WRITTEN EVIDENCE
SUBMITTED BY
SENSE, THE
NATIONAL DEAFBLIND
AND RUBELLA
ASSOCIATION (LOCO 02)
1. SUMMARY
¾ A move
towards greater localism must not have a negative impact on those
with low incidence disabilities.
¾ Statutory
guidance places duties on local authorities to meet the social
care needs of deafblind people. Local authorities must fulfil
such guidance and there is a need for central government to ensure
this.
¾ Total
Place pilots indicate some potential opportunities to provide
services in a more joined-up way.
¾ Central
government must monitor local implementation of national policy
so as to avoid failure to implement it correctly.
2. INTRODUCTION
2.1 Sense is the leading national charity working
with, and campaigning for, children and adults who are deafblind.
Sense provides expert advice, support, information and services
for deafblind people, their families and professionals.
2.2 Deafblindness is a combination of both sight
and hearing difficulties. The complex impact of dual sensory
loss means that it is a unique disability. Support with communication,
access to information and mobility are key areas for deafblind
people. There are an estimated 365,000 deafblind people in the
UK, of whom the largest group are people over 70 with acquired
dual sensory loss.[43]
3. TOTAL PLACE
3.1 There is positive potential in services thinking
beyond their own local authority boundary. Deafblindness is a
low incidence disability and deafblind people are not always known
to services. Commissioning services across local authority and
health boundaries could be an effective way of using resources
most effectively to meet the needs of people with low incidence
disabilities.
3.2 Appropriate joined-up assessment for health,
social care and possibly other services could benefit deafblind
people. It is however essential that individuals have access to
specialist knowledge as part of integrated assessment processes.
We would hope that such a process could lead to an increased focus
on meeting the needs of those with complex needs in a joined-up
and preventative way.
3.3 We do see a potential for spreading good
practice between areas. While each area may need to meet the needs
of deafblind people through different models of service provision,
it is undeniably useful for good practice to be shared, especially
amongst rural areas (where deafblind people may be more greatly
dispersed) or areas with a large population of older people (where
the level of deafblindness will be higher).
3.4 In some Total Place pilot sites, single points
of contact for all services were established, including for face
to face services. Face to face contact with services must be preserved
in locations that are easily accessible to those who find it difficult
to both travel large distances or access information in alternative
ways.
3.5 There are strong suggestions that the local
voluntary sector should be involved in ensuring appropriate services
are in place. This is often not appropriate for individuals with
low incidence disabilities. Such groups will often not be represented
at a local level and national organisations may not have the capacity
and/or local involvement to carry this out effectively.
3.6 For some deafblind people, a relatively low
level of support can prevent escalation of needs and higher cost
packages. However a number of deafblind people, particularly those
who are congenitally deafblind, require intensive specialist support.
Total Place processes can identify more explicitly the cost of
relatively expensive support for individuals with complex and/or
specialist needs. While it is clear that resources must be used
efficiently, expensive/intensive support packages must not be
stigmatised.
4. THE ROLE
OF LOCAL
GOVERNMENT
4.1 Local authorities should ensure that legal
requirements such as those bound by statutory guidance are met.
The Deafblind Guidance is statutory guidance issued by the Department
of Health for local authorities in England.[44]
Where it is implemented, the positive impact is clear with more
deafblind people receiving specialist assessment and services.
Moves to decentralise power must be accompanied by central government
mechanisms that can ensure local authorities fully implement such
statutory guidance.
4.2 Given the increase in personalisation of
service, it is vital that local authorities take an active role
in ensuring services are available to meet the needs of the local
population, whether this be through council-run or independent
services. This process should look at the needs of those with
more specialist requirements and ensure that seldom heard groups
are included in analysis of local need.
5. THE LIMITS
OF LOCALISM
5.1 The limits of localism can take two forms.
These are unintended consequences and a post code lottery. An
example of unintended consequences can be seen in events following
the Concessionary Bus Travel Act 2008. An example of the post
code lottery can be seen in the implementation of Fair Access
to Care Services (FACS) guidance.
5.2 In April 2008, the Concessionary Bus Travel
Act came into force. The Act was brought in to allow disabled
and older people to travel between different local authorities
for free. Previously, bus passes would only allow disabled people
to travel in their own local authority. By bringing in a national
pass disabled people can use buses for free outside their own
local authority. At the time of the Act coming into force, many
local authorities decided to review the discretionary concessions
that they offered disabled people, including companion passes
for those who are unable to travel independently and peak-time
travel. The Act did not change requirements on local authorities
in terms of these discretionary elements, but the national change
had negative consequences at a local level, where many local authorities
withdrew companion passes, or started to charge for them when
previously they were free. Many people also lost free peak-time
travel. The failure to include the companion pass and peak-time
travel in the Act has led to a piece-meal entitlement for disabled
people, some of whom have had to challenge their right to a companion
pass in order to use what should be free travel.
5.3 The Fair Access to Care Services (FACS) system,
by allowing each local authority to set their own threshold for
social care services, allows for a postcode lottery. For disabled
people, access to vital services, which make a major difference
to their quality of life, is governed by a system of local discretion.
In addition to this, local authorities have also ignored parts
of the guidance which support provision of services other than
personal care, as well as preventative services.
6. ACTION BY
WHITEHALL DEPARTMENTS
6.1 It is essential that Whitehall departments
have a clear, responsible and active role in working towards decentralised
public service delivery. An example is the role out of personal
budgets for social care. It is government policy to ensure all
adult service users have a social care personal budget. So there
is clear national ownership of a policy that is to be implemented
by local authorities; this implementation is currently very patchy,
including for those with specialist needs.
6.2 Where there are significant issues with rolling
out such a policy, such as insufficient budgets being allocated
to individuals, it is not sufficient for central government to
state that local government is solely responsible for effective
implementation. It must also not be left up to individuals to
challenge the way policy is implemented. Central government must
have an active role in identifying challenges and barriers to
implementing policies locally, in providing support, guidance
and where appropriate resources in order to effectively implement
them and mechanisms whereby they can ensure that local authorities
implement policy correctly.
September 2010
43 Robertson, J, and Emerson, E, Centre for Disability
Research, 2010, Estimating the Number of People with Co-occurring
Vision and Hearing Impairments in the UK. Back
44
Department of Health, 2009, Social Care for Deafblind Children
and Adults LAC (DH) (2009) 6. Back
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