Equality Impact Assessment Details

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Equality Impact Assessment Details

Policy Title: 18 Weeks: The Referral to Treatment Standard

Department: DIRECTOR-GENERAL HEALTH AND CHIEF EXECUTIVE NHS SCOTLAND

Group: HEALTH DELIVERY DIRECTORATE

Division: Access Support Team

Branch: Head of Access Support Team and PS

Aims of the Policy

What is the purpose of the policy (or the changes made to the policy)?The Scottish Government has set out the vision for a stronger NHS which will make better use of NHS capacity to deliver a better deal for patients. A major element in achieving this vision will be a new national waiting times guarantee: "a whole journey waiting time target of 18 weeks from general practitioner referral to treatment - by December 2011". From December 2011, 18 weeks will become the maximum wait from referral to treatment for non-urgent patients, but most patients will be seen more quickly. The aim is to build on successive reductions in waiting times over previous years to improve patient experience and deliver better outcomes for patients.

The scope of this assessment concentrates on the core policy and the introduction of referral to treatment measurement, alongside stage of treatment measurement. Detailed definitions will be developed throughout the life of the programme and steps put in place to ensure that key guidance takes account of EQIA as it is developed. The policy is due to be delivered by December 2011 and as such we plan to have full EQIA completed by then.
Who is affected by the policy or who is intended to benefit from the proposed policy and how?The 18 Weeks RTT Standard is wide ranging and designed to cover most elective activity. As such, it will affect the majority of those who require to access consultant led services for treatment in NHS Scotland. There will be a small number of services excluded which will be fully described within the National Access Policy (currently being developed), for example Mental Health Services will require separate guidance, as it would not be appropriate in many cases for these patients to wait 18 weeks for treatment.

NHS Staff will also be affected by this policy. The 18 Weeks RTT Standard will require NHSScotland to measure the total period waited by each patient up to treatment and to manage each patient's journey in a timely and efficient manner. This may require a significantly different way of working in some areas and could impact on staff roles and responsibilities. It could also impact on work/life balance for some staff who may be undertaking additional (e.g. weekend) working.

There will also be implications for how NHS Staff interact with patients and the way in which complaints are dealt with and administered.
How has the policy been, or will be put into practice, and who is or will be responsible for delivering it?NHS Boards have the responsibility for delivering the policy. The 18 Weeks RTT Programme Board has overarching responsibility to support NHSScotland in delivering the 18 Week Standard by 2011 and has set up National Delivery Teams to focus on specific aspects. Where required the Programme Board will provide direction, reporting to Scottish Ministers on progress towards this target.

Delivery will require a drive from local programme teams to fully engage and embed improvements through operational and clinical management across whole systems, as well as active and sustained clinical and executive level leadership. This is already well underway and Boards are undertaking their own EQIA on the implementation of the 18 Weeks RTT Standard. Any insights from this work will be collated and fed back to the overarching policy EQIA where appropriate.
How does the policy fit into the Scottish Executive's wider or related policy initiatives?This is an integral element of the five strategic objectives set by the Scottish Government. The delivery of the 18 Weeks Referral to Treatment (RTT) Standard will contribute to each of these five strategic objectives:

A Wealthier and Fairer Scotland - faster access to hospital treatment means fewer people unable to work and better equity of access not dependent on where you live or on the ability to pay for private healthcare.

A Healthier Scotland - there is significant evidence that waiting too long for even 'routine' treatment leads to poorer outcomes and higher morbidity. The 18 Weeks Standard will help to sustain a better quality of life for patients.

A Safer and Stronger Scotland - stronger local healthcare, helping communities to flourish, reversing the poor health record of Scotland.

A Smarter Scotland - retaining and attracting skilled healthcare professionals to NHS Scotland, a healthcare system which will be in the international top-league of healthcare systems.

A Greener Scotland - driving out duplication and waste, making better use of Scotland's healthcare resources.
Have the resources for the policy been allocated?Yes
What's known about the diverse needs of the target audience?
Is there information on Age?Yes
Age - EvidenceFigures published on 23 Feb 2010 show that there is very little variation in waiting times for under 17's, 18-64 year olds and for age 65+. There is also very little variation in the average wait for treatment irrespective of age.

