The Public Health Medicine Environmental Group (PHMEG) supports in principle the creation of an agency for the purpose of improving public health protection.
We welcome the bringing together of the 4 national bodies with specialist roles in health protection and we particularly welcome the strengthening of the specialist technical expertise on chemical hazards.
The majority of our members also welcome the move to bring Consultants in Communicable Disease Control (CsCDC) and PHLS/CDSC into the same organisation. This should improve joint working, particularly collaboration on surveillance programmes.
We believe that the development of a Field Services Division within the Agency would greatly facilitate the contribution of CsCDC (and other locally based specialist staff such as infection control and public health nurses) to the development of national policies and programmes. They would bring their extensive experience in developing and implementing communicable disease prevention and control programmes in the local multi-agency setting
The development of the Field Services Division could strengthen local and regional services, by allowing certain functions to be carried out more efficiently and by encouraging better integration between the work of the regional epidemiologists and CsCDC and their teams.
However we are concerned that the agency will not achieve its aims without a better understanding of the nature of the local specialist health protection service and particularly the role of local authorities and PCTs in the health protection function. Delivery of the local health protection function and other elements such as the timely provision of notification and surveillance data which support regional and national health protection function are dependent on the local relationships and links between the NHS, local authorities and other local agencies. These are the foundations upon which the health protection of the population are built.
We suggest that the name Public Health Protection Agency might be a better name for the agency. This would help distinguish us from other key players in the field of health protection, such as local authority environmental health departments which are increasingly named health protection departments. However we are happy to support the name “Health Protection Agency” if that is the majority view.
The information provided does not allow us to comment on which of the proposed bodies would best support the health protection function particularly at local level. Whichever model is adopted, it must allow for CsCDC to be eligible for appointment as proper officers of local authorities in respect of relevant public health legislation.
The lack of clarity about the role of the agency in the provision of local health protection services is of major concern to us.
Section 1.2 of the consultation document indicates that “the agency will take over responsibility for providing or commissioning the health protection functions provided by consultants in communicable disease control and their staff”.
However, section 4.11 talks about the agency giving “support for the provision of services at local level”, and states that the agency would “assist Primary Care Trusts (PCTs) in the discharge of their functions of providing a health protection service”.
These two sections are not congruent. The former suggests that CsCDC and staff will move into the agency, but continue to provide the local health protection functions. The latter gives the impression that PCTs would have to re-provide the CCDC service with the CCDC advising and supporting from the agency.
Getting Ahead of the Curve listed nine key responsibilities of CsCDC, including: -
1) strategic leadership and co-ordination of local programmes for communicable disease and infection control for a defined population,
2) leadership for health protection activities which require multi-agency collaboration at local level.
The consultation document does not explain how the delivery of these two extremely important functions be secured with the development of the agency. We believe that these roles should continue to be part of the agency’s specialist local function, with PCTs developing their operational capacity to deliver the programmes.
Changing the role of the CCDC and staff from one of “providing health protection functions” to “providing advice and support” could result in a loss of protection for the local population, because of the loss of the leadership function. The lack of clarity about the function of the Agency at local level makes it difficult to judge whether or not new burdens are being created for PCTs or for local authorities, who have an important role in local health protection.
We therefore suggest that greater clarity is required about the functions of the agency; what is it responsible for, what it is going to provide, what it will commission and what form its support to the NHS and local government will take. We would welcome an opportunity to contribute to the clarification of these vital issues, in conjunction with other key partners particularly PCTs, NHS Trusts and local authorities.
We echo the concern raised by local government (5.27) about the risks that Agency staff might not have sufficient local knowledge to enable them to function as proper officers.
While clearly both local authorities and PCTs have local knowledge, this will not replace the local knowledge and relationships built up over many years by CsCDC and their teams. The new arrangements must not divorce local specialist health protection teams from their populations. To do so could result in a loss of protection.
We believe that the legislation should provide a right for the agency to publish its advice.
There is a lack of clarity about accountability which we believe could seriously weaken the health protection function. Attempts to sketch relationships between the agency and key partners show lines of accountability from the local agency team to the PCTs, local authorities, upward within the agency to a Regional tier, to the DoH and to the Regional Directors of Public Health.
We believe this is complexity is related to the lack of clarity about the functions of the various players, and it represents a potential loss of protection.
We would welcome a small board which conducted its business efficiently and effectively while taking into account current government guidance that public bodies should be open. We agree that appointments should be delegated to the NHS appointments commission.
PHMEG members who are NHS employees are concerned that the move to the new agency might result in terms and conditions which were less advantageous than the current NHS terms and conditions. We would welcome confirmation that this will not be the case.
We are concerned that the proposed changes are expected to be resource neutral. We consider this expectation completely unrealistic. Many local teams already under-resourced having for many years had new responsibilities assigned without any additional resource. They have been further disadvantaged by the dispersion of shared support staff and the loss of local public health colleagues with the demise of district health authorities.
The suggestion that the agency could take on additional responsibilities, such as the surveillance of chemical hazards, without new funding would even further stretch existing capacity.
There are likely to be considerable start-up costs for the local agency teams and any attempt to re-distribute staff and resources without reference to local needs could seriously damage health protection.
We believe it is important to safeguard and develop the ability of all medical microbiological laboratories (reference, specialist and clinical) to contribute as required to both the routine and emergency health protection functions, whatever management arrangements are put in place.
We hope that are comments are useful and we look forward to working with the DoH and relevant partners to help shape the new Agency.
Dr Ruth Gelletlie
President PHMEG
September 2002