Equality impact assessment: 'Who I am matters'

Page last updated: 3 November 2022

Independent voice review: People with a learning disability and autistic people’s experience of acute care

Contents

  1. Aims and objectives
  2. Engagement and involvement
  3. Impact and mitigation
  4. Cross-cutting and emerging equality issues and action planning
  5. Human Rights duties assessment
  6. EIA sign off and review

1. Aims and objectives

Research has shown that on average, people with a learning disability and autistic people die earlier than the general public, and do not receive the same quality of care as people without a learning disability or who are not autistic.

The LeDeR programme (Learning from lives and deaths – People with a learning disability and autistic people) reviews deaths of people with a learning disability and autistic people to see where there are areas of learning, opportunities to improve, and examples of excellent practice. This information is then used to improve services for people living with a learning disability and autistic people.

The LeDeR review of one person with a learning disability who was also autistic recommended that:

“As part of ongoing developments, the CQC should consider undertaking a thematic review in acute hospitals in relation to how they support people with learning disabilities and autistic people”< /p>

Following this recommendation, and as part of our programme of work to improve services for people with a learning disability and autistic people, we have carried out a review to better understand the experiences of people with a learning disability and autistic people when they go to hospital.

The criteria for the success of the work will be:

  1. An understanding of the national picture of experiences of people with a learning disability and autistic people when accessing the acute hospital setting. This includes understanding the key challenges and barriers to good care. Is this care is received in a way that demonstrates people and families are listened to and that people's specific needs are met? 
  2. Clear findings (including good care stories) that demonstrate what is required to improve services and how to drive those improvements across the system.  
  3. Meaningful involvement of people with a learning disability and autistic people and their circles of support in the process. (References to ‘circles of support’ unless specified otherwise refers to people who are paid or unpaid members of a person's social network of support. People with a learning disability and/or autistic person’s circle of support can include but is not limited to family, friends, informal care givers, paid carers, advocates, interpreters.)
  4. Delivery of reflective report for a variety of audiences including acute care providers that talks about delivering services for people with learning disabilities and autistic people at a local and national level. 
  5. Improved tools that enrich methodologies for assessing care provided to people with a learning disability and autistic people for use in our regulatory approach, including development of new aspects. 
  6. Timely delivery of the review. 
  7. Engagement throughout the review is accomplished in collaboration with colleagues across the system internally and externally.  
  8. The review makes an effective contribution and makes an impact to CQC’s    overall purpose and aligns with our strategic objectives.   
  9. External stakeholders’ opinion of CQC is strengthened through actions related to the review. 

The themed report that will result from this review will be based on findings from bespoke fieldwork that will start with people who use services and will aim to understand what the contributing factors to a successful experience of care in an acute hospital setting. To support that understanding the fieldwork will also involve conversations with people providing care in this environment and leaders within acute hospital trusts. This project recognises that not all the complex factors that contribute to equity of care for people with a learning disability and autistic people will be in the scope of this work.

This work may also help to inform development of our future regulatory approach and identify areas where we could consider further action outside of this project, in our role as a regulator.

2. Engagement and involvement

To inform this EIA, CQC’s engagement team worked with people with a learning disability or who are autistic to support the project team to understand more about their experiences and inform the approach. Furthermore, the team engaged with the expert advisory group to share the proposed framework and methodology. The expert advisory group are a group made up of people with lived experiences, their circles of support and other stakeholders. CQC worked with this group to ensure the insight, knowledge and skills held by these individuals was given due consideration in the planning and delivery of the project. Suggestions from this group were incorporated into the final methodology and resulted in Experts by Experience being included in the fieldwork teams.

The draft framework has also been shared with the neurodiversity sub-group of the CQC Disability Equality Network to ensure that it asks the right questions to fulfil the aim of the review.

The progress of this work has been regularly shared with the director for learning disabilities and autistic people who is accountable for this work, as well as the wider steering group addressing the work of CQC in regulating services for  people with a learning disability and autistic people. We are also learning from recent work on the provider collaboration review of services for people with a learning disability. 

By paying attention to the input of people with lived experiences, it is hoped that the resulting report will have direct benefits for people with a learning disability and autistic people. Through the initial engagement work, it has become clear that often the expectations of people with a learning disability, autistic people, and their circles are support are relatively low. A key aim of this work and subsequent report will be to highlight where we see good practice making a positive difference. This should help to support a clearer understanding of what good should look like and equip those with lived experiences to challenge when they feel the care they’ve received falls short.

