CCG consultation Across Birmingham and Solihull: Prepared by Healthwatch Solihull

Ref:  CCG consultation Across Birmingham and Solihull: Prepared by Healthwatch Solihull: Date 19th August 2017 

I am writing to you with respect to your current consultation about merging three CCGS in Birmingham and Solihull.  Healthwatch Solihull has some observations to make about the consultation process itself, and also views on the consultation options which we would like to be taken into account as you analyse your consultation responses.

The Consultation Process

Healthwatch Solihull draws from its experience in public engagement in making some observations about the consultation process.

There are key factors that Healthwatch Solihull would like to highlight that allow us to reflect on the consultation to ensure that the voice of the people are heard highlighting the need for engagement pre, during and after consultation.

The consultation document highlights that there has been pre-consultation engagement with stakeholders and that internal reviews have been undertaken.  However, we are unclear on the extent to which this pre-consultation engagement process involved members of the public, and how their comments helped shape the identification of the options presented, and the assessment of the impact of the proposals.

Our sense is that more meaningful engagement is needed on all levels, in how consultations are written and presented to the public. This reflects some of the thoughts from the people at the locally held consultation meetings. It is so important engage with members of the public and that the information that you present to those who are effective is not only transparent but meaningful. Members of the general public felt that the campaign would reach a wider audience if it was written for those who it was intended to reach and was clear and concise highlighting how it would affect localization and the people who used the services involved. For example, the consultation document does not clearly articulate how the proposed merger will help tackle inequalities, although oral presentations have been much clearer on this issue.

It is evident that steps have been taken to advertise the consultation, including through radio interviews, press releases, social media such as Facebook, and posters in GP surgeries. However, it was reported on the ground that people had not seen these adverts in surgeries or seen or head of the consultation in the media. The way in which the information is presented on websites could also have been improved – for example, on the Solihull CCG website, the main article about the planned merger does not mention that it is subject to public consultation, only to NHS England approval, and does not carry a link to the consultation document – that has to be found on another page on the website.  Active consultation is key and understanding your demographics and how best to reach out to ever changing populations is key to successful engagement.

People attending the meetings were concerned that their voice and opinion may not be taken into consideration and I think it is key that the CCG and NHS England look at how they effectively give feedback to members of the public. We understand the tight timetables you are working to in order to analyse and present the consultation response, and we urge you to ensure that this speed does not mitigate against a comprehensive review of all comments made, as these can inform the implementation of the preferred option.

Overall, therefore, we have picked up that people felt that they did not have all the facts to allow them to make an informed decision and felt they needed answers as to why the CCG had not put in cost-saving techniques before now, how they could be re assured that the newly formed CCG would continue to support the needs of the ever changing population without getting into financial difficulties and finally more information on how the newly proposed CCG would help localization and equally help tackle health inequalities in the north of the Borough were it was reported that people felt that they had seen no improvement at a local level for some time now.

Healthwatch Solihull Consultation Response

Whilst our concerns about the limitations of the consultation process as set out above have limited our ability to develop a detailed response to the proposals, we are grateful for the time given to attend our Steering Group and explain the thinking behind the proposals in more depth.  This has allowed us to form a view.

Overall, Healthwatch Solihull is able to support the preferred Option 3 with some caveats.  We think it is absolutely essential that a merged CCG, which we understand would then be the largest in the country, and covering a population of 1.3m, builds into its governance very robust locality working arrangements, in order to retain a focus on the needs of particular areas.  This locality working should be led by clinicians who understand the needs of their patients.

In addition, we also think it critical that the stated benefits of the proposed merger in tackling inequalities should result in a levelling up and not a levelling down of services – using the larger footprint of the CCG to identify and implement best practice in clinical pathways and procedures.  This is also very important when it comes to tackling health inequalities – there are major differences in life expectancy across the proposed footprint, and indeed within our own Borough, and we would hope and expect that this larger organisation will use its economies of scale to best effect in providing expertise in tackling these.

Finally, we think it of paramount importance that any new organisation sets out from the outset what difference its new form will make for patients, and that it judges its own performance against this measure.

We would be grateful for your consideration of these points and would be very happy to work with you in helping ensure a strong public and patient voice informs your next steps.