We have now submitted our response to the Scottish government’s consultation on guidance for the implementation of the Health and Care (Staffing) (Scotland) Act 2019.
In our response we comment in detail on a range of aspects of the guidance, but one of our main issues is about training for nursing staff.
The guidance is intended to make clear in non-legal language the requirements of a piece of legislation that is complex in places. It is not a training manual for frontline staff.
So, as we make clear upfront in our response, employers must make good on their duties to train nursing and other staff with resources that are accessible and easy to understand.
We had extensive engagement, as a key stakeholder, with Scottish Government on the draft guidance, prior to the public consultation. That meant that over 70% of our comments had already been addressed. However, in our response we highlight issues including the role of integration authorities, the status of nursing students, calculating agency costs, reporting, defining risk and the status of bank staff.
Commenting on our response, Eileen McKenna, RCN Scotland Associate Director, said:
“First of all, I would like to thank the many RCN Scotland members who shared their views of the guidance with us over the past few months. As staff whose roles will be heavily impacted by the guidance, their insight is invaluable. Only with their expertise have we been able to scrutinise the guidance to make sure it is fit for purpose. I hope the Scottish government will take full account of our response to help ensure implementation of the Act from next April is as successful as it needs to be.
“Implementation of the Act has been a long time coming. It remains important that we have a baseline to start from, against which the Act’s effectiveness can be measured. In our 2023 Nursing Workforce in Scotland report we asked for this, and we look forward to seeing that baseline by March 2024.
"We have serious concerns about the stubborn level of vacancies in nursing posts and how that will affect implementation. Thousands of registered nurses are missing from teams across Scotland, impacting on the safety and quality of patient care. This puts even more pressure on staff who are already working extra unpaid hours to cover gaps. We know that nursing staff often go home feeling that they are unable to provide the quality of care they want people to receive. There is a lot of work still to be done if the Act is to have the positive outcomes we expect from it.”
