The so-called People’s Commission was meant to identify and present the views of the people of Calderdale about the kind of future NHS and social care in the area that will be best for us.

It has now published its Report, which Calderdale Council will discuss on 9th February at 6pm in Halifax Town Hall.

The proof of the pudding is in the eating – so what does the Report propose?

The Report gets the Plain Speaker red herring award for misleading the public.

Set up in order to listen to and report on the public’s views on our future needs and wants for the NHS and social care in Calderdale, the People’s Commission has ended up advocating the imposition of Coalition government NHS policies, as laid out in the Keogh Report on urgent and emergency health care and in Simon Stevens’ NHS England Five Year Forward View.

What about our A&E?

The Report says our hospitals should be reconfigured in line with the Keogh Report’s recommendations for a few centralised specialist hospitals in each region.

A key paragraph in the Report criticises our hospital Trust’s preferred option of closing one A&E department:

“…we do not consider that either the case for changing Calderdale Royal Hospital and Huddersfield Royal Infirmary to specialist hospitals, with only one of them having a fully functioning accident and emergency department, or the CCGs suggestions for minor injuries units, are well enough evidenced. Hence they are not convincing. In the case of A&E the national argument for developing sub-regional high level emergency care centres has not been properly considered in the hurried reaction to the serious but short term staffing and financial difficulties that Calderdale and Huddersfield NHS Foundation Trust finds itself in. It feels as if a “clinically led” NHS management has taken decisions that are driven by the suitability of buildings for refurbishment rather than a clear, costed and evidence driven plan that starts with the needs of residents.” (p8)

(Whatever the hell “sub-regional high level emergency care centres” are.)

A member of Save Calderdale Royal Hospital facebook group has commented,

“The thing I find difficult is understanding all the high fluting language used!! No wonder people find following issues difficult and fail to engage. I think, for what it’s worth! ‘Sub-regional high level emergency care centres’ are what MP Whitaker mentioned – regional AE,s as opposed to local ones.”

This section of the Report does look like code for advocating option 4 in the Trust’s Strategic Outline Case/Outline Business Case – here:

“Continue with the existing community service model and change emergency hospital care provided locally so that those people needing specialist treatments are transferred to a major emergency centre outside the local area. Huddersfield Royal Infirmary and Calderdale Royal Hospital would offer ‘see and initiate treatment’ services with people needing specialist treatments transferred to specialist centres. This would reduce demand at the local emergency centres in Halifax and Huddersfield.”

So basically: no A&E in Calderdale and Huddersfield? But this recommendation is cloaked in high falluting language – a form of code – because they daren’t propose it openly, in my opinion.

This more than ironic, since they freely criticise the NHS organisations for poor communication with the public. So, the People’s Commission also wins the “Pot calling kettle black award” – given to people or organisations who most obviously  blame someone else for their own faults, in order to distract attention from their failings.

The strong implication of this section of the Report is that we may well lose acute and emergency services not just from Calderdale but from Huddersfield too. For more detail on this, see Hospital Reconfiguration section, below.

Update: 3 July 2015  In June, Huddersfield MP Barry Sheerman told the Huddersfield Examiner that hospital sources have told him both Calderdale and Huddersfield A&Es are under threat. He said:

“I was briefed on this before the general election. We were told not to even discuss it with anyone; and of course now it’s here.

“It’s a very grave situation for hospital trusts up and down the country, including Huddersfield.

“Two senior people I’ve been talking to have said – don’t worry about whether it’s Halifax or Huddersfield that lose their A&E – it might be both.

“We may be in a situation where there’s no real A&E at either.”

Increased travel distances

It says setting up specialist emergency centres will increase travel distances for both ambulances and patients’ family and friends and this will need sorting out with Yorkshire Ambulance Services, public transport and hospital visiting hours.

It asserts that any risk to patient safety from increased distances to A&E is outweighed by the advantages of highly specialist acute and emergency hospitals, and ignores studies that provide evidence to the contrary.

It should be possible for both our hospitals to stay open, with new roles

Recommendation 6 in the Report says that it should still be possible for both CRH and HRI to stay open, complementing “the move to greater regional specialisation”, though their roles will change (in ways that the Report doesn’t indicate) p6.

Support for new community health care system despite lack of evidence it will do what it says on the tin

The Report endorses the NHS commissioners’ and Council’s proposals for integrated health and social care in the community. This new community health and social care system aims to reduce demand for health and social care services and also reduce acute and emergency hospital admissions of patients with complex chronic illnesses. (Despite the fact that there is no evidence that such schemes reduce hospital admissions.)

Urgent care and GP services

The Report says that every town should have some kind of urgent care service for minor cuts, scrapes and ailments.

It wants Calderdale residents to have equitable, high quality GP services.

