Equality and Diversity Strategy

Transcription

1 Equality and Diversity Strategy v st October 2013

2 Document Control Version History Version Issue Date Brief Summary of Change Author Document Creation and outline sections Steve Corton References sourced and checked and content Steve Corton amended. Circulated to stakeholders for comment and amendment plus draft introductory text for Chair s consideration Steve Corton/Dan De Rosa Chair s introduction amended, agreed and added. Steve Corton/Dan De Rosa Stakeholder comments and suggestions added to the strategy document. References and embedded hyperlinks checked. Submitted to Quality and Safety Committee meeting on 8 th October Strategy and Objectives AGREED Steve Corton incorporating stakeholder feedback. v st October 2013

3 Contents Page Introduction Chair Dr Dan De Rosa 1 Our Equality Objectives 2 1. Purpose 3 2. Our Vision and Values Principles 4 3. Wolverhampton in context 6 4. The case for Equality 9 5. Legal responsibilities for Equality The Business Case for Equality How we will ensure progress on equality Performance Monitoring Engagement and Involvement Equality Delivery System Conclusion 23 Appendix 1 Equality Action Plan Year 1 ( ) 24 Appendix 2 Summary of the Equality Delivery System 36 References 37 v st October 2013

4 Introduction Equality and Diversity are central to our commissioning plans, where everyone has the opportunity to fulfil their potential. Equality is about creating a fairer society and Diversity is about recognising and valuing difference in its broadest sense. Forty nine GP practices in the city are members of the CCG and this provides us with the opportunity to work with our patients to improve services and the overall health of the city. Our GP practice membership will ensure the needs and priorities of our population are clearly identified and addressed by delivering the right care in the right place, at the right time This strategy covers our relationships with service users, with our staff, and with other stakeholders, It builds upon the strong foundation for equality, diversity and human rights in our constitution and governance arrangements. It is key to how we will make decisions and how we contribute to strategic planning with our partners. It sets out how we will ensure equality considerations and valuing difference so that it becomes a systematic part of our thinking, our tone and our approach. Our approach to equality and diversity will directly influence the relationships and transactions we have with individuals and groups and local communities; the way in which we collect, analyse and interpret information and evidence; the collaborative arrangements we have with provider organisations; and finally the discipline we adopt to reflect and consider if we truly understand the consequences of our actions from the different perspectives of Wolverhampton people. This will apply particularly to those who are disadvantaged by, or vulnerable because of social determinants of ill-health. This discipline will help us to assess if we are being unfair or discriminatory in our assumptions. We have adopted the Equality Delivery System (EDS) to help us achieve effective delivery of this strategy, deliberately leaving us open to challenge and scrutiny through the involvement of local interest groups, who will critically evaluate our performance and progress. It will enable us to identify gaps and barriers in provision, which will help us to begin to address those health inequities which may disproportionately affect some groups more than others and those which could arise because of the unfair differential impact our policies and plans could have on different communities or on our workforce. The strategy is for The first year action plan for sets out our initial tasks to ensure that we have got the basics right; have critically reviewed the information and systems inherited from the Primary Care Trust; have reflected on our own culture and approach and that we have developed a fuller understanding of the way in which equality considerations can be placed at the core of commissioning decisions. We will then be on course to carry out the innovative work we need to do on equality to complement other work set out in our commissioning and engagement strategies to reduce unfair or avoidable disparities in health. Dr Dan De Rosa Chairman, Wolverhampton CCG 1

5 Our Equality Objectives Our Equality Objectives are set out below. These are supported by the actions set out in the Equality Action Plan (Appendix 1) which will be updated each year of the 4 year strategy to ensure continuous development and improvement. In this way, the equality objectives will not be static for four years. They will evolve to stretch the ambition and achievements of the CCG. 1. To ensure that Leadership and Governance arrangements persist in offering high level assurance of equality. 2. Equality approaches are effectively included in key mechanisms of commissioning (such as business case development, procurement, contracting). 3. Equality Analysis becomes part of our organisational processes so that projects, policies, strategies, business cases, specifications and contracts have all been developed in consideration of equality, diversity and human rights issues. 4. To apply Goals 1 and 2 of the Equality Delivery System to an average of at least three patient pathways for each year of the strategy, and to demonstrate year on year improvements for Goals 3 and 4 (Staff and Leadership) 5. To regularly review and update the strategic action plan and equality objectives (on at least an annual basis) to ensure that it is providing appropriate targets for development and improvement. 6. To ensure all CCG staff receive basic training to ensure awareness of Equality Act 2010 responsibilities and the NHS Constitution, and that specific training on Equality Analysis and the Equality Delivery System is targeted to all staff who are involved in these processes. 7. To ensure that Equality and Diversity forms an ongoing part of our leadership and organisational development programmes 8. To ensure that Equality and Diversity approaches are fully included in our engagement of people who use services and in our work with strategic partners and other stakeholders. 9. Improve accessibility of information and communication for people from statutorily protected groups and other disadvantaged groups. 2

