Legislative Changes affecting
Ambulance Services in WalesWelsh Government
Consultation – Summary of Responses
Digital ISBN 978 1 4734 1031 2 © Crown copyright 2014 WG21186
Part 1 – Introduction 2.
Part 2 – The Consultation 5.
Part 3 – Responses: Main Consultation 6.
Part 4 – Concluding Remarks and Next Steps 12.
The Minister for Health and Social Services decided in July 2013 to implement an Ambulance Reform Programme following the publication of the ‘Strategic Review of Welsh Ambulance Services’ authored by Professor Siobhan McClelland.
The Review made a number of recommendations to inform the delivery of outstanding ambulance services in Wales.
The McClelland Review stated that current accountability, governance and funding
arrangements for ambulance services were complex and ineffective, and recommended maintaining the current arrangements should not be viewed as a viable option.
Under existing arrangements, the Welsh Government pays Local Health Boards a block grant each financial year for the provision of NHS services to patients, and the Welsh Ambulance Services NHS Trust receives its funding for emergency ambulance services from Local Health Boards.
Local Health Boards currently plan and commission emergency ambulance services through the Welsh Health Specialised Services Committee (WHSSC), which is currently legally responsible for exercising the functions of planning and securing high volume emergency ambulance services on their behalf for the people of Wales.
WHSSC also has responsibility for ensuring that the population of Wales has fair and equitable access to the full range of specialised services. This includes planning and
commissioning a significant number (in excess of 60) of low volume services (such as fertility services, treatment of skin conditions and breast surgery).
The McClelland Review stated that the existing arrangements for emergency ambulance services required strategic commissioning but the mechanics and levers for achieving this, such as service specifications, Service Level Agreements (SLAs) and contract management, were not being used, and proposed a different approach which is set out overleaf.
“The Review found a fundamental problem with the current accountability and governance arrangements for ambulance services in Wales which are multiple, complex and lacking in clarity and transparency.
This needs to be addressed to create arrangements which are simple, clear and aligned to the agreed vision for service delivery.” McClelland Strategic Review of Welsh Ambulance Services (2013).
Changes to Planning and Commissioning
A change was proposed because of the longstanding problems the previous accountability, funding and governance arrangements had caused the delivery of ambulance services. Professor McClelland acknowledged there was no ‘magic bullet’ to resolve these issues, although recommended the Minister for Health and Social Services consider implementing a national commissioning model as one of three potential models for improving
accountability, funding and governance arrangements.
The Minister for Health and Social Services agreed that a national commissioning model for emergency ambulance services with a commissioner and provider relationship supported by
a Chief Ambulance Services Commissioner,
represented the necessary change for a more robust and transparent way of planning emergency
The Minister’s intended approach is to establish a national Emergency Ambulance Services Committee that is specifically tasked with providing greater clarity on responsibilities; to address non-alignment of current accountability, funding and governance
arrangements; and to develop a robust commissioning framework overseen by an experienced Chief
Ambulance Services Commissioner.
A Clinical Vision for Emergency Ambulance Services
Additionally, the McClelland Review recommended that a clear vision was required for ambulance services, and that they should play a key role in the shaping of future models of service delivery.
The Review also suggested there is a need for a skilled workforce to make appropriate decisions and that there is a general consensus that the development of a clinical service requires an up skilled workforce with greater levels of autonomy and clinical decision making.
Clear recommendations were made for the development of alternative care pathways which enabled Trust staff with greater clinical skills to refer patients who do not need to be admitted to hospital to other healthcare settings in the community – or even to be treated at home on a face-to-face level by paramedics with advanced skills, or through telephony advice.
“The vision for Emergency Medical Services (EMS) - that is emergency ambulance response services - is for the delivery of a robust, clinical service that is a fundamental and embedded component of the wider unscheduled care system.” McClelland Strategic Review of Welsh Ambulance Services (2013).
4 It was also proposed that the workforce require a high level of clinical understanding,
support and leadership from within the ambulance service and from other clinicians working in unscheduled and primary care.