3. Impact and mitigation

This work provides an opportunity to promote parity of access and experience of acute hospital services for people with a learning disability and autistic people. The impacts below are being logged during the development of this work.

Age

Impact

We do not anticipate a specific impact in relation to age as a result of this work. 

We acknowledge that people’s experiences will be different at different stages of their lives, from children to adults. However, we do need to be mindful that our sampling may not include a full age range of individuals. People at different ages will have different experiences and have different degrees of support. The team need to be mindful of influencing factors, for example, children are more likely to have family who know them intimately as their support network, whereas an older person may rely on paid carers or be less able to have support in hospital.

Mitigation

We will endeavour to make sure we include people of all ages as part of the fieldwork to obtain a range of views.

We will involve inspectors with specific skills, for example, in relation to children’s services or older people’s services, as appropriate to meet the aims of the work.

Carers and people with caring responsibilities

Impact

One of the success criteria for this work is a clearer understanding of expected standards for patients and their circles of support. This review aims to highlight the key factors that led to a positive experience for people with a learning disability and autistic people. This should support carers and others to feel empowered to challenge where experiences fall short of expectations. As a result, we anticipate there will be a positive impact on people with caring responsibilities from this work.

A recent scoping review of patient safety outcomes for people with a learning disability found that carers (both formal and informal) are protective against poor care. Medical staff turn to care givers to facilitate communication and made limited use of reasonable adjustments. However, it is not clear how this affects people’s experience of care. Read the full review ‘Exploring patient safety outcomes for people with learning disabilities in acute hospital settings: a scoping review’ at BMJ Open.

Mitigation

The methodology of this review aims to enable the capturing of the experiences of carers and people’s circle of support. They are very much an integral part of the fieldwork process, which should ensure their voices are heard within the review.

Putting people front and centre of the methodology will ensure the evidence gathered reflects their experience of care in addition to safety outcomes.

Fieldwork teams will be briefed on the issues to consider in how we communicate effectively with people and families. The framework explicitly aims to capture the experiences of circles of support and in turn aims to identify how these experiences contribute to the quality of the experiences of people using services.

Disability

Impact

This review is looking specifically at the experiences of people with a learning disability and autistic people. It does not exclude autistic people who may not have a formal diagnosis or who may not consider themselves to have a disability because they are autistic. It aims to be guided by what people tell us about their experiences – where there have been good experiences but also where there have been challenges. The final review will report on these experiences and the factors that contributed to their success or otherwise. As an audience, people with a learning disability or autistic people should be able to use the findings of the review to create expectations about their care and experience when accessing acute hospital services. Healthcare providers should also be able to use their involvement and the learning from the final report to support improvement. As a result, we anticipate that this work will have a positive impact.

There is a risk that we are not able to find a balance to engage both groups. It will be important to engage with autistic people who do not have a learning disability. Forty percent of autistic people have a learning disability and one in 10 people with a learning disability are autistic. Three in 10 autistic people speak few or no words. In the pre-site visit work we have endeavoured to identify people with lived experiences who have a learning disability, or who are autistic or both in order to enable a balance to this work.

Mitigation

The methodology of this review aims to be as inclusive as possible, with different tools made available to do so. This aims to enable people with a learning disability and autistic people to be very much front and centre of the final report so that it is truly reflective of their experiences.

The methodology and approach to this work must consider the specific experiences of autistic people. Their experiences are often different for people with a learning disability. Autistic people have been intentionally selected in the engagement work and the team will proactively include autistic people in the sample for fieldwork.

Fieldwork teams must include colleagues with specific skills in communication systems, for example talking mats, to maximise our opportunities to talk with people most likely to experience inequality or barriers to good care.

To inform our approach and learning, we are also analysing the responses of people with a learning disability and autistic people to the 2021 inpatient survey. We intend to include site visits in our approach as well as remote methods, to maximise our opportunity to meet people with specific communication needs who may otherwise be overlooked or excluded.

Race and ethnicity

Impact

Intersectionality means that inequalities experienced by people with a learning disability and autistic people risk being magnified by other characteristics (such as race and ethnicity) and could affect their experiences of care.

Aggregated data from LeDeR reviews 2018-20 show that people with a learning disability from a minority ethnic background:

  • die younger compared to White British people
  • have fewer long-term health conditions reported 
  • are over two times more likely to be prescribed an antipsychotic
  • are less likely to have their death reported to LeDeR
  • more likely to have a family member or informal carer as main source of support.

