Mobility and Access Committee for Scotland (MACS) - Response to Consultation on NHS Scotland Climate Emergency and Sustainability

MACS Response to Consultation on NHS Scotland Climate Emergency and Sustainability - Draft Strategy 2022 to 2026.

Page 7, Paragraph 13

Comment

Paragraph reads: NHS Scotland cannot deliver its sustainability aims on its own.

We also need to work closely with local communities, local authorities and other public bodies, third sector organisations and our suppliers to achieve them. We will actively engage in existing forums for collaboration and assist in creating new ones where they are needed.

Suggested amendment/text

This paragraph would benefit from the inclusion of “we also need to work closely with Disabled People’s Organisations” (DPOs), Transport Scotland’s Transport Equalities Network and Transport Citizen Panels, the latter still in development as part of the Working with Partners work-stream from NTS2.

Page 10, Paragraph 12

Comment

Paragraph reads: To help raise awareness, each Health Board will develop and implement communications plans to help staff, patients and visitors make sustainable choices and raise awareness of its own plans, actions and progress in developing a more sustainable health service.

Suggested amendment/text

These communication plans need to be available in various formats including easy read, braille if requested and in paper as well as on-line with on-line publications published in a format accessible for people using screen reading software. Diagramatic information needs to be represented by text-based explanations. The Inclusive Communications Hub can offer advice about making communication inclusive and accessible; visit inclusivecommunication.scot.

There should be no “lag time” between the documents going live and being available in various formats to promote inclusive communications and prevent exclusion.

Page 54, Paragraph 24

Comment

Paragraph reads: To ensure the sustainable development of new builds and major refurbishments Health Boards will:

Maximise the quantity and quality of greenspace at the location of all new healthcare facilities and design to promote equality and healthy choices
Integrate path networks and greenspaces within and to the healthcare  estate to create green networks that encourage walking and cycling for relaxation, exercise, meetings and active travel

Suggested amendment/text

These actions are welcome but the guidance needs to direct NHS Boards that local engagement takes place with key stakeholders, including Local Access Panels and Disabled Peoples Organisations to ensure local engagement and inclusive design principles are at the heart of this work to prevent failure and exclusion that would prevent access to essential services.

The NHS guidance would benefit from explaining that care needs to be taken to ensure that facilities to encourage active travel do not create barriers for disabled people. The National Institute for Healthcare Excellence published ‘Physical Activity and the Environment’ guidance to support people of all abilities become more active through improvements to the built and natural environment. It is recommended the NHS guidance references these guidelines and they are adopted.

The Health and Social Care Alliance (The Alliance), the Mobility and Access Committee for Scotland (MACS) and Disability Equality Scotland (DES) facilitated a series of 4 themed webinars around the aspirations of 20minute neighbourhoods. These discussions focused heavily on disabled people and older people’s needs and had the added value of tapping into and building on direct lived experiences. The work and recommendations from these 4 themed events would be of benefit to this strategy. Areas covered included:

Event 1 - Introduction to 20-minute neighbourhoods
Event 2 - Getting around and accessing services (including health and social care) - Event input assisted by Spinal Injuries Scotland
Event 3 - Housing and Greenspace
Event 4 - Designing the 20-minute neighbourhood

A video of summarising these events is available and a report will be available from The Alliance by end January 2022.

Page 2, 3 and 4, Paragraph 29

Comment

Paragraph reads: By reducing the need to travel and supporting the shift to active travel and vehicles powered by renewables, we will help improve air quality and cut carbon emissions

We will do this in a way, which supports the Scottish Government’s National Transport Strategy 2 and its aims of  reducing inequalities by providing fair access to the services we need and improving health and wellbeing.

This will help to reduce the demand for both renewable and fossil fuels and promote more sustainable and healthy ways of travelling such as walking, wheeling, cycling and public transport.