Age - Consultation
Is there information on Disability?Yes
Disability - EvidenceRegistered disabilities are not collected as part of the current waiting times dataset. Indications from current available waiting times data show that 99.9% of patients are treated within 15 weeks. New Ways of Defining and Measuring Waiting Times is currently being revised and will include guidance on the need to put in place additional support for patients with disabilities to ensure the 18 Weeks RTT Standard is delivered for those patients. It is intended this guidance will be issued end November 2010.
Disability - Consultation
Is there information on Faith/Religious Belief?Yes
Faith/Religious Belief - EvidenceIndications from available current waiting times data show that 99.9% of patients are treated within 15 weeks. NHS Boards have systems in place to ensure that they are aware of patients' religious beliefs and any necessary implications which this may have, through obtaining this information at pre-assessment or admission stages of the patient journey.
Faith/Religious Belief - Consultation
Is there information on Gender?Yes
Gender - EvidenceDistribution of waiting times published Feb 2010 shows very little variation in the waiting times for males/females as well as very little variation in the average wait for treatment for these groups.
Gender - Consultation
Is there information on Lesbian, Gay, Bisexual and Transgender (LGBT)?Yes
LGBT - ConsultationGender realignment is not covered by the 18 Weeks RTT Standard due to the need for the patient to take time to reflect and consider the psychological and physical ramifications of procedures which can dramatically change their physical appearance. However, once the clinician and the patient have agreed to such treatment this will be covered by the proposed Treatment Time Guarantee which is contained in the Patients Rights Bill.
LGBT - Evidence
Is there information on Race?Yes
Race - EvidenceEthnic data is collected by some NHS Boards but not all. We recognise the need to improve systems in the recording of ethnicity of patients and to ensure appropriate communications and support are in place particularly in relation to translation services. It is intended that this will be included in guidance to be issued end November 2010.
Race = Consultation
Is there enough information to help understand the needs and/or experiences of the target audience regarding:
Age?Yes
If not, what other information is needed?There is the possibility that the elderly age group may find the new process confusing and may not understand why they are being given appointments more quickly, which could cause unecessary anxiety. Communication of the Standard is key to ensuring patients are clear about the process and the reasons for appointments being given more quickly.
Disability?Yes
If not, what other information is needed?Registered disabilities are not collected as part of the current waiting times dataset, however, all patients on pathways within the scope of the policy will be subject to the 18 Weeks RTT Standard and therefore there should not be an adverse impact on this group of patients. New Ways of Defining and Measuring Waiting Times is currently being revised and will include guidance on the need to put in place additional support for patients with disabilities to ensure the 18 Weeks RTT Standard is delivered for those patients. It is intended this guidance will be issued end November 2010.

Mental Health services are excluded due to the likelihood of patients requiring early intervention and therefore 18 Weeks is not an appropriate timescale for this group of patients in many circumstances. Separate waiting times standards are being developed for these pathways.
On Faith/Religious BeliefYes
If not, what other information is needed?All patients on pathways within the scope of the policy will be subject to the 18 Weeks RTT Standard and therefore there should not be an impact on this group of patients. Indications from available current waiting time data show that 99.9% of patients are treated within 15 weeks. NHS Boards have systems in place to ensure that they are aware of patients' religious beliefs and any necessary implications which this may have, through obtaining this information at pre-assessment or admission stages of the patient journey.
Gender?Yes
If not, what other information is needed?Obstetric services are excluded as relates to maternity which is not appropriate to be within a target. It also excludes assisted conception - an expert group is currently looking at setting a separate waiting time target for this service.
On Lesbian, Gay, Bisexual and Transgender?Yes
If not, what other information is needed?Although specific information is not automatically collected on sexual orientation, unless it is specifically related to the treatment being proposed, such as gender realignment, all patients on pathways within the scope of the policy will be subject to the 18 Weeks RTT Standard and therefore there should not be an impact on these patients. Although gender realignment is not covered by the 18 Weeks RTT Standard, due to the requirement for appropriate psychological assessment and thinking time, once the patient has agreed treatment with the clinician they will be covered by the proposed 12 week Treatment Time Guarantee contained in the Patients Rights Bill. It has been agreed with the Equality & Human Rights Commission to establish a separate protocol for access to treatment/management of Gender Identity Disorder to be agreed and ready for issue by the end of January 2011. The existing exceptional aesthetic referral protocol will also be revised to reference the more extensive protocol for Gender Identity Disorder.
Race?Yes
If not, what other information is needed?All patients on pathways within the scope of the policy will be subject to the 18 Weeks RTT Standard and therefore there should not be an impact on this group of patients. No indications from current waiting time data to suggest that patients from ethnic backgrounds are being disadvantaged. NHS Boards will need to improve information around patient ethnicity.
What does the information given say about how this policy might impact positively or negatively on the different groups within the target audience?
On AgeSpeech and Language Therapy and Occupational Therapy are not included in the 18 Week RTT Standard. This could potentially have a negative impact on older people and children as they are more likely to access these services.