6 1. Purpose 1.1 Wolverhampton Clinical Commissioning Group (WCCG) is fully committed to promoting equality of opportunity, eliminating unlawful and unfair discrimination and valuing diversity. We will ensure that we: commission accessible, high quality health services on the basis of clinical need, tailored appropriately to the different healthcare needs of the various groups in the community we serve; achieve equality and fairness in our employment practices. 1.2 Our Equality and Diversity (E&D) policy document provides the equality and diversity framework within which WCCG will operate. We recognise that our aim is not to treat everyone as though they were the same, but to value the differences between individuals and deal with everyone fairly in that context. 1.3 This Equality and Diversity strategy sets out our Equality Objectives for the next four years. It explains how our approach to equality, diversity and human rights is consistent with our commissioning vision to deliver the right care, in the right place, at the right time for the people of Wolverhampton, and shows how compliance with the public sector equality duty will be achieved and performance measured. A detailed action plan for the first year is set out at the back of this document. The action plan will be developed annually to ensure that we grow as a CCG to improve our understanding and responsiveness to equality matters. 1.4 Wolverhampton CCG has already demonstrated a commitment to equality as part of the authorisation process for CCGs, by ensuring constitutional and governance arrangements are established to deliver its duties and responsibilities. The requirement is for the CCG to demonstrate compliance with the Public Sector Equality Duty and to use the Equality Delivery System (or an equivalent method) to help attain compliance and to ensure good equality performance. Our governance arrangements and responsibilities for equality are explained within this document. 1.5 We will build on the learning outcomes and key messages for CCGs left for us from the work done by the Black Country Cluster of PCTs (2013), including the development of leadership; addressing gaps in equality data; developing understanding of equality in primary care; using contractual levers to promote equality with providers; and being involved in partnership work on the causes of the causes of health inequalities (Marmot 2010b). 1.6 The CCG has commissioned work from the Central Midlands Commissioning Support Unit (CSU) to ensure that it can call upon the appropriate advice, guidance, and expertise in implementing this strategy and to ensure good practice and compliance with equalities and human rights legislation 3

7 2. Our Vision, Values, and Principles 2.1 The development of our mission, vision and values was led by our governing body, with the involvement of patients and the wider public, and through our regular community workshops. These guiding principles are enshrined in our constitution and we have shared the finished articles with our patient groups and delivery partners as part of the developed of the CCG s first integrated commissioning plan. 2.2 Mission Wolverhampton CCG will be an expert clinical commissioning organisation, working collaboratively with our patients, practices and partners across health and social care, to ensure evidence-based, equitable, high quality, and sustainable services for all of our population. 2.3 Our Aims We have a range of challenging health issues in Wolverhampton with a diverse population. So we have used the evidence to inform our strategic aims, which are to: i. improve and simplify arrangements for urgent care; ii. address variations in the quality of planned care; iii. improve the care of those with chronic conditions; iv. reduce health inequalities across the City; v. commission the highest quality of services within the available resources This will be done in collaboration with our key partners. 2.4 Our Vision Our vision is for the Right care in the Right place at the Right time for all of our population. Our patients will experience seamless care, integrated around their needs, and they will live longer with an improved quality of life. 2.5 Our Values Good corporate governance arrangements are critical to achieving the group s objectives. The values that lie at the heart of the group s work are: i. to be a dynamic, responsive and innovative organisation ii. to drive the commissioning agenda in the City iii. to be a trusted and valued partner contributing positively to the health and social care economy iv. to have a proactive, inclusive, equitable and professional approach that will secure best value for money and high quality in all that we do v. to be open and responsive to the local population, patients and clinicians 4

8 vi. to have ways of working that encourage people to want to work for and with us. 2.6 Our Principles We will: commission high quality, patient-centred care improve patient care by focusing on quality adhere to evidenced based decision making treat patients, carers and their representatives with respect be open about what is possible, what cannot be changed and why involve local people in decision making respond to concerns and views and demonstrate how we have responded and what impact this has had include those who are marginalised and seldom heard, by understanding our communities and stakeholders and valuing partnership working undertake decision making in a fair way so that no one group is significantly disadvantaged by the decisions we take demonstrate a commitment to learning and development, exploring different ways of working and evaluating and implementing our learning for continual improvement. 5

