LCA works with the Healthier Lancashire and South Cumbria Regulated Care Sector Workstream. We have submitted a paper on engaging with the independent sector which you can read here. We attend selected RCSW meetings and the subgroup on finances.
If you are a provider in the Lancashire and South Cumbria areas and you want to know more about this area of work contact email@example.com for an initial discussion.
Healthier Lancashire and South Cumbria (HLSC) Service Specification
We encourage all providers in the Lancashire and South Cumbria area to complete this survey response (the link to the survey is here) the deadline is 30th August 2019. This has been discussed previously at the Health and Social Care Partnership Steering Group, at the LCA Seminar in June and at the recent County-wide Provider Forum.
LCA’s main points are: the service specification should be fit-for-purpose and it should be designed with providers through the existing partnership forum, it should not in itself be overly onerous, it should not duplicate information collected elsewhere (e.g., by CQC or local authority or CCG commissioners or Healthwatch), data collected should be clearly linked to quality monitoring rather than ‘feeding the beast’ data collection (this requires an item by item review, which is a quite lengthy process given the number of items), it should be clear why a particular item of data is requested, provider rights should be respected (‘natural justice’ principles should apply) and there should be processes covering factual correction (we have for instance, been told some of the percentages calculated are inaccurate) as well as independent appeal/ review. Quality monitoring also requires that commissioners be fully accountable, too. It is a whole system that delivers outcomes not just care providers.
LCA have drafted an initial response and will publish its full response shortly. If you have any comments, please share them in confidence with us at firstname.lastname@example.org or direct to email@example.com
LCA’s Keynote Concerns
→ The service spec is very one-sided. It places all the obligations and risks on one party to the contract and none on the other party/ parties (the NHS, local authority commissioners). This imbalance, without some significant re-drafting, would in our view make the contract unfair.
→ We do not see this as a simple ‘add-on’, of some separate and distinct character, to the contract with the provider. This is fundamentally part of the service contract. Many providers tell us, incidentally, that they are unaware of either LA or NHS contracts.
→ If it is to replace the current arrangements with the various local authorities and CCGs in the LSC footprint there would need to be the appropriate consultation nb the Gunning Principles for consultation.
→ There is some concern expressed that it blurs the distinctions between personal care and nursing care (without any evidential base).
→ If it is a measure of the nature of the relationship between those providing care and those commissioning it, it has no recognisable ‘co-production’ features, despite the suggestion there was some consultation before launch. We note there is further consultation to come, which we welcome.
→ Providers have conveyed to us their fear that this is still shaped by a punitive culture, symptomatic of the longstanding rift between health and local authority commissioners on the one hand and independent sector providers on the other, rather than a genuine attempt at working as partners in ‘co-production’ to find new and better ways of working for the benefit of residents.
→ There is no line of sight to resourcing issues.
→ It is unclear how this sits alongside the CQC inspection framework. The spec should not merely repeat what providers are obliged to do elsewhere in law or regulation through CQC or local authority and CCG commissioning or Safeguarding.
→ The service spec should also set out the commissioner role, duties and competencies and what providers can reasonably expect of commissioners in addressing the shared goal of delivering quality care.
→ There should be a financial impact assessment of the service spec requirements.
All providers should have received the following information in an earlier letter from HLSC:
“What we would like to do next
We are now at a point where we have a draft of the service specification which we would like to share with care home colleagues for comments.
In order to aid this process, the link below will lead to the service specification and a survey for you to complete with your comments about the specification:
Find the survey here https://nhs.researchfeedback.net/s.asp?k=156162935231
Please could all comments be returned by 30th August 2019.
We will be liaising with local provider forum leads to identify representatives from across Lancashire to attend a workshop to review comments from this survey in September, please let your forum lead know if you would like to be included in the event.
Responses will be collated, and we will host an event on 23rd September 2019 to collectively review the key themes that emerge and generate any further clarifications to the service specification where appropriate.
The aim is to have a final version of the service specification available by the end of October 2019 to take though governance processes within Local Authorities and CCGs.
The specification will be implemented as contracts become ready for renewal from April 2020 onwards.”