Consultation Response

 

I refer to the CAMHS consultation on the Emotional and Mental Health of Children    and Young People and the committee’s inquiry to consider whether the review of CAMHS is on track to deliver the ’step–change’ in CAMHS services that is needed under the following headings:

Specialist CAMHS.

Transition to Adult Services.

Links with education (emotional intelligence and healthy coping mechanisms).

 

South Wales Police (SWP) acknowledges the changes to CAMHS services facilitated by the additional funding from Welsh Government to improve services to children and young persons (C&YP’s) under 18 years of age and report as follows under the above headings:

 

Specialist CAMHS

1.1 South Wales Police recognises the new service provision of the crisis liaison teams in each of it’s 3 local health boards between the hours of 9am and 9.30 pm, with out of hours CAMHS On-Call maintained at the switchboard at the University Hospital of Wales. This service will provide vital contact advice which is required  under the Police and Crime Act 2017 (when effective later this year) where officers must where practicable telephone for advice from a health care professional prior to arrest. The police officer must, if it is practicable to do so, consult with-

 

a)     A registered medical practitioner,

b)    A registered nurse,

c)     An approved mental health professional.

 

1.2 For 2015/16 and 2016/17 the number of section 136 detentions has increased from 36 to 48 respectively against a total number of all detentions of 680 which represents a significant increase year on year for C&YP’s. Whilst police officers are encouraged to use police protection powers under the Children’s Act 1989 so as not to stigmatise children, officers are too often left with no choice but to invoke section 136 in the best interests of the child or young person.

 

1.3 Designated places of safety remain the same for C &YP’s as they do for adults. However on occasions officers are encouraged/directed to use CAMHS establishments such as St David’s Hospital in Canton, Cardiff. Whilst using these resources during office hours perhaps consideration should be given to having separate PoS’s within each LHB or a regional facility such as Ty Llidiard as a hub for the reception of C&YP’s detained under section 136.Completion of the requisite section 136 forms by CAMHS is indifferent and should be forwarded to the mental health act department in each LHB in every case.

 

1.4 Additionally, expanding the services of Ty Llidiard as a triage centre could facilitate the reception of C&YP’s in need of specialist help. In August 2017 SWP dealt with a C&YP discharged from section by Ty Llidiard into the care of local services only to be re taken a short while later by police under section 136 to A&E, before being returned to Ty Llidiard where they were detained under the act. Such a facility would reduce demand on A&E departments.

 

1.5 SWP understands that there is insufficient in –patient capacity in Wales

 

1.6 Liaison and diversion services are yet to be determined by CAMHS in the SWP force area for C&YP’s who have committed a crime under the Welsh Government’s Policy Implementation Guidance on Addressing Mental Health Problems of Children and Young People in the Youth Justice System. By employing means designed to keep a small but often vulnerable group of children and young people out of the criminal justice system, it is more likely to stop problems from escalating and, critically help prevent the stigma and debilitating effect of a criminal record later on in life.

 

1.7 SWP acknowledges in cases of crime, specialist forensic opinion may be required from the CAMHS psychiatrist to the Forensic Adolescent Consultation Team (FACTS). This is also incorporated in the MOU on Murder /Manslaughter which will soon to be finalised with services.

 

1.8 SWP have in place the Welsh Accord for the Sharing of Personal Information (WASPI)  agreement with the 3 LHB’s in it’s force area. Information sharing can on occasions be difficult to access and is an area for improvement.

 

Transition to Adult Services

1.9 SWP acknowledges that as a C&YP approaches the age of 18 there is difficulty in determining the appropriate action in the best interests of the C&YP. SWP advocate a joint partnership approach by CAMHS and adult services so that C&YP’s do not fall between services.

