ADPH Consultation Response: UK Covid-19 Inquiry Draft Terms of Reference

April 7, 2022 in ADPH Updates, Covid-19, Health Protection by Heather Partridge

The Association of Directors of Public Health (ADPH) is the membership body for Directors of Public Health (DsPH) in the UK. It represents the professional views of all DsPH as the local leaders for the nation’s health.  

The Association has a heritage dating back over 160 yearsand is a collaborative organisation, working in partnership with others to strengthen the voice for public health. It seeks to improve and protect the health of the population through collating and presenting the views of DsPH; advising on public health policy and legislation at a local, regional, national and international level; facilitating a support network for DsPH; and providing opportunities for DsPH to develop professional practice. 

Introduction 

  • The ADPH welcomes the opportunity to make a submission to this important consultation and contribute to national learning about the pandemic experience. 
  • Public health in local authorities (LAs) has played a crucial role in tackling the virus in their local places and stitching together the different elements of the Covid response. All local areas have worked with, and strengthened, national programmes such as Personal Protective Equipment (PPE), the Test and Trace Service and the vaccination programme – bringing together local knowledge and strong relationships and ensuring that approaches work on ground and reflect the diversity of communities and the range of needs that exist (from language to inequalities).  
  • Health Protection, and public health in general, is reliant on true collaboration and interconnectedness across local, regional and national systems. Whilst some aspects of the Government’s response to COVID-19 have undoubtedly been commendable, the centralised nature of some elements has, in some cases, significantly impeded effective collaboration and communication with local authorities. The pandemic has helped to develop the evidence base of what does and does not work in policy development and implementation in an emergency situation and offers valuable learning which should be captured within the Inquiry.  
  • The Terms of Reference as currently drafted is too heavily focused on the actions and decision making of national bodies. There is a risk that this will mean the contributions of local government will not be fully recognised and key lessons not appropriately captured.  

Consultation Questions 

  1. Do the Inquiry’s draft TOR cover all the areas that you think should be addressed by the Inquiry? 

The ADPH does not feel that the draft TOR sufficiently covers all the areas that should be included within the scope of the Inquiry. Set out below are the additional areas ADPH would like to see addressed in Part 1 of the inquiry’s aims:  

Central, devolved and local public health decision-making and its consequences 

Preparedness and resilience  

  • Whether appropriate planning took place to enable a swift and effective analysis and understanding of the emerging threat, rapid mobilisation of existing systems and approaches (across science, operational and policy aspects) and resourcing of key bodies and expertise.  
  • An exploration of the impact historic underinvestment (ie in the public health system) – and funding constraints throughout the pandemic – had on the capacity and ability of local and national bodies to respond effectively.  

How decisions were made, communicated and implemented  

  • Consideration of whether there was sufficient understanding of, and respect for, the existing systems (ie multi agency civil contingency emergency planning structures) and the statutory roles and responsibilities of relevant local, regional and national public bodies. 
  • Consideration of how the Government engaged with stakeholders during policy development and ahead of press announcements, in particular the role and balance between national and local leaders in public communications. 
  • An exploration of whether there was clear and consistent messaging to the public rooted in behavioural science to support compliance. 

The availability and use of data and evidence  

  • An assessment of how GDPR was applied and the overall approach to data-sharing across public bodies, including the impact of delays and restrictions to data-sharing on the effectiveness of the response at all levels.  

Further areas that should be covered within this section include: 

  • The role of local government in delivering the national response to the pandemic. 
  • The balance between and efficacy of national and local delivery of services and support to communities, businesses and individuals. 
  • Evaluation of the coherence of the Government’s overarching approach, strategy and decision-making processes for managing the pandemic set against existing public health principles and systems, local emergency response structures and capabilities, and the developing evidence base and scientific advice.  
  • Scrutiny of the procurement process and the value for money delivered by public contracts across crucial aspects of the response (eg PPE, testing and consultancy). 
  • The extent to which underlying health inequalities contributed to the levels of hospitalisations and mortality; and an assessment as to whether the response to COVID-19 – in terms of policies and programmes – further exacerbated inequalities or created new ones. 
  • The impact of the pandemic on children and young people specifically including: 
  • The impact on children’s safeguarding, development and wellbeing of multiple services (ie health visiting) moving online, restricting access or closing altogether, parents (including new parents) being isolated from wider family and friends support networks, limited access to mental health services and access to services like speech and language therapy.  
  • The relationship between the Department for Education, councils and education settings during the pandemic, including in relation to data collections, guidance and funding, to ensure lessons are effectively learnt for the future. 

The response of the health and care sector across the UK 

Additional areas that should be covered within this section include: 

  • Consideration of the experiences and impact of the pandemic on health and care sector workers and education staff, plus other key workers such as children and family social workers, during the pandemic. 
  • How much profile and emphasis was given to adult social care from the outset. 
  • The impact of decisions to redeploy NHS and local government staff on the health, safety and welfare of specific, and vulnerable groups (ie changes in the priorities for health visitors, school nurses, children’s mental health workers). 

With regards to Part 2 of the Inquiry’s aims, the ADPH believes that in identifying lessons to be learned from the UK’s response, the Inquiry should also:  

  • Consider what investment is needed in terms of resources and workforce planning, training and development to ensure we have a resilient locally led health protection system going forward.  
  • Consider what local capacity is needed in the future to step up the response to cope with the demands of the pandemic in terms of health protection, local testing, vaccinations and contact tracing while maintaining the delivery of existing core services. 
  1. Which issues or topics do you think the Inquiry should look at first? 

Given the risk of new variants or vaccine escape within an existing covid variant within the timeframe of inquiry, it would be helpful to prioritise those themes that can help inform the national response to such a situation. In addition, the ADPH believes it would be helpful for the Inquiry to prioritise the interplay between national, regional and local decision making.  

  1. Do you think the Inquiry should set a planned end-date for its public hearings, so as to help ensure timely findings and recommendations?  

We believe the Inquiry should set a planned end-date for its public hearing and the for the publication of the final report, although we appreciate this may not be easy to do given the extent of the Inquiry’s remit.