We acknowledge that some Black and minority ethnic people and their families and informal carers experience exclusion or further barriers to care. This can be caused by a multitude of reasons, for example bias or prejudice, trust in the NHS following poor experiences on the basis of ethnicity, a greater likelihood to be on a low income and therefore face access barriers, for example transport, entitlement to free NHS care if people are subject to overseas charging, or language barriers.

Mitigation

This review will address how well services provide for people with a learning disability or autistic people, who also may come from a minority ethnic background as well as other protected characteristics.

Although the scope of the work may mean the team are not able to make direct comparisons of experiences of people by ethnicity, our methodology and approach is planned to proactively include Black and minority ethnic people in engagement work, fieldwork site visits, including people and families and informal carers who use an interpreter where possible. As a result, we anticipate that our work will have a positive impact on the experiences of Black and minority ethnic people with a learning disability or autistic people, when they use acute hospital care.

Gender

Impact

We do not anticipate a specific impact in relation to gender as a result of this work. However, we do need to be mindful that our sampling may not include an equal split of genders. Furthermore, in relation to autistic people it is recognised that diagnosis of females is less common than diagnosis of males. A 2017 meta-analysis found the male to female ratio for autism diagnosis is 3:1. There is a gender bias meaning girls who meet the criteria for Autism Spectrum Disorder are at disproportionate risk of not receiving a clinical diagnosis. Read more about this in ‘What Is the Male-to-Female Ratio in Autism Spectrum Disorder? A Systematic Review and Meta-Analysis’ in the Journal of the American Academy of Child & Adolescent Psychiatry. Not having a formal diagnosis may impact on people’s experience of care.

Mitigation

The framework and methodology are designed to capture people’s experience of care. Our approach will be to include autistic women and men who do not have a learning disability, including people who do not have a formal diagnosis of autism. 

Gender reassignment

Impact

Intersectionality means that the perceived inequalities experienced by people with a learning disability or autistic people risk being magnified by other characteristics (such as gender reassignment) and could affect their experiences of care.

Mitigation

Part of this review will address how well services provide for people with a learning disability or who are autistic, who also may have other protected characteristics and there is a key line of enquiry specifically designed for that purpose.

Marriage and civil partnership

Not applicable.

Pregnancy and maternity

Impact

Intersectionality means that the perceived inequalities experienced by people with a learning disability or autistic people risk being magnified by other characteristics (such as pregnancy and maternity) and could affect their experiences of care.

A scoping review called ‘Exploring patient safety outcomes for people with learning disabilities in acute hospital settings’ found:

  • increased rates of pre-eclampsia, pre-term birth, low birth weight, induction and caesarean.
  • Increased rates of readmission and attendance to emergency departments postpartum.

This review will not have a specific focus on people using maternity services although people using maternity services would not be excluded.

Mitigation

Part of this review will address how well services provide for people with a learning disability or who are autistic, who also may have other protected characteristics and there is a key line of enquiry specifically designed for that purpose.

The findings from this work will be shared with the CQC maternity working group.

Religion and belief

Impact

Intersectionality means that the perceived inequalities experienced by people with a learning disability or autistic people risk being magnified by other characteristics (such as religion and belief) and could affect their experiences of care.

Mitigation

Part of this review will address how well services provide for people with a learning disability or who are autistic, who also may have other protected characteristics and there is a key line of enquiry specifically designed for that purpose.

Sexual orientation

Impact

Intersectionality means that the perceived inequalities experienced by people with a learning disability or autistic people risk being magnified by other characteristics (such as sexual orientation) and could affect their experiences of care.

Mitigation

Part of this review will address how well services provide for people with a learning disability or who are autistic, who also may have other protected characteristics and there is a key line of enquiry specifically designed for that purpose.

4. Cross-cutting and emerging equality issues and action planning

Focus on acute care experience

Impact

In order to address the key question of this work, it is necessary to be tight in the scope and methodology. While the team recognise that acute hospital care is just one part of a person’s healthcare pathway, it is not possible to cover in the scope of this review the lived experiences of this patient group in primary care, or when they leave hospital. However, the risk of this approach is that it could make the report feel less relevant to people with lived experiences in relation to their whole experience of health care.