 

Links with Education (emotional intelligence and health coping mechanisms)

2.0 SWP are aware of the services CAMHS provides but do not directly have involvement through the schools programme. We are therefore unable to comment further on any improvement to their service since implementing any changes. Anecdotally we are aware that there is a long waiting time for C&YP’s identified as needing counselling services. Our schools community police officers (SCPO’s) do not refer pupils into CAMHS and schools are not allowed to make direct referrals to CAMH’s. The parents are advised to go to their GP. We understand that schools are unhappy with this direction. SCPO’s may, however be aware of pupils currently either waiting for or receiving CAMHS services.

 

2.1 Children do not suddenly become unwell, then have a few months treatment and are cured. Meaningful provision means preventative steps must be taken to protect our young minds from an early age. We need far more robust education in our schools and care homes to identify the signs of mental health – and strategies and support put in place to help these C&YP’s. It is also crucial that there are ‘step down’ facilities so C&YP’s have the support to re integrate them into society and are not just referred back into the situation that caused their illness in the first instance.

 

 

I submit this response on behalf of South Wales Police to the children, Young people and education committee.

 

 

 

 

 

 

 

 

holds have increased or that delays have shifted from assessment to treatment. In relation to the 26 week neurodevelopmental target reporting, I understand that there has been ongoing work to ensure this develops. However, I continue to receive calls from parents and professionals concerned that children and young people with often complex needs, including neurodevelopmental, continue to be placed on lengthy waiting lists for assessment. Whilst I acknowledge progress in this area, as with the other targets now set for implementation, Welsh Government and local partners will need to ensure that they monitor and review achievements and address any outstanding issues preventing the change required in this respect for children and young people. In relation to evaluating equitable access to CAMHS across Wales, the NHS Wales Child & Adolescent Mental Health

Services Report on Baseline Variation & Opportunities Audit5 should be a valuable source of intelligence. This data was the first of its kind in Wales and a very welcomed development. Whilst further work around audit could provide an

3 https://www.childcomwales.org.uk/wp-content/uploads/2017/04/The-Right-Way.pdf 4 https://statswales.gov.wales/Catalogue/Health-and-Social-Care/NHS-Hospital-Waiting-Times/Inpatient-and­Outpatient-Waiting-Times-for-Non-RTT-Specialties/waitingtimes-by-specialty-patienttype 5 http://www.goodpractice.wales/SharedFiles/Download.aspx?pageid=185&mid=326&fileid=650

opportunity to better reflect the rights of children and young people to good health and healthcare6, I must acknowledge

progress here as we are now gathering more information on CAMHS provision than prior to the Programme. We must however, not become complacent and ensure that momentum continues through the NHS Benchmarking annual audits and that such data continues to be captured and used to inform service development through demonstrating quantitative improvements and areas in need of attention. Transparency and communication are also key components to consider here, alongside the role that direct involvement and qualitative feedback from children and young people can play in informing results.

I am aware that there has been development of local crisis intervention teams across Wales, as a result of the Welsh Government’s wider financial investment in CAMHS in 2015. I am also aware of the Pathway Development Plan for Crisis Care Services, as a result of the Programme’s SCAMHS Framework for Improvement7. However, I am unaware of the current level of implementation. The evaluation and review of these developments must be addressed as I continue to hear of young people presenting in crisis and their needs not being met sufficiently. Children and young people are referred to within the Mental Health Crisis Care Concordat8, published in 2015, to ensure they too feel supported and protected at times of particular crisis and have access to appropriate crisis care. Within my work with the other UK Children’s Commissioners in reporting to the UN Committee on the Rights of the Child in relation to their examination of the fifth periodic report9, we reported the need for age appropriate 24hour community based services to replace the use

of police cells. However, there should also be careful consideration afforded to the potential risk that a decline in the use of police cells could result in an increase in the use of adult mental health wards, a situation which should only occur in exceptional circumstances only. The current evaluation of the Concordat, undertaken by Bangor University, could be an opportunity to reflect these wider issues within any final report to Welsh Government.

