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Care Standards Update
Edition No. 7 - August 2001
1. FREE INCONTINENCE PRODUCTS
Introduction
The Press Release issued by the Department of Health following the concession made in the final days of the last Government did not ring true. The odd wording used indicated that 'free incontinence products' were only likely to be made available to those who paid for their own care - and subject to similar restrictions to the introduction of 'free nursing care'.
Chief Executive Officer, Frank Ursell, was among a number of key stakeholders invited to a meeting at the Department of Health on Wednesday 18th July 2001 to discuss the implementation of this initiative.
Who Pays ?
The introduction of 'free' incontinence products from 1 October is limited to those who pay for themselves. The number quoted, 24,000, is simply two thirds of the figure of 35,000 who the Government believe will be entitled to free nursing care.
Civil Servants at the meeting clearly identified that there was to be no 'new money' to pass from the Department to health authorities to meet this new expenditure - health authorities will be expected to fund it from 'baseline' sources.
It is incomprehensible that a Government should trumpet that they will be providing incontinence products free from October this year when they are making no attempt to introduce any 'new' money to health authorities for its funding.
A continence adviser from Oxfordshire said that there had not been an increase in their funding for fifteen years. It was obvious that this is yet another example of a Government policy without Government money to follow it.
A Department of Health press notice of 12 July 2001 revealed that 59 out of 99 health authorities reported a deficit for 1999/00 and 150 of the 377 Trusts reported a deficit for the year 1999/2000. The total deficit of both health authorities and Trusts was £129 million.
What sort of service will be provided ?
Amongst those at the meeting on Wednesday were a number of continence advisers. Two or three of them had quite a lot to say in relation to how they were constrained, in their own localities, from providing a proper service. In particular it became very clear that the majority of 'free incontinence products' were of the reusable style, rather than the disposal style which is to be commonly found amongst nursing homes at present.
Continence Advice v. Free Pads
There was a lot of focus by these continence advisers on proper assessment and looking for a 'cure' to incontinence rather than simply a process of controlling incontinence.
Frank Ursell made the point that as we were currently having to fund incontinence products ourselves, this approach was to be found almost universally amongst nursing home owners at present.
What was clear was that there was insufficient funding currently made available to continence advisers to do a proper job and a concern must be that the introduction of free incontinence products is likely to lead to a lowering in the current high standard of dealing with incontinence in nursing homes.
One of the other issues which became very clear was the difference in quality between the reusable pads which most areas were providing and the highly absorbent pads which most nursing homes were providing. This difference was noted by the continence advisers who observed that nursing home owners could not expect to receive the same quantity or quality of pads when free incontinence products became available.
Who else is a Loser ?
Also at this meeting were a number of major manufacturers of incontinence products and also a small independent supplier. Some sympathy was registered for this independent supplier because, as he so clearly pointed out, his future, and that of people like him, was considerably threatened by these proposals.
His view of supply in general is one of concern. At present it would appear that most health authorities insist upon people coming to collect a month's supply of incontinence products from some central store. Few have a home delivery service even though, if properly arranged, it was probably no more expensive. Some health authorities no doubt have arrangements with the manufacturers to deliver direct.
Smooth Transition ??
As with the introduction of free nursing care, there is anticipation that there will be absolute chaos from 1 October 2001. There will be patients in nursing homes paying for their own care who will be able to seek free incontinence products. They will have to make application to a continence adviser for assessment who, following that assessment, and assuming that the assessment endorses the need for incontinence pads, will authorise a fixed number of reusable incontinence products.
Other patients in a nursing home, whether funded by local authorities or on preserved rights, will not be entitled to free incontinence products and rather than have a limited number of reusable products, will continue to have an unlimited number of the highly absorbent high quality incontinence products that nursing home owners currently purchase.
There is every likelihood that this is going to lead to tension between patients and their relatives and nursing home staff over the raised expectations that patients and relatives will have following the Government announcement.
Hidden in all of this, of course, is the question of who washes the reusable incontinence products. Some of the continence advisers, in a negative way, raised concerns they had over some private sector home owners making a charge for washing these products. Home owners may well consider themselves justified if this action results in further work or cost to them.
Good Practice in Continence Services
It became apparent that there had been a group of continence advisers who had been invited to become members of a 'Good Practice Incontinence Group' at the invitation of the Department of Health and that had resulted in the publication of a document called "Good Practice in Continence Service". The report, is available on the Department of Health website at www.doh.gov.uk/continenceservices
Conclusion
The next stage is for the Department of Health to write to all Health Authorities and Primary Care Trusts outlining their responsibilities and the timetable for the introduction. 'Free incontinence products' are to be extended to all patients from April 2002.
2. NATIONAL MINIMUM STANDARDS FOR INDEPENDENT HOSPITALS
At the same time as the publication of the draft Registration Regulations and the consultation paper on regulation fees the Department of Health also published the draft National Minimum Standards for Independent Hospitals. These are also in draft format for consultation.
Unlike the Registered Homes Act 1984, The Care Standards Act 2000 does recognise palliative care, although not as an extension of long term care. It is defined in Section 2 of the Act which refers to Independent Hospitals. Home owners who are involved in the provision of palliative care on a formal basis might wish to look at the National Minimum Standards for Independent Hospitals.
The consultation document is available on the Department of Health website at www.doh.gov.uk/ncsc. It includes draft regulations and a Regulatory Impact Assessment and totals 260 pages. Members who are unable to access the Internet should contact Deirdre Kowalski at Head Office for a copy of the relevant pages.
They comprise a set of Core Standards together with additional standards for acute, hospice, children etc. Significantly, there is not an inclusion of the specific environment standards which we are required to provide for long term care - i.e. room sizes or singles v. doubles - just a requirement that "premises are designed and maintained with the safety of patients in mind and ensure that patients' privacy is protected"
Dual Registration
In a statement which challenges even the latest double speak, we are advised that dual registration as experienced under the Registered Homes Act 1984 will not be allowed under the Care Standards Act. However, "where services provided within a building or site satisfy more than one of these definitions the distinct services will be regarded as separate 'establishments' within the building or site and registered separately as such." (Commonality with Care Homes on page 7)
Whilst it may be a little presumptuous to imagine that a home owner could register a four bedded room as a separate 'Independent Hospital' to provide palliative care - the draft national minimum standards do appear to offer that opportunity !
There has been an absolute forest of paper which has passed though RNHA head office in July. Members have had copies of all that affects nursing home owners. Many are consultation documents - your views are very welcome.
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