9 3. Wolverhampton in context 3.1 Wolverhampton Clinical Commissioning Group is wholly committed to improving the health and wellbeing of its population. The City of Wolverhampton faces significant challenges including difficult indicators for socio-economic status and for deprivation; the significant incidence of long term illness; low overall life expectancy and the differential impact of these factors in different parts of the city. The CCG also faces considerable financial challenges, but we will seek to ensure that every pound spent on healthcare is spent wisely and works efficiently and effectively for the people of Wolverhampton. 3.2 Wolverhampton s resident population is approximately 249,500. It is one of the most densely populated places in the country, with nearly 9,000 residents per square mile. The city s population is predicted to grow by 2035 (to 273,000) and its composition will change significantly. By 2020 there will be a growth of between 5% and 10% for 0-39 and year olds while the 80 and over population will have increased by nearly 20%. Further into the future, by 2035, the 80 and over population is forecast to have increased by more than 60%, with lesser increases for 0-39 and year olds. 3.3 Over one third of the population (35.5%) is of black and minority ethnic (BME) origin. The city s Sikh community makes up around 10.5% of the total population, while Black Caribbean communities account for around 5%. The mixed heritage population in the city is relatively small and very young; mixed race children now account for 8% of all children under the age of There are approximately 800 asylum seekers in the city. It is estimated that at any one time up to 3,000 failed asylum seekers may be in Wolverhampton but it is hard to gauge the exact numbers as they will often not be in contact with statutory services. Wolverhampton has also seen a rise in migrant workers since the expansion of the European Union. Again it is difficult to give a precise view of their impact in the city as many just stay for short periods and are also difficult to track once they arrive in the UK. 3.5 Health and well-being and the use of health services are inextricably linked to socio-economic factors and this is seen starkly in Wolverhampton. The health of the people of Wolverhampton is generally worse than the England average. The city is ranked twenty-eighth most deprived out of 354 local authorities. But deprivation is not concentrated in a few areas almost half of the city s neighbourhoods are amongst the 20% most deprived in the country as shown in Figure 1 below. The pattern of disadvantage is closely linked to a past history of heavy industry in the centre and east with relative advantage in the west and city edges. This pattern of deprivation has remained persistent over time. 3.6 The city also has significant indicators of social deprivation and poor health: 6

10 Life expectancy in Wolverhampton is in the bottom 20% nationally; 32% of the population report a limiting long term illness; The 4 th highest rate of teenage pregnancy in England; Rates of obesity amongst middle aged people are above regional averages; Early death rates from heart disease, from stroke and from cancer have decreased, but are still above the England average. Men from the least deprived areas can expect to live 7.4 years longer than those in the more deprived areas, whilst in women this difference is 5 years. The percentage of obese children and the estimated percentage of obese adults are high and the estimated proportions who eat healthily (fruit and vegetables) and are physically active are low. Eligibility for free school meals varies by ethnic groups with lower proportions in White and Asian children. Figure 1 Map of deprivation in Wolverhampton (source Wolverhampton Health Profile 2012; Public Health Observatory) 3.7 The CCG s Equality and Diversity Policy recognises that our aim is not to treat everyone as though they were the same, but to value the difference between 7

11 individuals and deal with everyone fairly in that context. That makes it essential that we recognise differences such as: Infant mortality is higher for children with mothers born in Pakistan and the Caribbean; the prevalence of stroke is much higher among African-Caribbean and South Asian men; young Asian women are twice as likely to commit suicide as young white women; the incidence of diabetes is 5 times higher among South Asians and 3 times higher among those of Caribbean backgrounds than in the general population; people with learning disabilities or long-term mental health problems are 58% more likely to die before the age of 50. 8

12 4. The Case for Equality...serious health inequalities do not arise by chance, and they cannot be attributed simply to genetic makeup, bad or unhealthy behaviour, or difficulties in access to medical care, important as those factors may be. Social and economic differences in health status reflect, and are caused by, social and economic inequalities in society. Marmot (2010a) 4.1 Professor Sir Michael Marmot s report Fair Society, Healthy Lives expressed concern with the social determinants of health which he called the causes of the causes of health inequalities those fundamental social and economic conditions which have been shown to have an impact on how healthy a person will be during the course of their life. This includes the conditions in which people are born, grow, live, work and age. It includes an individual s education and employment opportunities in life and their earning potential; it can include belonging to a minority group or being socially excluded from mainstream society. Inequalities in the social determinants of health act as barriers to addressing health disparities. 4.2 Individuals and communities that experience inequalities in the social determinants of health not only carry an additional burden of health problems, but they are often restricted from access to resources that might help reduce these problems. For instance, people living in conditions of low income. This is linked to increased illness and disability, which in turn represents a social determinant linked to reduced opportunities to engage in gainful employment, thereby aggravating poverty. Physical environments such as crowded housing conditions have been associated with stress. Although these links have been evidenced by statistical information, what remains less well understood are the ways in which this happens how social determinants influence health. The processes involve complex interconnections and demonstrating these is difficult. 4.3 Health inequity refers to health inequalities which are unfair or which arise because of some form of injustice (Kawachi, 2002) (Dahlgren and Whitehead, 1992). The distinction between the two terms is that the identification of health inequities carries a value judgment about social justice and a recognition that social and economic factors leading to health inequalities which are unfair and avoidable should be put right. Why have Equality? Studies have shown that the actions and or attitudes of professionals in their normal interactions with patients can impact positively on empowerment and health (UCL institute for Health Equity, 2012; p12) 9

