Cynulliad Cenedlaethol Cymru

Prynhawn da. Welcome to the Equality and Social Justice Committee. All Members are present; I've received no apologies. Are there any declarations of interest? I see none.

We're going to continue our Stage 1 scrutiny of the British Sign Language (Wales) Bill. I'm very pleased to welcome Angela Hughes from Cardiff and Vale University Health Board, Sarah Morley from Velindre University NHS Trust and Michelle Fowler from Velindre University NHS Trust. Angela, I just wanted to start with you, to tell us how well you manage the service for BSL users at the moment and what are the main barriers that you face to ensuring that Cardiff and Vale health board's services meet the needs of BSL users. Could you start by telling us exactly what your role is, please?

Thank you. My role is assistant director of patient experience at Cardiff and Vale health board. I manage complaints, claims, inquests, volunteers, chaplaincy, bereavement and feedback within those teams.

I've been involved with our deaf community for several years and working with them to look at how we can best support their needs within healthcare. I think it's very fair to say that they're a community that needs support with access to services and actually having the same rights as somebody who's hearing and using those services, and often it isn't recognised. I think it is challenging still and I think one of the biggest challenges that we do face is the small number—between 52 and 56; the numbers do change—of BSL interpreters across Wales. BSL is a language that doesn't always lend itself to the online services. We do use online BSL interpretation, but it is a very visual three-dimensional language and actually is often better delivered in person.

But we recognise that healthcare isn't always planned, so we have to have devices available, for example, when there are emergency needs of people or within primary care when, perhaps, somebody has an appointment on that particular day or emergency care. So, we do use things like iPads, if you like, on stands that we can wheel around and actually use. Some people do like the use of that, some people don't. Some of the community tell me that they like the anonymity, because often, interpreters are quite well known because they're quite a small number of people, and healthcare can be a very private area that people like that confidentiality with. Sometimes, you do need an in-person interpreter, and as I say, the challenge is often the numbers of people.

I think the recognition of staff for the needs of people who use BSL or also the deaf community who don't use BSL, because there are many deaf communities who lip read, for example, and don't class themselves as BSL speakers. So, it is quite varied and often it is that awareness. Pre COVID, we did a lot of training for several thousand of our staff, actually, in BSL awareness, which was delivered by people who were deaf, and that was really effective. But I think it's something you have to maintain and you can't do once. Then you have to have the services available to actually meet the need, and I think that is challenging. I hope that answers it.

We'll come back to some of those things, as Members have different areas of questions. But before I pass to the other two witnesses, could I just ask you to say how many BSL users you have in the Cardiff and Vale health board? Do you have a number that you could say that this is the community that would be benefiting from this Bill?

The approximate number that we work on is around 2,000 people who use BSL in the Cardiff and Vale area.

Thank you, that's very helpful. If I could now turn to Sarah and Michelle. I wonder if you could both, at the beginning of your answer, say what your role is. So, if I start with you, Sarah Morley.

Yes, absolutely. I'm the executive director for organisational development and workforce for the trust. I've got executive responsibility for equality, diversity and inclusion. This sits under my portfolio at board level.

Thank you. Michelle Fowler, what is your role in Velindre health board?

Good afternoon, everybody. My role within Velindre is equality, diversity and inclusion manager for the organisational development for Velindre workforce.

When a patient is referred to Velindre for your specialist services, presumably the referrer, the other health organisation, will disclose whether that person needs to use BSL as their main language.

If I can come in there. I think that's a really good question. We run two services: one national in the Welsh Blood Service, and then, as you say, in terms of cancer services for the south-east Wales region predominantly. Because we deliver part of the pathway for cancer in that area we very much rely on that information getting passed through. I think what we'd accept, and this goes similarly around Welsh language needs and other needs, is that that information doesn't necessarily flow through the patient record. Sometimes, that information is needed to be asked for again, or it can't be completely relied on to flow through all of our operational patient systems.

