public sector equality duty annual report
TRANSCRIPT
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January 2020 to December 2020
In the event of any queries relating to this report, please contact Ojalae Jenkins,
Transformation Manager via [email protected].
PUBLIC SECTOR EQUALITY
DUTY ANNUAL REPORT
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Contents
1. Introduction 3
2. Equality Objectives (2019 to 2023) 4
3. Organisation Context 5
4. CCG Leadership 7
5. CCG Engagement, including duty for public consultation
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6. Health Inequalities Reviews and action plans 9
7. Commissioning and Procurement 12
8. Workforce Information 13
9. Workforce Race Equality Standards 13
10. Conclusion 14
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1. Introduction
The Equality Act provides a legal framework to strengthen and advance equality and
human rights. The Act consists of general and specific duties. Both general and
specific duties are known as the Public Sector Equality Duties (PSED). These
require public bodies to consider how the decisions that they make, and the services
they deliver, affect people who share different protected characteristics. The specific
duties require public bodies to publish information to show they did this.
There are nine ‘protected characteristics’ covered by the Equality Act: race,
disability, sex, age, religion or belief, sexual orientation and gender reassignment,
marriage and civil partnership, pregnancy and maternity
The general duty requires public authorities to:
Eliminate unlawful discrimination employers.
Equal opportunities
Encourage good relations
This report meets the specific duties by including details on:
Commissioning of services – evidence of our equality impact analysis
Information – details of information taken into account when assessing impact
Consultation – details of engagement activity that has taken place
Public authorities must:
Publish by 31 January each year their relevant and proportionate information
showing how they meet the Equality Duty.
Set specific and measurable equality objectives by 6 April every four years.
Buckinghamshire CCG’s were set in April 2019 and stand until March 2023
(Section 2 of this report).
Coronavirus COVID-19 pandemic: PSED reporting obligations
This report covers the period January to December 2020.
The Coronavirus COVID-19 pandemic has, in 2020, clearly drawn an increased
attention to the health and wider inequalities that persist in our society, linked to a
visibly increased risk of dying among those diagnosed with COVID-19 in Black,
Asian and Minority Ethnic (BAME) groups.
This is a major theme explored further within this 2020 report, reflecting
Buckinghamshire’s known areas of deprivation and use of needs analysis and its
Population Health management (PHM) programme to drive continual improvement.
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As a consequence of the pandemic, the Equality and Human Rights Commission
has reviewed the PSED specific duty reporting obligations. The requirements of the
general duty remain in force and are critical in ensuring that public bodies consider
the needs of people with protected characteristics as they respond to coronavirus.
In England, planned compliance activity on the specific duties for 2020 has been
suspended. Whereas ordinarily public authorities must publish by 31 January each
year their relevant and proportionate information showing how they meet the Equality
Duty, on this occasion the date has been deferred to 30 March 2021.
2. Equality Objectives (2019 to 2023)
CCGs are required to set specific measurable equality objectives by 6 April every
four years. Buckinghamshire CCG’s most recently agreed objectives will be valid
from 2019 – 2023:
1. Provide targeted support to identify and treat those with hypertension who are
BME and/or live in quintile 5 as demonstrated by improvements in prevalence
rates and % of hypertensive patients treated to target by 2022 from the 2018
baseline.
2. We aim to promote good mental health for all and improve access to mental
health services when these are needed, with an additional focus on those
children and young people who are more vulnerable to poor mental health. We
will baseline current activity across schools, colleges and health and identify
where we should target support to schools and colleges in catchment areas that
have the highest levels of deprivation.
Measure 1: Increased number of Mental Health Support Teams
(MHSTs) against targeted schools and colleges in catchment areas
that have the highest levels of deprivation (DQ5)
Measure 2: Increased numbers of children and young people from
schools within DQ5 accessing mental health services in 19/20
(compared to 18/19 baseline)
3. Reduce the gap between the experience of BME and White British patients in
feeling supported with their Long Term Conditions (including mental health).