 

Funding:

NHS expenditure on mental health problems in Wales continues to be the largest single programme budget in 2015­201610 . However, within this data, spend by the £million on CAMHS continues to be the lowest sub-category (ibid.). This was a finding highlighted by Pricewaterhouse Coopers (PWC) in their Review of the financial ring fencing arrangements for mental health services in Wales11. This is despite the growing concerns that referrals to mental health services continue to increase rapidly. An update on the Welsh Government’s progress in continued response to this review and how far the Programme can evidence any issue of resourcing could prove an interesting consideration as part of the Committee’s

6 http://www.ohchr.org/EN/ProfessionalInterest/Pages/CRC.aspx Article 24. 7 http://www.goodpractice.wales/SharedFiles/Download.aspx?pageid=185&mid=326&fileid=652 8 http://gov.wales/topics/health/publications/health/reports/concordat/?lang=en 9 https://www.childcomwales.org.uk/wp-content/uploads/2016/04/Report-of-the-UK-CCs-UNCRC-Examination-of-the­Fifth-Periodic-Report.pdf 10 http://gov.wales/docs/statistics/2016/160511-nhs-expenditure-programme-budgets-2014-15-en.pdf 11 http://gov.wales/docs/dhss/publications/150824reporten.pdf

Inquiry. I understand that the All Wales SCAMHS and Eating Disorders Network Steering Group (SCAMHSED) have recently

established a SCAMHS Data Set to pilot across Wales. This is a welcomed development but I do not believe it currently captures (or was intended to capture) data on expenditure. With regard to Welsh Government’s announcement in May 2015 that extra funding would be made available to mental health services, including CAMHS, I was pleased to see the particular inclusion of extra funding for the provision of psychological therapies across Wales. Whilst I’m aware that each LHB will have spent varying amounts on the development of such, this should have allowed for some focused identification of the need to address this shortfall. An update on the current level of provision from LHBs across Wales as part of the Committee’s Inquiry will be much needed as I continue to hear from children, young people and their families of a lack of therapeutic provision locally. Given the limited availability of psychological therapies, I am concerned that LHBs may not necessarily be in a position to comply with the current National Institute for Health and Care Excellence (NICE) clinical guidance on ‘Depression in children and

young people: identification and management’12 which states that antidepressant medication should not be offered without “ a concurrent psychological therapy” (2015:23). As I have raised before, it continues to be the case that Welsh Government policy implementation guidance on psychological therapies makes no reference to children or young people13 . Further work in relation to adults only was developed as part of Matrics Cymru in June 201614 and whilst I am aware that consideration was given to children and young people, and that these interventions were likely to be different, I cannot report much knowledge of progress in this regard. Given developments to date with Matrics Cymru and also the learning to be had from the Improving Access to Psychological Therapies initiative in England15, which includes children and young people, I consider this to be an issue that the Programme should prioritise in its final stages.

Transition to Adult Services:

Transition to adulthood continues to be a priority area for me, including the issues young people face whilst transitioning between CAMHS and Adult mental health services. I continue to hear from children, young people and their families that transition planning has not sufficiently met their needs, or indeed has not taken place and that they continue to face a complete ‘cliff edge’. Poor service transition can often lead to disengagement, despite continued need. This risks impacting further on their health and wellbeing and also many other aspects of their lives. Whilst I understand that the Programme has developed a distinct ‘good transition’ guidance document16 and a Young Person’s Transition Passport17 earlier this year, it is important now to ensure that this progress makes a real difference for young people and that they

12https://www.nice.org.uk/guidance/CG28/chapter/1-Recommendations#care-of-all-children-and-young-people-with­depression 13 http://www.rcpsych.ac.uk/pdf/Psychological%20Therapies%20in%20Wales.pdf 14 http://www.1000livesplus.wales.nhs.uk/opendoc/295511 15 https://www.england.nhs.uk/mental-health/cyp/iapt/ 16 http://www.goodpractice.wales/SharedFiles/Download.aspx?pageid=185&mid=326&fileid=751 17 http://www.goodpractice.wales/SharedFiles/Download.aspx?pageid=185&mid=326&fileid=752

form part of the review and monitoring process outlined. I will continue to keep abreast of developments, including the

expectation that LHBs:

“…keep transition arrangements under review as detailed in section 2 to ensure they

remain fit for purpose. Following adoption Welsh Government will undertake a review

of these arrangements within two years to ensure consistency of application across

Wales and that arrangements are meeting the transition needs of service users”. (2017:4).

