NHS consultation - sustaining the secret society that is the NHS

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NHS England is:

...seeking your views to help shape the future of general practice services in England.

On the face of it, this is brilliant. And they say that they wish to:

...to stimulate debate in local communities...

Again fantastic.

Except they don't mean a word of it. This is who they mean by community:

...GP practices, area teams, CCGs, health and wellbeing boards and other community partners...

The patient? The taxpaying public? Nope, not included. Local doesn't mean you and me, oh no. it means:

A number of area teams and CCGs are already working collaboratively to develop shared strategies for primary and integrated care, and the questions in this ‘call to action’ are designed both to support these existing examples of local action and to stimulate similar approaches in all other parts of the country.

I'm sure it's wonderful stuff all this collaboration and so forth. But where in all this improving of General Practice is there any attempt to talk to the poor folk who actually use the service?

Maybe it's in the 'online' survey - perhaps that will provide ordinary patients with a chance to say what they want from their GP and local medical centre? You can have a go if you want! But it's not for the faint-hearted. I'm on a Health & Well-being Board, I'm informed, experienced and trained and this is just wibble - and bear in mind this is supposed to be something that "citizens" can "engage with":

How can we best mobilise existing improvement resource (e.g. NHS IQ) and facilitate access to other potential external support for primary care transformation?

How might we develop QOF so that that we preserve its essential features but create more flexibility for practices and reduce the feel of a tick-box culture?

How do we create synergy with the new system of CQC ratings and inspections to create a clearer sense of what patients can expect from good general practice?

What is the potential future role for PMS and APMS contracts in stimulating innovative approaches or helping address particular local challenges?

And there's loads more where that came from. The truth is that the NHS has no desire or intention to consult real people - the patients, the carers, the public - preferring instead to consult itself in some sort of mutual backscratching exercise. And the end result will be a little money bunged at GPs, a whole raft of meetings, strategies, pilots and boards all doing precisely nothing other than sustain the secret society that is the NHS.

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On consultation...

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Local government is encouraged - in that gloriously passive aggressive manner beloved of the Department for Communities and Local Government - to "consult" on the setting of budgets. And Councils, carefully and studiously adhere to this requirement setting about extensive and carefully planned consultations.

This evening I attended one of those consultations. Not in Bradford but elsewhere to see what it looks like from the perspective of a consumer of consultation rather than a producer. The Council in question has gone to a lot of trouble - a structured and engaging process, lots of nice technology and a slightly patronising presentation that had the merit of not quite saying "this is all too complicated for ordinary humans to comprehend."

I understand that this show had been on the road - popping into different locations across the borough in question to do the consultation with folk for whom going into the town centre is a rare (even unlikely) occasion. Tonight it arrived in town complete with the Council leader, Chief Executive, Director or Finance and a collection of other councillors and officers. The Council in question has made a genuine and substantial effort to "consult".

And they engaged with about 30 members of the public (including several like me who are offcumdens and only there because our professional life requires it). And this - the lack of public - underlines the problems with consultations. Let's assume that the consultation roadshow stopped at twenty places, each generating 30-50 members of the public. That's 1000 people who have taken part in the consultation out of a population of over 200,000. Those people are not representative - indeed the chances of them having (as I did) a vested interest in one or other aspect of the Council's work is, I suspect, pretty high.

There is no way that - however hard the Council has tried - this consultation can represent the views of the local populace. And this begs a question about the whole process - the perceived need for this "consultation". It seems to me that this "need" reflects the loss of confidence in representative democracy rather than any improvement to the processes of government.

Today, rather than our role of representing the people who elect us in the decision-making of the Council, us local councillors are told we are "community leaders". Instead of representation our role is to act as some sort of cheerleader for endless processes of "engagement" and "involvement". Yet, despite this change, 90% of the population remain neither engaged nor involved in these processes. And the result of this disengagement and non-involvement is that consultation processes become captured by the interested rather than reflecting of public concern (let alone opinion).

The odd thing is that us councillors are told our authority is undermined by low turnouts. Yet around 4,500 folk took part in electing me - almost certainly more that will take part in Bradford's budget "consultation". And in the course of the year I will speak to hundreds of those folk - listening, arguing and, if you must, "consulting". All that these requirements to consult do is to further undermine the role of the councillor.

We replace electoral accountability with consultations that fail to reflect the views of most people, can be manipulated by the interested and that are controlled by council officers. I see no point or purpose to them.

