The House of Commons Select Committee on Health recently published its report scrutinising the proposed changes in the delivery of Public Health. TCC had previously submitted its own detailed submission with an emphasis on the issue of behaviour and culture change – a summary of which was covered in a previous posting here.
Whilst there seems to be broad public consensus for the Government’s public health proposals, in contrast to the controversy surrounding other NHS changes, nevertheless, the Select Committee made a number of practical recommendations for improvements:
- The Secretary of State for Health to be given (under the Health and Social Care Bill) an explicit statutory duty to reduce inequalities in public health as well as to protect the public from dangers to health.
- The Department of Health should set public health budgets, both nationally and locally, that take account of objective measures of need.
- The Cabinet Sub-Committee on Public Health to be given a clear remit to scrutinise the public health impact of policies across government.
- The Chief Medical Officer to give professional leadership in respect of both the medical and public health professions.
- The Government to review its opposition to the proposal that the Health Professions Council should regulate public health specialists as an additional profession, to accommodate specialists who are not members of another regulated healthcare profession.
- The role of the Public Health Interventions Advisory Committee of the National Institute for Health and Clinical Excellence to be clarified
Public Health England
- MP’s argued that Public Health England (PHE) must be a fearlessly independent champion of public health standards and objectives. There is also the need for more clarity about who will be in charge in a public health emergency – such as a flu pandemic.
- Public Health England must also be given a clear leadership and coordination role for developing – and when necessary – delivering ‘surge capacity’ at the supra-local level where public health emergencies cross local boundaries.
- The work of the Public Health Observatories is valuable part of the public health system. MP’s expressed concern that three of these – in London, the North East and the North West – might be at risk of closure. They asked Ministers to clarify their plans for all the Observatories as a matter of urgency to ensure that this important resource is not lost before PHE is established.
Local Government and Public Health
- Just as PHE needs to be visibly independent of central government, MP’s strongly recommended that the director of public health in each locality needs to be a chief officer of the local authority with a statutory duty to address the full public health agenda within the locality.
- Directors of Public Health should also be members of the Board for each Clinical Commissioning Group and for a qualified public health professional to sit on the NHS Commissioning Board.
In terms of behavioural interventions, the Committee made two further important points. On the Public Health Responsibility Deal it expressed some scepticism:
“With regard to the national policy dimension of health improvement, we remain unconvinced that the new Responsibility Deal will, by itself, resolve major issues such as obesity and alcohol abuse. The Government must set out clearly how progress will be monitored, and when tougher action will be taken if ‘nudging’ does not work.
This comment was in a similar vein to the House of Lords Science and Technology Committee report on Behaviour Change which we previously blogged about here. We have also previously suggested some changes to this to encourage business to engage at a much more local level.
The other concern expressed by the Committee was on the Health Premium, where it asked the fundamental question as to how one balances the need to target the most difficult public health challenges if incentives are then given to the areas that make the most progress, which may not be the objectively worst areas?
“We are concerned about the so-called ‘Health Premium’. The effect of this policy appears to be to target resources towards those areas which have made greatest progress with their public health challenges and away from areas which face the greatest outstanding problems. It is, of course, not only a question of the level of resources, but also of the use to which they are put; but if resources are not being used well in the areas of greatest challenge, the solution is to improve the way the resources are used, not to cut the resources”.
We know from our use of values segmentation to understand varying motivational needs that some segments of the population are more likely to respond to pro-social public health messages and behavioural interventions, so the danger is that some areas could always be the winners under incentives for maximum progress. Clearly the Premium is going to have to be much more sophisticated than that!
Hopefully the Government will clarify policy in these areas further. It would be a disappointing if such an important area of public policy with such a wide consensus so far was mired in political controversy.