This will be evidenced by improved experience of Care and Support Planning for
these people from the 2018 baseline. It will be supported by improved recording
of ethnicity in the Primary Care Record from 2018 baseline.
4. To reduce the prevalence of smoking generally and to see the greatest
reduction in smoking prevalence in GP Practices in quintiles 4&5.
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3. Organisation Context
Buckinghamshire CCG is a membership organisation. It is made up of 48 GP
practices across the county. It describes itself as, “your local doctors and their teams
working in partnership with the public to identify the community’s health needs and
buy services to meet them”.
Our Aim
Our aim is to improve health outcomes by working together. We aim to close any
gaps between health and wellbeing, care and quality, by:
Reducing inequalities in getting health services. This is one of the reasons for
differences in life expectancies and outcomes.
Providing the best quality care for patients as close to their homes as possible
Healthcare professionals working with patients and carers to make the right
decision about treatment and care.
Ensuring we all use innovations and technology to meet the changing needs
of our patients.
Stopping people being admitted to hospital or using A&E services if they don’t
need them. We will achieve this by increasing the offer of care in the
community.
In Buckinghamshire, the statutory organisations together form an Integrated Care
Partnership (ICP) to deliver health and care services and provide an overall better
experience. Planning and tailoring services together, based on the needs of the
population, can improve the health of our residents. This approach to planning and
tailoring – commonly referred to as Population Health Management (PHM) – is also
informed by needs analysis provided by Public Health at Buckinghamshire County
Council.
Health and social care is struggling with rising demands and costs with variable
quality. To commission better value care for our patients, we are shifting from a
supply-driven system that focuses on volume and units of care to an outcomes
based approach. This will focus on what patients need to achieve. This helps deliver
a long term ICP vision of “everyone working together so that the people of
Buckinghamshire have happy and healthier lives.”
The Buckinghamshire ICP care model can be seen below:
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The strategic priorities for health and care partners across Buckinghamshire for
2020/2021 are:
Develop resilient integrated care locally that meets the needs of residents, in
line with the law.
Progress a joined up approach to transforming health and care to allow us to
cope with increased demand. It will also help deliver better outcomes for our
residents and provide experience and efficiency.
Develop the ICP to get better value for money and reduce duplication.
Make sure we live within our means and be more efficient.
Redesign care pathways to improve patient experience and clinical outcomes.
We will make the best use of clinical and digital resources.
These are a continuation of objectives unchanged from the previous year. This is
given the known impact of the Coronavirus COVID-19 pandemic on years lost to life
and time likely required to restore and subsequently recover a range of patient
services and pathways affected in a variety of ways.
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Executive
Committee
Governing
Body
Public Sector
Equality Duty
Equality,
Diversity &
Inequalities
Steering Group
Getting Bucks
Involved Steering
Group
4. CCG Leadership
The Governing Body and Executive Committee are responsible for our compliance with
the Public Sector Equality Duty and tackling health inequalities in its communities. This is
both collectively and as individuals. They provide strategic leadership to the equality,
diversity and health inequalities agenda.
The Governing Body is required to have a lay role as a patient champion. This person
has also chaired the Equality, Diversity and Inequalities Steering Group. They are
responsible for ensuring our resident’s voice is heard and that equal opportunities are
created for patient and public involvement and engagement.
The day-to-day oversight of the Public Sector Equality Duty is delegated by the CCG
Governing Body to the Executive Committee. The Transformation Manager takes lead
management responsibility to ensure the CCG’s performance improves and statutory
responsibilities are met.
The CCG’s objectives for improving their equality and inequalities performance are
agreed by the Executive Committee. It ensures that equality is a core consideration in
discussions and decisions. All members are expected to lead by example and actively
champion equality and diversity. When attending commissioning meetings, staff fora and
public events/community groups, they always take the opportunity to reduce health
inequalities.
Figure One: CCG leadership for the Public Sector Equality Duty.
NHS Buckinghamshire Clinical Commissioning Group (CCG)
Buckinghamshire
Integrated Care
Partnership
Governance and
operational
means of
delivering
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Note: the role of the Getting Bucks Involved Steering Group is described further in
Section 4 below
Line Manager Responsibilities
All Line Managers are responsible for ensuring:
Employees have equal access to relevant and appropriate opportunities for
promotion and training.
