FOI – 000094 Effective use of Support Garments for parastomal Hernia (HTML)

Date received – 19 April 2022 | Date responded – 29 April 2022

Request

Could I please submit the following FOI request.

Can I remind you also that all Scottish public authorities should perform within the spirit of the legislation, in that they must always consider the obligations placed on them by FOISA to consider Section 15 of FOISA "Duty to provide advice and assistance" at all times to a person who proposes to make, or has made, a request for information.

1. The first Document that I attach is dated June 2019 and titled Effective use of Support Garments for parastomal Hernia. It states that it was ratified by the Scottish Executive Nurse Director Group. I believe that this group comes under the auspices of your NHS Scotland/Scottish Government Operation/Public Health Scotland. The contact on it is no longer employed by the NHS in Scotland. Can I find out is this Document owned by NSS Scotland? If not, can you shed light on the ownership of it?

2. Can I ask as well are the recommendations contained within it, just that recommendations or indeed Scottish Government Policy or a Policy Document from NHS Scotland. Or are they even just part of a paper on Health care?

3. Also, can I ask for a copy of the Equality Impact Assessment that would have accompanied this document?

4. On the Second Document Titled: National Stoma Quality Improvement which again says this was ratified by the Scottish Executive Nurse Director Group. Again, I believe that this group comes under the auspices of your NHS Scotland/Scottish Government Operation/Public Health Scotland. Can I check is this document is owned by NSS Scotland? If not, can you shed light on the ownership of it?

5. Can I ask as well are the recommendations contained within it, just that recommendations or indeed Scottish Government Policy or a Policy Document from NSS Scotland. Or are they even just part of a paper on Health care?

6. Also, can I ask for a copy of the Equality Impact Assessment that would have accompanied this document?

8. Can I ask what group/organisation/postholder set up the National Stoma Quality Improvement SLWG (NSQIG) Group? Can I also ask for the Terms of reference for this group. Is this group a group set up to make Government policy or is it to carry it out? Who does this group report to? Is this group charged with decision making or does it merely offer advice?

10. Can I ask for the NSS Scotland policy on involving patients and patient's groups in policy decisions directly affecting their care?

12. Can I ask for the NSS Scotland policy on involving organisations that are funded by pharmaceutical companies and lobby for pharmaceutical companies as direct members in the decision-making groups regarding health policy in Scotland?

Response

I refer to your freedom of information request that we received on 19 April 2022 requesting the following information:

I can advise you that we have now completed the search of our records and can provide you with the following information:

1. The first Document that I attach is dated June 2019 and titled Effective use of Support Garments for parastomal Hernia. It states that it was ratified by the Scottish Executive Nurse Director Group. I believe that this group comes under the auspices of your NHS Scotland/Scottish Government Operation/Public Health Scotland. The contact on it is no longer employed by the NHS in Scotland. Can I find out is this Document owned by NSS Scotland? If not, can you shed light on the ownership of it?

This document was created by the Support Garment Short Life Working group set up during the work on the National Stoma Quality Improvement Short Life Working Group (SNLQ). The SNQIG was commissioned by the NHS Scotland Executive Nurse Director Group (SEND) and established in February 2018. Ownership would then be the SNLQ.

2. Can I ask as well are the recommendations contained within it, just that recommendations or indeed Scottish Government Policy or a Policy Document from NHS Scotland. Or are they even just part of a paper on Health care?

The recommendations in the document are as stated, recommendations.

3. Also, can I ask for a copy of the Equality Impact Assessment that would have accompanied this document?

No Equality Impact Assessment was carried out for this review.

4. On the Second Document Titled: National Stoma Quality Improvement which again says this was ratified by the Scottish Executive Nurse Director Group. Again, I believe that this group comes under the auspices of your NHS Scotland/Scottish Government Operation/Public Health Scotland. Can I check is this document is owned by NSS Scotland? If not, can you shed light on the ownership of it?

In this document on page 3 under the “Document Control Sheet” section, the owner is clearly stated as:

Craig Stewart Associate Nurse Director /IJB Lead East Ayrshire Chair of National Stoma Quality Improvement SLWG

Although Craig Stewart has since retired ownership would be presumed to remain with the National Stoma Quality Improvement SLWG.

