Our Equality, Inclusion and Human Rights Commitments
NHS Lincolnshire CCG is a newly formed organisation as of 1 April 2020 the integration merger of the four previous CCGs in Lincolnshire: NHS Lincolnshire East, South, South West and Lincolnshire West CCGs. NHS Lincolnshire CCG is committed to designing and implementing policies, procedures and commissioning services that meet the diverse needs of our local population and workforce, ensuring that none are placed at a disadvantage over others.
The relevant publications of the four former CCG’s can be found on our legacy page. Other relevant documents will be published at appropriate points as work progresses.
The CCG will publish its Annual Equality Report in March 2021. The principle of publication for the CCG is that the Annual report includes an update on progress against the Equality Delivery System 2 (EDS2) framework and should be viewed in company with the CCG’s equality objectives reports. The CCG’s Equality Strategy further details our strategic intentions, which are designed to ensure Equality, Diversity, Inclusion and Human Rights (EIHR) remains at the heart of what we do. This ensures the best possible outcomes for the local community; CCG staff and especially those seldom heard groups who experience health inequalities.
Equality, Inclusion and Human Rights Objectives April 2020 – March 2023
These objectives are drawn from and take account of the four previous organisations EIHR work and objectives.
Note: These objectives are currently draft and are awaiting final approval via the relevant committee.
- Workforce data and staff support
- Enhance the data quality held on CCG staff via ESR, through an updated data cleansed system to improve data recording and monitoring.
- WRES/WDES delivery of annual submissions to NHSE and implementation of action plans.
- GPG reporting – dependant on the workforce numbers (threshold 250 staff), the new CCG will need to consider submitting gender pay gap data and so be responding to this data with an action plan.
- Introduce staff networks to support the development of different protected characteristics.
- Visible leaders to champion EDHR
- Leaders to be at the forefront of improving engagement with vulnerable groups/populations with regards to service change.
- Managers to be more involved in implementing EDHR actions/initiatives as part of their roles and responsibilities.
- Senior staff to be involved with the new Lincolnshire CCG Equality Forum –set up to support the implementation EIHR objectives and monitoring and review of outcomes.
- Support providers to address barriers to accessing services to by patients
- EDHR training
- Assess current EDHR training provision and staff professional development
- Improve the contents and uptake of EDHR mandatory training for all staff
- Introduce more face to face EIHR related training to support the work of staff from leaders to front line staff.
- Standards and Charter Marks
- EDS version 3 – All future work will be done in line with the new framework which will be released in 2020 by NHS England and piloted over the year
- Disability Confident – to obtain Leader Status by 2022
- Identify other relevant EDHR Charter Marks and assess/update new CCG policies and practices towards achieving these.
5. Equality Objective for Lincolnshire CCG to support BAME staff and communities in response to national reports.
Objective: Implement actions within the new NHS Lincolnshire CCG to assess the disproportionate impact of Covid 19 on BAME staff and communities in line with the associated health inequalities issues raised in the PHE disparities report.
Actions with regards to the workforce:-
- Collect/analyse workforce data trends paying specific attention to higher bands and create initiatives to address the under-representation of BAME staff at executive/senior level – relate to WRES work;
- Encourage the participation of BAME staff in the decision making process of the CCG, through networks with access at Board level but also other means e.g. staff consultation and engagement forums and staff surveys
- Organise training for all staff in a leadership role to help raise their awareness and confidence in having honest and difficult conversations with BAME staff about their circumstances
- Review the induction process with a view to include reference to the availability of additional support for all new and existing BAME staff;
- Conduct ongoing risk assessments on those BAME staff who may be at greater risk of infection and provide targeted support as required;
- Ensure that the CCG continues to conduct Equality Impact Assessments (EIA’s) when reviewing existing and developing new workforce policies and practices to address any disparities that may exist with regards to BAME staff.
- Ensure all staff are kept up to date with BAME issues, developments and initiatives through regular communications and engagement of information
- Actions with regards to the communities:-
- Review Lincolnshire wide demographics and health inequalities data to assess disparities and compare trends amongst different BAME communities and associated factors;
- Focus on targeting support to specific geographical areas of the county where disparities among certain communities may be more prominent;
- Engage with our partner organisations across the STP/ICS to ensure there is a system wide approach to tackling inequality across the Lincolnshire STP workforce
- Through communication and engagement exercises ensure that up to date information is distributed widely as possible and is accessible in different languages and formats as required – assessing the demographics of the areas being targeted prior to conducting exercise, helps to ascertain communication and engagement methods.
- Our EIHR Action Plan 2020-23
Meeting our Equality and Health Inequalities Legal Duties
CCGs and NHS England play key roles in addressing equality and health inequalities; as commissioners, as employers and as local and national system leaders, in creating high quality care for all.