We know it's something that is needed, so that we can rely on that record 100 per cent wherever and whatever part of the system that you join or you interact with. I think that's true of health systems in general. I know you've got colleagues from Digital Health and Care Wales joining you later on. I think that's really one of the challenges for a whole range of issues where we would like to be able to rely on information being collected once, and we can then plan to deliver appropriate, in this case, BSL services when we say 'Book an appointment', because we know we need to do that way upstream, rather than relying on the individual necessarily to ask or request that. So that, I think, is not there all of the time at the moment.

Thank you. And what role, Michelle Fowler, do you play when Velindre receives a referral for a patient whose main language is BSL?

If I'm honest, within my role, it's mostly focused on workforce and staff, not necessarily patient and donors. But for patients and donors themselves, there are gaps there and there is a lot of work that needs to be done to be able to improve those issues. As Sarah said earlier, with regard to the information being passed from care service to care service, it's not necessarily passed down, it's not consistent.

And are there other BSL users in Velindre who are able to communicate with patients in the event that Velindre has not been told that they're BSL users?

At the moment, if I'm honest, we don't know, out of our workforce, who can use British Sign Language. We do tend to book interpreters to come along, but, obviously, we tend to use interpreters internally a lot, because we use them as a system, if you like, and they are available on a nine-to-five basis via the video relay service. A lot of the time, deaf patients who are British Sign Language signers will get their appointment letters and they don't know if an interpreter has been booked. So, they have that anxiety going into an appointment already and that uncertainty of whether or not somebody is going to be there, and they themselves then have that added barrier of not being able to ring and find out if an interpreter has been booked. So, we wanted to make sure that our service is as accessible as possible, in order that BSL is at the same level as Welsh and English. So, that's why we've provided that online service so patients can contact us.

Thank you. Jane Dodds. 

There are staff in similar roles, but I suppose it depends on the member of staff and whether or not they are patients or staff themselves. I just focus on staff and workforce within my role. The equality leadership group that we have, we have regular meetings with them, but they're all hearing people. I'm the only deaf staff.

Julie Morgan.

Prynhawn da. I just wanted to follow up what you said about transferring the information from care body to care body. What exactly is the block that means that it doesn't actually get transferred?

Being a non-technical person, my understanding of that is twofold. Maybe not all of the systems actually necessarily capture or have fields within them to be able to capture that information, but then it's about consistency of recording of that information. It depends whether or not somebody has decided to communicate that across any system they can have. I do think that embedding the need to take these things is vitally important when people interact with health services, because ideally, from the point of primary care, that information should flow through, shouldn't it? We shouldn't need to have to capture it at lots of points of contact. But I think, at the moment, that whole joined-up system is not necessarily there.

We'll pick that up with our next panel, which is Digital Health and Care Wales. I just want to move us on a bit more briskly now. Could you just tell us what your involvement has been in the development of this Bill, if any? Briefly, Angela.

Thank you. We did provide some feedback initially when this Bill was suggested. It's certainly something, when I meet with the deaf community, that we've talked about, and I know that they're very enthusiastic and have very strong views around this coming forward.

Thank you. Velindre—Sarah and Michelle.

We did provide a response to the consultation. That's been my only involvement.

Thank you. Michelle Fowler, have you had any involvement in the development of the Bill?

Yes, we were respondents to the consultation, as part of Velindre.

Thank you. Starting with Michelle, could you tell us what your overall views on the Bill are and its provisions? 

For me, and my view as a deaf person, from a deaf perspective, yes, we need that legislation within Wales. It is important for BSL signers within Wales to have that health inclusion and to be able to challenge the organisations when we need. For the equality law that we have currently, that BSL aspect is not strong enough. I do feel that this BSL Bill becoming an Act is going to add that strength to it. I feel it's important because the BSL community has been engaged about different things for so long. They provided their feedback, they provided their views, their experiences, they've been involved in consultations, but, from that consultation, the actions that have been taken have been tokenistic and haven't really had an impact. I feel this Bill will do that, especially because things like complaints procedures aren't accessible for British Sign Language signers. There are gaps within the health service and within other services that may be covered by this Bill.