Democratic deficit 

Much of the Report is about recommending bureaucratic processes for making its proposed NHS and social care changes, within the dysfunctional madness of the NHS structures that the 2012 Health and Social Care Act set up.

It attempts to translate the 2013 Keogh Report and NHS England’s Five Year Forward View into proposals for the NHS and social care in Calderdale.

By putting bureaucratic process centre stage, and not questioning the politically-driven programme of NHS and social care cuts and sell offs, imo the Report puts the cart before the horse.

Instead of saying: What NHS and Social care have the people of Calderdale told us they want, need and deserve, and how do we recommend that the NHS bean counters and politicians who are supposed to represent the people turn this vision into reality?  the Report puts the needs and processes of NHS bureaucrats and central government edicts first.

It tells us we will basically get what they decide to provide.

In my opinion, there is a democratic deficit at the heart of the so-called People’s Commission, just as there is at the heart of Calderdale Council and the national government.

The People’s Commission Report adopts a paternalistic, patronising view of the public. Several times the Report refers to the public’s need for “reassurance” – as if we are witless, ignorant, frightened children.

Where are the voices of the Trades Unions, the NHS and social care staff, the patients, their friends and family and any other members of the public who may somehow not fit into any of those categories?

They are absent, or tacked on as a thin afterthought. Because the public by and large shunned, disregarded or didn’t know about the so-called People’s Commission.

The Report ignores clear, unequivocal statements it received from the public about the general satisfaction with the hospital as it is.

It mentions but glosses over the strength of public opposition to the proposals to cut and close acute and emergency services at CRH, patting the public on the head with statements about the need to “reassure” us.

If you want more detail, please read on…

Hospital reconfiguration

The Report says our hospitals should be reconfigured in line with the Keogh Report’s recommendations for a few centralised specialist hospitals in each region. (Recommendation 4, p12)

It says that the 10 West Yorkshire NHS commissioners, including Calderdale Clinical Commmissioning Group, are currently working out where to put major A&E centres in West Yorkshire. (p12)

It suggests this would probably mean that we would lose acute and emergency services from Calderdale (Recommendation 4, p5.)

On p 9 the Report proposes that:

“Very specialist services should be organised on a sub-regional basis supported by a range of fully functioning community hospitals, as recommended in the NHS Five Year Plan.”  [I think this is a typo for NHS England’s Forward Five Year View?]

It’s worth thinking about this p9 proposal in connection with Recommendation 6.

Recommendation 6 says that it should still be possible for both CRH and HRI to stay open, complementing “the move to greater regional specialisation”, though their roles will change (in ways that the Report doesn’t indicate) p6.

It sounds as it the Report is proposing that both Calderdale and Huddersfield Hospitals become community hospitals in line with NHS England’s Five Year Forward View. If this is the case, it looks as if A&E would be lost from both hospitals.

The People’s Commission need to clarify this issue asap.

The Report rejects the Outline Business Case proposal to make one of the hospitals an acute and emergency hospital and the other a planned care hospital.

On p 14, the Report points out that this OBC proposal is based on the need to put all acute services on the same site as the single A&E department. So if the Report is rejecting the proposed split, without proposing that both hospitals should retain their A&E departments, the strong implication is that this is because the specialist A&E department will be somewhere else in West Yorkshire.

The Report says the creation of a specialist acute and emergency hospital will increase travel distances for both ambulances and patients’ family and friends and this will need sorting out with Yorkshire Ambulance Services, public transport and hospital visiting hours.

It asserts that any risk to patient safety from increased distances to A&E is outweighed by the advantages of highly specialist acute and emergency hospitals, and ignores studies that provide evidence to the contrary. (p17)

In short, the Report’s proposals about “reconfiguring” the Calderdale Royal Hospital are about imposing the “cuts and sell offs” agenda of the Keogh Review and NHS England’s Five Year Forward View onto Calderdale’s NHS.

In embracing these Coalition government plans, the Commission appears hung up on the marketisation and privatisation agenda of the Health and Social Care Act 2012 – which created the policy context for the Keogh Review and NHS England’s Five Year Forward View.

Recommendation 2 calls for the Calderdale Health and Wellbeing Board to oversee the development of plans for Calderdale health and social care, with input from Providers as well as the CCG and Council. Recommendation 6 takes this further, saying that the hospitals Trust, the CCG and CMBC should develop proposals for hospital reconfiguration.

The Report says that the proposed hospital reconfiguration review in Calderdale Health and Wellbeing Board should take account of “the emerging move to greater regional specialisation” as proposed in the Keogh Review.

So presumably, once the decisions about the future of our hospital have been made at a regional West Yorkshire level (by the West Yorkshire Commissioning  Collaborative of the 10 W.Y CCGs working together with W. Yorks NHS England), the Health and Wellbeing Board will oversee the decisions on what services Calderdale and Huddersfield’s two community hospitals will provide.

