Department of Health
Published: 16 May, 2014
guidance on adult safeguarding
Back to adult safeguarding
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Our opinion is that prisons should have a statutory seat on SABs.
Local Authorities should consider how they are represented in terms of commissioning and delivery of Council services. The outline of membership given is appropriate. Paragraph 14.105 should be stronger on the requirements of partner agencies to fund the Board’s activities to meet the objectives in it’s business plan. The phrase ‘this might be through payment to the local authority’ is not strong enough. The wording should reflect the approach taken in ”Working Together to safeguard children’ Guidance “All LSCB member organisations have an obligation to provide LSCBs with reliable resources (including finance) that enable the LSCB to be strong and effective”
It is important that regulators such as Care Quality Commission are added as core members given the Winterbourne Review and the Midstaffordshire enquiries. Also, possible consideration to include elected members to the Board.
In agreement with principle of local determination of SAB activity and Governanance. However there should be a core constituent membership of senior Executive leaders to maintain the strategic profile of the SAB and adult safeguarding activity. There should also be a requirement for both lay and voluntary sector membership.
This response is submitted on behalf of the London Safeguarding Adults Network – the group of local authority safeguarding adults lead officers in London.
We would like to see the guidance say that CCGs must have designated professionals, doctors and nurses, for safeguarding adults and for these designated professionals to be members of SABs.
We would like the guidance to recommend consideration be given to involvement of the third sector perhaps through umbrella organisations.
Gateshead’s Safeguarding Adults Board recently appointed two lay members to sit on the Board. The aim of this exercise was to ensure that the policies implemented and the activities commissioned by the Board continued to retain a person-centred approach. The role of the Lay Member is to offer an independent view on all aspects of the Safeguarding processes and procedures to widen the scope for development. The independent status of both the Chair of the Board and the Lay Members provides a balance against the wide range of professionals and officers who represent the key public bodies at the Board. The Care Act guidance notes provides a list of potential other members to be involved in SABs from a range of organisations. Board members who represent organisations will be duty bound to promote the policies and work of their respective organisations. From a Gateshead perspective, the impartiality of our Lay Members will make certain that our processes are scrutinised without agenda and will ensure that the procedures are amended to improve the outcomes for the service users.
There should be adult safeguarding doctors and nurses etc and medical etc exams and assessments, just like the provision for child protection. These people should along with carers and service users themselves be part of the SAB.
Community safety partnership representatives should be part of the Core Membership as should Probation as well as the other suggested representatives.
Consideration should be given by Boards about user representatives – how can this be achieved in a real sense.
Local colleges and universities should be invited to attend as occasional members – providing information on how they are implementing safeguarding principles into practice etc.
Other possible members of Boards are Council elected members and GPs.
Social isolation is identified in the guidance as something that needs to be addressed in the SAB’s policies and procedures – this is a much wider issue than safeguarding and needs to be addressed through local employment strategies, regeneration, national government policies etc. Isolation as a social issue cannot and should not sit within safeguarding.
My feeling is that in trying to be concise the Act has not explicitly referred to the developments that SABs have made to incorporate independent chairs and wider representation
Senior Nurse representative on the board should be similar to that required on the Safeguarding Childrens Board. The Designated Adult Safeguarding nurse who is able to give Strategic and operational expertise and oversight of the Health provider organisations in the local area and understanding of National picture.
The persons who should sit on the safeguarding adult board should be similar to the specifications set for the safeguarding children’s board. Designated nurses for children must sit on the children’s board. Designated nurses for adults should also be required to sit on the Safeguarding Adult’s board. These posts allow for expertise, strategic and operational oversight to be fed into the SAB.
I agree with earlier comments that there needs to be a far wider representation on the Safeguarding Adults Board.
Section 14.27 lists relevant partners of the local authority who must agree to cooperate – NHS, Job Centre’s, Police and Prisons etc. This is a very limited group as it does not include the DWP, housing authorities, nor representatives from care companies or local voluntary organizations, the organisation providing the IMCA service.
However, the most significant omission seems to be the lack of any good practice or professional guidance, at the table where decisions will be taken concerning the individual and their current situation.
Good practice guidance should be available relevant to the situation under discussion.
It might be advisable to have a professional social worker with experience in Best Interest Assessment or a representative from a voluntary association/charity with a special interest in the area or a professional with expertise with respect to the particular aspect of care or lack of care being discussed. This may be covered by co-option as stated in Para 14.102
Guidance para 14.28 advises ‘The six principles that underpin adult safeguarding (see above) apply to all sectors and settings including care and support services, social work, healthcare, welfare, housing providers and the police. ‘
The principles underpinning No Secrets were – privacy, dignity, choice, rights & fulfilment. For this Act the DoH has devised new principles. Empowerment (which is understood as personalisation), Prevention, Proportionality, Protection, Partnership, Accountability, listed in a box following 14.4.. I believe we need to include most of the original principles in the current Act. I believe that there should be 7 principles and that Empowerment and Personalisation should be separated. Thus:-
Empowerment is a commitment to promoting the client’s well being, rights and dignity. With a focus on fostering the clients self respect, and enhancing their relationships with those close to them; so that the client is able to exercise freedom of choice and action. This in turn enables the client to better influence the course of their life and give informed consent for the decisions which affect them.
Personalisation is the provision of flexible, individually chosen services where the client has more control and as a result is able to play a positive role in the community.
Respective Voluntary sector groups, Local BME and disability groups should be included.
The voluntary sector should be represented on Safeguarding Adults Boards. CQC should be a key agency on Safeguarding Adults Boards in order to give a strategic and preventative overview of safeguarding concerns expressed by the regulator. NHS England should also be a key member, represented by the area team for the Safeguarding Adults Board’s area.
