I thank members for inviting us here today. The IASLT welcomes this invitation by the Oireachtas Joint Committee on Health to address concerns about the HSE's standard operating procedures on the assessment of need. Our colleagues from the PSI and the Association of Occupational Therapists Ireland, AOTI, along with the parent group, DCA Warriors, addressed the committee earlier this year on 27 June. I thank the members for meeting us today and giving us the opportunity to meet them.
The IASLT is the recognised professional association of speech and language therapists, SLTs, in Ireland. It provides up-to-date information for the public to aid in the understanding of speech, language and communication needs, as well as that of feeding, eating, drinking and swallowing disorders. Some of its aims include: establishment and maintenance of professional standards in SLT practice within Ireland; evaluating, accrediting and monitoring of speech and language therapy training courses in Irish universities; representing the profession at national and international level; supporting continuing professional development through education and research; and co-ordinating the gathering and dissemination of relevant information to promote the exchange of professional information.
As the committee heard, my name is Vickie Kirkpatrick and I am the chairperson of IASLT. I am joined by long-standing IASLT full member, Ms Deirdre Kenny. We are delighted to have this opportunity to speak to the committee about the concerns of our members and the risks the assessment of need, AON, standard operating procedure, SOP, poses to the children and families we support. Having recently reviewed the transcript and video of our health and social care professional colleagues' presentations in June, the IASLT wishes to echo many of the concerns presented and expand on those specific to SLTs.
First and foremost is consultation. Concern was raised by our members about the absence of formal consultation. While 8 September 2017 is reported as the date of the HSE consultation on the AON SOP, members have reported that notice of this meeting was poorly communicated. The short notice meant that front-line clinicians who had pre-arranged appointments and front-line obligations could not attend. Furthermore, the IASLT never received formal invitation to this meeting, nor has it received a copy of the AON SOP to date. Information on the AON SOP came to the IASLT's attention via our own members.
The lack of consultation with SLTs is further evidenced by the inadequate definition of communication in the SOP. SLTs hold expertise in speech, language and communication needs, and absence of a proper definition poses risks to the identification of such needs. Further consultation could be considered through partnership with the HSE's own health and social care professional, HSCP, office, which co-ordinates many working groups with representation from various health and social care professionals, including SLTs who represent the IASLT. They work collaboratively with stakeholders to facilitate a unified voice for health and social care professionals. One of the office's key aims is the co-ordination of HSCP input to design, plan and implement strategy within the HSE. Collaboration between the HSE disability operations and the HSCP's offices would ensure appropriate governance, terms of reference and operational recommendations are in place.
The IASLT welcomes the plan for progressing disability services and recognises the need for standardisation of assessment of need. Appropriate consultation and collaboration are vital, however, for appropriate and effective change management to ensure the best outcomes for the children and families we support.
The need for resources - those being human, infrastructure and IT - to support the implementation of the national programme entitled Progressing Disability Services for Children and Young People was widely discussed at the committee's previous meeting. We welcomed the acknowledgement by Dr. Morgan that disability services have been under-resourced and are hopeful that the 100 posts announced in the recent budget are part of a multi-year programme of investment. As previously mentioned by our colleagues in the Association of Occupational Therapists of Ireland, AOTI, chapter 9 of A National Model of Care for Paediatric Healthcare Services in Ireland outlines the need for detailed workforce planning for health and social care professionals at primary, secondary and tertiary care level. The operation of this standing operating procedure is challenged by these resource issues across both social and primary care.
One key challenge to speech and language therapist, SLT, staffing is the length of time it currently takes to replace vacancies. It can take six to eight months from one staff member walking out the door to a replacement SLT arriving. Experienced, knowledgeable staff members who avail of promotional opportunities are often replaced with less experienced staff who need more time to upskill in the clinical area and join the new team. The new clinician may not have been trained up in some of the assessments required to determine the presence of a disability. The standard operating procedure as outlined cannot work without a properly trained team with the necessary skill mix.
We know from talking to the families we work with that they want the right care for their child in the right place and at the right time. If children could access the intervention services they need in a timely fashion there would be a reduced number requesting assessments under the Disability Act and the need for this standard operating procedure would be greatly reduced.
Margaret Lennon of DCA Warriors identified the need for Irish data on the numbers of children presenting with disability. If we are to adequately meet the needs of children and families we need to collect information on prevalence and incidence of disability and its subtypes in Ireland.
As to best practice guidelines, Irish Association of Speech & Language Therapists, IASLT, members are bound by the IASLT code of professional conduct and ethics of 2015. As practitioners in the Republic of Ireland, speech and language therapists must hold registration with the Health and Social Care Professionals Council, CORU, under the Health and Social Care Professional Act of 2005. The assessment of need standard operating procedure is in breach of the following sections of the code - to "act within the best interest of the service user"; and "a member shall also appropriately address concerns regarding policies, working conditions, actions or inactions of others which compromise the care of service users or public safety". For speech and language therapists, as with other health and social care professionals, assessment is a dynamic and ongoing process whereby clinicians rely on their training and experience to assist parents in setting goals to meet the child and families’ needs. The preliminary team assessment as outlined in the standard operating procedure is in many ways a breach of this. In many instances a complete diagnostic assessment is required to ensure appropriate differential diagnosis. Differential diagnosis is essential for clinicians to make recommendations regarding appropriate pathways of intervention. Without complete diagnostic assessments, children and families will be unable to access additional services such as home tuition, autism spectrum disorder, ASD, special classes, or other specialist placements. Such recommendations are not possible without comprehensive diagnostic assessment. The standard operating procedure will result in delays in accessing appropriate interventions as well as accessing the most suitable educational placement, thus placing additional stress on the families.
Finally, the code of professional conduct and ethics further states that "members should take any time necessary to sensitively communicate their decision/s with the service user and family members, in the context of the constraints of confidentiality". The standard operating procedure is intended “to ensure that children and their families access appropriate services as quickly as possible”. However, in its current form, in some areas, it will place additional demands on teams that are already struggling in provision of services. An audit of assessment of need practices across the country would highlight areas where assessment of needs have been of benefit and the reason for the bottlenecks. An audit would ensure all children with suspected disabilities access services in a similar manner, as well as highlight the barriers in other areas where assessments of need are either under or over utilised, and establish why this is so? The absence of an audit results in a ‘one size fits all’ model without considering local differences. Furthermore, the limitations of the preliminary team assessment will breach best practice regarding the HSE’s own policy on informing families.
We have outlined the main issues for speech and language therapists in relation to disability services, but also want to summarise some recommendations, many of which have already been identified by the HSE. These include detailed workforce planning; collection of data on incidence and prevalence of disability in Ireland; developing an implementation plan for progressing disabilities services utilising existing structures including the health and social care professional, HSCP, office; and, consultation in relation to proposed changes using the HSE change model.
In conclusion, IASLT recognises the need for standardisation of procedures for the assessment of need process. However, the increased demand for assessments of need must be evaluated and an appropriate response put in place. IASLT welcomes formalising structures for appropriate consultation with the HSE, the HSE’s disability operations officer, as well as with the Minister for Health to ensure services developed adhere to best practice guidelines for both our clinicians and the children and families they support.
Ms Kenny and I welcome the opportunity to discuss this further and answer any questions.