Without a risk assessment this NHS consultation is nonsense

The Coalition Government's failure to make public a risk assessment carried out on the NHS reforms created a huge controversy.

NW London NHS has gone one step further by refusing to carry out a risk assessment on the changes to the local health service and hospital provision it proposes in 'Shaping a Healthier Future'. Instead they will do so AFTER the consultation, which means of course that individuals, patient groups, GPs and local councils will not be fully informed of the risks when they submit their views.

What kind of democracy is it when you are unable to put forward an informed view because the decision maker won't carry out a vital assessment of the impact of proposed changes?. Changes which could be a matter of life or death

In case you missed it Rob Sale had a letter published in local papers last week about the issue:

We are writing to alert your readers to the way those pushing through the ‘Shaping a Healthier Future’ changes to our NHS, including closure of the four A&E departments, are refusing to produce a ‘risk register’ for the stated options until after the ‘consultation’ finishes on the 8^th October and the decision has been taken.

This became clear at a meeting of the Joint Overview and Scrutiny Committee of the eight local councils affected by the proposals held on 2^nd August in Harrow. The Vice Chair of this committee is Brent Councillor Sandra Kabir.

Preparation of a risk register, listing key risks with possible mitigation factors in clear tabular form is a standard tool used in assessing the pros and cons of courses of action. Brent Council has such a scheme in its Corporate Risk Register.

By refusing to carry out this process until AFTER the decision has been taken, the authors of these proposals show their unwillingness to consider the severity of the risk posed to residents by their plans, which clearly could be a matter of life or death. We, the people affected, and our elected representatives are to be deprived of this vital information during the consultation period. This must call into question the will for genuine consultation and, indeed, whether the whole process runs the risk of legal challenge, something we would encourage our Council representatives to investigate.

The Chair of the Committee, Cllr Lucy Ivimy (Conservative, Hammersmith and Fulham) made her position clear in an email to a member of the public who attended the meeting:

‘…for the NHS to produce (a risk register) only after the decision has been taken is extraordinary. The committee will be looking further into various aspects of risk. I am personally concerned that the full impact of the proposed changes has not been made clear in this consultation process’.

We therefore urge the Committee to insist upon risk registers for all of the options including 'doing nothing’ to be provided in advance of any meeting to reconsider risk and these documents should be publicly available. Time is running out.

Robert Sale

On Behalf of Brent Fightback