DESIGNED FOR PEOPLE WITH CHRONIC CONDITIONS – SERVICE
DEVELOPMENT AND COMMISSIONING DIRECTIVES – EPILEPSY
RESPONSE FROM THE CHARTERED SOCIETY OF PHYSIOTHERAPY (CSP)
1.1 The Chartered Society of Physiotherapy (CSP) is pleased to provide a
response to this Welsh Assembly Government consultation document.
1.2 The CSP represents around 1,500 physiotherapists, technical instructors,
assistants and students in Wales. CSP members work primarily in the
NHS but also in the independent sector, education, research, the
voluntary sector, industry and occupational health.
1.3 The CSP is the professional, educational and trade union body for its
47,000 members in the UK, physiotherapy being the third largest health
profession after doctors and nurses. 98-99% of all registered
physiotherapists are members of the CSP.
1.4 Chartered physiotherapists, their technicians and assistants provide
treatment and support for their patients, clients and carers in a variety of
different clinical environments in the course of NHS treatment. These
include intensive care, acute and rehabilitation hospital wards, outpatient
departments, hydrotherapy pools and multidisciplinary clinics.
Physiotherapists also work in community settings, within schools, GP
practices, health centres and in peoples own homes.
1.5 ‘Physiotherapy is a health care profession concerned with human function
and movement and maximizing potential. It uses physical approaches to
promote, maintain and restore physical, psychological and social well-
being, taking account of variations in health status. It is science-based,
committed to extending, applying, evaluating and reviewing the evidence
that underpins and informs its practice and delivery. The exercise of
clinical judgement and informed interpretation is at its core.’ (Chartered
Society of Physiotherapy (2002) Curriculum Framework for Qualifying
Programmes in Physiotherapy. CSP, London).
2. Welsh Assembly Government Consultation Questions
2.1 Are you satisfied with the scope and vision of the Service Development
and Commissioning Directives for Epilepsy?
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The CSP considers the document has attempted to map out the scope
and vision successfully. However, there remain some concerns about
service transition between children and young people’s services and adult
services (referred to on page 4 of the document). Local action plans will
need to address this and it would be valuable to make reference to
transitions issues in the ‘key actions’ section relating to Chapter 1.
2.2 Do you agree that the Directives are helpful in setting out the actions
needed to help modernise and improve health and social care services for
people with epilepsy in Wales?
The CSP has no additional comments in relation to this question.
2.3 Is the document comprehensive, accurate and applicable to the key
issues that face people with epilepsy, service providers, planners and
commissioners in Wales?
The CSP considers the document is comprehensive but will need some
reviewing in light of the current consultation on structures in the NHS.
With the removal of the internal market, it will be essential that planners
and providers work closely together and key actions will need to be re-
written to be relevant in the new operating environment.
2.4 Does the document provide clear guidance to service planners,
commissioners, service providers and health professionals?
In addition to the answer above (2.3) the CSP considers the document
does not provide clear guidance in its current state. A re-draft is required
in light of the consultation on NHS structures.
As part of the on-going developments linked to new NHS structures it will
be important to ensure ‘Needs Assessment’ continue with a degree of
‘localism’ that ensure the needs of people with epilepsy are identified. The
importance of Health, Social Care and Wellbeing Strategies at a local level
will also need to be highlighted.
P35 makes reference to managed clinical networks. The use of these
within the new NHS structures will also need to be determined.
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2.5 Have any key issues that effect people living with epilepsy been missed in
As far as the CSP is aware, there are no issues that affect people living
within epilepsy that have been missed in the document.
2.6 Do you have any further comments to make on the document?
1. The CSP is pleased to see reference to physiotherapy on page 32
of the document but concerned that the inference of the document
is that access to physiotherapy is only within a ‘specialist treatment
and care’ scenario. (Reference to physiotherapy is made in the
section 4.3.6 of the document). The CSP would argue that people
living with epilepsy should be able to see physiotherapists,
occupational therapists and others in primary care and community
settings – not just in the secondary care setting. Reference is
made (on page 29) to the multidisciplinary approach where
‘therapies’ and ‘rehabilitation’ are highlighted. The CSP would like
to see reference to physiotherapy and other allied health
professions (AHPs) here to ensure the message is clear.
2. In ‘key actions’ for chapter 4, reference is made to workforce
development. The CSP considers this is of paramount importance.
More detail is needed with regard to this key action around
identification of future workforce needs in relation to epilepsy
service provision and access to support services. These
requirements (which might well be identified by the managed
clinical networks) must be fed in to the integrated workforce
planning process developed by the Welsh Assembly Government.
3. 5.2.9 highlights the importance of Aids and Adaptations.
Recommendation of action required is included within the text but
there is no ‘Key Action’ on page 43 to take the action forward. The
CSP fully supports the statement on page 41 that ‘Timely
assessments and the provision of aids and adaptations can often
have a significant impact on independence for people with
neurological conditions’. It is important that action to develop joint
services should be pushed forward.
4. Typo – page 18
‘Correspondence is copied …’
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3. Concluding Remarks
3.1 The CSP has been very pleased to play an active part in this consultation
process and is happy for the response to be published in the public
3.2 A key consideration by the profession is the need for the Welsh Assembly
Government to review this guidance (and indeed the other commissioning
guidance documents already published) in light of the current consultation
on NHS structures. This is, in the CSP’s view, essential in order for the
guidance documents to be used in an effective way post abolition of the
3.3 If there are any questions arising from the response please do not hesitate
to contact the CSP’s Cardiff Office.
Philippa Ford MCSP
CSP Policy Officer
029 2038 2429
In association with:
The Welsh Board of the Chartered Society of Physiotherapy
The All Wales Physiotherapy Managers
The Wales Neurological Physiotherapy Network
The Wales Paediatric Physiotherapy Network
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