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Public engagement - West Yorkshire Police Authority style

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The great and good of West Yorkshire Police Authority are planning to descend on Keighley where they will present to us (or rather the dozen or so who know about the occasion and can be bothered to attend) stories of the wonders done by the Authority and the Police Force it doesn't really run:

Kiran Bali, vice-chairman of the committee, said: “This is our third visit to the Bradford district since we started taking this committee out into communities within West Yorkshire over a year ago, but our first visit to Keighley."

No idea who Kiran Bali might be - except that he's certainly not from Keighley and seems inordinately smug about three trips to the "Bradford District" (population 500,000). Apparently the occasion will feature a discussion on "public confidence in the police".

Unfortunately either the newspaper or the police authority have neglected to tell the reader when or where the consultation event is to take place. So those readers will just move on and live with the fact that they have a police force noticeable mostly by its absence. A police force that can find 1500 officer to police a handful of EDL demonstrators - and then spend endless hours bragging about how well it handled that problem - but can't find a copper to man a front desk overnight to deal with the desperate victim, the frightened old lady or the offender who hands himself in.

It really is a bit of a joke really.

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Consultation on plain packaging for cigarettes - what you need to tell the government

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The government has launched a consultation on the introduction of plain packaging for tobacco products - be warned the questions are loaded and partisan. However, you do get the chance to make your comments. My advice - be moderate in your comments, provide evidence where you can and stick to the core objections:

1. The proposals fail to understand the role of brands:

"Branding fulfils many significant and positive functions for both consumers and markets. Take it away and consumers lose out and markets become commoditised, with price rather than quality being the influencing factor. As well as calling on Government to consider carefully whether plain packaging will yield any positive impact in practice, we will also encourage it to look at all the possible negative impacts."

2. Plain packaging makes counterfeiting and illicit sale of cigarettes more likely:

BASCAP (Business Action to Stop Counterfeiting and Piracy) is concerned that plain packaging requirements would increase the prevalence of counterfeit goods in the market and reduce brand owners' ability to take action against such activity, besides undermining the ability of consumers to make informed purchasing decisions. Trademarks serve these important functions in the market for all branded goods. Plain packaging [is] likely to increase rather than decrease burdens on already overstretched public agencies working to enforce intellectual property protections in the face of escalating counterfeiting and piracy in the United Kingdom and worldwide."

3. Plain packaging threatens jobs:

Mr Barber said: “These proposals could have serious implications for our business as tobacco packaging is vital to our turnover. It could cost up to 50 per cent of the jobs here."

4. The proposals will damage businesses:

...a report from Deloitte titled “Potential impact on retailers from the introduction of plain tobacco packaging”, February 2011, states that the operator of a service station can expect to incur additional staff costs of between A$9,000 and A$34,000 due to the extra work that would be required to handle plain packaged tobacco products.

I'll leave you to add your comments on how the proposals are illiberal, anti-business and based on the flimsiest of evidence. I would also urge - as well as responding to the consultation - for you to write to your MP making the above points - this is an unjustified idea without evidence that will destroy jobs, promote crime and damage personal liberty.

The consultation is here - be prepared to give an hour of your time.

http://consultations.dh.gov.uk/tobacco/standardised-packaging-of-tobacco-products/consult_view


And just for the record, I am a non-smoker.
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Your chance to tell the government about fake charities like Alcohol Concern

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There has long been confusion as to whether a charity is defined by what it does or by the source of its income. Most of the public think of charity and charities in terms of income source – our understanding is that their income is freely given by people wanting to help the particular cause.

The problem is that this isn’t how the system defines a charity which is on the basis of deeds rather than income.

Charities must provide benefit to the public, not to a specific individual. Their aims, purposes or objectives have to be exclusively those which the law recognises as charitable. A registered charity will usually be given a special tax status and benefit from a number of tax exemptions and reliefs.

The law sets out a series of “charitable purposes” and, if your organisation is involved in one or more of these then you are entitled to register as a charity.

Prevention or relief of poverty

Advancement of education

Advancement of health or saving of lives

Advancement of citizenship or community development

Advancement of arts, culture, heritage or science

Advancement of amateur sport

Advancement of human rights, conflict resolution or reconciliation or the promotion of religious or racial harmony or equality and diversity

Advancement of environmental protection or improvement

Relief of those in need by reason of youth, age, ill-health, disability, financial hardship or other disadvantage

Advancement of animal welfare

Promotion of efficiency of the armed forces of the Crown or the efficiency of the police, fire and rescue or ambulance services

Any other purposes recognised as charitable under the Act - this last item covers a charitable purpose that is within the spirit of the above purposes and is a mechanism for future development of the list of charitable purposes

The government is reviewing the 2006 Charities Act (the one rammed through by Labour as a stick to beat private schools) and has issued a series of questionnaires as part of a wider consultation on charities and charity laws. Clearly these matters of definition are significant and it seems to me that the process presents the opportunity to raise the matter of what get called “fake charities” – organisations that enjoy charitable status yet are wholly or predominantly funded through government contracts.