Mitigation

The framework that supports this review can be adapted to support a similar look at the experiences of this group in different areas of the health pathway – for example primary care. Communication needs to be clear that this work is part of a group of work addressing the experiences and provision of services to people with a learning disability and autistic people.

Remaining actions

Learning from this work to be shared more widely and used to inform other work of a similar nature. Furthermore, findings can inform business as usual work that can have a clearer look at care along a pathway.

Action owners: Deborah Ivanova and Project Lead, supported by working group
Action timescale: during analysis, report writing and publication phases
Date completed: ongoing

Findings of the literature review

Impact

The literature review has identified and validated the rationale for completing this review citing the contributory factors to the experiences of people with a learning disability and those who are autistic. As part of that work, it has identified clearly the importance of acute hospitals operating as part of a system that supports this patient cohort in a joined-up way to ensure parity of access to services. Due to legal limitations on the scope of this review it is not possible to comment on commissioning during this report. However, the effectiveness of the relationship, and oversight thereof by commissioners should be included. In essence the literature has identified sources of inequality – of which commissioning is one – and this should be picked up through this work.

Mitigation

The work needs to be able to articulate the way in which the wider “system” works to support and have oversight of the services provided to people with a learning disability and autistic people. This point has been picked up in the literature review and as such will be referenced in the report. The review has been shared with the fieldwork teams who will take into account its findings when conducting the activities to gather evidence to inform the final report.

Remaining actions

As a direct result of the literature review, a template has been written and plan made to discuss services in hospital trusts with the local clinical commissioning groups to understand the mechanics and effectiveness of their oversight of services. These interviews will inform and link in with findings relating to individual hospital trusts to support an understanding of any themes and trends relating to how CCGs and hospitals work together to deliver services.

Action owner: Project Lead
Action timescale: before and during fieldwork, February to April 2022
Date completed: February 2022.

Ensuring the voices of people who use services are heard and acted on

Impact

There is a risk that the accounts we hear about from people who use services may not tally with our framework and will potentially bring to light further issues not covered by this piece of work. The scope of this review is intentionally tight, but as it is being led by the accounts of people with lived experience, we need to be prepared for information that needs to be escalated both within the organisations we visit and within CQC.

Mitigation

If teams hear information of concern, or if information gathered does not fit within the scope of the review there is a process of escalation for such issues to be raised so they can be addressed in a more appropriate way.

The group have produced a document that explains the scope of the work being carried out. This is also available in an easy read format. The aim of this is to enable people with lived experiences, their circles of support and staff to have an understanding of the purpose of the work and the types of questions that will be asked.

The framework and methodology are being designed with support from and engagement with people who use services. This lowers the risks that the review may uncover unexpected themes although it does not remove it all together.

Remaining actions

Organisations have been advised that if the work uncovers areas of concern, the team will follow a process to escalate this accordingly. Furthermore, consent forms have been drafted that explain that if the team are concerned about any information shared with them, they will raise this in line with an agreed process.

Be ready to identify and escalate any concerns arising during fieldwork (including potential discrimination or safety concerns), so these may be addressed through our regulatory work and to support providers to improve or take other action to ensure people’s safety.

Produce a final report in easy read format, focussed on people’s lived experiences and ways for providers to improve.

Action owner: Project Lead
Action timescale: before fieldwork, December 2021 to February 2022
Date completed: February 2022

Impact of the pandemic and continued limitations of access to services

Impact

The ongoing coronavirus (COVID-19) pandemic has created barriers to accessing services for the fieldwork team in the way in which the work was originally planned. However, it is also recognised that inequalities can deepen during times of sustained pressure and the need to review and report on this remains.

Mitigation

There is a need to “pandemic-proof” the methodology to enable the momentum of the work to be maintained and work accordingly in order to preserve the integrity and reach of this work for those who need to read it.

Methodology has been reviewed to reduce the amount of time required on site and changed to ensure the information can be gathered in the safest way. In practice what this means is that interviews with identified key staff in acute hospital trusts, and focus groups involving larger numbers of people have been adapted to occur online. This means that less time is required on site and can focus on talking to patients, their circles of support and staff on the wards directly providing services.

Action owner: Project Lead, supported by the working group
Action timescale: before fieldwork, December 2021 to February 2022
Date completed: February 2022.

