HC 1048-III Health CommitteeWritten evidence from the Family Planning Association (PH 42)

1. Executive Summary

1.1 FPA is one of the UK’s leading sexual health charities, with over 80 years’ experience of providing the UK public with accurate sexual health information, education and advice services.

1.2 FPA represents a national voice on sexual health, working with and advocating for the public and professionals to ensure that high quality information and services are available for all who need them.

1.3 We welcome the inclusion of sexual health services in public health as it recognises the major public health role that sexual health services play in people’s health and wellbeing.

1.4 In principle we welcome the proposal that local authorities will commission public health services, but have some concerns around the execution and mechanisms of localised commissioning.

1.5 We welcome the ring-fenced public health budget but have concerns over whether the budget allocation will be sufficient to fund the full range of public health services proposed.

1.6 It is vital that the indicators on under-18 conceptions, rates of Chlamydia diagnosis and late diagnosis of HIV are retained in the Public Health Outcomes Framework. We would also like to see indicators that pay attention to the importance of sexual health throughout people’s lives and not just for young people.

2. Creation of Public Health England

2.1 FPA welcomes the creation of Public Health England as a body to focus specifically on public health. We think that greater detail needs to be provided about how the functions of Public Health England at a national level will be supported.

2.2 We welcome the inclusion of sexual health services in public health given the important public health role that these services have in treating and preventing the spread of infection and enabling people to maintain their sexual health and wellbeing. We also welcome the inclusion of contraception services, sexually transmitted infection (STI) services, abortion services and health promotion and prevention services in the definition of sexual health services contained in Healthy Lives, Healthy People. The commitment that these services will be easy to access and delivered in a confidential and non-judgemental way is also welcomed.

3. Future role of local government in public health

3.1 We agree with the principle of local authority commissioning of public health services, including sexual health services, but do have concerns over the execution and commissioning mechanisms.

3.2 We think that there is a risk that certain elements of sexual health service delivery could become politicised given the involvement of locally elected representatives. For example, abortion is often seen as a controversial issue and, although it is clear that delivery of sexual health services must include abortion, some people seeking elected office may wish to make it a political issue. It must be made clear that the role of the public health service is to deliver high quality services, including abortion services, to meet the needs of the local population and that local politicians are not able to prevent service provision on political grounds.

3.3 It will be important that efforts are made to ensure that local knowledge of sexual health need and mechanisms to assess the need successfully are maintained through the transition and into the new structures to ensure that local Joint Strategic Needs Assessments are meaningful and accurately inform commissioning.

3.4 It is not currently clear whether Public Health England will issue guidance to local authorities to support them in commissioning public health services. It can be difficult to assess local need for sexual health services accurately because the stigma and embarrassment that are still associated with sex and sexual health mean many people are reluctant to talk about the services they need. We are concerned that local authorities may not have the expertise needed to assess local need accurately and to understand the services they will need to commission. Clear commissioning guidance from Public Health England may overcome some of these issues.

3.5 FPA welcomes the recognition in Healthy Lives, Healthy People that some public health services will need to be co-ordinated and delivered at a national level by Public Health England. We recommend that this includes the commissioning of a comprehensive sexual health information service to ensure that high quality information is available to all those who need it. FPA currently runs the sexual health direct service through a contract from the Department of Health. Through this service we deliver a wide variety of information functions including:

A national telephone helpline and a web enquiry service, Ask WES that respond to 45,000 enquiries a year.

Development and publication of a range of over 30 booklets on sexually transmitted infections, contraception and pregnancy choices that are based on the latest available scientific evidence, are regularly reviewed and are extensively consumer tested. We distribute around eight million of these booklets to GUM, contraception and general practices across England.

A website featuring a clinic finder which receives an average of around 23,800 hits a month and an innovative decision-making aid My contraception tool, which was viewed almost 10,000 times between the beginning of September and the end of November 2010.

National awareness raising campaigns on sexual health, recent topics for which have included older people’s sexual health, the links between alcohol and sexual health and the range of methods of contraception available.

4. Commissioning of public health services

4.1 As mentioned previously FPA warmly welcomes the inclusion of sexual health services in public health. We think that it should be mandatory for local authorities to commission comprehensive, open access sexual health services, including STI testing services, contraception services and abortion services.

