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No Equalities Impact Assessment was done

The Trust Special Administrator did not perform a Health and Equalities Impact Assessment, despite government guidelines requiring them to.  Below are some of the key issues with not providing this report.  Not only does it not allow the people of Lewisham to respond to the HEIA, it means the TSA may process may not account for the demographic diversity across South-East London.

Health and Equalities Impact Assessment          

TSA’s Draft Report, Appendix H HEIA Scoping Report                     (page references to Appendix H)


  • The TSA has not performed any health & equalities impact assessment prior to the end of the consultation period
  • Appendix H scopes what should be done but has not started the assessment
  • TSA proposals have therefore been developed without knowing the potential impact
  • Matthew Kershaw has confirmed that when the HEIA assessment is completed it will be after the closure of the consultation period[1]
  • The Secretary of State for Health will receive the HEIA but the public and Lewisham Healthcare will not be able to respond
  • This is fundamentally flawed and unjust and the failing is in the context of Lewisham and Greenwich being amongst the most deprived local authority areas in the country whilst Bexley and Bromley are amongst the more affluent (notwithstanding small individual pockets of deprivation within Bexley)
  • TSA report refers to benefits of super-centres for stroke, heart attack, vascular and major trauma emergency as an argument supporting the loss of Lewisham’s A&E en route to better care; ignoring the vast majority of urgent medical situations of the local population, many of which are linked to deprivation and the specific needs of a multi-ethnic population such as Lewisham, a few examples being:
    • Diabetic crises
    • Bleeding in pregnancy
    • Sick children
    • Sickle Cell crises; etc
  • No serious assessment of impact on access to A&E healthcare for Lewisham residents has been done: estimates are based on travel at times when there is ‘no traffic’ (Table 4)  p25
  • Barriers to access put before a vulnerable population will harm health
  • No health equalities assessment = no credible proposals



  • The TSA makes no recommendations on children & young people in South-east London and Lewisham – 20% of the population of 1.5 million – and
  • The TSA relegates CYP down to the level of afterthought, to be picked up in the HEIA stating that: “The HEIA will need to consider the potential impact of the recommendations on children and the younger population”                                                       p29



  • Lewisham and Greenwich share high levels of deprivation and associated vulnerability
  • Linked to this, of the four boroughs of Lewisham, Greenwich, Bexley & Bromley:             p18
    • Lewisham has the youngest average age
    • Lewisham & Greenwich share the worst life expectancy for males; Lewisham has the worst for females
    • Lewisham (16th) and Greenwich (19th) have the highest ranked level of deprivation compared to Bexley (180th) and Bromley (217th) – ranked amongst 326 local authorities in England
  • Lewisham and Greenwich have the highest population of people of black and minority ethnic communities by far
  • For children & young people
    • The highest birth rate                                                                                                    p33
    • Lewisham has the highest population of children under 5                             p27
    • the youngest age profile of children under 16
    • Greenwich (19.3%) and Lewisham (8.4%) have the highest projected growth of population (Bromley, 4.6%; Bexley 3.5%) over 2012-22                                           p38
  • Lewisham has the 2nd highest teenage conception rate in London & joint 3rd highest in England                                                                                                                                                 p33
  • Lewisham has the highest disability rate (20.4%) amongst adults 16-64                   p31




Appendix H

Summary statistics for the south east London health economy Table 2 P18
Incremental travel time from Lewisham to other hospitals (no traffic) Table 4 P25
Population age Table 5 p27
Percentage of people in working age who have a disability Table 6 P31
Population by ethnic group Figure 10 P32
Births and total population Table 7 P33
Projected rate of population growth by ethnic group 2012-2022 Table 9 P38



Health and equality impact assessment categories

  1. Patient outcomes
  2. Care closer to home
  3. Patient experience
  4. Travel considerations
  5. Integrated pathways
  6. Psychological barriers
  7. Patient choice



Tony O’Sullivan

[1] Verbal confirmation at consultation meeting on 19th November 2012, at St Andrew’s Centre, Brockley, SE4

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