13 4.4 Equality is important for many reasons. People enjoy life more if they are treated fairly. They give more. Society is richer because each and every person can do what they are best at and, it is easier for people to live side-byside and get on with each other if everyone feels they are being treated fairly. 4.5 Equality is not about levelling down the services available or finding the lowest common denominator for service delivery. It is not about diluting or frustrating innovation. Equality is an investment with a considerable return. Accepting the principle of equality is recognition that by enabling people to maximise their potential, and take opportunities which might otherwise be denied, we increase the knowledge, skills and resources available to us all. In healthcare we can benefit society as a whole by having fitter, healthier, more productive people, in control of the decisions which affect them, and taking active and responsible roles as stakeholders in the NHS. It will also have economic benefits in reducing the costs of illness. 10

14 5. Legal responsibilities for Equality 5.1 In addition to the benefits offered by an approach which values equality discussed above, Wolverhampton CCG also has legal responsibilities under the Equality Act 2010, the Health and Social Care Act 2012, and the Human Rights Act Equality Act The Equality Act 2010 provides a legal framework to protect the rights of individuals and advance equality of opportunity for all. Public organisations including Wolverhampton CCG have some specific responsibilities known as the Public Sector Equality Duty. This is set out in the Act at section 149. It requires us to have due regard to the need to: I. Eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act. II. Advance equality of opportunity between people who share a protected characteristic and those who do not. III. Foster good relations between people who share a protected characteristic and those who do not. 5.3 The protected characteristics refers to the groups of people who are specifically offered protection by the Act. Before the Equality Act, NHS Trusts already had to demonstrate that they were treating people of different races, disabled people, and men and women fairly and equally. The Act has added extra groups of people to the equality duty: People of different ages referring to a person belonging to a particular age or age group Lesbian, gay and bi-sexual people whether a person s sexual attraction is towards their own sex, the opposite sex, or to both sexes. People who are transitioning from one gender to another. A person who is Transgender is someone who expresses themselves in a different gender to the gender they were assigned at birth. Although the legislation covers gender reassignment, we recognise that the term trans better encompasses the wider community. People with a religion or religious or philosophical beliefs, (or people without a religion or belief e.g. Atheism). Generally a belief should affect your life choices or the way you live for it to be included in the definition. Political beliefs are not afforded protected characteristic status. Women who are pregnant or expecting a baby (Pregnancy) and the period after the birth (Maternity). Maternity may refer, for example, to maternity leave in the employment context, or in the non-work context protection against maternity discrimination is for 26 weeks after giving birth, and this includes treating a woman unfavourably because she is breastfeeding. People who are in a civil partnership or are married. Marriage is defined as a union between a man and a woman. Same-sex couples 11

15 can have their relationships legally recognised as civil partnerships. Civil partners must be treated the same way as married couples on a wide range of legal matters. 5.4 The Public Sector Equality Duty requires Wolverhampton CCG to consider all individuals when we carry out our day to day work in shaping policy, in delivering services and in relation to our own employees. It supports good decision making. It encourages us to understand how different people will be affected by our activities, so that our policies and services are appropriate and accessible to all and meet different people s needs. By understanding the effect of our activities on different people, and how inclusive public services can support and open up people s opportunities, we can be more efficient and effective. The Health and Social Act We also have a legal duty under the Health and Social Care Act 2012 to reduce inequalities between patients regarding their ability to access health services, and with respect to outcomes. The CCG must also ensure that services are provided in an integrated (or joined up) way. We cannot act alone to change the unequal distribution of social and economic conditions which lead to unequal health outcomes. This is why our strategies for commissioning, for communications and engagement, and for equality, stress the importance of working with our partners in local government, public health, and across the voluntary and community sectors, as well as with our provider organisations, to adopt a comprehensive approach towards these issues with shared goals and plans which link strongly with each other rather than each of us acting independently. The Joint Health and Wellbeing Strategy produced by Wolverhampton Council and Wolverhampton CCG will ensure that this coordinated approach to commissioning develops and strengthens, for example on approaches to tackle diabetes, urgent and emergency care, and dementia. Human Rights Act (1998) 5.6 The CCG has obligations under the Human Rights Act As a public body we must at all times act in a manner compatible with the rights protected in this Act and safeguard these for patients and staff in our care and employment. 5.7 Human Rights are underpinned by a set of common values and have been adopted by the NHS under the acronym FREDA. The FREDA principles represent: i. Fairness (e.g. fair and transparent grievance & complaints procedures) ii. Respect (e.g. respect for older people, same sex couples, teenage parents,) iii. Equality (e.g. not being denied treatment due to age, sex, race) iv. Dignity (e.g. sufficient staff to change soiled sheets, help patients to eat /drink) 12

