The purpose of Sustainability and Transformation Plans is to help ensure health and social care services in England are built around the needs of local populations.
It is difficult to see how this can be achieved without considering the different needs within a local population.
For example, evidence suggests the reconfiguration of health and social care could improve the services for people with learning disabilities or those from Black and Minority Ethnic communities who face poorer experiences and outcomes in healthcare.
The question is: how will the STPs maximise benefits to these various groups?
At the October NHS Equality and Diversity Council meeting we considered how the needs of different groups were being considered by those developing STPs and concluded that we need to do more.
We acknowledge that STP footprints are not organisations in their own right. Some may say that the Equality Act 2010 public sector equality duty does not apply and that partner organisations will carry out the necessary equality analysis work on their own parts of the plans. A similar argument might be made about the health inequalities duties of CCGs under the Health and Social Care Act 2012. But it is important not to get too tied up in legal niceties here. If STPs are making decisions – even “in principle” – factoring equality and health inequalities into those decisions will not only fulfil the spirit and intention of these duties but will help STPs fulfil their core purpose. And this is likely to save duplication of work in STP partners.
The next period of STP development is critical for this work as STP footprints start to get into implementation plans for their priorities.
Based on the experience of the Care Quality Commission (CQC), The Race Equality Foundation and The Five Year Forward View guidance on Engaging local people, published by NHS England, this process of “equality and health inequalities analysis” should be systematic and logical – but it can be simple. For example, an STP footprint could look at the following six questions:
- For each priority or workstream, what do we know already about the access, experience and outcomes for people with each of the “protected characteristics” covered by the Equality Act 2010 – or other groups that might be facing inequalities in health access and outcomes?
- What do we know about the potential impact of STP plans on workforce equality in the local health and social care economy?
- What does this mean for targeted engagement – to fill gaps in our knowledge or because a group will be particularly affected by STP plans so need to be involved on an ongoing basis?
- What does this evidence and engagement tell us about how we can maximise opportunities to advance equality and minimise risks to equality in our plans?
- What concrete changes need to be made to implementation plans?
- What do we need to do in the future to monitor and evaluate the impact of our plans on promoting equality and tackling health inequalities?
This might seem a daunting task – but support is at hand to do this. STPs can draw on:
- Local expertise – Equality and diversity leads in partner organisations, CCGs and CSUs are skilled at carrying out this type of analysis. Engagement of local communities is vital in gathering evidence and in looking at options maximising the impact of STPs on different equality groups, so Patient and Public Involvement leads and the voluntary and community sector will also play an important role.
- Local evidence – partner organisations will have access to good area-wide evidence through the following sources: EDS2 analysis, WRES returns and previous impact analyses that will help answer these questions. You can also access information through the local Joint Strategic Needs Assessments (JSNA)s, and a range of local data sources for promoting equality and tacking health inequalities through variations in access to services and health outcomes : Commissioning for Value Packs produced for CCGs; the Atlas of Variations in Healthcare; Marmot Local Authority Profiles and Challenging Health Inequalities, which is guidance for CCGs to help identify areas of variation in emergency admissions as an indicator of inequality.
- National support – The Five Year Forward View guidance on Engaging local people is helpful. The guidance for NHS Commissioners on Equality and Health inequalities legal duties will be relevant to STPs. Some of the STP aide-memoires cover equality issues or will help in this task– not least by focussing on person-centred care which is more likely to meet the needs of a range of equality groups. The use of the new Equality and Health Inequalities Impact Analysis tools and updated legal guidance (developed by NHS England, the Race Equality Foundation, and The LGBT Foundation for internal use), would also help. Other NHS colleagues can access the documents on request, if they would find them helpful in their work. Please email the NHS England Equality and Health Inequalities Unit (EHIU) on firstname.lastname@example.org
Importantly, the NHS Equality and Diversity Council will be considering this topic again at our next meeting and welcome ideas and experiences from STPs around equality and health inequalities in your work. Please contact us at email@example.com.
One final thought, Equality Analysis may seem dry and procedural. But a good analysis – systematic, logical and yet simple – can provide valuable insight into how STP footprints can flex their plans to ensure they better meet their core purpose – to help ensure that health and social care services in England are built around the needs of local populations.
This blog was written by Lucy Wilkinson, Equality, Diversity and Human Rights Manager, Care Quality Commission – lead author of the blog. Lucy would like to acknowledge Jabeer Butt from the Race Equality Foundation and Anu Singh, Director Patient and Public Participation and Insight, Nursing Directorate, NHS England for their help with writing this blog.
Lucy Wilkinson, Equality, Diversity and Human Rights Manager
Lucy leads on equality and human rights for the Care Quality Commission (CQC) including the Human Rights Approach which embeds equality and human rights throughout CQC’s regulation of health and adult social care services. Lucy also leads on equality and human rights strategy, such as Equality Objectives. Previously, Lucy worked for CQC and Commission for Social Care Inspection (CSCI) leading national reviews of safeguarding, health care in care homes and the CSCI “Equality matters” publications covering race, disability, sexual orientation and gender reassignment. Prior to this, Lucy worked for Oxfam, Refugee Action and Shelter and, more recently, was the chief officer at Leeds Involvement Project – an organisation enabling people using health and social care services to influence service commissioning and development including through reference groups and local and national user-led research. In a voluntary capacity, Lucy has been active in equality groups and campaigns especially in relation to the rights of women, disabled people and LGB people. Lucy is a practicing Buddhist.