Trust Special Administrator
South London Healthcare Trust
Sidcup KENT DA14 6LT
12th December 2012
FORMAL RESPONSE TO YOUR DRAFT REPORT
Firstly, I would thank you for your time and courtesy in meeting myself and Bala during the course of the preparation of the above. Unfortunately, I fear that these may be the only kind words that I am able to include in this document.
Your recommendations relating to University Hospital Lewisham (UHL) are totally unacceptable and I reject completely the future you have set out for UHL. Your appointment as the Trust Special Administrator (TSA) is for the South London Health Care Trust (SLHT) and whilst I accept that you believe that you have been pursuing, in good faith, the remit provided to you by the Secretary of State, it is my understanding that the chosen legal process (Section 65F of the National Health Act 2006) under which you have been operating, does not provide lawful authority for you to be prescriptive on clinical services provided in UHL. Furthermore, your recommendations do not satisfy the four tests promulgated by the Prime Minister, the two Secretaries of State and the Parliamentary Under-Secretary at the Department of Health.
Your proposals will result in the destruction of UHL, a hospital rooted in its community; that enjoys a great deal of support across the board, which is being demonstrated yet again through the TSA consultation process. It delivers a much needed, high quality service to its population and it has a deservedly high reputation. It is NOT in financial difficulties as you have suggested in your report and it demonstrates an excellent record of improving care whilst meeting financial and clinical targets over the past six years.
It has also achieved the following :
- Strong commitment to safety, quality and patient experience[i]
- Rated in Top 40 hospitals nationally by CHKS for last 4 years (clinical effectiveness, patient safety etc.)
- Strong record in achieving national and local performance targets
- Operationally lean – Reference Cost Index – most efficient Trust in South East London delivering financial surpluses for last 6 years
- Successful integration of acute and community services, and strong links with social care, people of Lewisham are already reaping the benefits.
- Reputation for strong and successful partnership working – with Commissioners, GPs, the Local Authority and with our patients and staff
- UHL, with NHS London’s encouragement, pursued actively the Foundation Trust application and completed extensive assessments.
Your hurriedly cobbled together draft report, while it cost well in excess of £4m, is thin on evidence for the conclusions that you have reached particularly as they relate to UHL. You have NOT made the clinical or financial case for your proposals and the clinicians in Lewisham, including the PCT Public Health department, have convincingly set out the flaws in your report and the devastating impact it would have on the people I represent. I am not going to rehearse them again in my response, but what I will add is that wishing to close and disperse the current services that are vital to the community in Lewisham which are demonstrably excellent and judged to be so by a range of external bodies, is nothing short of vandalism.
The financial pages are full of unsubstantiated assumptions, no evidence or explanations are advanced, so it has not been possible to validate them. However within the financial pages there are some glaring errors that make me question the validity of the rest of the financial case. A business case without any risk or sensitivity analysis would never be acceptable yet your proposal to demolish UHL is based on just such a case. Your flawed financial assumptions and conclusions lead to risky and unsafe recommendations for the health economy in Lewisham as demonstrated by the following points.
1/. Appendix K, page 25 sets out I & E forecast for 2012/13 to 2015/16 for the Lewisham site. These numbers suggest a gap of £600k and £3m if, the 1% surplus requirement is included. This £3m is only 1.25% of income. Well within the margins of accounting spread. Yet you use these conclusions to pronounce that UHL is financially unviable.\cont
2/. Appendix K, page 31 suggests that the cumulative effect of recommendations 1 to 4 yields a saving of £69.8m. The deficits aggregated from Appendix K pages 22 to 24 for the SLHT is £74.9 (502.8-427.9), giving a difference of just £ 5.1m. Why are you exposing the whole health economy to all these risks and uncertainties just for £5m?
3/. Appendix K, page 38/39 suggest a Capex spend of £ 55.8m at Lewisham, a one off income for the land sale as £17m net and a recurrent annual saving of £22.4m. Of this, £12.3m is PDC and non PFI depreciation, which is simply an accounting device and not real hard cash that the tax payer would save. Indeed, in any normal business case, you will not be permitted by treasury rules to include these as ‘savings’. Further I’d suggest that you have overestimated the sale price and the land available for sale.
