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Introduction
From April 2002 a new organisation - the national Care Standards Commission - will take over the regulation of social care services and private health care from local councils and health authorities. Its aim is to ensure the quality of services and improve the level of protection for vulnerable people.
The Department of Health has issued the proposed regulations and national minimum standards - they are available on the DoH website at www.doh.gov.uk/ncsc - and welcomes feedback from interested organisations. A number of specialist providers have major concerns about the way the Registration Regulations ignore the needs of deaf people. UKCoD have been invited to participate in a joint response, which must be lodged with the DoH by early October.
Response
A Joint response from Deafblind UK, RNIB, RNID, Sense and the UK Council on Deafness
Introduction
Deafblind UK, RNIB, RNID, Sense and the members of UK Council on Deafness represent the vast majority of sensory impaired people in the UK, and also provide a significant amount of care home places for people with sensory impairment and additional problems (such as learning difficulties and mental health problems). In general we welcome the National Care Standards Commission and the new national minimum standards. We feel that they have the potential to improve the lives of people with sensory impairment who, for whatever reason, need to live in a care home. However we have major concerns about the way that the Registration Regulations ignore the needs of sensory impaired people.
Issues
We have major concerns about the registration requirements for services as set out in this document. They have a significant gap that means that their use for assessing the fitness of organisations to provide a particular service is severely compromised.
The lack of any requirement to register either care home or children's home as being able to meet the needs of people with sensory impairment (deaf, blind and deafblind) creates a situation where the needs of these significant client groups are likely not be adequately met. It is our opinion that these groups of people have distinct and particular needs that may not be adequately met in generic settings.
People with any of the three major sensory impairments (deafness, blindness and deafblindness) all require specific adaptations to the environment, to the way that staff work and to the way that information is passed on. This requirement is multiplied when additional impairments exist, such as learning difficulty or physical impairment.
Care homes need to be aware of the requirements of people with sensory impairments, they need to be able to communicate, and facilitate communication, and they need to provide an adapted environment and skilled knowledgeable staff. We do not feel that the registration regulations, as currently set out, encourage or facilitate this.
Issues for specific sensory impairments
Deafness
This invisible sensory disability affects one in seven of the adult population. People can be born deaf or acquire deafness in later life. There are degrees of deafness, yet the severity of hearing loss does not determine the communication or support needs of deaf people. Communication support requirements are more related to educational placements and whether the family was involved with or part of the deaf community. Depending on communication preferences, deaf people may require sign language interpreters or other assistance with communication, including assistive devices, such as loop and alerting systems, etc.
If deafness is combined with other complex needs access to language and effective communication is even more crucial as part of the care/treatment regime.
Deafblindness
"Persons are regarded as deafblind if their combined sight and hearing impairment cause difficulties with communication, access to information and mobility" (Social Care for Deafblind Children and Adults, Department of Health, 2001). The Department of Health has already recognised the unique nature of deafblindness and the requirements that deafblind people have for specifically trained staff, adapted environments and accessible information in its recent policy guidance.
Deafblind people face particular challenges that arise from the interactive nature of an impairment of both vision and hearing. They need the opportunity to benefit from environmental adaptation and strategies to aid interaction with the natural, physical and social environment. Communication strategies need to be carefully considered and implemented so that interaction between people living in the home can be facilitated. Deafblind people need specially adapted environments, specially trained staff and a focus on their needs as dual sensory impaired people if they are to benefit fully from residential provision.
Conclusion
The specific needs of sensory impaired people mean that care homes should be required to register this specialism in the same that that the proposed regulations suggested they register their ability to provide for people with dementia, or physical disability. This requirement has the potential significantly improve the lives and opportunities of deaf, blind and deafblind people living in residential accommodation.
The National Care Standards Commission (Registration) Regulations - Proposed Alterations
SCHEDULE 4
Add to 5 (b)
(vi) sensory impairment (vision, hearing or dual)
SCHEDULE 7 PART II
Add to 6 (c)
Sensory Impairment (Visual) SI (V)
Sensory Impairment (Auditory) SI (A)
Sensory Impairment (Dual) SI (D)
SCHEDULE 7 PART II
Add to 7 (c)
Children with sensory impairments SI
Press Release
Social Services and Sensory Impairment Charities Join in Expressing Serious Concern about New Regulations
The Association of Directors of Social Services and charities representing people with sensory impairments (Sense, RNIB, RNID, UK Council on Deafness, Deafblind UK) have jointly expressed serious concerns about the way that proposed new regulations from the National Care Standards Commission fail deaf, blind and deafblind people.
Mary Robertson, Chair of the ADSS Sensory Sub Committee and Director of Oxfordshire Social Services said "The National Care Standards Commission has the potential to be of enormous benefit to people with sensory impairments who need residential care, we are deeply disappointed. It's a shame that the importance of specialist support for sensory impaired service users has been neglected"
Benedict Lewin-Leigh, Head of Campaigns and Policy at Sense said, "People with sensory impairments are frequently failed by residential homes. The Care Standards Commission needs to ensure the rights of deaf, blind and deafblind individuals to have appropriate support from people that understand their needs"
The National Care Home Standards are due to come into force in April 2002 with the aim of improving the quality of service in care homes in Britain.
The coalition of organisations are concerned about the lack of any requirement in the regulations to register either a care home or children's home as being able to meet the needs of people with sensory impairment. This means that people with sensory impairments may be in unsuitable homes with staff who cannot meet their needs. We would like to see care homes register this specialist service in the same way that the proposed regulations suggest they register their ability to provide for people with dementia, or physical disability.
ENDS
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