16 v. Autonomy (e.g. involving people in decisions about their treatment and care) 5.8 The Equality and Human Rights Commission states that putting human rights principles into public service practice is in the public interest. The evidence shows that public bodies which take human rights seriously treat people better (Department of Health, 2008). 5.9 The CCG will endeavour to embed a human rights based approach in the way that it commissions services and in its role as an employer. This approach is not new, and is already evident in current initiatives such as Dignity in Care, Essence of Care, Standards of Better Health and the Knowledge and Skills Framework. NHS Constitution 5.10 Human Rights principles are also core to the rights of patients set out in the NHS Constitution: The NHS provides a comprehensive service available to all irrespective of gender, race, disability, age, sexual orientation, religion or belief. It has a duty to each and every individual that it serves and must respect their human rights. At the same time, it has a wider social duty to promote equality through the services it provides and to pay particular attention to groups or sections of society where improvements in health and life expectancy are not keeping pace with the rest of the population. NHS Constitution, The Report of the Mid Staffordshire NHS Foundation Trust Public Inquiry Chaired by Robert Francis QC (Francis Report, 2013) made several recommendations concerning the NHS Constitution including: Use of the Constitution as the first reference point for all NHS patients and staff (Recommendation 3) Its core values should be given priority of place, patients are put first, and everything done by the NHS is informed by this ethos (Recommendation 4) All NHS staff should be required to enter into an express commitment to abide by the NHS values and the Constitution (Recommendation 7) Contractors providing outsourced services should also be required to abide by these requirements and to ensure that staff employed by them for these purposes do so as well (Recommendation 8) Under Section 14P of the NHS Act 2006, the CCG has a duty to secure the provision of health services in a way which promotes the NHS Constitution, and to promote awareness of the Constitution among patients, staff and members of the public. As part of the fulfilment of this duty, the CCG has built consideration of the NHS Constitution s values into its Equality Analysis process which within the first year action plan, we will seek to apply to all new 13

17 business cases, service specifications, and procurements (also consistent with the Francis report discussed above). Beyond Equalities Legislation 5.13 In considering the different aspects of equality we will not be limiting the extent of our equality approaches to the protected characteristic groups set out in the Equality Act There are other socially excluded groups for example homeless people; Gypsy, Roma and Travelling communities, sex-workers, and migrant groups who often need reassurance and help to navigate the health system effectively and who may access healthcare in ways which do not necessarily meet their particular needs for example an over-reliance on A&E services. In this regard, there is also a clear economic case for considering the way in which such groups access and use healthcare services, and this underpins the CCG s priorities for efficiencies as part of the QIPP Quality, Innovation, Productivity and Prevention agenda discussed in our Integrated Commissioning Plan 5.14 The recent Independent Review (GEO, September 2013) commissioned by the Government has recommended retaining the statutory Public Sector Equality Duty and for a formal evaluation of its impact to take place in In addition the Equality and Human Rights Commission has been asked to produce more specific guidance for public bodies to help them practically in being compliant with the duty, and to better understand the extent of the due regard requirements in the Act. The CCG will be working with our partners in the Central Midlands Commissioning Support Unit s Equality and Diversity Team to ensure that we adopt new guidance speedily for the benefit of our local population. 14

