Consultation Responses 2013-14
Response to 'Freedom to Speak Up' review (September 2014)
In this response we outline our views on the procedures and culture needed to support workers raising concerns in the NHS. We also propose ideas on what would help to create an open and honest reporting culture in the NHS.
Response to CQC provider guidance on duty of candour (August 2014)
We are pleased the CQC intend to take a proportionate response to enforcing the duty of candour regulations.
Payment systems including the national tariff have incentivised access to treatment, driving down waiting times. Continuing to refine and improve these systems is welcome. We have also encouraged individual surgical and dental specialty associations to respond directly to relevant best practice tariffs and new
The RCS welcomes the majority of the recommendations and proposals in the review of the IPFR process. However, we would like to see better coordination among Health Boards, the Welsh Health Specialised Services Committee and Welsh Government and a more joined-up approach to the IPFR process in order to contribute to improved outcomes for patients.
The RCS believes HEE needs to be more transparent about the progress of its projects and work programme. It also needs to improve its engagement with providers of education and training, providing more transparency about how the commissioning of courses will work in practice.
The Royal College of Surgeons fully supports the signficiant changes that the CQC is making.
The RCS supports the introduction of a statutory of candour. However, we suggest that the terminology must be clearer so that the duty can be easily understood by patients, organisations and their staff.
Department of Health consultation on wilful neglect (March 2014)
The RCS supports a new criminal offence for wilful neglect applicable to the NHS and private healthcare.
The College supports the need to publish fundamental standards of care and we broadly support the standards published by the Department of Health. However, we also suggest a standard around the quality of communication.
This document sets out the College's views on NHS England's draft Research and Development Strategy. We welcome this strategy, while urging NHS England and its partners to address the underfunding of surgical research and to ensure that every patient who needs to is able to access new and existing medicines and treatments.
In this response, the College outlines its support for the principle of integrating health and social care. However, it urges the government to also think carefully about the implications for financial planning.
This document details the views of the College, having consulted with presidents and audit leads from the Surgical Specialty Associations, and considers areas for improvement following the first publication of data.
Department of Health consultation on 'Refreshing the Mandate to NHS England: 2014-15', September 2013
This document sets out the College's views on the Mandate to NHS England for 2014-15. We welcome the Department's intention to carry forward all the objectives in the current Mandate, while proposing a number of other points which we feel should be reflected.
NHS Hospital Data and Datasets, September 2013
The College responds to this NHS England and Health and Social Care Information Centre consultation exploring how better extraction of information from hospitals' data systems could help raise standards, improve safety and reduce inequalities in patient care.
Commission on Public Service Governance and Delivery in Wales, August 2013
In this submission to Wales' Commission on Public Service Governance and Delivery, we set out our views on: the inspection model for health services; how to improve governance through transparency about outcomes; and the culture and leadership of the health service, including clinical governance.
In this submission, we suggest that the CQC's new proposals provide the organisation with an opportunity not just to identify and eradicate poor care, but to promote and improve the quality of care.
Monitor and NHS England consultation on the NHS payment system, July 2013
This submission sets out a number of guiding principles which we believe should be used in developing a payments system.
Monitor consultation on draft guidance for commissioners procuring patient services, July 2013
In this submission, we support much of the guidance clarifying how current EU and UK procurement regulations apply to the NHS. Without which, sensitive decisions about the future of NHS services would be more frequently decided by law courts rather than allowing intervention by Monitor, a regulator with specialist healthcare expertise.
EU Cross-border Healthcare and patient mobility, May 2013
In this submission, the College advises the Department of Health of concerns about the implementation of the rights of patients seeking healthcare across national borders, and considers the effect this will have on the NHS.
Silk Commission, Call For Evidence, Wales, March 2013
Addressing the issues of devolution in Wales, this submission focuses on the impact of devolution on the provision of healthcare and makes recommendations to improve NHS performance.
EU balance of competences review, February 2013
This submission to the Government's EU balance of competences review highlights the College's position on a number of EU rules and regulations affecting medical professionals.
NICE consultation on potential new indicators for the 2014/15 Clinical Commissioning Group Outcomes Indicator Set, February 2013
In this submission, we stress the importance of involvement with professional bodies, and highlight the College's ongoing work with the Surgical Specialty Associations creating clinicial commissioning guidance.
The revision of European legislation on medical devices, January 2013
In this submission, we set out our position on the European Commission’s proposals for new regulation of medical devices, supporting increased scrutiny of high risk devices, harmonisation of regulatory standards across the EU, and the establishment of a new central European medical device database to improve transparency. Medical implants and devices have brought significant benefits to patients, and therefore continual innovation in this field must be encouraged and facilitated. This should not however happen at the expense of patient safety.
A consultation on strengthening the NHS Constitution, January 2013
The NHS Constitution provides a framework that defines the values which underpin the NHS, sets out what patients should expect from the NHS, and establishes the responsibilities and duties of healthcare professionals. Responding to a Department of health proposals to strengthen this Constitution, the College supports the aim to promote a patient centred approach to care with measures to increase the integration of care across the NHS being vital.