My response to the Norfolk, Suffolk and Cambridgeshire Strategic Health Authority (NSCSHA) Health Strategy 2005 - 2010.
This mail, dated 13th August,2005 was sent by a resigned PPI Forum member from the London area to a current member of another London PPI Forum. The resigned member also happens to be a Member of The Chartered Institute of Personnel & Development. I have his permission to post his mailing here:
Dear xxxxxx
3 issues:
1. Prescreening. Such a process of going from longlisting to shortlisting should be visible, work to the same clearly set out criteria as those being used for the interview itself and those undertaking the prescreening should be clearly identified. Is this the case? If it isn't, why not?
2. Restricted choice of potential candidates. As far as I know, there is no agreed arrangement for transfer of staff (TUPE) from the FSOs to CPPIH in the event of contracts not being rolled over, and equally no contractual obligation between CPPIH and FSOs for CPPIH to employ FSO staff facing redundancy. If I'm right on both points, it must be a breach of CPPIH's equal employment opportunities policy if these posts have not been advertised externally. The selection panel has been denied the best field of candidates from which to make a choice for a post which cannot be regarded as temporary. I'm not unsympathetic to the plight of those FSO staff facing redundancy but see no reason for them to be treated differently from other people when it comes to being appointed to work for CPPIH.
3. Level of satisfaction. You are absolutely right that the CPPIH procedure is crude and unsatisfactory. Particularly given prescreening, the reasonable presumption must be that all those being interviewed wholly or very largely satisfy the minimum criteria. The purpose of the interviews is therefore to establish how well they satisfy those criteria and to be able to discrimate legitimately between those who barely cover the criteria and those who offer greater skills, knowledge, understanding and experience. Most organisations I know using a scoring system (1-very poor/unacceptable, 5 -excellent) to help with the decision making.
Hilary
CPPIH make these statements: And from their values statement:
I have just send this mail to the Equal Opportunities Commission:
Hello.
I have been concerned about the employment policies and practices of the Commission for Patient and Public Involvement in Health for some time. Of particular concern is what appears to be a culture of sliding known people into vacant positions without giving others outside the organisation the opportunity to apply for these.
To try to find out more, on 11th June, 2005 I made a Freedom of Information Act request about a particular recent senior management appointment. I have just received their response (11th August, 2005) which bears out my concerns. This is attached.
Can you please comment.
This is CPPIH's response to my FoIA request:
1. From their job vacancies section: “We welcome applications from all sections of the community. All appointments are based on merit and the principles of independent assessment, openness and transparency.”
“Use an inclusive, anti-discriminatory approach within all our procedures and practices and fully adhere to all equal opportunities.”
Dear Mr Cox
I have been passed your letter dated 11 June 2005, received at the office on 3
August 2005. Further to your request under the Freedom of Information Act
2000 (the Act), I set out the responses to your queries below, in the order that
you raised them:
1. It is correct that Bernadette Beckett has been appointed to the post of Regional Manager
for the East of England CPPIH.
2. the process of appointment involved the position being advertised internally for one
week.
3. In total there were 4 candidates considered for the appointment.
4. the appointment was advertised internally via e-mail.
5. the interview panel consisted of the Director of Operations & PPI,South and the HR
Manager,South
6. there was no independent scrutiny of the appointment.
7. the appointment was not made under the aegis of the NHS Appointments Commission, nor
was there an inspection/scrutinising body as this it is not requisite in the process of
Commission staff appointments.
8. there were no service users or carers involved in the appointment.
9. the essential qualifications and requirements for the post are attached for your
information.
10. No CPPIH posts come under the scrutiny of the Office of the Commissioner for Public Appointments.
When/if I get one, I will post the EOC reply here.Measure the CPPIH stated values against this!!
4th August, 2005.Paul Burns sent a copy of a briefing document dated 02.08.05. from CPPIH to FSOs. Although there is no mention to date on the DoH website, nothing on the CPPIH website and a phone call to DoH registered a blank, a phone call to Eastern England CPPIH confirms it is genuine. The summary says:
“The CPPIH has been informed by the Minister of State for Health, Rosie Winterton of the following information:
1. The decision to abolish the CPPIH has been deferred from August 2006 to Summer 2007
2. There will be a review of public involvement and accountability in the NHS
3. The existing arrangements of PCT, Hospital, Mental Health and Ambulance PPI Forums will be maintained.
4. No new money will be available for the CPPIH. Therefore the Commissions budget will continue to be reduced over the next two years of operation.