In relation to this question, on p 14 the Report chides the hospital Trust’s proposals to turn Huddersfield Royal Infirmary (HRI) into a specialist acute/emergency hospital and Calderdale Royal Hospital (CRH) into a small planned care clinic, with the hundreds of unused beds given over to other commercial uses – possibly a care home and hospice.

It says HRI has poorer quality premises and CRH has been “heralded” as a centre of excellence, so why would anyone want to do this?

But the word is that people in the know say that in fact CRH is poorly designed with its design potentially putting patient safety at risk. HRI is the better designed hospital from the point of view of caring safely for patients.

HRI was designed by the NHS, so it was properly designed. By the time CRH was built, the NHS no longer designed its hospitals. Another example of how things go wrong when the NHS is carved up and sold off.

The Report is incoherent about the lack of evidence that CC2H will reduce acute and emergency hospital admissions

Despite its general support for the Right Care/ Care Closer to Home proposals,  the Report criticises the fact that:

“…the proposals so far from the Calderdale Clinical Commissioning Group do not evidence that they will take demand away from acute services in general and A&E in particular.” (p4)

This is true. This is because there is no evidence that Care Closer To Home-type schemes do reduce acute and emergency hospital admissions.

But this doesn’t stop the report, on p 9, from supporting the the Better Care Fund proposals, which work hand in glove with the Care Closer To Home scheme – despite the evidence already noted in relation to the CCG’s proposals, that such schemes don’t reduce acute and emergency hospital admissions.

The Report states the opposite:

“The Better Care Fund is only one example of a national initiative which recognises that community based alternatives to non-elective hospital admissions can and should be delivered.”

But since the evidence is that these community-based schemes do not reduce acute and emergency hospital admissions, they are not an alternative to non-elective hospital admissions.

Despite banging on about the fact that there is no evidence that the new type of community health care scheme reduces hospital admissions – which imo the Report is quite right right to highlight – it is inconsistent in applying this criticism to the CCG’s proposals, but not to the Better Care Fund.

And it fails to ask the obvious question of why Care Closer to Home should succeed in reducing hospital admissions in Calderdale, when it hasn’t in other places.

The Report makes poorly-informed suggestions about how to collect evidence about whether Care Closer to Home scheme will reduce hospital admissions

On p10, the Report says:

“Phase 1 of Closer to Home… presents a golden opportunity for the four parts of the system [CCG, Council, GPs and health care providers] to work together and design new ways of working that are evidence based and have a quantified financial structure and clear targets for volume of service and for diversion from hospital or institutional care.”

But this ignores the fact that that the CCG has said it that it will do this measuring over 3 months – from April to July 2015. The CCG is giving the Hospitals Trust 3 months to show that its Phase 1 community health care services can reduce “inappropriate” hospital admissions. If it can’t, the CCG’s response will be to consider looking for another health care provider that can.

The Report also ignores the fact that the fact that the CCG is already working on proposals for hospital reconfiguration, as stated at the Adults Health and Social Care Scrutiny Panel meeting last week, as well as in the December 2014 CCG Governing Body meeting and in the Right Care Right Place Right Time update report to the January 2105 Calderdale Health and Wellbeing Board.

The Report ignores legal issues about the timings of public consultation and of CRH hospital reconfiguration

The Report overlooks the fact that by making changes to community health services – deciding what services to take out of the hospital and put into the community – the CCG is already deciding what the reconfigured hospital services will amount to.

This opens any future consultation on the proposals to a legal challenge, since the consultation will not allow the public to give their views on the whole range of possible options, as some options will already have been determined.

By going ahead in the full knowledge that this is the case, the CCG opens themselves up to a future legal challenge and the possibility that a judge will order that they not only stop their reconfiguration but undo the changes they have already made without public consultation.

It is surprising that the so-called People’s Commission doesn’t seem to have sought legal opinion about this.

On p5, Recommendation 1 fudges the issue of public consultation.

It says that no change is not an option. It also says, vaguely, that the people of Calderdale must  have the opportunity to comment on and contribute to any proposals that are made about changing the NHS and social care.

It says nothing about the legal obligation for the CCG to formally consult the public on any proposals for significant changes to the local NHS, or about the responsibility of the Adults Health and Social Care Scrutiny Panel and the Calderdale and Kirklees Joint Health Scrutiny Committee to use their power to tell the CCG to consult the public, and to stop any damage to the area’s NHS.

It says that once the West Yorkshire Commissioning Collaborative (the 10 West Yorkshire CCGs) together with NHS England have decided where the regional acute and emergency specialist hospitals should be, there should be formal public consultation on their proposals.

But don’t take my word for all this….

You can read the Report here and make up your own mind.

Updated 7 Feb to add page number references and to edit content for greater clarity. Updated 8 Feb to add the quote on from p8 of the Report, and information about facebook discussion of this.