Suggested amendment/text

It’s unclear whether this relates to NHS staff and the NHS vehicle fleet, the wider public, or both? The guidance should recognise many disabled people depend on travelling either as a driver or passenger in cars. This may be as a result of their impairment, or caused by the lack of available, affordable and accessible public transport locally. The guidance therefore should recognise this and ensure that there continues to be protected car parking available at health and care sites for disabled people, that this improved rather than removed disabled parking and that there are no financial penalties incurred by blue badge holders not using electric vehicles. This is because the Motability Scheme which allows disabled people to lease an accessible vehicle currently does not offer many affordable accessibly adapted electric vehicle options for disabled people, so they are largely reliant on petrol or diesel cars currently via the scheme. The guidance should also recognise that service users and their carers may travel significant distances to certain health care facilities, e.g. from the islands to the mainland, or from another part of Scotland to Glasgow to access care unavailable locally. For such people car travel may be the only option.

Info box and Page 5, Paragraph 38

Comment

Reads: Data gathered by individual NHS Boards suggests that current rates of travel to main hospital sites by staff, patients and visitors are approximately:

Active travel: 2.8% of journeys
Public transport: 7.4% of journeys
Car use: 89.2% of journeys

We will support the continued use and expansion of NHS Near Me and other forms of remote consultation where it is clinically appropriate.

Suggested amendment/text

The shift to remote and online appointments via “Near Me” is very welcome for many disabled people who struggle with travel arrangements and where this is appropriate and their choice.

During MACS phase 1 work on transport to health and social care, evidence gathered from hospital websites, roundtable discussions and polls of disabled people, showed that public transport, mainly bus timetabling, lack of accessible information about options/ available services, routes, positioning of bus stops from hospital destination, pavement infrastructure between bus stop and hospital etcetera – were all barriers to using public transport to attend hospital appointments.

This needs to be addressed to reduce the percentage of people driving to sites and shift this to more sustainable modes and the work previously done by MACS would provide a robust starting point. View the MACS Transport to Health report.

Page 7, Paragraph 30

Comment

Paragraph reads: NHS Scotland seeks to find the right travel solutions for each of the communities we serve, maximising health and wellbeing through both the care we give and the way it is provided . We support the Scottish Governments ambition to create 20minute neighbourhoods - places where things that people need for everyday life are all located within a twenty-minute walking distance.

We aim to bring care closer to home, to make it more accessible to people, and we will work with communities and other partners to make twenty -minute neighbourhoods a reality across the country.

Suggested amendment/text

These actions are welcome and need to ensure that local engagement takes place with key stakeholders, including Local Access Panels and Disabled People Organisation’s to ensure local engagement and inclusive design principles are at the heart of this work to prevent failure and exclusion that would prevent access to essential services.

These discussions focused heavily on disabled people and older people’s needs and had the added value of tapping into and building on direct lived experiences.

The work and recommendations from these 4 themed events need to be factored into this strategy. Areas covered included:

Event 1 - Introduction to 20-minute neighbourhoods
Event 2 - Getting around and accessing services (including health and social care) - Event input assisted by Spinal Injuries Scotland
Event 3 - Housing and Greenspace
Event 4- Designing the 20-minute neighbourhood

A video of summarising these events is available and a report will be available from The Alliance by end January 2022.

Page 8, Paragraph 30

Comment

Paragraph reads: To help reduce the number of journeys taken by car we will:

Carry out annual travel surveys at each of our sites to monitor shifts in modes of transport and travel to and from NHS sites
Establish a target to reduce the number of journeys taken by car (staff, patients and visitors)
Support the continued use and expansion of NHS Near Me
Plan new facilities in communities using the principles of the twenty-minute neighbourhoods
Explore options for the better integration of care to reduce the number of separate appointments and journeys.