Diverse representation in site selection

Impact

A study investigating the association between race, ethnicity, social deprivation and autism spectrum disorder in English state-funded school children found social disadvantage was factor, with children eligible for free school meals around 60% more likely to be autistic. See details in ‘Association of Race/Ethnicity and Social Disadvantage With Autism Prevalence in 7 Million School Children in England’ in Journal of the American Medical Association Network Pediatrics.

Mitigation

The demographics of organisations has been a key factor in the selection of sites to be visited. The aim of this is selection is to work towards the sample being a fair representation of the general population, and findings therefore being equally representative.

When deciding on sites to visit for this work, the main objective was to get as full a range of acute hospital trusts as possible. Additionally, as this is aimed at being an appreciative enquiry, it was important to include organisations who through CQCs ongoing regulatory work, were highlighted as having offered particularly positive experiences to people with a learning disability or autistic people. Conversely, where there may be intelligence that suggested the opposite may be true, it also flagged as an opportunity to understand what the barriers and challenges may be in these places.

Of the eight sites selected, two were selected on the basis of having a history of particularly positive experiences reported to CQC. One was selected for the opposite reason. When selecting the remaining five sites the team focused on how they could achieve a broad selection of geography, demographics, trust size and ratings. The team used the inpatient survey to analyse feedback given to CQC either about people with a learning disability and autistic people or from people with a learning disability or autistic people themselves. A potentially interesting finding from this work will be whether the trust rating has any connection with how well people with lived experiences tell us they found the service. Early indications suggest that trust ratings do not guarantee experiences will be good, bad or otherwise.

With these factors in mind, there are two trusts each from the North, the Midlands, the South East and the South West. The sample includes trusts that are rated as outstanding, and trusts that are rated as good and requires improvement. There are large, multi-site trusts, and smaller single site hospitals.

Remaining actions

While it is impossible to have a truly broad sample, the group that remains is a group that is big enough to support the team to pull out trends and differences and to try and understand the factors that make them so. How these factors connect, remains to be seen and is part of the aim of this work.

Action owner: Project Lead
Action timescale: before finalising fieldwork
Date completed: December 2021.

Diversity in who we speak with on site

Impact

A study investigating the association between race, ethnicity, social deprivation and autism spectrum disorder in English state-funded school children found social disadvantage was factor, with children eligible for free school meals around 60% more likely to be autistic. See details in ‘Association of Race/Ethnicity and Social Disadvantage With Autism Prevalence in 7 Million School Children in England’ in Journal of the American Medical Association Network Pediatrics.

Mitigation

Planned engagement work proactively included people from Black and minority ethnic backgrounds and women and men with and without a formal diagnosis of autism and that both autistic people (with and without a formal diagnosis) and people with a learning disability are enabled to participate in the work and the development of the approach.

The group built in a focus on people with protected characteristics and people most likely to experience barriers to accessing care and least likely to be heard, into methods, tools and sampling (for example case tracking), building on the approach taken in CQC provider collaboration reviews and including issues relating to deprivation.

Remaining actions

Arrange learning for fieldwork teams to understand and explore the issues identified in this assessment including identified health inequalities and intersectionality.

It is not possible to control the numbers of people we speak with who have other protected characteristics, such as being from a Black or minority ethnic group. The organic nature of this work means that the teams will speak with whomever is available, willing and able to take part. However, in the analysis of the findings the team will be able to pick out trends and themes that relate to specific groups if they are apparent and the report can reflect the findings of such.

Action owner: Project Lead
Action timescale: before finalising fieldwork
Date completed: December 2021.

Autistic people without a formal diagnosis

Impact

There is a risk that the limitations of trust flagging systems may prevent the team gaining access to autistic people without a learning disability or a formal diagnosis of autism as part of this work. The potential impact of this in the final report is that the experiences of autistic people could get missed or are not represented in a proportionate way.

Mitigation

The team need to ensure that the trust have a comprehensive awareness of the purpose and content of the work before it begins in order that they can work to direct the team to people to take part in the review.

It should be noted that an inability to recognise autistic people could raise the question about how their needs are met and adjustments made, and if necessary, this work should report on that.

Remaining actions

In preparation for the on-site work, trusts will be provided with full details of the scope of the review and the people involved with the ask that they are identified for teams to speak with while on site. Furthermore, teams will look to identify patients during the fieldwork and talk to staff about how they make adjustments for people who may not flag as having additional needs.

Action owner: Project Lead
Action timescale: before fieldwork, December 2021 to March 2022
Date completed: March 2022.


