Equality Impact AssessmentOnRegional Communication SupportServices ReviewDATE: 26/01/20171 Page
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ContentsConsultation Announcement . Error! Bookmark not defined.Contact. 21. Executive Summary . 5The Organisation . 5Data Collection . 6Key Findings . 72. Background . 14Organisational Background . 14Equality Impact Assessments . 16The policy subjected to an Equality Impact Assessment . 17How will this be achieved? (Key elements). 19Screening and Scope of the Equality Impact Assessment . 293. Data Collection and Consultation . 29Interpreters . 31Key findings. 32Gender . 32Age . 34Marital Status . 36Religion . 36Ethnicity . 37All usual residents 1,810,863 . 37Political Opinion . 40Dependants (Carers) . 42Sexual Orientation . 42Disability . 44Table 16: Children with a Disability known to Social Services, by majordisability, NI - As at March 2012 . 464. Good Relations . 515. . Disability Duties. 52Article 25 Health . 54Article 26 Habilitation and rehabilitation . 543 Page
Article 31 Statistics and Data Collection . 55Accessible Communications Activities . 566. Human Rights . 577. Conclusions. 59Summary and Assessment of Key Findings . 59Proposed Action . 60Proposed Monitoring . 622Appendix 1 – The Steps of an EQIA . 64Appendix 2 – Human Rights Screening Tool . 66Appendix 3 - EQIA consultation comments . 67References . 724 Page
1. Executive SummaryThe OrganisationThe Health and Social Care Board (HSCB), together with its LocalCommissioning Groups (LCGs) is accountable to the Minister for Health,Social Services and Public Safety and translates the Minister’s vision forhealth and social care into a range of services that deliver high quality andsafe outcomes for users, good value for the taxpayer and compliance withstatutory obligations.A key role of the HSCB with the Public Health Agency (PHA) is effectiveengagement with providers, Patient Client Council (PCC), localgovernment, Service Users, local communities, other public sector bodiesand the voluntary and community sectors.Regional Communication Support Services ReviewThe Review of Communication Support Services Review (RCSSR)recommends that regional communication support services requirechanges to ensure an accessible, efficient, affordable and sustainableservice model is available going forward. Demand has increased over thepast five years and so have costs.In order to deliver the service more effectively, efficiently and consistently,one key recommendation is presented in the Review report:Develop and procure a Regional Standardised model of serviceprovision which will offer consistency, standardisation andaccessibility of service delivery;The Report outlines five options;1. The HSC Trusts and HSCB continue to contract with 2 providerorganisations and freelance interpreters to deliver the service.2. The HSCB devolves to the BHSCT and SEHSCT and thus enablesall 5 Trusts to procure their own service providers i.e. individualcontracts within all five Trusts.5 Page
3. The communication support service would be procured by HSCTrusts themselves, hosted by one Trust on a consortium basis, andcommissioned and contracted with a single provider who wouldprovide a regional service across all 5 Trusts.4. The regional communication support service would becommissioned by the HSCB through a contracted provider.5. The regional communication support service would be provided on ashared service basis by the HSC Business Services Organisation,managed independently of the HSC provider organisations.Preferred OptionBased on the options appraisal, the preferred option for the regionalcommunication support service is Option 5; a regional shared/managedservice provided by the HSC Business Services Organisation.The RCSSR was issued for public consultation on Monday 6th June 2016for 13 weeks (this was extended for a further 10 weeks to facilitateengagement with Hard of Hearing and Deafblind communities). Theconsultation document, the equality impact assessment document and theRCSSR report were published on the HSCB website on the same day. Allof the above documents were also made available in Easy Read/ plainEnglish versions, and BSL and ISL signed messages were available onthe HSCB and BDA websites. Hard copies (in chosen format) were madeavailable as and when requested.Data CollectionData was gathered for, namely: The general population, with a targeted focus on people with adisability, specifically those that are deaf or have partial hearing;and From the Association of Sign Language Interpreters (ASLI); and From the Delegated Statutory Functions; and6 Page