18 6. The Business Case for Equality Austerity need not lead to retrenchment in the welfare state. Indeed, the opposite may be necessary: the welfare state in England, the NHS itself, was born in the most austere post-war conditions. This required both courage and imagination. Today we call for courage and imagination again, to ensure equal health and well-being for future generations (Marmot, 2010a; p12) 6.1 Wolverhampton CCG has taken responsibility for commissioning healthcare at an extremely challenging time. Nationally, the country is gradually recovering from recession and we can anticipate that public finances will be limited for a considerable time to come. In the NHS we also have the QIPP challenge (Quality, Innovation Productivity and Prevention) to improve the quality of care the NHS delivers whilst making up to 20billion of efficiency savings by the end of the financial year. Strategic approaches which save money, or enable services to achieve greater efficiencies are therefore very important to identify. Prizing an equality approach to service delivery offers economic value to the CCG and to all residents of Wolverhampton borough. 6.2 At the global level, Wilkinson and Pickett (2010) have looked at the costs of inequality and the differential impact for countries and shown that better, more successful economic outcomes occur in those countries which have greater equality across different social conditions. LaVeist and others (2009) have looked at the economic burden of health inequalities in the US finding that over $230 billion additional costs over a three year period were due to direct medical costs faced by African Americans, Hispanics, and Asian Americans due to health inequities. A study in Switzerland by Bischoff and Denhaerynck (2010) concluded that language barriers have a negative impact on healthcare costs and that the use of interpreter services leads to more targeted healthcare and can prevent the escalation of long-term health costs. 6.3 Equality for our patients, staff and communities will be achieved when our equality values and principles are woven through every aspect of the organisation and its work, shaping and developing an organisational and workforce culture that is underpinned by inclusive values, rights and responsibilities that are embedded within every stage of our commissioning journey. Wolverhampton CCG s resolve is to build on the legacy from NHS Wolverhampton to secure improved outcomes. This applies just as much to our approach to equality as it does to the other responsibilities we are tasked with. Including equality in a meaningful way, within our other activities, means that we will be receptive to challenge. We welcome this as part of developing a better understanding of how equality considerations can improve the work we do and the relationships we have with service users. Through this, we will seek to gain the respect of local communities, and to become recognised as credible, sensitive commissioners of healthcare services and as a legitimate employer which values equality and diversity. 15

19 7. How we will ensure progress on equality 7.1 The CCG has established an Equality and Diversity Policy that underlines our commitment to promoting equality of opportunity, eliminating unlawful and unfair discrimination and valuing diversity all within the context of the group s overall Mission, Vision, Values and Aims. 7.2 The policy provides the equality and diversity framework within which the CCG will deliver, as a minimum, its statutory duties with regard to equality and the need to reduce inequalities, as required by its constitution. The policy addresses the responsibilities of the CCG as a commissioner and within the CCG as an employer. 7.3 The policy requires the CCG to use the Equality Delivery System (EDS) and this will enable us to begin to identify and address issues that might already disproportionately affect some groups more than others and those which could arise because of the unfair differential impact our policies and plans could have on different communities, or members of different groups within our workforce. Equality of Opportunity for our Employees 7.4 The CCG directly employs a relatively small number of employees and is in a good position to collect robust information from our staff in terms of protected characteristics. To that end the merits of answering equality monitoring questions will be promoted and the CCG will seek to identify any equality and diversity issues with regard to: composition of workforce, job applicants and leavers; employees who seek and receive training or study leave; employees who request and are granted flexible working arrangements; employees who raise formal grievances; employees who are subject to disciplinary investigation and action, being always mindful that results have to be interpreted with particular care when small populations are involved. 7.5 The CCG recognises that diversity in our workforce will make it easier for us to serve a diverse population and that being demonstrably inclusive in our employment practices will help us to build a stronger rapport with our local communities. 7.6 Our strategic aim in this area is the third Equality Delivery System goal: The NHS should increase the diversity and quality of the working lives of the paid and non-paid workforce, supporting all staff to better respond to patients and communities needs. This will be strengthened through our equality objective to ensure that Equality and Diversity forms an ongoing part of our leadership and organisational development programmes. 16

20 Culture and Processes 7.7 Delivering this strategy will demand effective leadership to instil both individual and collective commitment and ownership at every level of the CCG. Our employees and those who provide services to us must be supported and feel confident in their ability to challenge discrimination, advance equal opportunities, foster good relations and safeguard human rights for each other, and for patients as required by statute and the NHS Constitution. 7.8 In addition to the desire to get this right because doing so supports our other aims and objectives, there needs to be a corporate recognition that failing to deliver poses legal, professional, reputational and financial risks. 7.9 Our constitution establishes clear lines of responsibility and accountability and these are reflected in the Equality and Diversity Policy, particularly the role of the Accountable Officer, Quality and Safety Committee and Finance and Performance Committee In addition to creating the culture described above our strategic aim is to ensure that equality and diversity issues are considered at the beginning of decision making processes alongside option appraisal, not in an impact assessment carried out as an afterthought and/or seen as only a bureaucratic necessity. Instead of just consulting with those who already use or seek to use services, we will seek to consult with those who do not, in order to find out why that is. This should ensure that the relevant issues have already been addressed when Equality Analysis is carried out rather than being identified for the first time by that element of the process As a minimum we will: observe principles of good governance, including the NHS Constitution and Equality Act 2010 (constitution paragraph 4.5(d) and (e)); meet the public sector equality duty (paragraph 5.1.2(b)); have regard to the need to reduce inequalities in patients ability to access services and/or in the outcomes being delivered by the services they do use; eliminate discrimination, harassment and victimisation and any other conduct that is prohibited by or under the Act; advance equality of opportunity between people who share a relevant protected characteristic and people who do not share it; foster good relations between people who share a relevant protected characteristic and those who do not share it; publish relevant information to demonstrate our compliance with the duty. (References are to paragraphs in the CCG s Equality Policy) 7.12 The CCG s Constitution also contains important commitments and statements of responsibility including 17