Links with Education (emotional intelligence and healthy coping mechanisms):

It is imperative that curriculum reform in Wales, particularly the Health and Wellbeing Area of Learning and Experience, is planned and delivered together with the Programme. I have for some time now been highlighting the urgency in aligning these initiatives so that joint work can develop a collective vision for schools’ roles in preventing mental ill health and intervening early. I remain hopeful that my most recent communication should enable colleagues working in both Programmes to focus on improving this under-developed area. This also raises concerns that at Welsh Government level, there is further work to achieve in ensuring that policy and service developments for children and young people across all portfolio areas are sufficiently and effectively joined up. I recent published “Sam’s Story”18, a report on a project involving

children and young people within my school and community based Ambassador schemes, who were asked to express their feelings and experiences of bullying through an imaginary character called ‘Sam’. Within the report, I included a specific priority for improvement by the Welsh Government to ensure that through developing joint working between both the Together for Children and Young People and the Curriculum Reform Programmes, we could achieve the necessary plans and pathways for prevention, early help and support for children and young people in educational settings (2017:28). This work would help ensure that the promotion of strength and resilience within pupils, as well as access to psychological therapies when needed, could be better achieved. I have warmly welcomed the recently announced £1.4m investment to develop the support available to schools by

specialist CAMHS19 . However, this must be complimented by further, whole-school approaches to raising awareness of mental health and implementing prevention and early intervention measures for pupils. I am aware of some excellent examples of work in schools, including the benefits of introducing mindfulness20 and tackling issues of stigma and discrimination21 . Acknowledgement must also be made of the work of counsellors for school-aged children and young people. Given the importance their contribution can make and the collaboration needed between them and CAMHS to ensure timely access to treatment, an update on progress in implementing the Welsh Government’s 2016 guidance would

be useful22 .

18 https://www.childcomwales.org.uk/sams-story/ 19 http://gov.wales/newsroom/health-and-social-services/2017/specialist/?lang=en 20 https://mindfulnessinschools.org/ 21 http://www.timetochangewales.org.uk/en/get-involved/become-champion/ 22 http://gov.wales/docs/dcells/publications/161129-guidance-collaborative-working-between-camhs-counselling­service-en.pdf

With these developments in mind, I have recently highlighted my concerns at a lack of communication on the longevity of the Programme with the Programme Director, and as a member of its External Reference Group. I have had a positive response to my concerns but am yet to receive formal confirmation that plans are in place to address this. I also understand that the Cabinet Secretary for Health, Well-being and Sport has responded to the Chair of the Committee’s recent letter (dated 8 September 2017)23 requesting clarification on its end date and whilst I have had no sight of this, my team has been informed by Welsh Government officials that an extension has been agreed. It is my view that whilst there are risks associated with a Programme which continues indefinitely, likewise, placing arbitrary deadlines would not be reflective of its original aims and objectives24 . It must now focus on ensuring that progress to date is fully embedded and sustained locally, as well as addressing the remaining issues. It would be at this point, that any discussions on its formal ending should take place.

Submitted by:

Professor Sally Holland Children’s Commissioner for Wales

23 http://senedd.assembly.wales/documents/s65968/CYPE5-24-17%20-%20Paper%2022%20-%20to%20note.pdf 24 http://www.goodpractice.wales/SharedFiles/Download.aspx?pageid=185&mid=326&fileid=306