Suggested amendment/text

Regarding annual travel surveys about travel modes to health care sites MACS strongly recommends that survey questions and data collection seeks to understand the travel habits of disabled people, and that where possible data collects and reports disaggregated findings for wheelchair users, people with mobility impairments, people with visual impairments, hearing impairments, learning disabilities and mental health problems. This is to understand whether people with particular impairments or disability results in those with that impairment or disability choosing a particular travel mode. This is essential to ensure that decisions based on data about travel habits do not inadvertently negatively effect disabled people.

Limited data is known about the travel modes and behaviours of disabled people to date. As such MACS have been working with the SG Analytical Team to add additional questions into the Scottish Household Survey (SHS) to allow for the collection and analysis of data on disabled people’s travel patterns and behaviours. This is to set a baseline to work from in “closing the mobility gap”, to feed into the “reduces inequality” pillar of NTS2 and to assist Transport Scotland’s Accessibility Team in progressing the Accessible Travel Framework, including prioritising work areas.

Transport Scotland have now published Disabled People and Transport – Findings from the Scottish Household Survey (SHS).

The main findings from this report include; that disabled people travel less often and less far than non disabled people, the more disabled you are, the more pronounced this difference is (those whose disability affects their day to day activities "a lot" make 60% of the journeys that non disabled people do). The report also confirms that disabled people most often travel by car (as driver or passenger), by walk/wheel and by bus.

MACS would ask that the above comments and the TS report on Disabled People and Transport form part of the Climate Emergency – Sustainability Strategy for 2022-2026.

Please see our comments on the 20 minute neighbourhood in previous sections of our response.

MACS Recommendation One from their “phase one” work on Transport to Health and Social Care is:

Recommendation One

“Transport should be built in as an integral part of the care pathway. Their needs to be better joined up care planning and working with NHS, Local Authorities and SAS, with CTA recognised as key partners in the planning and care pathway”.

MACS would ask that this recommendation (and the engagement and lived experience input behind it) is central to: “Explore options for the better integration of care to reduce the number of separate appointments and journeys”.

Page 12, Paragraph 31

Comment

Paragraph reads: To support an increase in active travel to NHS sites we will:

Work with local authorities, third sector organisations and partners to link our NHS facilities to active travel routes and networks in the wider community
Make outdoor sites easier, safer and more enjoyable to walk, wheel and cycle on including through improved way-finding
Provide detailed information to all our patients and visitors on how to avoid using a car when accessing our sites including details of cycle routes and paths, cycle parking, facilities and public transport options
Ensure that new NHS facilities (including pop -up clinics, vaccination centres and screening sites) prioritise access for people travelling actively and sustainably.

Suggested amendment/text

MACS welcome these initiatives and would ask for consideration of the existing work and delivery plans to be included within this strategy.

Take account of the work and outcomes/recommendations of MACS, The Alliance and DES after the webinar series on the 20 minute neighbourhood concept.

We would also highlight the need to involve local disability Access Panels (as partners) to ensure the needs of disabled people are central to prevent exclusion and comply with the PSED.

MACS would also signpost to their phase one work on Transport to Health and Social Care and ask that the reports from this work (2) and the 9 themed recommendations are utilised to progress this area. MACS have the backing of Scottish Ministers to address the failing in Transport to Health and Social Care and have been working with the Scottish Government Health Directorate (Primary Care Team – Fergus Milne) to take forward these 9 recommendations and this fits tightly with this commitment

Again MACS would stress the need to engage early with local disability Access Panels and Disabled People Organisations’ (DPOs) to ensure the needs of disabled people are central to prevent exclusion and comply with the PSED.

This information should be available in various formats and in “hard copy” as well as on-line. Information should not rely on disabled people being able to interpret maps or using Travelline or other tools but instead provide information about travel options to sites themselves. The onus should be on the NHS to ensure all patients have this information and not “as is” where patients have to search to find information on how to travel to hospital. To ensure this shift and that this commitment is delivered, transport needs to become part of the care pathway, rather than it starting at the door of the hospital (MACS Recommendation One from the work on Transport to Health and Social Care).