Employees undertake the equality and diversity mandatory training.
Any staff training needs to help meet the requirements of the Duty, and the
associated policies/procedures, are highlighted to the Transformation Manager.
Recruitment is an open, fair and transparent process.
Employees are supported to work in a culturally sensitive way and in an
environment free from discrimination.
5. CCG Engagement, including duty for public consultation
Equality, Diversity and Inequalities Steering Group
The Equality, Diversity and Inequalities Steering Group co-ordinates the delivery of the
Equality Duty. This group is made up of the Governing Body Lay Member,
Transformation Manager and a clinical member of the Executive Committee. It also
includes other CCG managers and representation from Public Health and ICP partners.
Key objectives are to reduce health inequalities and improve outcomes for patients and
ensure services are accessible to patients. At the same time, it recognises the financial
challenges faced across the NHS. Healthwatch Bucks is invited to attend.
The members develop, monitor and implement robust working practices. This ensures
equality, diversity and reducing health inequalities are a key part of the commissioning
cycle (see Section 7) and that staff adopt this approach.
The frequency of its meetings has been affected by the Coronavirus COVID-19
pandemic, however when it has met it has addressed and discussed the intensive action
planning and community communication required to tackle health inequalities. It also has
a work plan developed in line with national and local requirements to inform its agendas.
Getting Bucks Involved Steering Group
The Equality, Diversity and Inequalities Steering Group may escalate to the Getting
Bucks Involved Steering Group. This includes members of the public independent of the
CCG who represent diverse communities, from areas where health inequalities are
prevalent, and also lay representatives of Patient Participation Groups and Healthwatch
Bucks.
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The aims of the group now include:
Reducing inequalities – aimed at communities that are more susceptible to certain
clinical conditions. It will target health promotion and ill health prevention
messaging and service redesign involvements.
Promoting engagement - ensuring that patients and the public from our diverse
communities have a channel with which to engage. They will receive feedback on
how their involvement has been used.
This group ensures that patient and public involvement in commissioning is achieved. It
also ensures the voices of those with protected characteristics are considered in all
communication and engagement plans.
As with the Equality, Diversity and Inequalities Steering Group, the frequency of its
meetings has been affected by the Coronavirus COVID-19 pandemic, but it too has
focused on actions and engagement needed to tackle health inequalities in the CCG’s
diverse communities.
CCGs have a statutory duty to involve and consult patients and the public in the cycle of
commissioning. Outcomes of consultation are considered through the Group prior to any
recommendations to the CCG as the statutory body responsible for subsequent decision
making.
The work of the Getting Bucks Involved Steering Group is reported in quarterly reports to
the CCG Governing Body in public. Details of its agendas and meetings are published
here.
6. Health Inequalities Reviews and action plans
Health inequalities are defined as avoidable differences in health across the population,
and between different groups within society. They arise because of the conditions in
which we are born, grow, live, work and age.
The CCG understands the current health inequalities within its geography and has
undertaken reviews of objectives and priorities including patient stories:
14 November 2019: presentation to the CCG Governing Body in public. This
review was updated in 2020 and re-published here.
10 September 2020: CCG Annual General Meeting (AGM) for the public and its
member GP practices included a summary of its response the impact of the
COVID-19 pandemic on health inequalities in its communities. This included
positive messages to the Muslim community during Ramadan, and engagement
with Muslim GPs to support the community during fasting and Eid.
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These reviews have led to additional priorities in tackling health inequalities in its
communities from 2020, which are:
Smoking: reduction overall, with a focus on the most deprived
populations
Mental health for young people: increasing mental health support teams
in schools in deprived areas.
Care & support planning: improving the gap in patient experience
between the Black and minority ethnic (BAME) & white communities.
Improving the detection of hypertension and its management in our
deprived and BAME communities.
Progress on these priorities will be taken into account when the CCG further
reviews and redefines its measurable equality objectives in 2023 (Section 2 of
this report). This is subject to NHS statutory body arrangements as are in place
at the time (see Section 10 of this report).