Following this news the CPPIH will invite Forum members to extend their membership. Further details on when and how this will occur, will be available once the details have been worked through.
and
The CPPIH Executive Team and the Board have undertaken a detailed review of the functions and activities of CPPIH. This review of functions has led to a number of proposals for restructuring the CPPIH. It is important that CPPIH remains fit for purpose for the duration of its existence. Hence the proposals are not merely a reduction in certain posts but are a fundamental reshaping of the organisation.”
Items 2 and 3 are good news indeed, but CPPIH has never been “fit for purpose” – just the opposite. Watch this space.
The full briefing paper is available here.
I initiated a complaint about CPPIH’s failure to observe its legal obligations on 17th February 2005. The complaint, having run the course of the CPPIH policy, was referred to the Parliamentary and Health Service Ombudsman on the 8th May, 2005.
I have just had a letter from the Office of the Ombudsman dated 03.08.05. which says: “I am writing to inform you that we are still experiencing a delay in allocating cases to investigating officers. We will do everything possible to get your complaint assigned as soon as possible. please accept my apologies for the continuing delay to your complaint.” Six months on and running!
I wonder too, if the Patient Advice and Liaison Service (PALS) at the hospital and the Independent Complaints Advocacy Service (ICAS) had picked up any indications of things going badly wrong which they should have been alerting the Forum to and thence to the local authority Overview and Scrutiny Committee? Perhaps a new focus for investigation by Panorama?
I can't help wondering that there must have been complaints which, two years ago, would have been picked up, collated and actioned by that singe effective body the Community health Council (CHC). Now we have the fragmented system of PPI Form, PALS, ICAS and OSC not talking to each other so malpractice is being missed.
Is this a clever and devious move by the government - removing CHCs and replacing them with a system which they knew was bound to fail, thereby avoiding independent monitoring of the NHS?
The government announced yesterday that the DDA 2005 will not be implemented until December 2005.
At Last Some restraint on CPPIH’s scot free ability to discriminate against its volunteers. A quote from a letter from Rosie Winterton to my constituency MP dated 29.01.05. The DDA 2005 received Royal Assent on 7 April 2005,
08.06.05. Rosie Winterton announces new PPI resource centre “...is expected to be up and running in January 2006.” “The NHS Institute for Innovation and Improvement is to host responsibility for the PPI Resource Centre, managing it by contract.”
Announcement in the DoH 4th Transitional Newsletter 21.06.05.:
Appointments to Forums
As we announced in the Department’s Arms Length Body Review, the NHS Appointments Commission will be taking on responsibility for appointments to forums.
The NHS Appointments Commission will over the next year go through other changes. It will become completely independent of the NHS as its status will change to become a ‘non-departmental public body’ – the same status as, for example, CPPIH and the Healthcare Commission. This change will reflect its wider role in making appointments to non-NHS bodies and those across Government. As part of this change, from next April it will be known simply as the Appointments Commission.
My subsequent letter to Patricia Hewitt:
Patricia Hewitt, The Future of Patient and Public Involvement in Health (PPI) As a result of the Arms Length Body review set up by John Reid in 2004, the Government made several decisions about the future of PPI. Three of those decisions were:
“Mr Cox raised the issue of the rights of PPI volunteers under the Disability Discrimination Act (DDA). He asked about the possibility of introducing an amendment to the Disability Discrimination Bill (DDB) currently before Parliament to afford them and others like them protection. It is true that most volunteers are not currently covered under the DDA (see the CPPIH stated values no. 4 though! My parenthesis). However, patients' Forum members will be afforded cover under the new clause two of the DDB. Clause two covers, with some exceptions, functions of public authorities not already covered under the DDA, making it unlawful for a public authority, without justification, to discriminate against a disabled person when exercising its functions. This would cover the CPPIH in its functions of appointing members to Forums and providing them with support.”
Secretary of State for Health,
c/o Richard Bacon,
Member of Parliament for Norfolk South,
House of Commons,
London,
SW1A 0AA.
Dear Mrs Hewitt.