Page 16, Paragraph 32

Paragraph reads: To increase the number of journeys made by shared transport we will:

Work closely with local authorities to identify where public transport links to NHS sites need to be improved
Make accessibility by public transport a fundamental consideration in decision making about where to develop new NHS facilities
Work with Community Transport Association UK and volunteer transport groups to improve patient access

Suggested amendment/text

MACS welcome this commitment and offer the following advice.

This should also include engagement with local Access Panels and Transport to Health having high priority in each Local Authorities Local Outcomes Improvement Plans and local Transport Strategies, ensuring engagement with Regional Transport Partnerships, the Scottish Ambulance Service and Integrated Joint Boards.

This should include engagement with local Access Panels.

This work should be with the Community Transport Association (CTA) in Scotland and should see them represented on the Delivery Board of the NTS2. The CTA in Scotland have surveyed its operators on Transport to Health and Social Care, the survey results and recommendations should be included in the planning to achieve this objective.

Page 23, Paragraph 34

Comment

Paragraph reads: To accelerate the decarbonisation of our fleet and business travel we will:

Review and amend NHS Scotland mileage reimbursement rates and allowances to encourage staff travelling by sustainable means including bicycle.

Suggested amendment/text

MACS would suggest the mileage reimbursement and travel expense policy for NHS Scotland also needs revisited to make it easier to claim and travel by public transport and also to make travelling for medical appointments affordable for all. The affordability of travel to medical appointments was raised in MACS phase one work on Transport to Health and Social Care and this research and the recommendations should be considered in this strategy.

Page 2, Paragraph 57

Comment

Paragraph Reads: The earlier sections of this strategy aims to embed sustainable practices within the NHS and Health and Social Care System. In this part of the strategy, we set out our plans to support sustainable practices in our communities and neighbourhoods. It includes the following topics:

Supporting health and wellbeing
Building community resilience
Engaging our communities

Suggested amendment/text

MACS support these areas as part of this strategy and would make the following points.

During MACS phase one work on Transport to Health and Social Care, evidence through polls and lived experience examples showed the impact on peoples’ health and wellbeing of being unable to access medical appointments due to the failure of public, NHS and ambulance service transport.

There was also evidence of the impact on patient’s health and wellbeing from the additional stress of disabled people trying to navigate their way through various healthcare organisations (hospitals, GPs, the Scottish Ambulance Service and transport providers) to “find a way” to get to their appointment.

These lived experience exampled need to be used to evidence that transport to health fails disabled people and older people and this failure has a detrimental impact on their health and wellbeing and needs to be addressed with urgency.

The National Audit Office produced a report on Transport to Health and Social Care in 2011 and the conclusion of MACS phase one work in 2019 and 2020 found the same issues and that none of the NAO recommendations had been progressed and indeed things were worse over the 10 years since the first recommendations.

Both the above reports need to be used to address the transport failings and avoid another round of consultations to identify what is already known and impacts on many disabled people and older people.

MACS would again signpost to their work on 20 minute neighbourhoods and also ask that engagement with disability Access Panels is central.

Page 4, Paragraph 57

Paragraph reads: Playing a positive role in communities starts with minimising our own impact on the environment. In earlier sections of the strategy we have committed to actions under the following, which will have a positive impact on people’s health and wellbeing:

Promoting public and community transport

Suggested amendment/text

MACS support this commitment with the comments below:

Public Transport: MACS appreciate that the strategy is the driver for a comprehensive suite initiatives and commitments and recognise the challenges. However, we believe that this strategy seriously underestimates the challenge facing the transport sector - from policy makers to delivery partners - in addressing the transport barriers disabled people face in accessing health and social care services.

We also believe that this strategy underestimates the current inequality active travel where disabled people have been excluded and left behind (i.e. no public bike hire schemes have the option of a non standard bike, there is limited or an absence of storage for mobility equipment and NHS facilities and many active travel routes are not design to be inclusive for those using non-standard bikes (wider and longer) or mobility equipment.

