Consultation closes 10 February 2009
The Primary Care Child Safeguarding Forum is pleased to be able to respond to the production of NICE Guidance on Child Maltreatment in England.
The PCCSF is a UK-wide organisation, affiliated to the Royal College of General Practitioners, which represents Doctors who work within the NHS to Safeguard Children and Young People. Most of our members are General Practitioners, and many have extended roles with Primary Care Trusts/LCCSBs/Health Boards, or Healthcare Workforce Deaneries, working both with healthcare professionals and with NHS bodies to train the workforce in recognition of Child Maltreatment.
We welcome the production of guidance on Safeguarding Children in Primary Care, and particularly this guidance for professionals on recognising Child Maltreatment. Not only will it be of use to General Practitioners and their teams, but to Out of Hours providers, Sexual Health Clinics, Accident & Emergency Departments, NHS Walk-in Centres, and Private Hospitals and Clinics.
We are concerned that organisations like ourselves, with no administrative structure, are disadvantaged by being compelled to use a proforma to respond. We are concerned that you may take less cognisance of feedback which is valid, but not correctly formatted.
We are mindful that the scope of this document is actually to target and inform all healthcare professionals: in the introduction to the NICE guideline draft, and in section 1.2 of the full guidance, reference is made to “healthcare professionals who are not specialists in child protection … to support initial clinical suspicion before a child has been referred to children’s social care services or to a specialist child protection team”.
We are concerned that this may lead the uninformed reader to conclude that these guidelines are mainly intended to apply to professionals working in primary care, and we are sure this is not your intent. We feel that the use of the term “specialist” is unhelpful here in both senses. You may be unaware of the existence of practice, federation or community-based child protection or safeguarding teams. In the modern NHS, there is much less of a divide between primary and secondary care, with primary care taking on much of what were once considered to be “specialist” roles.
Our suggestion is that the guidance should be expressly applicable to all professionals working with children and young people, regardless of context.
We also have some concern that professionals may confuse the terms “consider” and “suspect”, despite the effort you have made to clarify what is meant. These are not terms used currently in this way in everyday General Practice. Other alternatives which you may wish to consider include “Traffic Light” [also known as RAG] systems, currently widely used in suspected cancer guidance, back pain assessment, and prescribing schemes, where Red Flags equate to strong suspicion, Amber might equate to moderate suspicion [where you now have “suspect], and Green equate to “Consider”. For consistency of style, it would be better to start in each section with “suspect” indicators, and then “consider” [see 1.5.8 in NICE Guideline for example].
This leads on to our final general concern, that you have different topic numbering in the “Full” guidance from the “NICE” guidance. The complex arrangements you have had to make to receive feedback provide evidence of the confusing impact this will have on teams who try to adopt these. It might be better to use lettering/numbering of sections, rather than just numbering.
Dr Andrew Mowat
PCCSF is an independent professional organisation set up to
support doctors with an interest or involvement in protecting
and safeguarding children. At present, it is funded by membership subscription, run as a not-for-profit company. PCCSF is affiliated to the Alliance of Primary Care Societies from the Royal College of General Practitioners.
We welcome members from all four UK jurisdictions, representing doctors from Primary Care with an interest in
the protection and promotion of welfare of children and young people. Our membership is predominantly GPs but we welcome doctors from other specialties interested in this work.
The benefits of membership include:
· A secure email discussion group;
· A regular newsletter;
· An annual conference ( The 7th is at RCGP in 2014)
A special seminar was held in 2013 to help define the role on Named GPs for Safeguarding Children and prepare a position statement on primary care safeguarding. Membership has grown year by year from 24 in 2007 to 70 in 2014.
For details of membership contact: firstname.lastname@example.org
Vice Chair, PCCSF