Submission regarding the Department of Health and Children's (DHC) Outline Sectoral Plan
(This plan forms part of the Government's Disability Strategy.)October 2005
Introduction
Comhairle supports the main aim of the plan, which is “to provide access to appropriate health and personal social services for people with disabilities.” Comhairle is happy to see the four principles, Equity, People-centredness, Quality and Accountability reiterated in this plan as these are at the heart of a good and inclusive health service. Most of the comments below relate to the Action Plan but a few concern the objectives which are stated at the beginning of the document. Given that the Health Service is being restructured, the inclusion of people with disabilities and their organisations at the planning stage is very important, in order that disability concerns are built into the whole service. It is to be hoped that the new Health Service Executive (HSE) Area structures will renew the co-coordinating committees of people with disabilities which were a feature of the Health Boards. In particular, Comhairle would hope to liaise with DHC on the second objective – ensuring access to information to people with disabilities. This will be particularly important in the context of the introduction of assessment of need and the advocacy service which Comhairle is to be entrusted with under the Comhairle (Amendment) Bill 2004. Demand for advocacy is likely to rise as the assessment of need process comes on stream. An education and information campaign prior to the roll-out of this process is essential if all those eligible are to come forward for assessment.
The emphasis on people centred-ness, participation and choice is also important and Comhairle would like to highlight the empowering aspects of the Personal Assistance Service in allowing people with severe disabilities to participate and exercise everyday choices. In other countries supporting choice has involved the use of direct payments to the person with a disability so that he/she can purchase services. This is an option which could be considered by DHC.
Comhairle welcomes the recent relaxation of income guidelines which has allowed more people to qualify for a medical card. However Comhairle believes that an increased threshold is necessary for people with disabilities. The NDA Costs of Disability research (Michael Foley Disability and the Cost of Living, 2004) pinpointed medical needs as one of the main extra costs for people with disabilities – with large amounts of disposable income going on drugs or on doctors' visits. The loss of the medical card is a major disincentive to people with disabilities who might want to participate in the labour market, particularly at lower wage levels. Ideally, the income limits for people with disabilities would be set at the level of the average industrial wage, but failing that, it should at least be set at the present (higher) level for those between 65 and 70. The Long-term Illness scheme is at present a source of inequity as the illnesses covered are restrictive – it applies to some illnesses but not to others, without reference to the degree of disability caused.
Comments on Action Plan
The principal aim of this interim Plan is to ensure that the main aspects of the preparatory work related to the provisions of the Disability Bill are completed. One of the main elements of the Disability Act 2005 is the establishment of an assessment of need process. Comhairle would welcome an opportunity to comment on structures and statutory regulations planned for this process for people with disabilities, in order that the new advocacy service proposed under the Comhairle Amendment Bill would be developed in tandem with these structures. Comhairle would also welcome the opportunity to provide information on these new structures at the earliest possible stage, so that as many people with disabilities will be aware of the process and in a position to advocate for themselves.
Access to Services
Comhairle supports the decision of the Department to carry out a strategic review of existing service provision, in consultation with relevant interests, with a view to enhancing the present organisation and delivery of health and personal social services to meet the needs of people with disabilities. As a statement of services needed will follow the assessment process and will, for those concerned, be the test of its practicality, it is important that a wide range of services are available to people with disabilities by the time the Assessment of Need process begins. Comhairle would like to draw the Department's attention to shortfalls in the following areas:
- Provision of residential services to people with intellectual disabilities
- Residential and other support services such as home help, home care, for people with severe physical disabilities who are often inappropriately accommodated (formerly known as the young chronic sick population).
- Personal Assistant (PA) scheme for people with significant disabilities in order to promote participation and choice. Expansion of this service and equitable access to this service across all regions is important.
- Mental health services, particularly those for adolescents need to be expanded
Liaison with other relevant Government Departments and Public Bodies
Comhairle welcomes the commitment to liaison arrangements with other Government departments and agencies. Comhairle would hope to liaise with the Department on the provision of new information and to develop existing arrangements which link the Comhairle database, OASIS with documents from the DHC's website.
Information
Comhairle welcomes the emphasis on making HSE information available to people with disabilities in accessible format. A Comhairle report on provision of accessible information, Access to Information for All has just been completed. (September 2005). It would be useful if the HSE could engage in an information and advice campaign when the assessment of need and statement of services required processes are introduced. Information on access to advocacy should be provided alongside information on these processes in order to ensure a seamless service.
Disability Awareness
Comhairle supports the provision of disability awareness training to all HSE staff – specialised training for working with people with communication difficulties should also be provided to staff who require it. In relation to hospitals, people with disabilities have sometimes reported a lack of awareness of particular needs – such as dedicated parking near to entrances – and the need for reasonable accommodation for people who need to bring assistive devices with them or who need to have a PA with them. These issues came up at the Mainstreaming Specialist Study Group which formed part of the DHC's own Strategic Review of Disability Services and where Comhairle was represented. (See Mainstreaming Specialist Study Group Report September 2005)
Complaints/ Appeals
Comhairle would support the provision of fair and accessible complaints procedures with information about these procedures widely available. It is important that independence be built into such procedures through the establishment of a separate office and the involvement of non- HSE staff in the system. A person with a disability should have the support of an advocate in making a complaint.
Monitoring
Section 9 of the plan relates to monitoring. Comhairle would underline the importance of good and regular monitoring of the objectives as set out in Section 9 of the DHC outline plan. It is important that people with disabilities and relevant representative organisations should have an input into this system of monitoring as at present happens through the National Monitoring Committee. This Committee is representative of the Department of Health and Children, the Health Research Board, the Chief Executives of the Eastern Regional Health Authority and the health boards, the National Federation of Voluntary Bodies Providing Services to People with Intellectual Disability, the National Association for the Mentally Handicapped of Ireland (NAMHI) and the National Parents and Siblings Alliance. One possible suggestion would be that representative bodies would be rotated so that a wider cross section of the disability community would be included.
Conclusion
Comhairle believes that good information and increased availability of services are the key to making the assessment of need process work. Cooperation between Comhairle and the DHC on provision of information about the new services and structures would smooth the introduction of the assessment process, leading to more equitable access by people with disabilities to health and social services and to greater transparency about conditions of eligibility.