We suggest that more significant strategic issues which disabled people face are:

Accessing suitable transport to health and social care
Inaccessible and hostile pedestrian environments which inhibit walking and wheeling and which are often a vital link in the journey chain including to NHS premises
The risk posed by the aspiration to reduce car journeys, especially in cities, bearing in mind the disproportionately high dependence of many disabled people on private cars (as a mobility aid)

We would encourage the owners of this strategy to refer to MACS’ website and in particular our Annual Reports, which show the priorities which MACS identify and which forms much of the advice we provide to Scottish ministers.

We suggest that a significant barrier lies in the fact that industries such as passenger transport, streetscape design etcetera have not historically developed from an “equality and human rights” perspective.

To put these at the heart of all policy making processes and strategy development is an enormous challenge to all stakeholders, NHS Scotland, the Scottish Ambulance Service, Local Authorities, Integrated Joint Boards to every transport operator.

Another barrier which we believe needs to be acknowledged is that there may be a financial cost to achieving equality and human rights, whether in the provision of NHS, public, community or commercial transport services (bus, taxi etcetera) or the design and maintenance of infrastructure (from bus stops and train stations to footways leading to NHS facilities).

Travel to health and social care is often a nightmare for many disabled people. Agencies do not collaborate effectively to enable disabled people especially to access appointments effectively and disabled people are often left to find solutions themselves, often at considerable cost both financially and in terms of stress and well-being. The lack of a person-centred approach is a major problem, which has been highlighted over the past two years by MACS. We would also sign post to this work as well as the NAO report of 2011 (on Transport to Health and Social Care).

We would also signpost to the work of Transport Scotland and in particular the Accessible Travel Framework, which has recently included Transport to Health and Social Care in its delivery plan for 2022-2023.

Community Transport: MACS believe that the CTA is Scotland should have a stronger voice at a more strategic level and that it should be acknowledge that they have a key role in transport to healthcare facilities. There also needs to be acknowledgement that the CTA needs to be properly funding rather than patients paying to use their services resulting in an inequality (as they are excluded from using their concessionary travel entitlement) and often leaving people making sacrifices to afford to travel to medical appointments (evidence shows people trading of heating and eating to afford to pay to travel to essential medical appointments).

Paragraph 65

Comment

Supporting Health and Wellbeing:

8. Ensure that community engagement principles meet the Scottish Government Guidance on Engaging Communities

Building Community Resilience:

2. Support our patients, staff and partner organisations in creating homes, communities and transport networks that increase resilience and minimise the impact on climate change.

Suggested amendment/text

MACS support these actions within this strategy and would make the following comments:

This must include early meaningful engagement with disabled people and or their representatives (Access Panels or DPOs)

This commitment must bear in mind that currently the transport network fails many disabled people and previous work (i.e. by the NAO and MACS) should be used to progress these recommendations. In relation to MACS work this is firmly based on lived experiences.

Paragraph 66

Comment

Engaging our Communities:

7. Support more, and clearer, inclusion of local communities in decision making

9. Work with local authorities and other on planning, providing good access to services, active travel options and public transport both on our own sites, and beyond them

Suggested amendment/text

MACS support these actions within this strategy and would make the following comments:

This is at the heart of getting it right and must include early and meaningful involvement in disabled people and/or their representatives (DPOs and Access Panels). This work should also ensure meaningful impact assessment are conducted early, for each area of work i.e. Equality Impact Assessments, Health Inequality Impact Assessments etcetera

This work should ensure engagement with local disability access panels and hold local authorities and other public bodies to account for the PSED. Transport to Health and Social Care needs to feature more prominently in Local Outcome Improvement Plans and the Delivery Plans for Regional Transport Partnerships.

Published Date 19 May 2022 Type

Report

Topic

Accessible transport