Most importantly it affords us the opportunity to raise the matter of “charities” being funded by government and then spending that funding on lobby the government:

Perhaps the most egregious example uncovered as yet is Alcohol Concern. Out of an income in one year of just shy of £1 million, 57% came from the Department of Health...and yes, Alcohol Concern has been and is quite vociferous in its lobbying of the Department of Health on how access to alcohol can and should be restricted. Private donations were a tad shy of £5,000 (yes, that's five thousand, not five hundred thousand nor even fifty thousand) so their income from real people actually supporting their efforts was less than 0.5% of their total income. It's extremely difficult to see that this is a charity and even more difficult to see why they should been given any credence whatsoever in the media.

The questionnaires are accessible on the Cabinet Office website and the consultation is open until 16^th April.

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Bradford's LDF consultation will be a disgrace...

Cottingley

The current planning legislation and the legislation wending its way through parliament in the form of the Localism Bill speak often and loudly about ‘community engagement’, about ‘consultation’ and about ‘community-led’ planning. Let me tell you the truth.

Planners – or those planners charged with drawing up local plans, spatial strategies and ‘development frameworks’ – do not think the public, you and me, are qualified to know about such lofty matters. I recall being at a briefing about localism and communities developing local neighbourhood plans when a senior planner at a large metropolitan authority (not Bradford for once) described such devolution and public involvement as “the thin end of the wedge”.

By way of illustration might I present Bradford’s “LocalDevelopment Framework Core Strategy Further Engagement Draft” – currently so draft that the page numbering is inaccurate but that amounts to over 300 pages.

But this is just the beginning – there are some other documents, some of which the council has yet to publish. These include:

Open Space Assessment

Bradford District Baseline Study

Bradford District Retail & Leisure Study

Conservation Area Assessments & Management Plans (various)

District Wide Transport Study

Draft Settlement Study

Employment Land Review

Gypsy & Traveller Accommodation Assessment

Local Infrastructure Plan

Sports & Recreation Facilities Assessment

Strategic Flood Risk Assessment

Affordable Housing Economic Viability Assessment

Strategic Housing Land Availability Assessment

Strategic Housing Market Assessment

Each of these documents will be over 100 pages – some much more than that. All of them will be hard to come by and laden with impenetrable technical language. It is truly a monument to the last government’s bureaucratic mindset and to the planners’ belief that only those will their occult knowledge can possibly create a strategic spatial plan for Bradford.

I am at a loss to understand how the ordinary public – the men and women whose local amenity and environment will be affected by these decisions – are able to engage with a process involving over a thousand pages of jargon-filled planning mumbo jumbo. This is not the local planning process we were promised when the “Planning and Compulsory Purchase Act” was passed by the Blair government.

People like me – with a little time and some knowledge – will try to understand what the planners are saying, will challenge their arguments on population growth, housing need and the distribution of employment, and will endeavour to get across to our local residents what the proposals are saying. But this massive, overweening, so-called “evidence base” will mostly go unchallenged except by those with the money to employ the experts to go through the documents and comment.

The Bradford LDF is planning to remove significant tracts of land from the ‘green belt’, to increase the size of villages like Denholme by approaching 50% and to force huge crowded “urban extensions” on to the fringes of the City. And it is that list of documents above that will be used to justify this pillage and to ignore the pleas of local communities for a conversation about the place they live. A conversation that would allow the negotiation of new housing – affordable and market – places for new employment and places that need protecting. Not from the view point of some expensive, besuited consultant but from the local people who the plan will affect.

It is a disgrace.

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Public health and private choice - thoughts on a consultation

This afternoon I attended a Public Health Consultation event organised (because I insisted) to allow Bradford councillors to have some input into the PCT/Council response to the Public Health White Paper. Obviously our input was constrained by time but we managed to comment at length on:

Domains and Indicators from Healthy Lives, Healthy People: Transparency in Outcomes: Proposals for a Public Health Outcomes Framework

And:

Commissioning and funding from Healthy Lives Healthy People: Consultation on the funding and commissioning routes for public health

In this discussion we looked at the different “measures” that might be applied to the assessment of public health effectiveness and hence the likelihood of Bradford Council receiving the “Health Premium” promised to Councils meeting targets. In listening to this – and looking at the targets – it struck me that there is an interesting and important discussion to be had as to what we actually mean by the term “public health”.