From the Northern Ireland Statistics and Research Agency (NISRA);and From a Public Consultation exercise.In preparing the final EQIA, the findings from a range of data andresearch sources were taken into account. Data was considered for olderpeople and men and women generally. There was not sufficient data tounderstand impacts on the grounds of political opinion, religion orethnicity. These were explored further during the consultation phase.Statistical information was available from Northern Ireland StatisticalResearch Agency (including Census information from 2011) andDelegated Statutory Functions Returns.Targeted engagement was also undertaken with relevant stakeholders inthe form of a regional workshop. Presentations were provided by a rangeof organisations (Association of Sign Language Interpreters, British DeafAssociation and Sign Language Interpreting Service). A Task and FinishGroup was formed to take the Review forward. A public consultation wasalso undertaken.Due to the nature of the review, it was agreed upfront to carry out anEquality Impact Assessment, to provide the opportunity to explore anyequality issues in more depth. This report is primarily concerned with theimpact of the review, and particularly the preferred option in the review, onpeople with a Disability, older people, men and women generally, peoplefrom minority ethnic backgrounds as well as political opinions and religion.The needs of the wider general population, outside of the aforementionedgroups were also taken into account in the consultation period.Key FindingsThis section reflects a summary of key findings for the main groups welooked at.7 Page
The analysis of the data gathered in the course of this report suggeststhat there is sufficient evidence on the effects of the reportsrecommendation on a number of groups.GenderThe data would suggest that there may gender difference issues withmore men experiencing deafness or partial hearing loss during adulthoodup until aged 80 than women when the prevalence swings in the oppositedirection and may need to be reflected in the gender make-up ofcommunication support staff. Gender make-up of the Interpretingworkforce is significant with regard to intimate care issues e.g.gynaecological matters.Whilst the number of available interpreters overall is small, there issignificantly more female than male interpreters available.AgeOf the total people with deafness or partial hearing loss (93,091), 55,504(59.6%) are aged 65 and 35,164 (37.8%) are aged 18 to 64. The datawould suggest that there may be age difference issues with more menexperiencing deafness or partial hearing loss during adulthood up untilaged 80 than women when the difference swings in the opposite direction.According to NISRA, the incidence of deafness or partial hearing lossincreases significantly from the age of 40 onwards. Additionally there is asignificant step rise in prevalence from the age of 65 onwards.The delivery of a consistent, professional service, as a result of thereview’s recommendation will deliver positive outcomes for those olderpeople that are more likely to utilise the interpreting service.Religion & Political OpinionWhile no data has been identified to suggest differential impacts ofCommunication Support Services on the grounds of political opinion orreligion, it would appear prudent to note the Survey Report produced byParks and Parks in 2012 that suggests most Irish Sign Language userswould identify themselves as Irish and therefore political opinion isinfluenced. The corollary of this would be that British Sign Language8 Page
users may identify themselves as British and therefore political opinion isinfluenced. Caution needs to be applied to these broad assumptions.Service provision must take into account the requirements of both BritishSign Language and Irish Sign Language users. Attention must also bepaid to the demographic spread of British Sign Language and Irish SignLanguage users. Whilst exploring this through the consultation phase ofthis EQIA BDA advised that ISL users of all religions and political opinionare likely to live in the border counties of N Ireland and some areas ofBelfast and BSL users of all religions and political opinion are likely to livein central and East of N Ireland. Therefore consultation Easy Readmaterials were amended to reflect that BSL and ISL are languages in theirown right and more appropriate visual images were used. From those thatresponded to this question in the EQIA consultation no views on this wereforthcoming. It is important to continue to monitor the use of BSL/ ISLalongside religion and political opinion in the future.EthnicityNo data has been identified to suggest differential impacts ofCommunication Support Services on the grounds of ethnicity. Due to thelack of available data, this was explored further during the consultationphase of the EQIA. From those that responded to this question in theEQIA consultation no views were forthcoming.DisabilityIt is important that Communication Support is available to people who aredeaf or hard of hearing and this is particularly important for those peoplewith co-morbidities or multi-disabilities.Of the total people with deafness or partial hearing loss (93,091), 55,504(59.6%) are aged 65 and 35,164 (37.8%) are aged 18 to 64. Given thisdemographic information the health and social care needs of people whoare deaf or partial hearing loss will be diverse and multi-faceted,therefore, interpreters should be competent to work in the area of healthand social care across the sectors of health and social care provision i.e.Primary, Social Care/SW and Acute Care.9 Page
