health.

“To consider where we can champion local activity at a national level” This section could perhaps be highlighted further up in the table below the National offer section. This section is key in acknowledging how much of the work is currently being done by the Boards and is important in highlighting the importance SG places on this work, given that most of the funding for these services within Boards is temporary funding found during the pandemic and now under threat.

Personal Assistant Wellbeing Subgroup N/A

The importance of recognising and including Personal Assistants as members of the social care and support workforce and enabling them to be part of the co design of wellbeing resources, training, coaching and leadership development

Recognising and including supported people/disabled people/ carers as employers of Personal Assistants and supporting them to be good employers, leaders, coaches so they can support their employee’s wellbeing.

The importance of PAs being ‘valued’ as members of the social care workforce impacts on wellbeing particularly during the pandemic when they were invisible The importance of being paid fairly impacts on wellbeing and makes it difficult to attract people to the profession.

Ensuring that the Wellbeing Hub ‘talks to’ and is relevant to PAs and PA Employers Ensuring access to Wellbeing Coaching opportunities for supported people/disabled people/carers who are employers.

Understanding the PAs unique position and how difficult it may be to go directly to your employer if you need support with your wellbeing since your employer may be struggling with their own wellbeing.

PAs generally don’t take time off for health or personal development since they know how difficult it is to get cover and how difficult it is to recruit PA. PAs do tend to stay in their job longer than other members of the PA Workforce and do report that their role as a PA has a positive impact on their mental health. They report that their relationship with their employer and the fact that they work directly for them has a positive impact on their wellbeing.

Head of Mental Health Workforce, Unscheduled and Primary Care 17/08/2023

I really welcome the name change to the document it was something I had been raising in previous iterations. On the whole the Framework and Action Plan would support the implementation of our MH WB workforce action plan it would be good to know what the timescales are for publication – we can catch up separately to ensure we capture wording.

The charter/pledge –It is hard to understand from the text if the pledge is for health, social care and social work – it would be useful to be clear on the scope? Would it be something that the voluntary, third sector, private sector could be involved in? Should there be links with fair work and the SG’s business pledge commitment? Is this just a nice to do ie how will we encourage the employers to sign up to the pledge ed through the ADPs.

Strategic board – from the text it appears there only role is to provide support for the above charter/pledge are they going to do more than this if so it would be useful to set out?

Action Plan – needs reviewed in terms of timeline (tenses in this document are not clear or applied consistently) Leadership (Objective 1) unclear on years it relates to i.e. Action 1, 24 participants was it May this year or next year? Action 2, Leading to Change website - again this seems like a past action? Might be my lack of understanding. Action 3, the delivery to date sentence does not make sense to me. Action 4, seems like an action that has already happened? Action 5, again unsure on timeline was it May this year or next year?

Equality - good actions and clear on progress to date. My only point again on language is use of 'leaders at all levels' is this term well versed in HSC and SW? i.e. do people know it means anyone can be a leader regardless of grade? I also wonder about the actions around line managers accessing training - is the ambition that it is then cascaded to all workers and how do we evaluate who attends i.e. how do we know there is the right uptake from across all sectors?

Wellbeing - some of the actions seem quite dated e.g. 'policy expected to be published October 2022' wording on menopause and menstrual health - with not much indication about what is happening now?

Some actions maybe need to spell out that they cover the three parts of the workforce particularly around championing local initiatives etc.

Keeping NHS staff safe in the workplace – interesting to see what stakeholders think about this not applying to social work and social care- could there be an action about considering the learning from this pilot being extended to wider. This could be similar to the Ethnic minority forum action.

Formal, written feedback

Scottish Association of Social Workers (SASW)

Social Work Scotland (SWS)

National Director SASW

Head of Policy and Workforce, SWS

Independent Adviser (Adults and NCS)

16/08/2023

General feedback taken from letter from SASW & SWS: “The document refers throughout to predominantly NHS systems and strategies. If the action plan is to affect the working lives of social services workers, that should be made explicit and meaningful links made to existing work around workforce support for social work throughout the document. The majority of social work and social care workforces are women, and many come from ethnically marginalised backgrounds. Whilst there is some mention of anti-racism in the action plan, we would like to see greater emphasis on diversity and equalities throughout the Framework, and specifically the Action Plan.

One of the main reasons for stress and poor wellbeing in social work and social care is the lack of time and appropriate support services to help workers to do their jobs well. This leads to secondary trauma and feeling of failure for individuals that are actually systemic failures. Any framework for workforce wellbeing must reference this tension.

In the current environment in which recruitment and retention of social work and social care professionals is so problematic, we are not clear what impact the ‘pledge’ would have. It may be viewed very cynically by the various workforces.”

Here is an overview of the tracked changes and comments.