5. Can I ask as well are the recommendations contained within it, just that recommendations or indeed Scottish Government Policy or a Policy Document from NSS Scotland. Or are they even just part of a paper on Health care?

The recommendations in the document are as stated, recommendations.

6. Also, can I ask for a copy of the Equality Impact Assessment that would have accompanied this document?

No Equality Impact Assessment was carried out for this review.

7. 8. Can I ask what group/organisation/postholder set up the National Stoma Quality Improvement SLWG (NSQIG) Group? Can I also ask for the Terms of reference for this group. Is this group a group set up to make Government policy or is it to carry it out? Who does this group report to? Is this group charged with decision making or does it merely offer advice?

In this document on page 4 under the Executive Summary, it clearly states that; “The National Stoma Quality Improvement Short Life Working Group (NSQIG) was commissioned by the NHS Scotland Executive Nurse Director Group (SEND) and established in February 2018.”

The Terms of Reference are noted on Page 8 under the “NSQIG Key Objectives” section, namely:

1. Review the current product prescribing data across Health Boards and identify and develop opportunities for optimal data reporting to drive quality and efficiency.
2. Review current Health Board formularies and scope the feasibility of a National evidenced-based ostomy product formulary that could be used as an equitable and pragmatic aid to decision making.
3. Review current processes for product access identifying alternative models to GP prescribing to support timely, efficient, equitable patient product access.
4. Identify the process for measuring effectiveness of product use and patient outcomes with minimal annual patient-reported outcomes measures (PROMs) that includes patient-related feedback.
5. To review the role of e-health / assistive technology in stoma care and identify opportunities for quality improvement in patient care.
6. To explore effective partnership working with Dispensing Appliance Contractors that would support data sharing of product use and develop variance monitoring against agreed national guidance.
7. To identify clinical, financial benefits and risks from implementation of processes identified from this SLWG activity and include this in project report and action plan.

9. 10. Can I ask for the NSS Scotland policy on involving patients and patient's groups in policy decisions directly affecting their care?

I am unable to answer this question directly but note that on page 15 in the document in Section 1.6 “Stakeholder Engagement” it is stated:

1.6.4 The SSF membership has wide representation including; Community Pharmacy Scotland and stoma trade industry body representatives, Scottish Stoma Nurse Group, appliance contractors, NSS NP and an NHS Board colorectal surgeon who acts as chair of the SSF. There are also 3 patient support organisations members representing; ileostomy, colostomy and urostomy patients.

During the work of this SLWG the NHS in Scotland, including NSS was subject to: CEL 4 (2010) Informing, Engaging And Consulting People In Developing Health And Community Care Services (https://www.sehd.scot.nhs.uk/mels/CEL2010_04.pdf); and The Patient Rights (Scotland) Act 2011.

These have been updated since to PLANNING WITH PEOPLE Community engagement and participation guidance released in March 2021.

11. 12. Can I ask for the NSS Scotland policy on involving organisations that are funded by pharmaceutical companies and lobby for pharmaceutical companies as direct members in the decision-making groups regarding health policy in Scotland?

Under Section 17 of the Freedom of Information Scotland Act an organisation does not require to provide information if it does not hold that information. NHS NSS does not hold this information.

However, NHS National Services Scotland National Procurement do hold that collaboration as vital to ensure successful delivery of its activities and along with many colleagues within NHS Scotland, we worked in close partnership with suppliers to ensure that the needs of Health Boards are understood and met.

I trust you will find the information of assistance and if you require any further information please do not hesitate to contact me.

If you are unhappy with any aspect of how we have dealt with your request you can make representations to us asking us to review the handling of your request. Please get in touch with us using the following contact details within 40 working days of the date of this correspondence:

Email: nss.foi@nhs.scot

If after a review you are still unhappy, you also have the right to apply to the Scottish Information Commissioner, who can be contacted at Kinburn Castle, St Andrews, Fife, KY16 9DS, or via their online application form.

If you have any queries about this letter, please contact us at the above address.