We regret the absence in the Act of the duty to co-operate. The Boards are often sorely tested by reliance on goodwill – goodwill which is tested by funding pressures, local and national politics and by service pressures. The duty to co-operate would enable a firm platform for Safeguarding Adults Boards to discharge their statutory function.
Additional possible SAB members to be considered;
Representation for organisation that supports homeless people
Drug/Alcohol organisations,Representatives from Financial Sector.
Other members should include probation and the guidance should be more explicit about health providers including Mental Health and adult care providers.
There should be some local demographic mapping to ascertain which groups may benefit from representation.
There also needs to be explicit guidance re a mandatory attendance element of core members.
Guidance needs to be explicit about the Board representation needing to be at senior “decision maker” level
It was felt that widening the scope of statutory SAB members to include the following front line organisations would improve the performance of the SAB:
•ambulance and fire services
•representatives of providers of health and social care services
•representatives of housing providers, housing support providers, probation and prison services
•members of user, advocacy and carer groups
•Care Quality Commission
Additional representation from Advocacy services and people who themselves require care and support.
14.108 – Chief officer of police may be unrealistic – a senior officer would be welcome.
Members should include:
Voluntary sector (including those representing carers organisations)
Care Home representative
Domestic Abuse specialist
NHS provider organisations as well as CCG
Fire and Rescue service
Some organisations could be represented on an operational subgroup of the SAB.
Consideration should be given to including NHS England and local Police and Crime Commissioners as statutory members of SABs
Colleges should be listed as potential members of the Board
A SAB should link to the LSCB directly
A SAB should link to the local Learning Disabilities partnership
Directors of Adult Care should not chair these boards as there is a clear conflict of interest when issues of concern arise, the worst being a case review / serious case review.
These boards in my view will do very little to make any impact as safeguarding work is so inconsistently undertaken and results in social workers services not really making impact on the growth of behaviours causing harm / abuse.
The boards will become talking shops to promote careers in safeguarding (as with children’s boards- we see abuses growing in many forms now many ignored in the not too distant past even by social workers).
The fact is the strategies may not be worth the paper they are written on when the vast majority of those who are the target group to be safeguarded have not been involved in the debate on abuse and safeguarding. The prescriptive ways outlined in the guidance here have not come from ‘bottom up’.
In any review, capacity assessment, risk assessment or care plan meeting, people who know the person best such as family members should be fully involved in the process. This is particularly important with those with learning disability whose understanding can often far outstrip their ability to articulate that understanding. People who know them will best understand how to communicate successfully with them rather than professionals who hardly know them and can easily misinterpret signals.
Would like to add district & borough councils throughout the regulations. Is essential to address the prevention agenda otherwise County Council will have to delegate everything. Needs to be very clear/explicit. (also feedback from Health & Wellbeing Board & recent Peer Review of safeguarding).
Level of representation needs to be considered. Sending people of sufficient seniority. May need beefing up in the guidance
Housing is not specifically mentioned and it would be helpful. Could be a representative of the sector through the Housing Federation
Include NHS England (group agreement)
Include mental health
Some representation from the faith community & BAME should be included
Ensure it includes disability ULO as well as voluntary sector as they are not necessarily the same
IMCA because they represent best interests of people
Are issues around the size of Boards in 2 tier area therefore not helpful to have a Board that is too large
Public health should be included
Mental health & / or psychiatric services
Citizens Advice Bureau
Faith groups should be specifically mentioned
Faith groups should be included
Education should be members
Public Health should be members
Where agencies are not members of the Board because it would make the Board to big to function then Board’s could be recommended to sign up other agencies to a Memorandum of Understanding
All Health Providers should be statutory members of the board. This is to ensure true engagement.
As the Annual Report should be shared with Healthwatch and HWBB these should also be statutory members. This would also ensure wider members engage with the SAB.
NHS England have in their guidance that they should be members of the SAB this should be replicated in the Care Act Guidance.
Question 66: Are there additional possible members of Safeguarding Adults Boards that we should add?
14.108 Service user rep? What does this mean? Needs more detail to make it have value?
Member of user advocacy and carer groups what does this mean?
Not clear and about whom and at what level. For example makes reference to LA and CCG as organizations but refers to Chief of police re. Police.
It is suggested that the only extra relevant partner to add to a Safeguarding Board would be an individual from the Department of Work and Pensions. This would possibly offer support around cases of financial abuse.
I believe CQC should be moved from 14.109 to 14.108. Listing CQC as an example of what could be expected is not strong enough. Lay members should also be supported to engage.
NHS needs to be broken down, to clear defined groups, CCG’s, University Hospital, Partnership Trusts, Mental Health.
Strongly agree with the link around Adult board and community safety partnerships.
The list of statutory organisations that MUST be represented is clear and the suggestions for other partner organisations is inclusive. The addition of some Lay Members on a SAB would be beneficial and enhance representation of the Service User’s views through open and honest discussion of the issues.
I feel that the inclusions in membership are relevant and proportionate. The third sector needs to be well represented. The notion of a safeguarding engagement group is positive as is the recognition of the third sector in the scope given their role in the provision of services supporting statutory and ‘for profit’ organisations
What does NHS mean? Hospital Trusts, Mental health Foundation Trusts, Clinical Commissioning Groups, GP Federations, Ambulance Trusts? These should all be included – communication between each is poor, so to assume any one can represent the other is misguided.
Registered Social Landlords should be included – those who have sheltered or extra care housing.
How does the Safeguarding Adult Board link with the Community Safety Partnership? There should be a statutory link between the 2 – or they won’t necessarily communicate!
Fire & Rescue Services should be included.
I would agree with previous comment but also like representation by advocacy organisations or some umbrela organisation which is lead for advocacy services.