In its paper of 1998, ‘Quangos, Opening the Doors’, the Cabinet Office said:
“The nature of the work of quangos and the commitment they require....must be such as to attract and retain the right people, who will be accessible, trustworthy and efficient. The Government wishes to achieve this by making quangos more accountable, open and capable of being understood.”
The Government failed, despite improvements, to any practical purpose, to do this.
Unfortunately, there have been many concerns from many sources about the trustworthiness and efficiency of CPPIH but their accountability, being a quango, is practically non existent (I had a complaint accepted by the Parliamentary Ombudsman in May but they have, as yet, been unable to allocate an investigator).
About decision 1. above, I had said:
“The transfer of responsibility for the appointment of PPI members to The NHS Appointments Commission (NHSAC) should bring a substantial improvements. The NHSAC is accountable to the Office of the Commissioner for Public Appointments which has high independent status and was set up via the Committee on Standards in Public Life itself. The OCPA also has an existing stringent Code of Practice, available from the website and a solid complaints policy.”
But, in the fourth PPI transitional newsletter published on 21.06.05. Meredith Vivian told us:
“The NHS Appointments Commission will over the next year go through other changes. It will become completely independent of the NHS as its status will change to become a ‘non-departmental public body’ – the same status as, for example, CPPIH and the Healthcare Commission. This change will reflect its wider role in making appointments to non-NHS bodies and those across Government. As part of this change, from next April it will be known simply as the Appointments Commission.”
This is surely ridiculously unacceptable on two clear counts:
The third decision above. Setting out Government intentions, Alan Milburn said:
“Unless we improve the NHS's governance and make it more representative of the local communities that it serves, we shall never reach the position at which local services are responding to the needs of local communities........ We need to ensure that the patients forums are not only representative of the local community but can express expertise on behalf of that local community.” (Commons Hansard, 2nd reading NHS Reform and Health Care Professions Bill, 10.01.01.)
As in my article: ‘PPI - The Nails in the Rural Coffin’ (PPIF website -www.ppif.org.uk) I have pointed out that the merging of all other PPI Forums with PCT PPI Forums will practically destroy PPI in rural areas. People with disabilities will be under represented because of inaccessibility; in particular the absence of involvement and representation for people with learning difficulties inherent in many PPI Forums will increase tenfold; the destruction of the mental health PPI Forum in this area will result in no involvement or representation for mental health (eight members in the MH Forum to go into seven PCT PPI Forums in the area - and most mental heath service users and carers need mutual support for effective participation); members of the public who live in rural areas will be cut off from PPI by distance - in the approximately 120 square miles of rural district where I live there is still no PPI presence whatever and no plans for there to be; eighteen months after PPI was launched and CHCs were taken away from us. That cannot fail to get worse with this decision.
There are undoubted issues of equal opportunities and institutional discrimination here. And I was under the impression that there is a responsibility for all Government departments to ‘rural proof’ all new policy. It is indisputable that the Department of Health have failed to do this.
I would be grateful if you, with fresh eyes, could review these decisions. When I asked Conservative Central Office in the run up to the recent general election (as I did all major parties) what their position is, they said they recognised the destructive effects of removing the specialist PPI Forums in rural areas and would be more flexible and differentiate between rural and urban areas. I would ask you please to consider that course of action.
There is an obvious anomaly in accountability between that of MPs and local authority councillors, and quangos: for example, for the former, referral to the Standards Board is available where there are questions around the observance of ‘Nolan’ Standards in Public Life. No such line of accountability is available for quangos. Perhaps this could be included
in legislation to attain some sort of parity.
CHCs were known and accessible in most centres of population. PPI is not. This position can only decline with the proposed changes. It is my belief that a shop front presence for PPI in all centres of population, including small market towns, would not only serve to familiarise the general public with PPI but also act as a spur to volunteer recruitment.
‘Quangos, Opening the Doors’ stated:
“The Government proposes to invite Parliamentary Select Committees (who already have the power to scrutinise any aspect of an NDPB’s performance) to take a more active role in scrutinising the work of NDPBs.”
That hasn’t happened, despite at least two separate requests for them to do so (mine via Richard Bacon and another via Bob Blizzard). Could this be looked at again?
In anticipation, I appreciate your time and attention and I look forward to your response.
Yours sincerely.
Mike Cox.
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