To support this clinical transformation, the Minister for Health and Social Services proposed renaming the Welsh Ambulance Services NHS Trust to reflect the delivery of a new clinical vision for emergency ambulance services in Wales, and the greater role they will play as a key part of the unscheduled care system.
In summary, the public consultation was launched to give an opportunity to the appropriate stakeholders and the public to give their views on the following four proposed changes:
I. an amendment to the Welsh Health Specialised Services Committee (Wales) Directions to remove the Committee’s responsibility for commissioning emergency ambulance services;
II. making of ‘Directions’ which will see Welsh Ministers directing Local Health Boards to establish a new joint committee – the Emergency Ambulance Services Committee - which would be responsible for the planning and commissioning of emergency ambulance services only;
III. making of the Emergency Ambulance Services Committee (Wales) Regulations 2014 which would govern the membership and proceedings of the Emergency Ambulance Services Committee. The membership would include a Chief Ambulance Services Commissioner employed by Cwm Taf LHB as the host body of the joint committee responsible for commissioning emergency ambulance services, monitoring WAST’s performance against national standards and taking action where adherence to a national commissioning framework is not achieved; and
IV. a proposed name change from the Welsh Ambulance Services NHS Trust to the Welsh Emergency and Clinical Services NHS Trust, intended to reflect the transition to a clinically driven service offered by the Trust.
The eight week consultation was launched on 19 December 2013 and concluded on 13 February 2014. Five questions were set out in a separate proforma-style response form as part of the consultation document which was published online on the Welsh Government website. Letters were sent to all Local Health Boards, NHS Trusts and Community Health Councils to alert them of the commencement of the consultation.
A copy of the consultation document can be accessed at:
We received 62 responses to the consultation. The full list of respondents / organisations is shown in Part 5 although it should be noted that some respondents wished to remain anonymous. Welsh Government officials made themselves available for meetings, forums and phone calls although no stakeholders or organisations contacted the consultation team for a briefing.
This document summarises the responses to the consultation questions and other evidence submitted related to the subject matter of the consultation. The aim of the document is to give an overview of the responses and to highlight the common themes and suggestions put forward. The quality of response was considerable, and many respondents went into great detail, and it would be difficult to reflect the full range of issues and suggestions raised. This document can only provide a summary of the responses.
However, all responses will act as valuable and informative tools for the Welsh Government and NHS Wales in delivering the Ambulance Reform Programme, and ultimately developing a world class ambulance service. The responses could also prove a useful resource for the development of policies and strategies by the Welsh Government, Welsh Ambulance Services NHS Trust and other organisations.
The Consultation Summary of Responses is set out in section three which includes responses given against the five questions featured in the consultation document
Responses: Main Consultation
In total, we received 62 responses to the consultation. The 62 respondents can be categorised as follows:
Member of the NHS staff 18
Members of the public 15
Organisation with an interest in the health service 22
Support organisation 2
Legal organisation 0
An analysis of the responses to this consultation is set out in the following pages.
Overview of Consultation Responses
The consultation document asked five specific questions on the proposals. Unless stated otherwise, throughout this report percentages are expressed as a measure of all
respondents. All such percentages have been rounded up or down to the nearest whole number.
Q1. Do you agree with the Welsh Government amending the Welsh Health Specialised Services Committee (Wales) Directions 2009 to remove the responsibility for
commissioning ambulance services away from the Welsh Health Specialised Services Committee?
From 62 responses, 31 of those agreed with the proposal, whilst 6 did not agree, and 25 neither agreed nor disagreed. This means that 50% of respondents agreed and 10% disagreed with this proposal.
Chart 1. Question 1: Amendment of the WHSSC Directions 2009
Within the responses to this question, five were from Health Boards, all of whom agreed with the proposal. There was broad and general support for the Committee with limited opposition.
Comments from respondents who disagreed with this proposal suggested that there should be LHB representation on the Committee with the final decisions being made by the
Ambulance Service. Concerns were also express about the potential loss of specialist commissioning knowledge available within WHSSC.
Many respondents chose not to comment on this proposal.