The delivery of a consistent, professional service, as a result of thereview’s recommendation will deliver positive outcomes for those peoplewith a disability, that are more likely to utilise the interpreting service.A revised Regional Communication Support service will involve asignificant cultural shift in how the HSCB and Health and Social CareTrusts currently ensure accessible health & social care. Thistransformation will involve a partnership approach between individuals,professionals and across all sectors to provide a broader understanding ofwhat Communication Support is and how to avail of it. This will requireconsideration of how we communicate and engage with staff and thepublic. Moreover, staff training and monitoring the implementation will beessential to ensuring Communication Support is a success.The scope of the Equality Impact Assessment therefore focussed on theequality outcomes and impacts, with a particular focus on potentialimpacts and particular needs for people within a number of the Section 75categories namely; age, disability, ethnicity, gender, ethnicity, politicalopinion and religion.ActionsGenderActionA limited number of interpretersmeans it may be difficult toprovide gender specific interpreteron request.Outside of normal bookingprocedures, a gender specificinterpreter will be considered ifrequired to meet a patient’sneeds, on request.The Commissioning Body and theBusiness Services Organisationwill endeavour to meet the needfor interpreters in HSC, identifyingand encouraging a genderbalance as appropriate10 P a g e
The gender of service users willbe monitoredService users requests for agender specific interpreter will bemonitored alongside the HSCservice it has been requested for.Religion/Political OpinionActionDue to limited availability of data,unsure of any likely impacts(particularly around the borderareas of NI) – association of eachlanguage with one of the two mainreligions/political opinions isassumedIssues of Irish SignLanguage/British Sign Languageservice user preference will bemonitored on the grounds ofpolitical opinion/religion, with aview to ensuring that provisionlevels for each language can meetdemandMonitoring of use of British SignLanguage and Irish SignLanguage will be undertaken11 P a g e
EthnicityActionThere is no known informationavailable at present as to thecurrent usage of communicationsupport services across the regionfor people from minority ethnicbackgrounds.A regional communication supportservice will be able to bettermonitor usage and identify thedemographic usage of the service.Any underrepresentation cansubsequently be addressed.A regional advisory group beestablished which would haverelevant stakeholders.12 P a g e
MonitoringThe governance arrangements for the regional communication supportservice are set within the context of the overall Transforming Your CareProgramme governance arrangements.It is proposed that the regional shared/managed service provided by theHSC Business Services Organisation would work closely with the Truststo ensure consistency of data gathering and monitoring, including Section75 data.It is further proposed that, as for the existing Regional Language andInterpreting Service, a regional advisory group be established whichwould: Be chaired by the provider organisation (HSC Business ServicesOrganisation), with accountability to the commissioner; Include Public Health Agency representation to advise on publichealth considerations for deaf people; Include a representative of the Regional Interpreting Service; Include Trust representation through the Equality Leads and otherstaff such as Sensory Rehabilitation, Audiology, EmergencyDepartments, Regional Emergency Social Work Service; Include representation from Integrated Care Directorate regardingGeneral Medical Practice needs in and out of hours provision; Include Independent Contractor representation; Include Service User representatives, including British SignLanguage and Irish Sign Language Service users, British DeafAssociation, Action on Hearing Loss, SENSE, Hearing Link, NI,National Deaf Children’s Society, Action Deaf Youth;13 P a g e
Include representatives from the Deaf , Deafblind and Hard ofHearing communities; Include a representative from a regulated Interpreter Body such asNRCPD, ASLI and/ or VPL; Include a Risk and Governance representative to account for thelegal and governance requirements of the health and social carefamily towards deaf people.2. BackgroundOrganisational BackgroundIn 2005, the NI Review of Public Administration (RPA) concluded thatmajor reform was required in the administrative structures of health andsocial services. In addition an Independent Review of Health and Socialcare Services in NI conducted by Professor John Appleby the same yearhighlighted the need for reform and modernisation of the management ofthese services.As a first phase of the RPA reforms in health and social care, fiveintegrated Health and Social Care (HSC) Trusts were established in April2007 to operate alongside the existing Northern Ireland AmbulanceServices HSC Trust.Following public consultation, the Minister of Health, Social Services andPublic Safety announced details of the second phase of health and socialcare reform in Northern Ireland. Central to this was the establishmentfrom 1st April 2009 of a new Health and Social Care Board (HSCB),including 5 Local Commissioning Groups coterminous with the Trusts, thePublic Health Agency (PHA), a Business Services Organisation (BSO)and a Patient and Client Council (PCC).14 P a g e