Getting appointments quicker as a result of the 18 Weeks RTT Standard could cause patients, but in particular older patients, anxiety about their health (they may think something more serious is wrong if they are receiving appointments much quicker). Communication of the Standard is key to ensuring patients are clear about the process and the reasons for appointments being given quicker.
On DisabilityRegistered disabilities are not collected as part of the current waiting times dataset. New Ways of Defining and Measuring Waiting Times is currently being revised and will include guidance on the need to put in place additional support for patients with disabilities to ensure the 18 Weeks RTT Standard is delivered for those patients. It is intended this guidance will be issued end November 2010.
On Faith/Religious BeliefReligious beliefs or practices could affect the range of treatments offered if a treatment or appointment date is ruled out by a patient on religious grounds. It is important that an alternative is available within the 18 Week RTT Standard.
On GenderDistribution of waiting times published Feb 2010 shows very little variation in the waiting times for males/females as well as very little variation in the average wait for treatment for these groups.
On Lesbian, Gay, Bisexual and TransgenderGender realignment is not covered by the 18 Weeks RTT Standard due to the need for the patient to take time to reflect and consider the psychological and physical ramifications of procedures which can dramatically change their physical appearance and ensure that patients are not rushed into a major decision. However, once the clinician and the patient have agreed to such treatment this will be covered by the proposed 12 week Treatment Time Guarantee contained in the Patients Rights Bill.

It has been recognised that the existing 'exceptional aesthetic referral protocol' requires to be revised with regard to gender realignment treatment. It has been agreed with the Equality & Human Rights Commission that a separate protocol for access to treatment/management of Gender Identity Disorder will be developed, agreed and be ready for issue by the end of January 2011. This more extensive protocol will be referenced in the 'exceptional aesthetic referral protocol'.

Services will be more linked through the 18 weeks RTT policy which could have a potential negative impact on someone who does not want to disclose their sexual orientation to a particular organisation.
On RaceEthnic data is collected by some NHS Boards but not all. We recognise the need to improve systems in the recording of ethnicity of patients and to ensure appropriate communications and support are in place to ensure these patients are treated within 18 weeks. A new guidance and definitions document is in the process of being drafted and will include guidance on the need for support to be put in place, particularly in relation to translation services. It is intended that this guidance will be issued end November 2010.
Will there be any changes to the policy?
On AgeNo
On DisabilityNo
On FaithNo
On GenderNo
On Lesbian, Gay, Bisexual and TransgenderYes
On RaceNo
CommentsThe resulting National Access Policy and Revised Guidance and Definitions Document which will stem from this policy will be subject to EQIA as these will form the principles and rules for NHS Boards to follow in their delivery of the 18 Weeks RTT Standard. This should include assessment of exclusions from the policy.

It has been agreed with the Equality & Human Rights Commission that a separate protocol for access to treatment/management of Gender Identity Disorder will be developed, agreed and issued by the end of January 2011. The existing exceptional aesthetic referral protocol will be revised to reference the more extensive protocol for Gender Identity Disorder. This work is being led by the Access Support Team.

