Written evidence from Mind (COM 137)
ABOUT MIND
Mind is the leading mental health charity in
England and Wales. We work to create a better life for everyone
with experience of mental distress by campaigning for people's
rights, challenging poor practice and informing and supporting
thousands of people on a daily basis. A fundamental part of Mind's
work is provided though our network of over 180 local Mind associations
who last year worked with over 220,000 people running around 1,600
services locally. Services on offer include supported housing,
crisis helplines, drop-in centres, counselling, befriending, advocacy,
and employment and training schemes.
INTRODUCTION
Mind welcomes the opportunity to provide evidence
to the Health Select Committee on the move to GP Commissioning.
Mind's response to this inquiry is underpinned by a single principle:
that these reforms do not result in any disruption to people's
access to health services and, ultimately, result in improvements
to their quality, availability and the outcomes that they deliver.
Mind believes the Government must address three
key areas to ensure that mental health services are not adversely
affected by changes to commissioning: GPs' competence and confidence
in mental health commissioning; improving pathways to recovery;
and vulnerable groups and people with a limited voice.
COMPETENCE AND
CONFIDENCE IN
MENTAL HEALTH
COMMISSIONING
1. We recognise that PCTs have not always
commissioned mental health services well, although there are signs
that things are improving. It is imperative that the progress
that has been made is embedded within any new system and that
any new system ensures further improvements in both quantity and
quality of commissioning. This will ensure that those with mental
health problems have access to the care and support that they
require.
2. The shift to GP-led commissioning is
an opportunity to improve the commissioning of mental health services.
However, anecdotal evidence from service users indicates that
many GPs do not have sufficient understanding even of mental health
in primary care, and may not be best placed to commission secondary
care. Recent findings from the charity Rethink[56]
indicate that GPs themselves do not yet feel confident to take
on commissioning and commissioning for mental health in particular.
This knowledge gap needs to be filled before GP consortia take
on commissioning. If GPs' understanding of mental health services
is not addressed, mental health service provision will not improve.
Consortia that do not fully understand the breadth and range of
mental health treatments and services may well fail to commission
the right services.
3. It is imperative that GPs are supported
in commissioning mental health services. Whilst this support will
come primarily from the NHS Commissioning Board, it is important
that expertise within PCTs is also utilised and not lost.
4. The expertise of those involved in the
delivery of serviceseg psychiatrists, social care professionals,
nurses and occupational therapistsshould be utilised, as
should the expertise of the third sector and, most importantly,
mental health service user groups and individual service users
themselves.
5. It is important that NHS, social care,
and public health strategies are fully integrated. We hope that
at a local level, mental health commissioning decisions will not
be taken in isolation from public health and social care decisions.
This coherent approach will deliver both greater efficiencies
and a more effective series of interventions.
6. All commissioning decisions should undergo
a thorough impact assessment to ensure that particular groups
within a locality are not adversely affected. Robust evaluation
will assess a GP consortium's performance in delivering on key
outcomes, such as recovery and patient experience with be needed.
However, the information gathered and evaluated must be consistent
across the country so that the performance of different consortia
can be accurately assessed. This will highlight cases of good
and bad practice, and enable patients to make informed choices.
IMPROVING PATHWAYS
TO RECOVERY
7. People with mental health problems often
rely on a range of services across health, social care and public
health services. It is vital that the commissioning process allows
for joined up, coherent care packages to be put in place without
the individual having to undergo repeated assessments.
8. Recently service providers have improved
their ability to collaborate, delivering full packages of services
for PCT commissioners. These packages will often cross boundaries
between the statutory, private and voluntary sectors. Collaborative
approaches place the patient at the centre and lead to a much
better patient experience and faster recovery. However Mind is
concerned that this approach may be judged anti-competitive by
the new economic regulator, Monitor.
9. It is vital that a service user's journey
along the care pathway is smooth. However, as the market opens
up, this will increase the numbers of individual providers. If
an individual patient has to access a greater number of specialised
providers, his/her journey may become more complicated and potentially
more stressful. The White Paper's emphasis on choice is welcomed,
but could exacerbate this complexity.
10. A potential solution could be an expansion
of the use of navigators and advocates, as currently provided
by some services. These are designed to support people in accessing
a range of services and travelling along their care pathway.
11. Mind is also aware that in many cases
services are better provided closer to the individual's community,
and so potentially as an extension to primary care. We are not
clear how GP consortia would be able to commission such services
or whether these would need to be centrally commissioned.
VULNERABLE GROUPS
AND PEOPLE
WITH A
LIMITED VOICE
12. The White Paper indicates that transparency
will be the main mechanism for ensuring consistently high quality
services across the country. This approach relies on patients
being able to access, understand and analyse information before
making a decision about the services they need. However people
with mental health problems, when they are unwell, are often less
able than other groups to access and analyse information. Furthermore,
many mental health service users are not in a position to travel
and cannot simply transfer to another provider if they experience
a poor service.
13. Stigma and discrimination is a significant
problem for mental health. It is not well understood by the public,
and therefore fails to generate much public sympathy. GPs groups
have already expressed a fear that they will be subjected to doorstep
lobbying, and pressured into commissioning those services that
enjoy the most vocal and widespread public support. Mind is concerned
that mental health will lose out in the battle for resources.
14. The role of local HealthWatches will
become crucial. They must ensure that the experience of all patients
from all backgrounds are heard and fed into the commissioning
process. In particular, they must ensure that the voices of the
least vocal and most disadvantaged members of a community are
actively sought out and communicated. A failure to do so could
well result in a decline in the availability of mental health
services.
15. Mind is concerned about the lack of
a formal complaints procedure for dealing with problems that arise
from the commissioning process. While complaints regarding the
quality of a service can be communicated to a local HealthWatch,
and escalated to the Care Quality Commission, no such process
exists for complaints about the commissioning process. This is
a concern, particularly if commissioning decisions seriously fail
to consider the interests of a vulnerable group, such as those
with mental health problems. Mind would like to see the establishment
of a formal complaints procedure by which serious complaints can
be dealt with by the NHS Commissioning Board.
December 2010
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