The Welsh Government issued new guidance to health boards and trusts on 22 September, so just two or three weeks ago. If this legislation were not to go ahead—and we are certainly going to play our part to make sure it does—could the aims of the Bill be achieved through reinforcing the obligations outlined in this new guidance?

No, I don't feel it could. I feel it needs to have an Act. It needs to be in legislation to make sure that it has that power and that robustness, exactly the same as the Welsh language.

Very good. Angela Hughes, what's your overall view of the Bill and its provisions, and could you also answer whether you think the objectives could be met by other means, were this legislation to fall?

I think the Bill is very important because of its recognition. I think it gives recognition to our BSL communities and their rights, and, actually, I think that's really important. I think it does have to work with some of the existing legislation. So, accessible standards, I think, have a part to play, as do the equalities. I would say, from a complaints perspective, we do currently have regulations. That system can be made accessible to people who are BSL users. We've had our phone line in Cardiff and Vale for a long time where the deaf community ring and they're put through a system where they see the BSL interpreter on their phone and they have the same access as a hearing person. I think what we should be doing, actually, is making those systems accessible. I think that's really important, and I wouldn't want to lose that.

But I would agree with everything that Michelle said. I think, for a long time, we've talked about improving things for our deaf communities, and lots of organisations have done different things, but actually giving it this platform and this legislation, and having to report against it, feels that it will progress that. I do think we need to capture the information at the source, so when people tell us they're deaf, wherever they're seen in healthcare, that should be following through. The same with education of children as well—it absolutely needs to follow through that process all of the time so that we're always recognising that need.

Thank you. We're going to now look at specific aspects of the Bill. Julie Morgan, would you like to ask your questions?

Thank you. How confident are you that your organisation will be able to successfully complete the requirements in the Bill, and how much time do you think that would take? Shall I start with Angela?

Thank you. I think there will be some challenges with implementing it. I think there are resource issues. I've said about availability of interpreters, and I think there's a huge cultural change, but that awareness with staff as well, I think, is really important. So, I think it will be challenging, but often the right thing to do is challenging, and this is absolutely the right thing to do. So, we need to meet the challenge, but I don't underestimate the resource issue and the time that that will take.

Thank you. And Velindre.

Yes. Shall I go? I think I'm confident that we could absolutely meet the requirements of the Bill over time. I think the constraint—and this is as Angela's referenced, really—is the availability of interpreters in the system. We've got a very small number across Wales. Every health, education and local authority system is going to be pulling on that same resource. To my mind, this is why, hopefully, a Bill will enable a system-wide view of the availability of interpreters, as one example, but also a system-wide look at our systems, so that we can use every technology that's available to us as well as using people for that, because it's about how we make the best use of the resources that we can, and, obviously, we have got more technology now than we've ever had. I do think it's going to take time to embed that and, clearly, the pull on resources is considerable across health, and it's how we make sure that we can prioritise the appropriate resource to devote to this, both human resource and other resources, to make sure that we deliver the very, very best service that we can for patients, but also that we open up the world of donations for blood services across Wales, as far as our service is concerned, because that's something we're very, very keen to do as well. So, I think, yes, it's absolutely going to be a challenge. I think the Bill will put the commitment front and centre, and it's about how we can, all of us, across the system then join up with our plans of implementation to make the best use of it as we can across Wales.

Diolch for that. Michelle, do you have anything to add to that?

No, I've got nothing to add. Thank you. I think Sarah and Angela have covered everything.

Okay. Thank you.

Julie, Jane Dodds just wanted to ask a quick question.

Shall I go first? We don't keep that data, as far as I'm aware. So, that's a really good question, isn't it, in terms of the gap. We can't identify that. 

Angela.