4/. If the recommendations are implemented, £55.8m will be added to the current PFI debt of £55m (devalued from £69m). This is in addition to the debt of £12m+ £2m that was incurred in building the UCC and A & E, Birth Centre, HIV and Haematology clinics etc. The PFI annual repayment would be well in excess of £16m. Clearly this additional cost will be unaffordable, given that
your proposals will be taking away between £90m and £100m worth of work from Lewisham. Your proposals would add Capex of £77.3m in SE London just to close UHL as a main hospital.
5/. There is no evidence to support the assumption that all hospitals (except Guys) will use Lewisham for their non-complex elective work. The mechanisms for sharing of the revenue and expenditure are also unclear.
6/. If King’s College Hospital (KCH) acquires the PRUH, and the efficiency savings are achieved, that would create sufficient capacity at the PRUH to deal with the non-complex elective work there and not at UHL.
7/. Discussions I have had with the CEO of GSTT leads me to believe that centralising the non-complex elective work at UHL would be difficult, if not impossible, to achieve given the diverse demands of the stakeholders such as CCGs, Hospitals, and patients.
8/. Appendix K page 38 assumes that theatres will operate 6 days a week 12 hours per day for 50 weeks which has not been implemented in any other NHS institution. This mode of operation is more costly than current practice. There is no evidence that your financial modelling includes the additional cost for Saturday and extended day working.
I would also contrast the vastly more favourable manner in which KCH is treated in relation to PRUH compared with that of UHL and QEH
I would expect to see a robust business case for the £65m being suggested as the “transitional payment” to be paid to KCH for the acquisition of the PRUH. The prescriptive approach to service change is not the way to achieve high quality services or instil ownership in those charged to deliver the services changes. I am broadly neutral on the merger of UHL and QEH, so long as it does NOT adversely impact on services currently received by Lewisham residents. I must state, in no uncertain terms, that I do not support the detailed and specific service changes recommended in your draft report. This is merely a service reconfiguration through the back door which the Secretary of State has specifically ruled out.
You have not provided the Health and Equalities Impact Assessment (HEIA) statement merely a scoping document. Therefore your recommendations for Lewisham have been made without knowledge of their potential risks and likely impact. Further it is clear that your recommendations take no account of the nature of the population that UHL serves, for, if you did, you would arrive at the same conclusions as the “Picture of Health” review and the Independent reconfiguration panel which examined them in detail.
I believe the current proposals for UHL will have a negative impact on our deprived and vulnerable community in Lewisham. You must assure me and others that every assumption you have made will be revisited and reviewed in the light of the HEIA. You need to be cognisant of the fact that every change in accessibility to a service, any barrier that is created will result in the destruction of local pathways (that clinicians and others have painstaking established), disruption to local services and increased travel difficulties for the people of Lewisham. You make some incredible statements relating to the additional average time to travel to adjoining hospitals, not even the officer who attended the public meeting in Rushey Green from the LAS could support them!
Conversations that I have had with clinicians confirm the cavalier attitude you have taken in this whole exercise. You have repeatedly claimed that you have local clinician support for your proposals. Senior clinicians tell a totally different story. They are angry that you have used them to try to prop up your claim that you have the engagement and support of local clinicians. They feel that they were simply told what would happen, not consulted.
I was part of the delegation to Downing Street that presented a petition signed by some 1000 clinicians in London which included more than 100 Lewisham clinicians and GPs in opposition to your proposals. The numerous responses that you have received must show you that your proposals, far from increasing patient choice, reduces it drastically for the Lewisham population. If you still believe that your proposals are clinically sound in relation to UHL let me refer you to the angry clinicians and their well-argued response.
Finally if your proposals to close the A&E, the Medical and Surgical emergency care, Maternity services, Children’s services and Critical care are carried out in UHL, I do not believe that the quality of services to the people of Lewisham would be maintained, never mind improved and in the medium term it will result in the loss of the facility to the NHS.
I urge you to abandon your drive to demolish UHL.
I also append letters/e-mails from 37 constituents who may, or may not, have contacted you directly themselves. Bala, of course, is also a Lewisham resident and his support for this letter should also be noted.