Impact of the COVID-19 pandemic on community inequalities
This review will take into account the already known impact on communities of the
COVD-19 pandemic, especially the national trend of excess death in people with learning
disabilities and for Black, Asian, and Minority Ethnic (BAME) communities – both patients
and health and social care staff.
Rightly so it has been a key theme of discussion at the Getting Bucks Involved Steering
Group. But it is too early to determine how it is has affected the potential years lost to life
from causes amenable to healthcare. Although local data is currently limited, there is
high confidence that these inequalities will also be replicated within Buckinghamshire.
Our approach must be underpinned by working with our BAME communities. Therefore a
strategic group, with membership from across health and social care partner
organisations, has been established to:
1. Provide strategic direction in the development and implementation of an action
plan to address health inequalities for BAME communities during the COVID-19
pandemic
2. Ensure joined up working across Buckinghamshire ICP in addressing health
inequalities for BAME communities during the COVID-19 pandemic
3. Review national and local evidence about the impact of COVID-19 on BAME
communities, identify emerging priority actions and establish new approaches to
address them
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The Buckinghamshire Action Plan to Address BAME Inequalities in COVID-19 has six
priorities for action:
1. Better Data including ethnicity coding to inform future actions.
2. Culturally Competent Communication Campaigns to facilitate early identification,
testing and diagnosis.
3. Enhanced Community Engagement to understand the impact and identify future
prevention measures.
4. Culturally Competent Health Promotion and Disease Prevention programmes
including weight management, physical activity and smoking cessation.
5. Protecting BAME staff at work.
6. Tackling the impact of Covid-19 on BAME patients and service users.
It forms part of the Buckinghamshire Population Health and Wellbeing Recovery Plan
and reports to the Health and Wellbeing Board. The action plan will also form part of the
implementation of the Buckinghamshire Outbreak Control Plan, overseen by the Health
Protection Board. Therefore, the work of this Board will report to a number of groups,
with final accountability to the Health and Wellbeing Board.
Ethnicity Coding Understanding inequalities in health, and access to and outcomes of healthcare services,
between ethnic groups also relies upon high quality ethnicity coding in patient records.
A national project led by the Nuffield Trust has been examining the completeness,
validity, and consistency of ethnicity coding within NHS health datasets in England
(excluding GP records), in order to establish the extent and nature of data quality issues.
This provides the basis for action to improve data quality, and to inform more robust
analysis and reporting of ethnic inequalities.
The project aims to report in spring 2021. Locally, data quality analysis is ongoing to
reach the same objective.
Progress on the NHS Long Term Plan
A sizeable focus on health inequalities was cited within the 2019 NHS Long Term Plan,
whilst the CCG also sought its own aims for greater digital enabling of its communities.
Whilst these remain relevant, there will obviously need to be a concerted priority effort to
restore routine services and reduce growing waiting lists arising from the pandemic.
Population Health Management
Population Health Management relates to the patient data to design new models of
proactive care and deliver improvements in health and wellbeing, which includes tackling
health inequalities.
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Locally this links to the BAME action plan described above and has a specific ongoing
focus also on the highest areas of inequality and Cardiovascular disease. It involves data
segmentation and analysis in order to provide an evidence base to drive a number of
commissioning and service design objectives:
Prevention : Lifestyles : smoking / Drinking/ Diet/ Exercise
Early detection ; Case finding/ Health Checks/
Self-care/self-management :Personalisation / Education
Best Clinical Management : Clinical pathways/ variation / interventions
Much of this work is co-ordinated through the Primary Care Networks (PCNs), which link
local practices in small collaborative groups to offer primary care health services that are
in addition to their core contracts with the NHS. Analyses undertaken to date include:
Patients with heart failure, Hypertension (poor control), Diabetes, at least one
hospital admission in the last year.
Patients with mid to high comorbidities plus social deprivation aged over 18 years
Patients with serious mental illness/severe depression who are high intensity
users (20+ GP encounters and at least one emergency admission).