CCGs and NHS England have two separate key duties, one on equality and one on health inequalities. Both require informed consideration by decision makers, but it is important to appreciate that they are two distinct duties.
Equality Act 2010 – Public Sector Equality Duty (PSED)
As an authorised public sector organisation, NHS Lincolnshire CCG is required by the Equality Act 2010 and Human Rights Act 1998 to work in ways that ensure equality and inclusion is embedded into all of its functions.
It is the intention of the CCG to eliminate unfair and unlawful discriminatory practices in line with current equality and Human Rights legislation. There are a number of duties which the CCG must address:
- In the exercise of its functions NHS Lincolnshire CCG must have due regard to the need to:
a. Eliminate discrimination, harassment and victimisation and any other conduct that is prohibited by or under the Equality Act 2010;
b. Advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it;
c. Foster good relations between persons who share a relevant protected characteristic and persons who do not share it.
- The CCG must prepare and publish one or more equality objectives at intervals of not greater than 4 years and each objective must be specific and measurable.
- The CCG must publish information, not later than 30 March each year, to demonstrate compliance with the PSED. The information published must relate to persons who share a relevant protected characteristic who are:
a.Its employees (only when employing 150 people or more)
b.Other persons affected by its policies and practices
The characteristics which are protected under the Equality Act 2010 are:
- Gender reassignment
- Pregnancy and maternity
- Religion or belief
- Sexual orientation
- Marriage and civil partnership (but only in regard to the first aim – eliminating discrimination and harassment)
Health and Social Care Act 2012 – Health Inequalities Duty
The Health and Social Care Act 2012 introduced the first legal duties on addressing health inequalities, with specific duties on NHS England and CCGs. Under the Act, NHS Lincolnshire CCG has duties to:
- Have regard to the need to reduce inequalities between patients in access to health services and the outcomes achieved;
- Exercise its functions with a view to securing that health services are provided in an integrated way that would improve quality, reduce inequalities in access to those services or reduce inequalities in the outcomes achieved;
- Include in an annual commissioning plan an explanation of how they propose to discharge their duty to have regard to the need to reduce inequalities;
- Include in an annual report an assessment of how effectively they discharged their duty to have regard to the need to reduce inequalities
More information about meeting the equality and health inequalities legal duties can be found on the NHS England website.
Equality Delivery System2 (EDS2) including annual equality reporting
The EDS was developed as a product by the Equality and Diversity Council of the NHS Commissioning Board (now NHS England). More information about the EDS can be found on the NHS England website.
The Equality Act 2010 requires CCGs to annually publish information which demonstrates the progress they are making against Equality, Inclusion and Human Rights. EDS2/equality reports and related documents are published below:
Links to EDS2/equality Assessment Reports/Annual report 2020
Workforce Race Equality Standard (WRES)
The NHS Workforce Race Equality Standard has been in place for a number of years and places obligations on both Commissioners and Providers of services. CCGs and Provider organisations are required to publish an annual update template showing outcomes for White and BAME staff and develop action plans to address any issues that emerge. NHS Lincolnshire Clinical Commissioning Groups is also required to monitor and assure itself that those organisations providing services on its behalf have implemented the standard.
The CCG’s reporting template and action plans can be found below:
The publications of the previous organisations can be found in our Legacy page
The WRES technical guidance documents and all other WRES resources are available via the NHS England equality web page.
Workforce Disability Equality Standard (WDES)
The Workforce Disability Equality Standard (WDES) is a set of ten specific measures (metrics) that will enable NHS organisations to compare the experiences of Disabled and non-disabled staff. This information will then be used to develop a local action plan, and enable NHS organisations to demonstrate progress against the indicators of disability equality. The WDES came into force across NHS Trusts and Foundation Trusts on 1 April 2019 and is restricted to those organisations for the first two years.
The implementation of the WDES will enable NHS organisations to better understand the experiences of their disabled staff. It will support positive change for existing employees, and enable a more inclusive environment for disabled people working in the NHS. Like the Workforce Race Equality Standard on which the WDES is in part modelled, it will also allow NHS Lincolnshire CCG to identify good practice.
The WDES Technical Guidance and other resources are available via the NHS England website.
Accessible Information Standard
The Accessible Information Standard aims to make sure that people who have a disability, impairment or sensory loss get information that they can access and understand, and any communication support that they need from health and care services.
The Standard tells health and social care organisations how they should make sure that patients and service users, and their carers and parents, can access and understand the information they are given. This includes making sure that people get information in accessible formats.
The Standard also tells organisations how they should make sure that people get support from a communication professional if they need it, and about changing working practices to support effective communication.
AIS Information sheet for Providers of Health and Social Care and CCG’s