The framework and action plan needs to provide more definitions, references and must be more specific. For example, when we say we want to “improve leadership”, what does this mean in terms of specific outcomes? These desired outcomes need to be supported by evidence that is referenced throughout or included in a bibliography.

The document is too health focused. They would like more references to social work. They also question the ordering of “health, social care, and social work” throughout. They suggest we change the order throughout so it doesn’t seem health biased.

Within the actions section, they frequently ask for more social work actions and question why they are health or health and social care focused.

We need state how we intend to evaluate the impact of our actions on our overall objectives. Formal, written feedback

GMC

Head of GMC Scotland

General Medical Council

23/08/2023

Overall feedback from Head of GMC Scotland

“Hi all, thanks for sharing the framework and action plan – I really like it and think it’s in a much better place than previous versions so thanks for all the work on it.

I have a new clinical fellow working with me on wellbeing and culture – he is an emergency medicine trainee from Forth Valley – you will see his comments included. He said the framework is good and in his opinion it will likely create a neutral response from front-line staff, who will recognise the intention, but will need to see implementation before seeing it in a more positive light.

We also have our Medical Workforce Wellbeing Stakeholder Group meeting today which may result in further feedback from the BMA and Scottish Academy Reps.

Happy to help in any way to promote etc once it is ready to be shared more widely and if you would like to include any reference to our outreach offers as outlined in the comments, do let me know.”

Main points from edited framework/action plan:

Need to be clearer on who deserves the best level of care, are we focusing on staff or patient/services users?

Training and learning should more of a priority.

We need to be careful it doesn’t sound like we are ‘demanding’ staff need to do certain things. The Pledge could include stronger language which they believe may help facilitate change.

More outreach work with the wider workforce is needed to increase the variety of staff involved in programmes focused on diversity and inclusion.

Formal, written feedback

BMA 30/08/2023

Overall feedback from BMA:

BMA’s main concern is that this document does not address the criticisms and feedback already received. There must be a robust focus on short-term initiatives, alongside the longer-term strategies.

They do not think the document includes sufficient provisions for addressing immediate concerns or cover basic and simple needs.

The direct advantages for doctors seem to be somewhat limited in the framework/action plan. The tone and content of the document suggest a more pronounced potential impact on nursing and allied health professionals, particularly in secondary care.

Why are we only trying to increase minority ethnic staff in senior "non-medical" roles? Why is this aim not applied universally across all roles?

They do not think the framework/action plan will land well with doctors, especially when considering upcoming winter pressures.

There are not enough ‘small’ actions in the action plan like supplying free coffee and tea, hot meals, designated spaces to take breaks, working appliances, secure storage for personal items, adequate changing rooms, reliable Wi-Fi, opportunities for skill development, and secure parking facilities.

The doctors they represent are currently grappling with excessive workloads, burnout, and an acute lack of time. Considering the present scenario, it's unlikely that doctors would realistically be able to engage in additional training without experiencing added pressure and burdens.

They are disappointed by the lack of progress in matters such as overnight rest facilities and the availability of food, as evidenced by the lack of advancement in the Expert Working Group's (EWG) 48-hour maximum working week report recommendations.

The framework/action plan needs to better encompass the following statement: "Provide financial Investment to help Health and Social Care staff with their practical and emotional needs, including pastoral care and other measures to aid rest and recuperation".

An area that causes significant distress to doctors is the dismissal of medical professionals' perspectives including when they raise concerns, leading to personal repercussions and career setbacks.

A BMA survey from earlier this year showed that nearly 50% of respondents remain hesitant to express concerns despite the measures implemented around whistleblowing.

They want assurance that the immediate and practical steps to improve the wellbeing of doctors have not been overlooked and how these fit into the framework.

Formal, written feedback

OD Leads 26/09/2023

SG to update:

Too strategic – need to focus on what will it mean for staff on ground/middle managers

Too aspirational considering immediate challenges

SG speak

No mention of line manager/employee relations e.g. appraisals, checking in, learning plans, staff career aspirations

Succession Planning

Boards already doing things – can we help to collate and share best practice?

Cultural intervention (for international recruits)

Cultural collaborative

Behavioural framework & values

Spaces for listening

WeCare staff health and wellbeing programme

Wellbeing needs to be linked to staff development

In accordance with the PSED, we will undertake further Equality Impact Assessment (EQIA) for individual interventions outlined in the IWWC Action Plan under the pillars of Wellbeing, Leadership and Equalities. These will be monitored and reviewed proportionate to the outcome of their respective EQIA.

Responsibility for oversight will be shared between the Scottish Government Culture, Pay and Partnership Division and respective delivery partners. This includes, but is not limited to; Wellbeing Champions, Ethnic Minority Forum and NHS Education Scotland (NES).

Contact

Email: LCW@gov.scot

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