The local programme is based on a nationally published framework published at the
following link:
NHS England » Population Health and the Population Health Management Programme
7. Commissioning and Procurement
Intelligence gathering
When making decisions about services to be commissioned, the CCG ensures that
inequalities, equality and diversity intelligence informs its decisions. This is done by using
the Health and Wellbeing Strategy developed by the Buckinghamshire Health and
Wellbeing Board and the Buckinghamshire Joint Strategic Needs Assessment developed
by Public Health.
Subsequent CCG equality and diversity profiles can support project specific equality
impact analysis. These are further supported by Primary Care Network (PCN) based
Population Data and project specific analysis as described above. This intelligence helps
the CCG prepare plans which understand the population’s needs based on
demographics, health inequalities and access to services.
Equality Impact Assessment (EIA)
These are assessments carried out to predict their impact on equality (i.e. the nine
protected characteristics) before implementing policies, service design changes or
external procurements. The Equality Act 2010 does not specifically require them to be
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carried out, but their use does form contributory evidence towards compliance with the
Public Sector Equality Duty.
Where projects/impacts are risk assessed as “medium” in any one of the protected
characteristics, then the Equality Impact Assessment would be reviewed and approved
by the Equality, Diversity and Inequalities Steering Group. If this rating becomes “high”
for any one of the protected characteristics, then the Equality Impact Assessment would
escalate to the Getting Bucks Involved Steering Group.
This robust process ensures that people from all protected characteristics have been
considered. This helps the CCG develop campaigns for communication and engagement
where the voices of all impacted communities are heard.
Equality Duty compliance by commissioned providers
The CCG does not delegate its responsibilities and duties for equality. Where a provider
is being commissioned to deliver services, the CCG ensures they are required to comply
with their Equality Duties (as per the standard NHS national contract).
This contract requires providers to demonstrate ‘equity of access, equality and no
discrimination’, as well as ‘pastoral, spiritual and cultural care’. We have kept under
review the compliance of our three main providers for their Equality Reports, their use of
the NHS Equality Delivery System, their Workforce Race Equality Standard metrics and
their Equality Objectives.
8. Workforce Information
The Public Sector Equality Duty requires that information on the make-up of the
workforce is published where public authorities have 150 or more employees. As of 31
December 2020, Buckinghamshire CCG employed a shared headcount of 106 people.
This includes our ‘officer’ or lay member appointments.
Workforce statistics are reported to the Executive Committee. The CCG also undertakes
its own annual staff survey. We are satisfied that the culture, systems, policies and
procedures support our statutory duties as a public sector employer with respect to
equality and diversity.
9. Workforce Race Equality Standards
In April 2015, the NHS introduced new Workforce Race Equality Standards (WRES)
which aims to ensure that employees from black and ethnic minority backgrounds have
equal access to career opportunities and receive fair treatment in the workplace.
The WRES requires organisations employing NHS workforce to demonstrate progress
against nine indicators of workforce equality. All organisations are required to publish
their own data on an annual basis. The CCG can confirm that all providers for which we
are the Lead Commissioner have made a return in 2020. Action plans are in place to
address any issues identified.
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It was previously recognised that it would be problematic for CCGs, due to their small
workforce, to implement WRES. However, they must have due regard to the standards
and collect and analyse their own data to consider what gaps might exist between the
experience of BME and white staff. CCGs are also expected to consider the aims of
WRES when a workforce policy is being developed, implemented and reviewed.
The WRES metrics for the CCG are published on the CCG’s website.
10. Conclusion
Data quality and understanding of the coronavirus disease has much improved nationally
over the course of the COVID-19 pandemic. But the real impact is expected to be felt for
years to come, both in relation to health and economically. There is also a known
potential for clinical commissioning groups in their current form to be abolished from April
2022. This is subject to confirmation that white paper legislative proposals for a health
and care bill (as published February 2021) subsequently pass into law.
The CCG’s 2021 report, to be published early 2022, will provide opportunity to report
progress in both respects and implications for tackling health inequalities and
commissioning patient services in future years.