Within the NHS, there appears to be a lack of accountability. Feedback from staff within the Midlands reflects some of the findings of the Francis report to that effect. Comments made by staff stated that progress has been too slow, and, in some areas, we are observing no change in eliminating discrimination due to a perceived lack of accountability.

When issues are highlighted, staff must feel confident that they will be listened to, their issues investigated, individuals held accountable, and action taken.

We also need to ensure that issues of equality are central to the CQC inspection measure. Trusts have been rated ‘outstanding’ or ‘good’ by the CQC despite demonstrating a lack of progress in addressing equality issues. In future, the CQC should hold organisations that are not tackling equality issues to account and rate them appropriately.

While the People Plan references the need for accountability, it does not dictate what the sanctions need to be for the lack of progress. This issue needs to be addressed by the national NHSE&I team.

The CEO is ultimately the most senior person responsible and accountable with regards to ED&I within any organisation. As STP/ICS develop, we need to clarify the level of accountability System leads have for dealing with organisations failing to progress on ED&I issues.

A study carried out by UCU revealed that sanctions were the most effective method in tackling racism.

Strategic approach to build accountability

These recommendations are for short term goals for 3-6 months (S), medium term goals for 6-12 months (M) and long term goals for 12 months (L).

• NHSE&I to develop an Independent race equality and inclusion panel to act as a critical friend to the Regional People Board. (M)
• The level of responsibility and accountability needs to clarify at each STP/ICS regarding ED&I matters. (M)
• NSHE&I to work with all senior leaders, including ED&I leads, staff network leads, WRES Experts, and system leads to agree on expectation for senior managers and appropriate sanctions if expectations are not met. (M)
• Organisations will be held to account by system leaders, and the regional people board if they do not meet BME staff targets at all levels. (M/L)
• ED&I will be an essential component to determine whether an STP can apply to become an Integrated Care System*. (S)
• Staff network groups should have the authority to hold leaders accountable for a perceived lack of progress in ED&I matters. (S)
• Equality and health inequalities impact assessment need to become an essential element of regular board meetings. (S)
• All leaders must demonstrate that they are prepared to hold others to account by challenging behaviours that are not compassionate and inclusive. (S)
• All organisations must report on the number of formal disciplinary cases of bullying, harassment and discrimination to system leads (frequency to be confirmed) and this needs to include:
  • Actions taken against all formal cases of bullying, harassment and discrimination raised
  • actions that demonstrate appropriate sanctions have been taken. Sanctions applied should consider their role and level of seniority

*To approve an ICS, it is proposed that they need to provide evidence about how well they have implemented the regional Race, Equality and Inclusion Strategy within their system. The ED&I regional subgroup and the proposed Independent Race Equality Panel will agree on the minimum required standard.