Response to the Draft National Care Standards Third Tranche � Services for Adults Draft National Care Standards for Day Care (Support) Services Introduction and Background Since 1988 NSF (Scotland) has been managing a growing number of day services for people affected by mental illness, and for carers and families, in different parts of Scotland. These now comprise: 13 Drop-in Centres; 9 part-time Drop-ins usually based in other organisations premises; 4 Outreach services; 4 employment support and training projects; 2 counselling services; 8 carers support and information services; individual projects providing befriending, support for voice hearers and a telephone support and information service. The projects are all independent but work in close association with other local mental health services. Use of the services is entirely voluntary, with only a very small number of service users including attendance at any of our projects in their Care Plans. The geographical dispersal of projects is from Golspie in the north-east to Stranraer in the south-west. Nearly all the projects are funded through Mental Illness Specific Grant, which has had only one financial increase in the past seven years. Small amounts of funding are received from other statutory sources (e.g. NHS, Social Work Departments). Some local projects, particularly in rural areas, have only one staff member. General Comments NSF (Scotland) broadly welcomes the intention to establish national care standards. We particularly commend the effort to transfer vision and values into achievable standards. This coincides with the values and purpose of the NSF (Scotland) mission. We are quite sure, however, that achieving the standards for many existing service providers will only be possible with additional resources and revenue funding. From a presentational perspective the standards are well set out. The preamble to the Day Care (Support) Services states that in 1999 there were 17 "traditional" Mental Health Day Care Centres in Scotland, but there is no explanation of what a traditional centre is, nor any acknowledgement that there are different models of day care in existence. It leaves open the question to what type of service are these standards to apply? As noted in the Introduction above, NSF (Scotland) alone manages 13 Drop-In Centres for people affected by mental illness, none of which are included in the Scottish Community Care Statistics. As one of our managers succinctly put it when referring to the draft standards, "Do they mean us?" The preamble also states that "there is a view that day service provision encourages dependency�", again without acknowledging the different models of day care that exist, nor backing up this "view" with any evidence. NSF (Scotland) does not dispute that such a view exists, but it would have been helpful had the preamble elaborated on this point and given examples of the type of establishment or models of day care that encourage dependency. We believe it is important to recognise the need to reconcile achieved outcomes of a service (p 52) with levels of service user satisfaction. In our experience the two do not necessarily go hand in hand, and where we have conducted user led evaluations of services, the criteria for evaluation defined by service users have differed significantly from established outcome measures. The frequent reference to a person centred approach needs to be clarified, particularly when it stands alongside a stated aim of day care as being "seeking to integrate people who use support services with other members of the community by�" It seems a little ironic to have such a concrete agenda while at the same time describing a service as being person centred. We believe that reconsideration should be given to having the same standards applied to widely different groups of service users. For example the concept of life plans has a logic and purpose that is commendable. However it is our experience of care planning that comprehensive and lengthy care planning procedures can sometimes feel difficult and intrusive for mental health service users, and can lead to them avoiding services, which defeats the purpose of the exercise. The description of the life plan seems very institutional compared to models of self assessment and self directed care planning. When considering the application of many of the standards to our existing day services (e.g. premises and compliance with the DDA, eating well and service users being offered a menu that reflects their preferences), these appear quite unrealistic and unattainable without considerable additional resources. As it states on page 56 that "the SCRC will use the standards to decide whether to register a support service", the implication for us is that some of our services will not comply with the standards as they stand. Is it being proposed that lead-in periods will be available to assist organisations acquire the extra resources they will need to comply with the standards. Many of the standards do not fit comfortably with the principles and practices of mental health drop-in centres, particularly in relation to assessment and record keeping. There will also be practical difficulties for many providers to supply the lockable space for records and for service users belongings (Standard 13). Specific Points and Queries (For details of which parts of the Draft Standards the following passages refer to, see www.scotland.gov.uk/government/rcp. Standard 1 It would be helpful to include something within this standard about an individuals right to choose whether they wish to use a service or not, and to be able to change their mind about using a service (although Standard 16 does touch on this). The standard will also have to address the situation of service users who are under Community Care Orders. Many organisations will struggle to provide information in the many different languages that exist in the local community without the guarantee of additional resources. And in any case does this standard mean much if services do not additionally have access to interpreters or multi-lingual staff? The standard makes no reference to presenting information in appropriate ways for people with sensory impairment (although this too would have to be funded from somewhere). Standard 2 This standard will amount to a large increase in the amount of paperwork for providers, and will not sit comfortably with those services that adopt an informal, open door policy. Clarification is required to explain what the relevant qualifications of staff are/should be. Standard 3 All of the components of this standard are laudable and desirable, but they are simply unaffordable for many providers. This standard should certainly apply to new services, but without additional help existing services will not be able to comply. A realistic time-scale for implementation would be helpful. Standard 4 Good. Standard 5 Most of the comments with regard to this standard have been made under the General Comments above. Clarification on the mix of skills within the staff group would be helpful, particularly where the staff group may consist of only one or two staff. It would also be helpful if this standard made reference to confidentiality. Standard 6 Good. Standard 7 Access to trained independent advocates and expert advice on welfare benefits can be very difficult for small, rural projects. We know, we already have this problem. Standard 8 Item 12 needs to be clarified because as it stands it appears to be a licence for bullies. Services will have ground rules and contracts (as per Standards 1 and 2) that will normally refer to unacceptable behaviour. This item is ridiculous. Standard 9 Good. Standard 10 Very laudable to put so much emphasis on choice, preferences and nutrition, but the implementation is likely to have resource implications. The catering side of our existing projects is under pressure for financial reasons to minimise waste. Increasing choice inevitably leads to more waste. Standard 11 Good although not particularly relevant to mental health services. Standard 12 Good. Standard 13 Good, but lockable space may be a significant practical problem. Standard 14 Good. Standard 15 Here are again cost implications in being able to comply with this standard. Standards 16, 17 & 18 All very laudable but not very meaningful if the external resources to meet these standards are not in place, and for rural projects that is generally the case.

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