In its response to a call for evidence launched by the Department of Health and Social Care (DHSC) on the impact of local authority public health prescribed activity, FSRH called on DHSC to strengthen the SRH mandate by improving its guiding principles, amending the regulations and enhancing accountability.
It is now over four years since public health duties transferred back to local authorities (LAs). The 2012 Health & Social Care Act allows the Secretary of State (SoS) to make regulations requiring LAs to take particular steps to improve or protect health – what is called ‘prescribed’ activity. Through this consultation, the Government wants to take stock of whether the current arrangements set out in the regulations will be fit for purpose in the future. The Department wants to gather evidence on the impact of these regulations have had in practice.
This consultation is particularly relevant given the announcement in December 2017 that the Government intends to replace the ring-fenced public health grant with local authorities’ own business rates retention funding from 2020.
When it comes to SRH, LAs’ prescribed activity functions outlined in the regulations concern the provision of contraceptive services, including ensuring access and the provision of advice on contraceptive methods, unplanned pregnancies and preliminary information on sterilisation and vasectomy. The regulations also specify that LAs should provide care for sexually transmitted infections (STIs), including partner notification.
FSRH called on DHSC to strengthen the SRH mandate by improving the principles that guide the mandate and amending the regulations. Our main recommendations are as follows:
- To amend the guiding principles so that it is clear that it is sexual and reproductive healthcare services that must be open access and available to all
- FSRH believes much remains to be done to tackle regional inequalities and guarantee full access to contraception, including emergency contraception.
- FSRH encourages DHSC to take into account the principles of FSRH’s Vision as guidelines for the delivery of high-quality SRH care that is not compromised by cuts and the politicisation of the SRH mandate at LA level.
- SRH services must be delivered by LAs in accordance with nationally recognised standards in SRH such as FSRH and BASHH standards, guaranteeing high-quality SRH care and patient safety. Strengthening LAs mandate on prescribed SRH activity requires mainstreaming standards of care at LA level, and FSRH would like to see DHSC and PHE collaborate on this matter.
- To amend the regulations so that it includes advice on, and confidential, open access to the full range of contraceptive methods available in the UK and access to specialist SRH services according to recommendations set out in nationally recognised standards in sexual and reproductive healthcare such as FSRH and BASHH standards instead of ‘reasonable access’ to a ‘broad range’ of contraceptive methods as is currently specified by the regulations
- LAs and CCGs must work collaboratively to support positive health outcomes, and DHSC must ensure that this joint working happens in practice.
- FSRH believes PHE should have stronger enforcement powers to enable the agency to act on the findings and analyses it produces and to hold LAs and commissioners to account for their performance, developing more stringent accountability structures with LAs.
- Existing accountability mechanisms must be enhanced, enabling the SoS to hold local authorities to account in their devolved delivery of his public health responsibilities
You can download FSRH’s response, which includes a complete summary of recommendations, below.