1. Introduction


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1. Introduction

  1. 1. DESIGNED FOR PEOPLE WITH CHRONIC CONDITIONS – SERVICE DEVELOPMENT AND COMMISSIONING DIRECTIVES – EPILEPSY RESPONSE FROM THE CHARTERED SOCIETY OF PHYSIOTHERAPY (CSP) IN WALES 1. Introduction 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? Yes Comments Responses 2008 – Epilepsy 08 Page 1 of 4
  2. 2. 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? Yes Comments 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? Yes Comments 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? No Comments 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. Responses 2008 – Epilepsy 08 Page 2 of 4
  3. 3. 2.5 Have any key issues that effect people living with epilepsy been missed in the document?. No Comment 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? Yes Comments 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 …’ Responses 2008 – Epilepsy 08 Page 3 of 4
  4. 4. 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 domain. 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 internal market. 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 April 2008 029 2038 2429 fordp@csp.org.uk 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 Responses 2008 – Epilepsy 08 Page 4 of 4