Q2. Do you agree that LHBs should establish a new joint committee for commissioning emergency ambulance services (i.e. the Emergency Ambulance Services Committee) to jointly exercise the function of commissioning emergency ambulance services? Do you have any comments on the Directions or Regulations?
From 62 responses, 31 of those agreed with the proposal, whilst 9 did not agree, and 22 neither agreed nor disagreed. This means that 50% of respondents agreed and 15% disagreed with this proposal.
Agree Disagree No opinion
Directions to the seven LHBs to Establish a new Joint Committee and Regulations to govern the membership and proceedings of the Committee
Chart 2. Question 2: Establishment of the joint Emergency Ambulance Services Committee
Within the responses to this question, five were from Health Boards. Of these four agreed with the proposal and one disagreed.
The proposal for establishing a Committee solely responsible for commissioning and
planning emergency ambulance services was broadly welcomed. There was support for the appointment of a Chief Ambulance Services Commissioner, and a commissioner / provider relationship between LHBs and the Welsh Ambulance Service Trust.
A number of respondents welcomed the particular focus on optimising the clinical contribution of ambulance services, embedded as a key part of the overall delivery of unscheduled care as a positive step.
There was also agreement that the re-definition of responsibilities for governance should provide greater clarity regarding the individual and shared responsibilities between Local Health Boards and the ambulance Trust.
Cardiff and Vale University Health Board disagreed with establishing a new joint committee. Concerns were raised about whether this option would address the current challenges facing the ambulance service, and whether it would be too challenging for LHBs to identify the additional resources required to support the role of the all-Wales committee from within existing funds.
Many respondents chose not to provide comments on this proposal.
Q3. Do you agree with the proposal set out in this document regarding the re-naming of the Welsh Ambulance Services NHS Trust?
From 62 responses, 18 of those agreed with the proposal, whilst 32 did not agree, and 12 neither agreed nor disagreed.
Chart 3. Question 3 (Proposal to rename the Welsh Ambulance Services NHS Trust)
This means that 29% of respondents agreed and 52% disagreed with this proposal. Within the responses to this question, five were from Health Boards. Of these three agreed with the proposal to rename the Trust and one disagreed. Comments in support included that the current title does not reflect fully the new function for the all-Wales ambulance service. Hywel Dda and Aneurin Bevan Health Boards disagreed with renaming the Welsh
Ambulance Services NHS Trust. Their concerns were that renaming the organisation will potentially add more confusion for the public not less.
Most respondents took the opportunity to voice their concerns that the removal of the word ‘ambulance’ will confuse the public and will not be consistent with the rest of the UK. Every respondent that did not agree expressed concern about the cost involved with renaming the Trust.
Agree Disagree No opinion
Amending the WAST Establishment Order to Rename the Welsh Ambulance Services NHS Trust
10 All Health Boards agreed that if the name is to change, it should reflect the core functions and responsibilities of the organisation.
Q4. Do you agree with the proposed name for the ambulance service model in Wales? Does ‘Welsh Emergency and Clinical Services NHS Trust’ clearly reflect a service which will deliver clinical and emergency ambulance services?
Of 62 responses, 11 agreed with the proposal; 38 did not agree; and 13 neither agreed nor disagreed.
Chart 4. Question 4 (Proposal to Rename the Welsh Ambulance Services NHS Trust the Welsh Emergency and Clinical Services NHS Trust
This means that 18% of respondents agreed and 61% disagreed with this proposal. Within the responses to this question, five were from Health Boards and all disagreed with the proposal. Concerns were expressed that a name which doesn’t include the word
‘ambulance’ will be hugely misleading to the public, and that the proposed name does not clearly convey to the public what services it provides, thus confusing the service with other areas of NHS care. The Welsh Ambulance Services NHS Trust did not give an opinion on the proposed name.
Q5. We have asked a specific question. If you have any related issues which we have not specifically addressed, please use the space below to report them:
Of the 62 respondents, 31 (50%) took the opportunity to raise further issues. Although some of the issues raised were outside the scope of this consultation, many discussing their own experiences when accessing ambulance services, other suggestions included:
The necessity for a consultation on the transfer of non-emergency patient transport;
11 That Motor Cycle Paramedics should be introduced especially in rural areas to ensure that someone is at the scene as early as possible; and
Disappointment that the only mention of nurses is in relation to undertaking triage over the phone. They would like to see further use of advanced nursing roles as a way of aiding clinical diagnosis. Further feedback is available on request.
