Health Commission Wales’s comments on the draft report
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In its written comments on a draft version of this report, HCW said that eating disorder patients do not, as a rule, ‘fall ill’; rather, they develop the disorder over a period of time. It said this usually allows for the reasonable engagement of local services. HCW said its policy includes an ‘exceptional circumstances’ clause which can cover circumstances such as those which arose in this case; however, it said that the decision making process must always be informed by the information known at the time. HCW said that its policies deal with reasonably foreseeable situations; it said that this was the only case in six years where the patient was under the care of services outside Wales and where local services did not engage appropriately. HCW said that it had examined the policies of comparable commissioners in England via the internet, and said that none of these referred to the ‘very rare’ circumstances demonstrated by this case.
HCW said that in reaching the decision not to fund in-patient treatment, its individual patient commissioning panel did look at the evidence available to it at the time and did use its discretion. It said that the panel has a ‘clear and demonstrable’ track record of dealing with cases on their merits. It said that this has been the case for many eating disorder cases where the evidence has supported the emergency status of the patient. It said that in those circumstances the panel has agreed to fund in-patient care before local discharge arrangements had been agreed. HCW said it responded flexibly when the clinical information provided showed a need for immediate action. HCW said that there have been, and continue to be, circumstances where patients present with a very low BMI of 12-13 and it had reacted, and will react, promptly.
Turning to Miss S’s complaint, HCW said that it was continuing to pursue the matter and secure the involvement of the Welsh Consultant throughout the process, and could demonstrate that that was the case. It said that when a patient decides to pursue private treatment, there would normally be no further role for HCW until the patient presented for NHS services. It said in these circumstances HCW’s normal policy is not to reimburse the cost of private treatment. HCW said that this particular case was complicated by the fact that neither Mrs S nor the Welsh Consultant followed its normal appeals process.
Turning to the requirement for a discharge plan to be in place before funding was agreed, HCW said that from its practical experience, if plans are left until the patient is admitted, the engagement of local services is much poorer and plans are not prepared in a timely manner. It said that the existence of a plan, or even a commitment to a plan, shows that local services have engaged in the care package, which is essential if there is to be long-term benefit from the in-patient admission. HCW said that where local services do not demonstrate this engagement when a patient is admitted, the result will be an unnecessarily long in-patient stay. It said that these are ineffective and harm the care available to other patients who require specialist care by needlessly reducing the resources available.
HCW said that, as stated earlier, it will act to mitigate risk to patients who need emergency admission by acting flexibly and admitting them before full plans are available; however, it said that in this case, it was not made aware of the degree of urgency and that is why it decided that local services should be responsible for Miss S’s care at that time. HCW said that to avoid any doubt, it will incorporate its practice into future policies.