The HSCB, together with its Local Commissioning Groups (LCGs) isaccountable to the Minister for Health, Social Services and Public Safetyand translates the Minister’s vision for health and social care into a rangeof services that deliver high quality and safe outcomes for users, goodvalue for the taxpayer and compliance with statutory obligations.A key role of the HSCB with the Public Health Agency (PHA) is effectiveengagement with providers, Patient Client Council (PCC), localgovernment, Service Users, local communities, other public sector bodiesand the voluntary and community sectors.In short, the HSCBs key functions include: In line with Ministerial objectives, ensuring effectivecommissioning to secure the provision of health and socialservices and other related interventions that address the needsof people from pre-conception to death; The efficient, effective and appropriate use of delegated fundingof some 4bn per annum to meet agreed objectives in line withMinisterial objectives and Department policy in order to maximiseaccess to quality and safe services and reduce unnecessarybureaucracy; Implementing a comprehensive framework for performancemanagement and service improvement that will monitor HSCperformance against relevant objectives, targets and standardsand provide appropriate assurance to the Department and theMinister about their achievement; Establishing arrangements at a regional and local level thatensures close strategic and operational partnership with keystakeholders both within the HSC and wider public sector inmeeting the objectives of the Board and proactively engages andinforms local communities and the voluntary and communitysectors on the work of the Board; Establishing a close working relationship at a regional and locallevel with the PHA minimising unnecessary duplication and15 P a g e
ensuring a seamless approach to the improvement of the healthand social wellbeing of all the people of NI reflected in thedevelopment of an integrated annual commissioning plan forapproval by the Minister; Facilitating and supporting Local Commissioning Groups in theirrole of achieving effective locality based commissioning,managing their performance, and holding them to account so thatthey can exercise their devolved authority within an effectiveframework of regional priorities and standards; Within the parameters of the Department’s overarchingFramework Document, working with other key stakeholders suchas the Department, Public Health Agency, Trusts and Regulation& Quality Improvement Authority (RQIA) to ensure clarity ofresponsibility and appropriate provision for the safety of services,the management of critical incidents and service failings and theprotection of the public; Ensuring that regional priorities – for example programmes forimproving cancer services – are integrated into local plans whilepromoting real delegation to a local level within that framework;and Overseeing the agreed publication of performance information.Equality Impact AssessmentsSchedule 9 of the Northern Ireland Act 1998 provides for acomprehensive consideration by public authorities of the need to promoteequality of opportunity, giving effect to Section 75 of the Act, between: people of different religious belief, political opinion, racial group,age, marital status or sexual orientation; men and women generally; people with a disability and people without one; and16 P a g e
people with dependants and people without dependants.These are called ‘Section 75 Groups’ because the relevant law is Section75 of the Northern Ireland Act 1998. In addition, without affecting theabove duty, public authorities must have regard to the desirability ofpromoting good relations between people of different religious beliefs,political opinions and racial groups.Equality Schemes must be prepared, which among other things must setout arrangements for assessing the likely impact on the promotion ofequality of opportunity of the policies adopted or proposed.Where equality impacts are likely to be major, a public authority needs toundertake an Equality Impact Assessment (EQIA). This is “a thorough andsystematic analysis of a policy, whether the policy is written or unwritten,formal or informal, and irrespective of the scope of the policy or the size ofthe public authority.”As part of the assessment consideration must be given of anything thatcould reduce any adverse impact on equality of opportunity of the policiesproposed. Thinking through what opportunities exist to better promoteequality must also be a part of the assessment. Consideration toalternative policies that might better promote equality of opportunity mustalso be given.The policy subjected to an Equality Impact AssessmentThe purpose of the Regional Communication Support Services Reviewwas to review the arrangements for providing interpreting services acrossall Trusts to ensure a consistent approach to interpreting provision and toexplore the potential for greater use of technology (RQIA:2011:pg15).The catalyst for the Regional Communication Support Services Review isto be found in the Regulation Quality Improvement Authority’s (RQIA)Review of Sensory Support Service in Northern Ireland (2011), whichrecommended the following:17 P a g e