What seems clear to me is that the domain of public health – our concern to do something about external and environmental factors contributing to disease and ill-health – has expanded to encompass things that are not external to individual choice. Hence the ‘new’ definition from the Faculty of Public Health:

“The science and art of promoting and protecting health and well-being, preventing ill health and prolonging life through the organised efforts of society.”

Public health is no longer concerned with externalities – with sanitation, with poor housing, with air pollution, with clean water – but with lifestyle choices deemed by “society” to be wrong. And the justification for this action is all couched in generic health outcomes, chiefly in “life expectancy” and “healthy life expectancy”.  Because, for example, reducing smoking is seen as improving overall “life expectancy” it becomes justified even though such interventions are not in areas of ‘public goods’.

Underlying this argument is the nature of the deal between the individual and the state – whether that deal in a collective or individual arrangement, between the ‘civic’ and the ‘personal’. And, most commonly, the argument is couched in terms of selfishness – my drinking, smoking or fatness means a greater burden on the NHS and less resource available to treat the illnesses of good people who eschew such a decadent lifestyle.

If however – as I believe is the case – my relationship with the state is a personal one, then this argument is false. I pay taxes, duties and other imposts in return for the state’s protection. And that protection applies to me personally not to me as part of a collective. My lifestyle choices – smoking, drinking, eating burgers, sky-diving, potholing, and so forth – are not a matter of public concern. Therefore public health cannot – as its proponents now argue – extend to controlling lifestyle choices but must be limited to public goods and to the impact of public services on health.

Nevertheless, the consultation paper on “proposed indicators” contains nine targets directly linked to levels of smoking, drinking or eating yet just two relating directly to housing. Yet housing conditions – damp, drafts, poor heating – are very significant factors in ill-health, arguably more significant that smoking, drinking or obesity. Add to this the incidence of ill-health linked to long-term unemployment and poverty and it is clear to me that the directing of around 60% of public health budgets to booze, fags and burgers is wholly misplaced – even if we accept the argument that there is a need to develop responses to these “problems”.

In the end, the experts – those nannying fussbuckets of the Faculty of Public Health – will win the day and the funding will go to continue the current strategy. And this is despite all the evidence that this strategy is failing to deal with the problem it intends to deal with (too much drinking, smoking and burger-eating). At the meeting I pointed out that reports of liver disease had risen during a time when the consumption of alcohol was falling – the answer to this conundrum is that the problem drinkers are drinking more ergo more liver disease!  I’m not sure that I believe this – the problem may relate more to the increase in drinking during the 1980s and the lag in presentation for liver conditions.

While I enjoyed the meeting and made a substantial and, hopefully, substantive contribution, I expect that we will end up with a centrally directed, nannying (or should I say nudging) approach focused – to the exclusion of almost everything else – on the poor lifestyle choices that some people make. And it won’t work – the single mum on the sixth floor of a council block will still want cheap stimuli, the little cheers and buzzes that get her through an otherwise crap life. Which means she’ll carry on smoking, drinking, enjoying sex, eating crisps or chocolate and watching telly – those things are her pleasures and telling her it’s bad for her won’t change a thing.

 If you want to change her outlook – or the outlook of a million or so other folk – you have to change economic prospects, improve the housing and clean up the locality. And all the public health fussbucketry won’t achieve any of that, will it?

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Fixing the system: political parties, funding and privilege.

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As you will know, dear readers, I have a slightly jaundiced view of the manner in which political parties are obtaining a constitutional position that extends beyond their established role as private organisations established for the purpose of promoting a particular cause.

We no longer need to clump together in class-based groups so as to protect our interests – we’re all pretty much middle class with much the same interests as each other. And in the main this interest involves keeping the Government and its agents out of our lives, getting on with raising our families, enjoying the house & garden on which we’ve spent all the cash the government leaves us after tax and not bothering our neighbours overmuch with our individual problems.

In truth we don’t need political parties. We don’t need to spend taxpayers’ money on sustaining the 1% of the adult population who join those parties. And we don’t need special protections or status in law for such bodies. If people like me want to join them that’s our business and we should not expect any privileged status or treatment for the organisation just because they are engaged in politics.

