102. Evidence submitted by Westminster
PCT PPI Forum (PPI 102)
1. What is the purpose of PPI?
The purpose of PPI is to ensure that the views
and experience of patients and the public inform and influence
decisions by NHS commissioners/providers about the planning, delivery
and monitoring of healthcare provision.
3. Why are existing systems for PPI being
reformed after only three years?
One of the reasons given is the need to widen
the membership of PPI organisations. However, this could have
been done under the existing system by having recruitment for
new/expanded PPIF membership reach out to representatives from
voluntary and community organisations. Another reason given is
that the increasing emphasis on commissioning within the NHS requires
that PPI organisations be established for a geographical commissioning
area rather than for a specific organisation. That is probably
valid, although it should be noted that PPIFs for PCTs (such as
ours) in effect already serve a commissioning jurisdiction. A
third reason cited is the inconsistency in effectiveness of PPIFs
across the country. However, "effectiveness" will not
automatically be improved simply by changing the structure of
the PPI organisation. So in the formation of LINks, there should
be emphasis not only on identifying "good practice"
among existing PPIFs, but also on understanding the reasons for
sub-standard performance so that can be avoided in LINks. The
comments of the Expert Panel to the DH (12/5/06) that "PPI
has suffered badly from ... stop-start policy" should be
heeded so that LINks do in fact build on the strengths of the
existing PPIF system in holding commissioning organisations to
account, where such experience exists.
4. How should LINks be designed, including
(a) Remit and level of independence. The
remit should focus on PPI in commissioning, with the understanding
that good commissioning encompasses consultation with users on
planning services, performance monitoring of providers and assessing
patient experience with services. We think that the proposal in
the 11/12/06 DH feedback on the Stronger Local Voice consultation,
to have working groups within a LINk to address the various parts
of its remit— commissioning, provider monitoring, specialist
providers—is good.
We think it is essential that LINks be independent
of the DH, Local Authority, NHS, Host and any other organisations.
(b) Membership and appointments. The DH
documents talk about both "organisation and individual"
members of LINks, but it is not clear how these different categories
of membership might work. There is also nice-sounding language
about LINks being not just a group of people but "networks"
and about how membership decisions will be up to individual LINks
instead of being prescribed centrally. But we think there is still
a big piece of work to be done on how the individual/organisational
membership structure of LINks might be operationalised. We think
that this needs to be addressed before LINks are unleashed to
tackle this on their own. One way of doing this is to ensure that
the early adopter sites go through a period of being a "shadow"
LINk (as suggested in Annex A of 11 December 2006 DH document)
and develop various models for membership. We reiterate our comments
on the Stronger Local Voice consultation that each LINk go through
a "shadow" stage, with perhaps a committee of two PPIF
members who want to transfer to the LINk and the Host being responsible
for selecting initial LINk members. Questions of member suitability,
time availability, expertise, experience and people mix also need
to be considered. In addition, we recommend that consideration
be given to paying volunteer members of LINks a stipend as a way
of attracting membership, particularly among younger people.
We are pleased that the Minister's covering
letter to the 11/12/06 DH document explicitly states that "it
is not our intention to abolish patients' forums ... until LINks
can be established." We think this is essential. However,
doubt is cast on this assurance by the worrying language in para
1.10 of the DH document that refers to "minimising the gap"
between systems.
(c) Funding and support. Funding should
not be any less than at present and should be ring-fenced. We
are pleased to see in 11 December 2006 DH document that detailed
specifications for the qualifications and level of support to
be offered by Host organisations are being developed. We note
that one reason often cited for poor PPIF performance has been
the poor performance of their FSOs. We think it cannot be assumed
that LAs will automatically be more effective than CPPIH in selecting
effective Hosts, even in view of their greater local knowledge.
Therefore, this procurement process needs very careful management
and guidance. We think it is essential that the LINk participate
in interview panels for new Host staff and in formal assessment
of Host performance.
(e) Statutory powers. We think that these
powers should not be less than for PPIFs and are pleased to see
in 11 December 2006 DH document that it has been decided to give
LINks the right of access to monitor and inspect services. LINks
should also have the power that PPIFs have to hold NHS organisations
to account by commenting on their declarations of compliance with
HCC standards as part of the Annual Health Check.
(f) Relations with local health Trusts.
Forming a good working relationship with local health Trusts is
desirable to permit joint working to improve PPI and the quality
of health services. LINk members should participate, as PPIF members
do now, as "critical friends" on Trust Boards, committees
and working groups.
5. How should LINks relate to and avoid overlap
with
(a) LA structures including OSCs. LINk members
should not be members of OSCs but should be given the opportunity
to contribute to OSC investigations. LINks should retain the same
ability to refer issues to OSCs that PPIFs now have. In this regard,
we are concerned that section 157 of the Local Government and
Public Involvement in Health Bill provides for referral of social
care matters to the OSC but not healthcare matters.
(b) Inspectorates including the HCC. LINks
should be given the opportunity to contribute to HCC and other
inspections.
6. Wider public consultation (including
section 11). The requirements now placed on Trusts to consult
with patients and the public on planning and proposing changes
to healthcare services should remain. This should include the
opportunity for LINks to provide a formal response to such consultations.
LINks should build on and strengthen existing PPIF work to hold
NHS organisations to account for conducting —and acting
on—appropriate consultations under section 11. While we
are pleased to see inclusion in the Local Government and Public
Involvement in Health Bill of section 163 regarding the duty of
NHS Trusts to consult about planning/changing health services,
we are concerned that the language refers only to "significant"
changes, thus potentially diluting the effect of the current section
11 duty.
Tera Younger
Co-Chair, PPI Forum for Westminster PCT
Brigitta Lock
Co-Chair, PPI Forum for Westminster PCT
10 January 2007
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