21 i. acting in accordance with the principles of the NHS Constitution Paragraph (4.5.1(d)) ii. compliance with the Equality Act 2010 (4.5.1(e)) iii. meet the public sector equality duty (5.1.2(b)) iv. Promoting awareness of the NHS Constitution (5.2.2) v. Have regard to the need to reduce inequalities (5.2.6) vi. The Deputy Chair of the CCG as the governing body lead for Equality and Diversity (6.6.2(c)(ii)) vii. A commitment to offering all staff equality of opportunity and that employment practices are designed to promote diversity and to treat all individuals equally (9.2) 8. Performance Monitoring 8.1 The delivery of the QIPP agenda is fully integrated within the day to day workings of the CCG s Development Delivery Groups (DDG s). A robust programme management approach will ensure rigorous performance management of the schemes. The CCG s Development Delivery Groups (DDGs) have been set up to cover the commissioning issues of: Planned Care Urgent Care Long Term Conditions Intermediate Care and Community Services Medicines Management Joint Commissioning and Mental Health Contracts and Commissioning Corporate matters. 8.2 DDGs will have responsibility for the sign-off of Equality Analysis processes for their particular area of focus. 8.3 The monitoring of this strategy will be achieved through the regular reports generated for the Governing Body and the Quality and Safety, Committee. These reports will regularly update the CCG on the progress of the Equality Action plan, its timeliness, and the extent to which its outcomes have been achieved. 8.4 Equality risks will be monitored using the CCG s DATIX risk management system. 8.5 Equality questions will, where appropriate, be included in the terms of reference for Internal Audits. 8.6 Patients, other people who use services, and the wider public will be actively encouraged and supported through our Communication and Engagement strategy to offer feedback. The CCG will also work in partnership with local interest groups to apply the Equality Delivery System to agreed patient 18

22 pathways and monitor performance and improvement in a way that has real meaning for patients. 8.7 By achieving and managing these monitoring processes effectively, we can ensure that the CCG Board and senior leaders conduct and plan our business so that equality is advanced, and good relations fostered, within our organisation and beyond meeting the integral parts of the Public Sector Equality Duty. 19

23 9. Engagement and Involvement 9.1 This Equality Strategy should be read alongside the CCG s Communication and Engagement Strategy (Reviewed and updated January 2013) which can be found at this link. This sets out our vision for communication and engagement and stresses the need to build continuous, meaningful engagement with patients and the public to shape services and to improve health, and to give everyone who wants to influence the planning, development, review, and improvement of services the opportunity to do so. 9.2 We understand and value the immense contribution that local patients and the community can make in shaping the services that we commission. When the government announced the creation of Clinical Commissioning Groups in 2010, it made a promise of no decision about you, without you. This is a founding principle of our CCG. We want every decision we make whether it be about the priorities we set or the services we commission to be informed by the views of local people. We have designed a comprehensive engagement framework at the CCG that comprises a range of local and city-wide meetings between GPs, patient and community groups. These enable us to work with our partners at every stage of commissioning from priority setting to reviewing service performance. All of the feedback from the meetings goes to our quarterly Joint Engagement Assurance Group. This comprises representatives from providers, the council, Healthwatch and patients to scrutinise the CCG s communications and engagement plans. 9.3 At their local GP Practice, many patients can now join a local Patient Participation Group (or PPG). These are constituted to be reflective of the composition of their local communities. By joining a local PPG, patients can work with GPs and practice staff to develop projects to support the patient community. Each PPG works slightly differently, depending on the preferences of its members. To find out if your local practice has a PPG and how to join, please speak to practice staff at your GP surgery. 9.4 We will also work with local City-wide representative organisations such as Wolverhampton Healthwatch, the Wolverhampton Equality and Diversity Forum, the Patient Partnership Group, Community Leaders Forum and the Clinician and Allied Professional Forum. 9.5 We also recognise the strong tradition of community engagement undertaken by partner organisations in the City Council under the auspices of Wolverhampton Partnership, the Local Strategic Partnership for Wolverhampton. There are three main aspects to this work: i. A joint community engagement strategy (due to be refreshed in 2013), setting out the City s approach to community engagement (which individual partners are signed up to) ii. Total Voice a commitment by individual partners to share the results of consultation and engagement activities so we can draw together a 20