It will also be important that NHS Boards include EQIA as part of their Operational Policies and Standard Operating Procedures. A Communications Strategy for 18 Weeks RTT is currently being drawn up which will be key to ensuring understanding at all levels.
Does the policy provide the opportunity to promote equality of opportunity or good relations by altering the policy or working with others?
On Age?Yes
Age - CommentsThe 18 Weeks RTT Standard covers all age groups, therefore will have a positive impact on all age groups by reducing waiting times. The 18 Week RTT Standard could have a particularly positive impact on older people as they will receive treatment quicker, potentially giving them a longer and better quality of life.
On Disability?Yes
Disability - CommentsThe 18 Weeks RTT Standard covers all patients on pathways within the scope of the policy, therefore will ensure that patients with or without a disability are treated within the 18 weeks standard.
On Faith?Yes
Faith - CommentsAll patients on pathways within the scope of the policy, regardless of their religion or beliefs, will be included in the 18 Weeks RTT Standard, creating a positive effect by reducing waiting times. Where a patient is unable to make a particular appointment date due to, for example, a religious holiday, the policy allows for a 'clock pause', which means they do not have to return to the beginning of their wait, and are offered a suitable alterative.
On Gender?Yes
Gender - CommentsAll patients on pathways within the scope of the policy, regardless of their gender, will be included in the 18 Weeks RTT Standard, creating a positive effect by reducing waiting times.
On Lesbian, Gay, Bisexual and Transgender (LGBT)?Yes
LGBT - CommentsAll patients on pathways within the scope of the policy*, regardless of their sexual orientation, will be included in the 18 Weeks RTT Standard, reducing waiting times.

*Gender realignment is not covered by the 18 Weeks RTT Standard due to the need for the patient to take time to reflect and consider the psychological and physical ramifications of procedures which can dramatically change their physical appearance. However, once the clinician and patient have agreed to such treatment this will be covered by the proposed 12 week Treatment Time Guarantee contained in the Patients Rights Bill. Following discussion with the Equality & Human Rights Commission, we have agreed to alter our exceptional referral protcol and create separate guidance specifically for Gender Identity Disorder. This stance has been well-received.
On Race?Yes
Race - CommentsAll patients on pathways within the scope of the policy, regardless of their race, will be included in the 18 Weeks RTT Standard, creating a positive effect by reducing waiting times.
Level of relevance to the policy, based on the work that has been done
AgeLow
DisabilityLow
FaithLow
GenderLow
Lesbian, Gay, Bisexual and TransgenderMedium
RaceLow
Does a further assessment need to be done?
On Age?Yes
On Disability?Yes
On Faith?Yes
On Gender?Yes
On Lesbian, Gay, Bisexual and Transgender?Yes
On Race?Yes
Comments if a further assessment is needed?Given that revised guidance and definitions are in progress and a National Access Policy is being produced, it is appropriate that these documents (essential to delivery of the 18 weeks policy) are EQIA assessed. These guidance documents will form the basis for NHS Board delivery of the 18 Weeks RTT Standard. It is also important that NHS Boards carefully monitor the impact of the implementation of the 18 Weeks RTT Standard to ensure that no particular group is adversely affected.

In addition, the Scottish Government are currently working on an agreement around 'tolerances' to enable appropriate pathways to be longer than 18 Weeks in particular circumstances e.g. patient choice. This is currently being consulted on with the service and is due to be issued November 2010.
Comments if no further assessment is needed?
How will this policy/function be monitored and evaluated to ensure there are acceptable outcomes for all?
CommentsThe 18 Weeks Programme Board are the governance body for this and associated policies and guidance and will be responsible for monitoring equality impact assessment.

Data against this target are due to be published in Spring 2011, to be delivered by December 2011.

The Access Support Team and Improvement & Support Team are available to support delivery of this target. Colleagues from the Analytical Services Division (ASD) and Information Services Scotland (ISD) are available for further statistical support.

Page updated: Tuesday, October 04, 2011