Thank you. The only data that we would keep would be if we had asked the Wales Interpretation and Translation Service for a BSL translator and we were unable to meet that requirement—that would be kept. And I think WITS keep that for the whole of Wales, that information, so that is there. The other thing, obviously, is in our concerns process, where we've had complaints where we've not met a need, and then, obviously, we do keep that information as well.

Thank you. Julie.

Several public bodies have suggested that the reporting duties set out in the Bill could be aligned to existing reporting duties, such as those required as part of the public sector equality duty. So, what reporting are you currently required to carry out, and how well would that align with the duties under the Bill? Shall I start with you, Sarah?

Yes, absolutely. What the Welsh Government have worked very hard to do, I think, over the last year or so, is try and align as much of our reporting against various different elements in the equality, diversity and inclusion space against the strategic equality plan reporting, so that there isn't a variety of requests coming in at different times. But above that, we are also required to submit an annual report for the Welsh language and also against the well-being of future generations Act. So, there are other reporting mechanisms, as well as against the strategic equality plan. But I think the more we can align those things, the better, because it's very often similar people who provide the reports, and there is cross-fertilisation between them as well. That would make more sense, I think, when the Welsh Government is scrutinising the reports, and also when we are getting that feedback.

Thank you. Michelle, have you got anything to add?

I think Sarah's covered everything. Thank you.

Angela.

The only thing I would add is probably the reporting that we're now starting to do under accessible standards. I think, as that's embedding, we are reporting through that. BSL would be part of that, but I think the problem is it sometimes gets lost in all of the other reporting. But some of the things that we report on and do there—for example, multiple ways to make contact, et cetera, with us—do help our BSL community as well, and when we add in text and e-mail, et cetera.

Thank you. The Bill would require listed public bodies to report on the implementation of their BSL plan within 12 months of its publication. Have you got any views on this timescale? 

Shall I go first? I think it's important to actually have that first look at 12 months, and that then would provide the opportunity for first sight of the plan overall. But in terms of how far along the implementation would have gone at that point, that's probably still quite early. But I think it's important to have that annual look.

Right. Thank you. Angela.

I'd absolutely agree with Sarah. Thank you.

Right. Thank you. Thank you very much, Chair.

Thank you. We'll now take a five-minute break to enable the interpreter who's working with the public to have a brief respite. We'll be back in five minutes.

I'd now like to ask Mick Antoniw to ask the questions that he's wanting to ask.

I only have a couple of short questions. Some of the issues that I wanted to ask about—the national BSL strategy and guidance—have partly been covered. In terms of the Bill itself, you will have seen the Welsh Government's guidance, which was issued in September, obviously anticipating the legislation, possibly, but also fulfilling obligations under the Equality Act 2010. In respect of that guidance, to what extent are you satisfied with that guidance, and how much further do you think the guidance should go once this legislation, presumably, is concluded? 

Who do you want to speak to first, Mick? 

Well, really, to either—whoever feels most comfortable answering it.

Shall I begin?

Yes. Sarah Morley, you begin.

Thank you. So, I think that the guidance is really welcome, and the refresh of the guidance, especially, is very welcome. But, in terms of how much further it needs to go, that is, I would say, about drawing that system together, as I said earlier, so that any future guidance could really illustrate how that might work. I would certainly say that that would be a huge benefit that we could see in future guidance.

Sometimes, it's quite difficult for different stakeholder groups to have a natural place where they come together. So, the guidance might help illustrate that by identifying best practice that is already in the system, but also maybe illustrating how we could put new practice in place to best use this Bill as a launch pad for the development of that future approach. So, I would say that that is definitely, for me, an additional step that would be very good to see.

Yes. Did anyone else want to comment? Otherwise, I'll move on.

I think that we need to hear from the Cardiff and Vale health board. Angela.

Thank you. I think that the guidance, I agree, is around operationalising it, isn't it? It's the 'how do you take this forward?' I think that you need the Bill to legislate it, if you like, and then the guidance will further become that operational tool and model that you're able to use. So, that's where I would see the guidance developing more in line, as this goes forward.

Mick, can I just come in and ask about the guidance, if you're planning to move on to something else now?