4.2 We believe it is vital that integrated, high quality sexual health services continue to be provided under the new system. Strong links between sexual health services delivered through the public health service and those which continue to be delivered by NHS services, including general practice should be maintained. For us the crucial consideration about commissioning sexual health services is continuing to ensure that people have choice about the sexual health services they access and effective integration is key to this.

4.3 We also believe that there needs to be a clearer statement of the importance of ensuring that sexual health services are commissioned for people of all ages. Rates of sexually transmitted infections are higher among younger people and consequently much of the prevention activity is targeted at this age group. However, official statistics show that rates of STIs diagnoses in older people are increasing and, although the numbers remain small, the rate of increase is faster than among younger people. It is crucial that people of all ages are able to access information and services to protect their sexual health and wellbeing.

5. Public Health Outcomes Framework

5.1 FPA broadly supports the overall framework for public health outcomes and the proposed domains.

5.2 We warmly welcome the inclusion of indicators on under-18 conceptions, rates of Chlamydia diagnosis and late diagnosis of HIV and believe it is vital that these proposed indicators are all retained for inclusion in the Public Health Outcomes Framework. There is strong evidence that robust national leadership on sexual health outcomes effectively translates into improved services and demonstrable improvements in sexual health.

5.3 FPA believes that the current proposed indicators relating to sexual health ignore the importance of sexual health throughout people’s lives. We know that it is not only young people who are sexually active and people need to be able to access information and services to protect their sexual health and avoid unplanned pregnancies and STIs whatever their age.

6. Funding of public health services

6.1 FPA warmly welcomes the ring-fenced public health budget, as funding for public health has previously been an easy target for cuts when budgets are squeezed. However, we fear that the funds allocated to local authorities as part of the public health ring-fenced budget will not be sufficient to fund the range of services proposed. Current expenditure on the full range of sexual health services is estimated to be around £700 to £750 million. Healthy Lives, Healthy People estimated that current spend on areas likely to be the responsibility of Public Health England is around £4 billion. With sexual health just one part of public health we are concerned that the ring-fenced budget will not be enough to meet the local needs for public health services.

6.2 It is vital that it is made clear that the ring-fenced public health funding is only to be spent on public health services and that it is not acceptable to re-define other services as contributing to public health to get around the ring-fencing. We are aware that local authority budgets are likely to be under significant pressure over the next few years and this must not have an adverse impact on the funding for sexual health services. Cuts to sexual health service provision may appear to be cost-saving in the shorter term but are actually more costly over the medium and long-term as the costs of increased rates of STIs and unplanned pregnancies have to be met. We urge the government to take steps to avoid reductions in services which would lead to a deterioration in sexual health.

7. Future of the public health workforce

7.1 FPA welcomes the intention of the Government to develop and consult on a public health workforce development strategy in 2011.Currently, there is not any detail around how clinical training for people delivering public health services will be planned and managed. For example, sexual health services will be part of the new public health structure but many of the skills required to deliver these services are clinically based, such as carrying out STI tests and initiating treatment. It is not clear how strong links will be made between public heath workforce planning and healthcare workforce planning to ensure these training needs are identified and met.

7.2 We are concerned that the proposals for the provision of workforce education and training to be made the responsibility of individual providers to fund and organise could see a loss to a co-ordinated approach to training. There is already a shortage of healthcare professionals trained to provide and fit all forms of contraception, and we are worried that this problem will be exacerbated by the proposed changes to responsibility for training provision.

8. Abolition of the Health Protection Agency and future of Public Health Observatories

8.1 FPA believes that publicly available national data on sexual health services are vital to be able to assess sexual health and wellbeing as well as the performance of services. This data will be crucial for local authorities in helping them assess local need, performance of services and address inequalities.

8.2 We would like reassurances that Public Health England will continue and even improve the functions it takes on from the Health Protection Agency (HPA). The data collection and analysis that the HPA currently carries out into STIs, including HIV, is crucial to informing service provision and assessing progress in improving sexual health. A loss of these functions would have a significant negative impact on the evidence base for sexual health service provision, making it more difficult to assess the need for services.

8.3 We think that Public Health Observatories also play a key role in sexual health data collation and publication. For example, the South West Public Health Observatory was commissioned to develop a set of sexual health process and outcomes indicators and created the Sexual Health Balanced Scorecard which is widely used. We seek reassurances that access to this data and its regular updating will be retained.

June 2011

Prepared 28th November 2011