24 iii. comprehensive picture of the needs, wants and aspirations of the people of Wolverhampton. This process is facilitated by the Community Engagement Database The Community Engagement Learning Programme a free programme of learning activities to support people in the city who are delivering community engagement work 9.6 In our relationships with patients and the wider public, and through our joint work with partner organisations in the Wolverhampton Partnership, the CCG will seek to: Better understand the needs and expectations of patients, carers and the public to ensure they are communicated to the Board Involve patients, carers and public in the decision making process and ensure feedback is used to inform the commissioning of services Listen and respond to patient and public comments Ensure that the Governing Body acts in the best interests of the local community 10. Equality Delivery System (EDS) 10.1 During , the NHS Equality and Diversity Council commissioned the development of an Equality Delivery System (EDS), aimed at improving the equality performance of the NHS and embedding equality into mainstream business. By using the EDS, commissioning organisations will make good progress towards meeting the requirements of the Equality Act The EDS requires NHS organisations, in collaboration with local interests, to analyse and grade their performance, and set defined equality objectives, supported by an action plan. These processes should also be integrated within mainstream business planning The EDS can be used to support commissioners to identify local needs and priorities, particularly the unmet needs of seldom-heard populations, and allow them to shape services around people s specific circumstances. The EDS is structured into 4 Goals with 18 objectives (please see Appendix 2). The Goals are: Goal 1. Better health outcomes for all The NHS should achieve improvements in patient health, public health and patient safety for all, based on comprehensive evidence of needs and results. Goal 2. Improved patient access and experience The NHS should improve accessibility and information, deliver the right services that are targeted, useful, useable and used in order to improve patient experience. Goal 3. Empowered, engaged and included staff The NHS should increase the diversity and quality of the working lives of the paid and non paid workforce, supporting all staff to better respond to patients and the wider communities needs. 21

25 Goal 4. Inclusive leadership at all levels NHS organisations should ensure equality is everyone s business, and everyone is expected to take an active part, supported by the work of specialist equality leaders Wolverhampton CCG has reviewed its original approach to implementing the EDS when selected objectives were chosen to be pursued. However, on reflection, we were concerned that this approach would not achieve systematic change speedily enough to have a real impact on patients and other people using services. We have therefore changed the emphasis and during we will adopt the following approach: i. Goal 1 and Goal 2 of the EDS will be implemented by applying the corresponding objectives to specific patient pathways. This means that we can consider our commissioning performance in more depth, and test ourselves in partnership with patients, carers and providers. This, we feel, allows for more meaningful change. For the first year of the strategy our focus will be on Urgent Care. We will use the learning outcomes from this pathway approach to inform other pathways for the second, and subsequent years of the strategy. ii. Goal 3 and Goal 4 of the EDS will be implemented by taking a whole organisation approach and ensuring that progress is made in our Human Resources and Organisational Development strategies, supported by the Central Midlands Commissioning Support Unit (CSU). iii. Additionally, a locally designed approach (reflected in the action plan) will be taken called the 3Ps Patients, People, and Processes. This will help to systematise equality in all aspects of the CCG s work, and will involve local interest groups in shaping commissioning policies, and in monitoring our equality performance. In the Action Plan at Appendix 1 each of the 3Ps is identified Our Equality Objectives have been developed as part of this reflection, and building on the discussions we continue to have with local stakeholders. 22

26 11. Conclusion 11.1 To be a trusted and inclusive organisation as set out in our values, we must demonstrate in both our commissioning activities and in the composition of our workforce that we are reflective of the population we serve. Our workforce must be supported and feel confident in their ability to challenge discrimination, advance equal opportunities, foster good relations and safeguard human rights for each other, and for patients as required by statute and by the NHS Constitution. We must also work effectively to relay this key message to our service users and stakeholders through effective and inclusive communication We will ensure that equality is everyone s business and everyone is expected to take an active part, supported by the work of specialist equality leaders and champions. 23

27 Appendix 1 Equality and Diversity Action Plan Aim Action Responsibility Outcomes Timescales 3Ps 1.High Level Assurance: Leadership and Governance 1.1 Clear lines of a).mike Hastings accountability for managing and reporting equality and diversity 1.2 Identify areas of equality associated risk 1.3 Advice and guidance to key CCG governance structures (eg. Board/QSC/CQRG) a).organisational and meeting structures to show clear lines of accountability for management of equality and diversity b) Equality and Diversity working group to be convened to monitor progress of this action plan Areas of risk included on the risk register for each area Attend CCG Board and Quality and Safety Committee and other key task and finish groups as required and offer advice and guidance in relation to Equality b). Equality and Diversity Working Group Sarah Southall (Matt Boyce) Steve Corton Steve Corton Governance arrangements agreed and implemented including reporting routes Areas of risk identified on risk register and action plans in place Equality considerations are seamlessly embedded within the core business of the organisation a). April 2013 b).e&d group to be established in October July 2013 April and Ongoing Process Process Process