In the past few days, the ‘Committee on Standards in Public Life’ began a consultation on the funding of political parties – you can go play with this consultation on-line here. Now, although I care deeply about the manner of party funding, I am just as concerned about the assumptions being made by the Committee in framing the terms of their consultation.

Political parties are an essential part of the sound operation of the democratic process. They offer individuals a way to participate directly in our democracy and are the means by which voters choose between alternative policies and candidates at elections. Through government and effective opposition, political parties shape public policy. If political parties are to operate effectively it is essential that they are adequately and appropriately funded but it is also important that the means by which this funding is provided commands public confidence.

This implies a privileged position for political parties within our constitution – they are “essential”, they offer individuals “a way to participate” and are the means of choosing between “alternative policies”. And because of this particular, gatekeeper role Government should concern itself with the funding of political parties.

I don’t agree. I do not accept that political parties have any special position of importance and should be given any special advantage over other organisations – however those other organisations are constituted. The fact that the Labour Party is a wholly-owned subsidiary of the trade union movement means that I will never vote for it. But if those wealthy, protectionist organisations choose to fund a political party, that is their business – at least until the Government gives political parties a special position within our constitution. Sadly, the previous Labour government gave just such a privileged position to political parties and in doing so granted an advantage to the larger parties despite their rapidly declining membership. Today less than 1% of the population are members of political parties – and that includes all the funny little left-wing and right-wing grouplets that come and go like mayflies.

Finally, rather than focusing on income – on where a political party gets its cash – we should instead look at spending, at what the party spends its cash on doing. I have long argued that election spending should be exclusively at the constituency level – all national campaign funding should be banned and a reasonable limit on local spending used. That would get away from the “business/unions/rich foreigners are buying the election” arguments and would make independent and local candidates far more valuable and likely.

But this won’t happen now, will it!

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Fixing the system: political parties, funding and privilege.

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As you will know, dear readers, I have a slightly jaundiced view of the manner in which political parties are obtaining a constitutional position that extends beyond their established role as private organisations established for the purpose of promoting a particular cause.

We no longer need to clump together in class-based groups so as to protect our interests – we’re all pretty much middle class with much the same interests as each other. And in the main this interest involves keeping the Government and its agents out of our lives, getting on with raising our families, enjoying the house & garden on which we’ve spent all the cash the government leaves us after tax and not bothering our neighbours overmuch with our individual problems.

In truth we don’t need political parties. We don’t need to spend taxpayers’ money on sustaining the 1% of the adult population who join those parties. And we don’t need special protections or status in law for such bodies. If people like me want to join them that’s our business and we should not expect any privileged status or treatment for the organisation just because they are engaged in politics.

In the past few days, the ‘Committee on Standards in Public Life’ began a consultation on the funding of political parties – you can go play with this consultation on-line here. Now, although I care deeply about the manner of party funding, I am just as concerned about the assumptions being made by the Committee in framing the terms of their consultation.

Political parties are an essential part of the sound operation of the democratic process. They offer individuals a way to participate directly in our democracy and are the means by which voters choose between alternative policies and candidates at elections. Through government and effective opposition, political parties shape public policy. If political parties are to operate effectively it is essential that they are adequately and appropriately funded but it is also important that the means by which this funding is provided commands public confidence.

This implies a privileged position for political parties within our constitution – they are “essential”, they offer individuals “a way to participate” and are the means of choosing between “alternative policies”. And because of this particular, gatekeeper role Government should concern itself with the funding of political parties.

I don’t agree. I do not accept that political parties have any special position of importance and should be given any special advantage over other organisations – however those other organisations are constituted. The fact that the Labour Party is a wholly-owned subsidiary of the trade union movement means that I will never vote for it. But if those wealthy, protectionist organisations choose to fund a political party, that is their business – at least until the Government gives political parties a special position within our constitution. Sadly, the previous Labour government gave just such a privileged position to political parties and in doing so granted an advantage to the larger parties despite their rapidly declining membership. Today less than 1% of the population are members of political parties – and that includes all the funny little left-wing and right-wing grouplets that come and go like mayflies.

Finally, rather than focusing on income – on where a political party gets its cash – we should instead look at spending, at what the party spends its cash on doing. I have long argued that election spending should be exclusively at the constituency level – all national campaign funding should be banned and a reasonable limit on local spending used. That would get away from the “business/unions/rich foreigners are buying the election” arguments and would make independent and local candidates far more valuable and likely.

But this won’t happen now, will it!

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