• The effective working of PPIFs relies on the recruitment of (eventually) approximately 9200 reliable volunteers throughout England;
• The organisation which governs PPIFs, The Commission for Patient and Public Involvement (CPPIH),(ext link) is a Non Departmental Public Body (NDPB, known otherwise as a QUANGO).
• QUANGOs are able to get away with some forms of maladministration which other bodies, i.e. local authorities, councillors and even members of Parliament, can be held accountable for. For instance, those other bodies have to comply with the Principles established by the Nolan Committee in Standards in Public Life. If in breach of these they can be held responsible for the breach. QUANGOs cannot be held responsible.
• Equally seriously, PPI volunteers can be, and have been, subject to disciplinary proceedings, suspension and dismissal by CPPIH. PPI volunteers in these circumstances have no supports, protections, contractual rights or means of representation which employees would have in the same circumstances. PPI volunteers in this position have no rights and are defenceless.
• In the one route of CPPIH accountability outside itself, referral to the Parliamentary Commissioner,(ext link) the above problem cannot be dealt with because volunteers are classed as coming under personnel matters, which the Ombudsman cannot address.
• PPI volunteers are doubly vulnerable becausethe CPPIH complaints system is set up in a way that enables malicious complaints by other members or PPI facilitators or managers (or indeed by NHS staff or members of the public).
• CPPIH because it uses volunteers, and because of the context, a good proportion of disabled volunteers, is able to get away scot free with discriminatory actions. And it has done that. This is because volunteers have no rights under disability discrimination legisation.
• PPI volunteers’ rights under health and safety legislation are at best uncertain. The Health and Safety Executive(ext link) says: “HSE considers it good practice for a volunteer user to provide the same level of health and safety protection as they would in an employer/employee relationship, irrespective of whether there are stict legal duties.” So again its discretionary. Just as CPPIH brazenly declares it works to Nolan Standards then fails to observe them without any sort of comeback, so it seems they would be able to with Health and Safety matters - it is again a personnel issue and so cannot be dealt with by the Ombudsman.
• John Reid’s review of Arms Length Bodies (QUANGOs) decided CPPIH
should be abolished. However, CPPIH currently remains the central agency
responsible for examining what the future governance arrangements will be
for PPIFs. In view of the undoubted existing breaches of human rights that
apply to PPI volunteers this seems particularly Machiavellian: CPPIH
working on its own can of worms!