Meeting people’s communication needs on site visits

Impact

The nature of this work means that the people who’s voices and experiences we want to hear, may have additional requirements to enable them to engage and communicate with this work. There is a risk that if the teams carrying out the fieldwork aren’t skilled, the review could miss key input from people with lived experiences.

Mitigation

The group considered how the skill mix of fieldwork teams could meet the needs of people with specific communication methods, for example Makaton and talking mats, and worked to ensure colleagues with relevant skills and experience (for example in children’s services, maternity or older people’s services) could support the work as needed. 

Action owner: Project Lead
Action timescale: before fieldwork, December 2021 to March 2022
Date completed: March 2022.

Consent

Impact

The legal basis for this work means that all participation is voluntary. In order to publish a report that contains information about a person’s experience it is necessary to gain their consent to doing so. There is a risk that given the nature of this work, we will need to exclude participation from individuals who do not have the capacity to consent to their involvement. This carries with it the risk that the group at greatest risk of inequalities in their care and treatment may not have their voices heard as part of this work.

Mitigation

There is a need to explain the purpose and product of this work in a way that is as accessible as possible to as many people as is possible, thereby maximising the involvement of people with lived experiences in this work. Furthermore, the team will need to be innovative in developing methods to include the experiences of people that do not directly involve a conversation for which they don’t have the capacity to consent.

The team have developed consent forms that are accessible to people with lived experiences who may need some additional support to enable them to understand the purpose and process of this work.

The team have devised and delivered a methodology that enables the fieldwork team to research “around” a person’s care, but that respects the legal framework for the review. For example, talking with circles of support and/or observing care, discussing scenarios with staff that could reflect a person’s needs.

Remaining actions

Try to maximise participation in the work from a broad range of people with lived experiences to work towards representation from them in the final report.

Action owner: Project Lead, working group support
Action timescale: before fieldwork, December 2021 to April 2022
Date completed: April 2022.

5. Human Rights duties assessment

Freedom from inhumane or degrading treatment

Human rights duties compliance

Could be a potential negative impact if this human right is not adequately considered in:

  • Development of methodology
  • Engagement with people who use services and their families and advocates.

Mitigation and opportunity

The methodology and engagement with people must be carried out in such a way as to enable this group to use their voice to inform the review.

Right to liberty

Human rights duties compliance

Some of the equality questions in the framework of this review ask questions of people’s right to liberty when accessing acute services, and how this aligns with the general population.

Mitigation and opportunity

By asking these questions the review aims to highlight areas of good practice and disparity for this population group.

Right to respect for family and private life, home and correspondence (includes autonomy issues in care and treatment)

Human rights duties compliance

Article 8 is a qualified right which means it can be “interfered with” by a public authority in certain circumstances including public safety, protection of health or morals, or for the protection of rights and freedoms of others. Any interference must be appropriate and proportionate. It is likely this review will highlight some areas where attention to this human right is required, and may include, but not be limited to, issues around “Do Not Attempt Resuscitation” orders, and consent.

Health and social care services may need to restrict access to families and friends in order to protect right to life. However, providers need to consider how they can impose limitations while fulfilling article 8 rights.

Mitigation and opportunity

If we find that the practices of individual providers are creating barriers for access, or other potential Article 8 breaches relating to issues such as consent or DNACPR, we will address this through our regulatory work, escalating as necessary; make sure our methodology enables inspectors to identify where this is happening and to support providers to improve or take other action to ensure people’s safety. Provide training to support teams as required.

Right to life

Human rights duties compliance

Many of the equality issues in the section above relate to right to life, if they could lead to deaths that were avoidable by public bodies taking a different course of action. This relates to CQC’s duty to protect people’s human rights through use of our regulatory powers.

Mitigation and opportunity

Review risk to disabled people’s human rights arising from changed pathways to access.

If we find that the practices of individual providers are creating barriers for access, or avoidable poor outcomes (including avoidable death) this will be addressed through our regulatory work, escalating as necessary; make sure our methodology enables inspectors to identify where this is happening and to support providers to improve or take other action Provide training to support teams as required.

Use provider engagement methods and work with system partners to flag good practice and expectations around equality issues in clinical decision-making.

6. EIA sign off and review

This equality impact assessment and action plan was approved by:

Head of equality, health inequalities and human rights on 21 September 2022.

Director for People with Learning Disabilities and Autistic People is responsible for delivering the action plan, which will be reviewed no more than 6 months after publication.