No, no. Go on. 

We're disappointed that the UK Government has yet to issue guidance on a Bill that was passed in 2022, so we are minded to recommend that the guidance has to be published in a certain timescale in order to avoid that happening again. I just wondered if you could briefly tell us how long that timescale needs to be to enable people to respond to drafts, so that we get it right and everybody knows the direction of travel. 

If I could respond to that, I think you're absolutely right in terms of there needing to be a definitive timescale. I think 12 months makes sense in my head, because that’s a clear message to the deaf community that this isn't going to just be a piece of legislation sitting on a shelf somewhere, but is something that we are going to immediately start to enact. That first step, as you say, is the development of the guidance and really engaging all of the stakeholders. That timetable can be drawn up in advance—I am talking theoretically now—so that that can really hit the ground running, because I think any lag time is a negative message into the system, and we don’t want that to be the case when there has been a huge achievement with the passing of the Act, as it would be then.

Okay. Michelle, before I go to Angela, is there anything you want to add?

I've got nothing to add, really, but I just think the Act needs to be in place and show that, if there is any delay, then obviously it has consequences for the deaf community. So, the guidance is needed in order to move that Act forward, I think, for the deaf community.

Thank you. Angela Hughes. 

I think I would just add that, even though we are talking about 12 months' time, actually there are still things that you could do almost with immediate effect, and I think for our communities, we need to be taking action quickly. There are lots of things that are already happening that I am aware of that people will be able to do, pooling their resources, and I think it ties up to having that long-term commitment as well. So, what does 'good' actually look like moving forward? I think that is where the guidance will support that development, but I think there has to be action quickly as well.

Thank you. We are having technical difficulties with the sound, Angela, so do we need to take a break? Yes. Can we just take a technical break to try and resolve this? 

Mick Antoniw, would you like to resume your questions to Velindre, please?

I certainly will do. Obviously, the guidance is crucial, in that it pulls together all those areas of advice and activity, and so on, that are taking place to provide some sort of cohesion. You mentioned earlier, of course, the opportunities there are now with technology and so on, but the issue of consistency across different public sector bodies, all of which have to relate to one another, how do you think that is going to be covered within the guidance? What do you think actually needs to happen to pull all that together? Because it's one of those things that it's easy to say, 'Let's do this', but we're talking about quite a diverse number of different organisations that all interact with one another in one way or another. Do you think the Bill is going to be capable of pulling that together? And in what way should the guidance then, when it is completed, be consulted upon?

Thank you. If I begin, you're absolutely right. When you think of the technical platforms that are various across different sectors, just talking from a health perspective, we have got some common platforms in terms of communication with our Microsoft Office contracts, which are Wales NHS wide. So, there's opportunity there, I think, for some consistency. How those tools are utilised in organisations, though, can vary and change. So, the BSL signers' experience of different organisations might then be different. I'm talking predominantly there about secondary care.

In primary care, there may be other systems at play. I think one of the pieces of work that needs to emerge within the guidance is how we can define common systems, or minimum viable systems that we should find in place, so that there can be some consistency and that we can actually meet the expectations of the deaf community. So, I think there's a conversation there—a technical conversation, a cultural conversation and a digital literacy conversation to have in that space.

Can I just ask on that? Where do you think the liability would lie for making sure that that happens? Because if it doesn't happen, a lot of the parts of this legislation will just fail to be properly implemented.

I think the liability would lie with provider organisations because they would be subject to the legislation, is my understanding. Therefore, that's a challenge in itself then, isn't it? Because if we're relying on joined-up systems and consistency, but the organisations that are going to be accountable for that are separate and are accountable in separate ways to Welsh Government in terms of health, for example, and are subject to their challenges in implementing that, then there's a conversation to be had there about how we break through that. That's a challenge for us in terms of any joined-up working. When we start to try and deliver services across regions across Wales, there's always that rub, isn't there, between how organisations are held to account for their performance versus how we can best deliver joined-up services. So, I think that plays into the delivery of this Bill as well.

