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From time to time, Camphill Scotland responds to consultations on policy and legislation from the Scottish and Westminster governments. Below, you can find information on some of the consultations we have responded to recently.
Consultation on the new National Health and Social Care Standards (January 2017)
Following on from the consultation of the National Care Standards in 2014, the next phase of the National Care Standards Review is to develop a set of Standards linked to the overarching Principles which were approved by the Cabinet Secretary for Health and Sport in February 2016. Views were sought to help develop the specific and general standards. Read Camphill Scotland's response and the Scottish Government's paper.
This consultation sought views on proposals to establish a procedure should an Adult with Incapacity have restrictions placed on their liberty. While we supported any move to avoid individuals being unnecessarily restricted, we expressed some reservations about the proposals. We highlighted the range of different settings covered by the 'care home' category, and wondered whether the same rules could/should apply to all of these settings. We also noted that the proposals did not include a review period, and recommended that providers be required to review restrictions on a person's liberty at least every six months.
Review of the Scottish National Care Standards (December 2015)
We endorsed the human rights-based approach to setting out principles that people should expect from care services, highlighting ways in which these fit neatly with the Camphill approach.
Children and Young People's Act draft guidance (continuing care) (September 2015)
We suggested some changes to the wording of the guidance, to ensure that disabled children and young people who are looked after have access to a full range of choices about their continuing care.
We raised concerns that the named person must be an employee of the service provider. Our concern here was that unsalaried vocational co-workers should also be able to take on the named person role where they are the most appropriate person in a specialist residential school to do so.
Public procurement rules in Scotland (April 2015)
We made suggestions of ways in which procurement by Scottish public bodies could best ensure that small to medium voluntary organisations can be helped to thrive, in particular in relation to competition for social care contracts.
We welcomed the proposal that the Care Inspectorate have front line resolution in their complaints procedure for registered services. We felt this would help reduce the anxiety and uncertainty created by lengthy complaints resolution processes that might unnecessarily escalate matters. We welcomed the proposals to include mediation as an option to assist with the resolution of complaints and to make the review process available for all complaints whether or not they are upheld or not upheld. More broadly, we think it is important to have a simplified complaints process for all public services.
Office of the Scottish Charity Regulator Targeted Regulation (October 2014)
We supported proposed changes to the information that charities are required to provide to the Office of the Scottish Charity Regulator (OSCR) and the idea of OSCR publishing charities' accounts online.
We suggested ways in which small charities could be supported to make sure they follow good practice in relation to governance.
National Care Standards Review (September 2014)
We shared our view that, while broadly supportive of the ways in which it is intended to review the National Care Standards, we are also satisfied with the existing standards and would be equally happy to see them maintained.
We expressed some reservations that the new Standards could become very long and unwieldy, and hoped that they would not be so prescriptive as to reduce flexibility when working with individuals.
Health and Social Care Joint Working Regulations (August 2014)
Further to our earlier comments on the principles of health and social care integration (September 2012, see below), we also responded to the consultation on the Regulations which will accompany the Public Bodies (Joint Working) (Scotland) Act.
We commented on one aspect of the Regulations, which asks Integration Authorities to report on their efforts to move away from institutional care. The proposal in the Regulations was that this should be done by reporting on the proportion of spend which goes to residential care or adult placements, and we made the point that not all residential care is institutional. We raised concerns that this measure would discourage Integration Authorities from viewing residential care, such as that provided in some Camphill communities, as a positive choice for some people.
We submitted evidence to this Commission which is considering the future of social care in Scotland. We highlighted the benefits of the Camphill model in terms of reciprocity, pointing out the benefits that this has for both staff and people we support.
We also raised concerns around restrictions in individual choice where people would like to look at support in a residential setting or away from their local authority area.
Care Inspectorate Methodology Review (July 2014)
We are contributing on behalf of communities to a review of care inspection methodology led by the Care Inspectorate.
Many thanks to the communities who responded to our request for your experiences of and ideas about inspections. Blair Drummond, Milltown, Newton Dee and Loch Arthur all provided very helpful insights that ensured our input was grounded in practical experience.
We attended the Coalition of Care and support Providers in Scotland (CCPS) Review Group meeting and put forward a number of points which you can read in this paper.
DEMOS Commission on Residential Care (April 2014)
In responding to a call for evidence from the DEMOS think tank we highlighted the model of accommodation-based care provided in Camphill communities, and the benefits of this for individuals.
We suggested that there are many misconceptions associated with the term residential care, and that it might be time to look for alternative language. We proposed the term shared living as most relevant in a Camphill context.
Residential Child Care Strategy (January 2013)
While supporting the intentions behind the development of a national strategy for residential child care, we were not able to support the proposals within this consultation.
We used our response to support the detailed cases made by Camphill School Aberdeen and the Coalition of Care and Support Providers in Scotland, which highlighted the difficulties with the procurement-based approach which was proposed.
Consolidation of SSSC Register (October 2012)
In this consultation we welcomed moves to simplify the register.
We recognised that the needs of adults and children are different but stressed that the B.A.in Social Pedagogy enables workers to build the skills and knowledge necessary to work with individuals across the life span.
We recognised that the protection of vulnerable people is a cornerstone of modern social care but recommended that one day mandatory PRTL on the protection of vulnerable groups would be better than two.
Children and Young People Bill (September 2012)
We used our response to highlight how children, young people and families affected by learning disabilities might have particular needs which may not be met by a general system of support for children and young people.
We welcomed the focus on wellbeing proposed for the Bill and identified some area where we had questions around implementation.
Health and Social Care Integration (September 2012)
We expressed concerns that a focus on older people's services in the integration agenda could lead to people with learning disabilities being adversely affected, both in terms of funding and in terms of the focus of outcomes/indicators to measure performance.
We raised some questions of clarification around how the integrated system would work, including around the role envisaged for the third sector.