Supplementary written evidence submitted
by the Department of Health |
Q How is senior and middle management in the
Department of Health made responsible for achieving sustainable
performance improvements? Do their objectives include references
to sustainable development targets?
We have robust governance arrangements in place for
ensuring that the strategic outcomes set out in our DH SD Strategy
are realised through monitoring delivery of the SDAP. Using the
DH project management approach, delivery of the SDAP has been
coordinated as a programme of work. Our SD Programme Board has
been established under direction from the SD High Level Group
and is chaired by our SD Programme Director and Senior Responsible
Officer. We have appointed lead senior managers as owners of each
of the nine areas within our sustainable Development Action Plan.
As members of the SD Programme Board, they are responsible for
reporting on and delivering agreed actions within their area.
In addition, we have put in place a network of Green
Champions to help with the improvement of sustainability in DH's
operations. This is a voluntary role, and Green Champions work
locally with their colleagues to support staff to live and work
more sustainably. We have grown the network to around 60 members.
Sustainable development is not currently part of
the Department's performance management framework. As such, performance
objectives do not routinely refer to sustainable development targets,
unless they are of particular relevance to a job or team.
The Department's Sustainable Development Action Plan
includes an action to include sustainability within the performance
framework for Senior Civil Servants, but it is in competition
with other objectives around staff management, volunteering, equality
and diversity, financial management and leadership. The performance
framework for SCS is largely set by the Cabinet Office.
Q In July the Department of Health issued
details of four tests that should be passed before service reconfigurations
go ahead - clear clinical evidence, patient choice and so on.
It might be argued that there is a more fundamental requirement
that changes are coherent in sustainable development terms and
that society's longer term interests are properly taken into consideration.
Did officials consider adding a reconfiguration "test"
that any changes should represent sustainable development? If
not why not? [Or - if this was considered why was it not included?]
This Government is committed to devolving power to
local communities - to the people, patients, GPs and councils
who are best placed to determine the nature of their local NHS
services. The objective of the four reconfiguration tests was
therefore to ensure patients, local GPs and clinicians, and local
councils have a much greater role in how services are shaped,
and to ensure that these changes will lead to the best outcomes
for patients. However, the tests were not intended to be a complete
list of the only issues NHS bodies should take into account when
planning and redesigning services. NHS bodies will continue to
need to have due regard for their wider legal and public obligations
in relation to the planning, operation and delivery of services.
DH addresses sustainable development and climate
change requirements for the NHS through its policy and strategy
as identified in:
- DH SD Strategy "Taking the Long Term View:
the Department of Health's strategy for delivering sustainable
- DH SD Action Plan 2009-2011;
- DH Climate Change Plan 2010-2012;
Operationally, these policies are delivered to the
NHS via DH's "the operating framework for the NHS in England
2010-11" and by standards and best practice guidance, such
- Sustainable Development in the NHS.
- Total waste management - best practice advice.
- Carbon/energy management in healthcare - best
Also an Environment and Sustainability suite of guidance:
- HTM 07-01 Safe management of healthcare waste.
- HTM 07-02 EnC02de - making energy
work in healthcare.
- HTM 07-03 Transport management and car parking.
- HTM 07-04 Water management and water efficiency.
- HTM 07-05 Waste Electrical and Electronic Equipment.
- HTM 07-06 Community pharmacy waste guide.
- HTM 07-07 Constructing Sustainable Healthcare
The Sustainability agenda is supported by:
- BREEAM Healthcare (Building Research Establishment's
Environmental Assessment Method specially adapted for healthcare).
- Good Corporate Citizen Model.
There is no legislative requirement within the planning
process to consider the environmental impact, but the BREEAM tool
was initially developed to provide this requirement. However,
it was never formally adopted by the building control and planning
bodies although many authorities have taken up the requirement.
It is DH policy within the capital procurement process
to require an environmental impact assessment to support a business
case. BREEAM Healthcare was specifically developed to meet the
need to ensure a sustainably constructed, energy efficient healthcare
estate and to allow the particular aspects of healthcare to be
embraced in an assessment.
DH also supported setting up the NHS Sustainable
Development Unit to support, empower and galvanise the NHS to
meet their obligations as a leading public sector body. A key
document for the NHS is the NHS SDU's
"Saving carbon, improving health: NHS Carbon
Reduction Strategy for England" 2009, updated 2010.
Q The Initial Equality Impact Assessment,
published alongside the Liberating the NHS White Paper,
notes that the new "Health & Wellbeing Boards will allow
local authorities to take a strategic approach and promote integration
across health and adult social care, children's services including
safeguarding, and the wider local authority agenda".
Will this wider agenda, include "wellbeing" programmes,
in the sustainable development sense of the term?
- With the demise of the Audit Commission, how
are you going to be able to assess how well local authorities
deliver on their enhanced health and wellbeing obligations?
Directors of Public Health in local authorities will
have use of a public health ring-fenced budget. The ring-fence
will predominantly be for health improvement. Local authorities
are best placed to make decisions about the services needed locally,
within the framework of a set of national outcomes for public
health. They will be able to use the ring-fenced budget widely
to improve public health in the local area, including jointly
with other Local Authority budgets such as those for children's
service, schools, housing, transport and environmental health.
Progress in improved health and well-being in local
communities will be assessed through a new public health outcomes
framework and local areas will be rewarded for improvements in
agreed health outcomes.
Q The Care Quality Commission was heavily
criticised in a report by the Sustainable Development Commission
in August 2009. The SDC report said the Care Quality Commission
"has yet to confirm that it accepts that sustainable development
falls within its remit, has failed to pursue a sustainable development
agenda, and has done little to inspire confidence that action
will be taken in the future" . What have you done to improve
the sustainable development credentials of the Care Quality Commission
before it takes on its bigger responsibilities?
The Care Quality Commission (CQC) is the independent
regulator of providers of regulated health and adult social care
activities. Its statutory role is to provide assurance that the
care delivered by providers meets essential levels of safety and
Providers of regulated activities must be registered
with CQC, and meet requirements set in regulations covering these
essential levels of safety and quality. CQC can take independent
enforcement action (including potentially closing a provider down)
where a provider is not meeting the registration requirements.
The enforcement powers available to CQC, set out in primary and
secondary legislation, apply where patients and people who use
services are being exposed to unacceptable risks or poor-quality
care. CQC's role has been confirmed recently in the White Paper,
Equity and excellence: Liberating the NHS.
The content of the registration requirements was
widely consulted on, and then debated in both Houses as part of
the affirmative procedure for making regulations. The registration
requirements do not cover sustainable development because that
would not relate to the essential levels safety or quality of
care that patients or people who use services are entitled to
Further we would not expect CQC to use its enforcement
powers in relation to registration to take action against a care
provider based on its sustainable development record, unless this
compromised the safety and quality of the care it delivers to
patients and people who use services.
While CQC does not have an agenda that directly addresses
sustainable development, many of its areas of interest will result
in improving the efficient use of resources.
As an executive non-departmental public body, DH
expects CQC to follow all appropriate guidance, including guidance
on sustainable development, relating to how it carries on its
3 November 2010
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