“A major issue identified during the review was access to sign languageinterpreting services, mainly due to the limited availability of qualifiedinterpreters. While this area was identified as under-funded across alltrusts, most trusts tried to address the issue through the re-allocation ofresources and by representing this gap as an unmet need to the HSCB.However, little progress had been made to improve the availability of signlanguage interpreting services, in line with other foreign languageinterpreting services. The HSCB informed the review team that it wantedto review the arrangements for providing interpreting services across alltrusts to ensure consistent approach to interpreting service and to explorethe potential for greater use of technology”. (Page 15, Standard 1 HumanRights and Equality). “Review of Sensory Support Service in NorthernIreland Overview Report”, September 2011.This Review of Communication Support Services Report recommendsthat regional communication support services require changes to ensurean accessible, efficient, affordable and sustainable service model isavailable into the future. As the Report states, demand has increasedover the past five years and so have costs.The aim of the Review was to scope and review communication supportservice provision for health and social care in NI with a view to providingdetails about current service provision and future requirements to supportan accessible, equitable and efficient service for people with hearing loss.For the purposes of this review ‘communication support’, is defined asSign Language interpreters, electronic or manual note takers, speech totext reporting and Lip to Speech-Deaf Blind Manual.A number of objectives were set out as follows:1. To undertake a regional communication support services scopingexercise;2. To analyse provider contract information returns with a view toprofiling need, uptake of service and cost regionally;18 P a g e
3. To stocktake current communication support service standards witha view to developing a regional minimum standard for futurecommissioning and delivery of services;4. To explore a range of options to meet the needs of people withhearing loss;5. To engage with service users in relation to the range of optionsidentified;6. To carry out value for money appraisal on each option;7. To present the preferred option(s) analysis to the relevantCommissioners.How will this be achieved? (Key elements)The key elements within the scope of the Review are: Review current British Sign Language/Irish Sign Languageservice; Review of current demand and supply; Identify options for new service delivery model and carry out anoption appraisal on each.There is four phases to the review.Phase 1: Project Set UpPhase 2: ScopingKey tasks included:Key tasks included: Establishing a Task andFinish Group; Develop Terms of Reference; Develop ReviewMethodology; Agree scoping exercise andtemplates for gatheringnecessary data. Mapping current provision –including demand andcapacity data; Understanding financialenvelope and costs ofservice – including baselinefunding and actual costs; Map current service modelsacross Trusts;19 P a g e
Identify unmet need; Review Best Practice outsideNI – collecting data fromservice in Republic of Ireland Identify Key Issue(s)/Groups- identify initial issues andtargeting stakeholders forengagement.Phase 3: EngagementPhase 4: Future ModelKey tasks included:Key Tasks Included: Engagement Workshop withall stakeholders – conducteda workshop which includedrepresentatives from serviceusers, services and otherstakeholders involved incommissioning, delivery,monitoring and users of theexisting interpreting servicesacross NI; Targeted individualengagements – this includedfocused meetings withservice users forum groups,service providers,Association of SignLanguage Interpreters (ASLI)and individualrepresentatives from each ofthe above groupings; Workshop Report - involvedwriting a document about the Identify lists of options forservice model; Engagement Process; Options Appraisal; Targeted ConsultationProcess (3 months); Preferred option agreed andpresented to Commissioner; Equality Good Relations andHuman Rights Screening; Develop specification for newservice model; Agreed Model Initiated.20 P a g e
content and outcome of theEngagement Workshops heldon 25th September 2013.The findings of the Review have identified a range of issues whichsupport and confirm the need for change including: accessibility, value formoney, sustainability, standardisation and modernisation.AccessibilityService Users and Sensory Support staff have expressed concern aboutthe booking time required and availability of communication support, forplanned appointments, emergency attendance at acute settings, out ofhours services and for non-health and social care appointments, mostnotably, onward referrals from a HSC professional to, for example, nonHSC specific leisure centres, social activities. This review was focusedonly on health and social care related access.It has been noted that service users also make requests for a particularinterpreter to support them when attending particular medical or otherconfidential appointments; however, the service user, could reside in theEast of the province and make a request for an interpreter who lives Westof the province, which incurs a much higher fee to cover mileage andtravel time.It has also been noted that in some instances family members are usedas interpreters which poses challenges on the level/accuracy ofinterpretation and raises issues aro
demographic information the health and social care needs of people who are deaf or partial hearing loss will be diverse and multi-faceted, therefore, interpreters should be competent to work in the area of health and social care across the sectors of health and social care provision i.e. Primary, Social Care/SW and Acute Care.
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