Concluding Remarks and Next Steps
We are grateful to everyone for their contributions. The variety of comments and suggestions and the significant number of responses has been encouraging and
demonstrates the importance placed on developing a world class ambulance service among public and stakeholders alike. Although we have been unable to include all of the comments and suggestions in this Report they have all been considered and appreciated.
The response findings highlighted strong support for removal of the responsibility for commissioning emergency ambulance services from the Welsh Health Specialised Services Committee, with only 10% of respondents disagreeing that this should take place.
There was similar support for directing Local Health Boards to establish an Emergency Ambulance Services Committee to carry out the specific function of planning and commissioning emergency ambulances services for Welsh residents. Only 15% of respondents disagreed that Health Boards should work collaboratively to plan and commission emergency ambulance services on a national level - albeit with an additional focus on local challenges.
There was broad support for the recruitment of a Chief Ambulance Services Commissioner to hold the ambulance Trust to account for the delivery of agreed national standards for emergency ambulances, and work diligently with Local Health Boards to ensure the ambulance Trust has the necessary funding to deliver safe, effective and timely services. In view of wide ranging support for these proposals, we intend to:
amend the Welsh Health Specialised Service s Committee (Wales) Directions 2009 to remove the function of commissioning emergency ambulance services from that Committee; and
direct Local Health Boards to establish the new joint Emergency Ambulance Services Committee and lay the Regulations which make provision for its membership and proceedings. The necessary Directions and Regulations will come into force on 1 April 2014.
The majority of respondents indicated that they disagreed with any proposal to rename the Trust and 61% of respondents objected to the proposed name (the Welsh Emergency and Clinical Services Trust). It was clear that there were general concerns about the proposal to rename the Welsh Ambulance Services NHS Trust.
Many respondents highlighted the necessity for maintaining the term ‘ambulance’ in the Trust’s name and others expressed concerns about potential confusion among the public. Although the intention was to change vehicles, uniforms, stationery and other Trust
13 paraphernalia as and when required, making any renaming exercise cost free, there were also concerns about the financial implications of name change.
It was also widely acknowledged that while the Trust may benefit from a name that provides greater context to the range of clinical services it delivers, identifying a suitable name is not without complexity. In view of the high interest, the range of alternative names put forward, together with the ongoing work into the non-emergency patient transport services the ambulance service will deliver, we will ask the Emergency Ambulance Services Committee to work with the Trust and other relevant stakeholders to determine whether there is a more suitable name that clearly conveys the Trust’s clinical transformation. The Committee will be asked to provide further advice to the Minister for Health and Social Services for
consideration regarding the renaming of the Trust by the autumn 2014. In the meantime we intend to keep the name Welsh Ambulance Services NHS Trust.
Following the publication of this consultation summary, we will undertake the necessary legislative arrangements to allow the Emergency Ambulance Services Committee to come into force by 1 April 2014.
Part 5 – List of Respondents
NHS Staff (29%) 18 respondents
Members of the public (24%) 15 respondents
Organisation with an interest in the health service (35%)
Abercarn Community First Responders Aneurin Bevan University Health Board Betsi Cadwaladr UHB
BMA Cymru Wales
Cardiff and Vale University Health Board Care Forum Wales
Conwy Local Committee, North Wales Community Health Council
Cwm Taf Health Board Flintshire County Council Health Inspectorate Wales Hywel Dda Health Board Montgomery CHC
Montgomeryshire MS Society RCN Wales
Royal College of Physicians (Wales) The Patients Association
The Welsh NHS Confederation UNISON Cymru Wales
15 Welsh Ambulance Services NHS Trust
Welsh Health Specialised Services Committee Welsh Medical Committee
Welshpool Town Council
Support organisation (3%)
Torfaen Voluntary Alliance
(N.B. In addition to the above respondents there were five (8%) who wished to remain anonymous.)