Do you consider that Welsh Government should take, perhaps, the leading responsibility in making sure that that co-ordination takes place?

I think there should be a responsibility there because, ultimately, it's very difficult otherwise to actually join those threads together. So, what could be included to help with that, to break through some of that barrier? 

Okay. The Bill does have provision within it that the listed public bodies have to revise their local BSL plans, and directed by Welsh Ministers. Are these the sorts of circumstances in which you consider that Welsh Government would actually play a role in making sure that that co-ordination happens? Or what are the circumstances where you think Welsh Government would be able to exercise that power? 

I think there needs to be a layer above those local implementation plans. So, there needs to be an implementation plan from Welsh Government that actually then local implementation plans would align with, or hook into. Because without that, it's impossible to deliver that joined-up approach. So, if that is seen as a key enabler, then we can only do that through that Welsh Government implementation plan. If we take the 'Anti-racist Wales Action Plan', for example, there are specific actions in there that are incumbent on Welsh Government to deliver, so that model could be something that could be looked at and replicated in terms of this implementation.

It's one of these areas, clearly, isn't it, where there needs to be clarity as to who's going to do what, who is actually going to make things happen, and legislation is all fine and proper. But I was wondering: do you have anything to add to that, Angela?

Apologies, I've been out of the room having a sound check. Apologies for that; I didn't hear.

Don't worry. I'm satisfied with the answer as we pursued it. It's one of the things I do have concerns about in terms of who makes sure what happens.

Just one final point, then. Presumably, any advice that takes place, any guidance that's issued, needs to have proper consultation on it. Now, that may add somewhat to the timescale, but would anyone disagree with the fact that there would need to be a consultation on the guidance, before it's issued?

No, absolutely not. It needs to be completely credible and owned by all of those parties involved, absolutely with the deaf community at the centre of that, because this is about a journey of trust, isn't it, that actually we're going to improve the accessibility of services. So, we need to start that journey of trust with the development of the guidance.

Okay, thank you. That answers my questions. I don't have any further questions, Chair.

Thank you. Before we move on, I wonder if I could ask Michelle whether there's some sort of kite mark for interpreting, for health interpreting, because it's very different from education interpreting.

At the moment, with regards to interpreting, they have their registration qualification badge with the NRCPD. So, the deaf community just know it as a yellow card, and it's the highest qualification that the interpreter can possess in order to be able to interpret in all fields, and that's as maximum as they can go. But, generally, the yellow card is what we as the deaf community would recognise.

Okay. Because when you become an interpreter in the health service in, say, Turkish, I believe there are some sort of standards you have to meet in order to be able to do that. Is that right?

So, obviously, for an interpreter to be interpreting in our health board, they have to be registered with an agency called the Wales Interpretation and Translation Service, and also they need to make sure they have their yellow badge, they have insurance as well, to ensure that if there are any liabilities for misinterpretation, for example, then there is some comeback to that. But that's about it. But they have to have their maximum, registered, qualified, yellow badge to make sure that they are able to interpret in all fields.

Thank you. Can we now move on to questions from Jane Dodds, please?

Thank you. I'll certainly try and answer. I had to turn the interpretation on, so apologies if I missed some of the beginning. I think we would need to do a bit of a stakeholder analysis to be clear that we are communicating with our deaf communities. Also with our translators it would be really important. And then I think also the provision of the online services, the Centre of Sign Sight Sound et cetera. So, I think all of these people would be stakeholders. I did miss the beginning bit of the question, so I hope that answers the question that you asked.

Co-production is quite important, especially to the BSL community. We need to make sure that we're working together, because, at the end of the day, they have that lived experience, they are the experts. Also, we need to ensure that we are having a diverse group who are from grass-roots as well, and not just other members of the community. Because those people who are grass-roots deaf people, their education would have suffered throughout the years. And it's to ensure that we're getting opinions from all across the deaf community and that we're learning from everybody's lived experiences.

Yes, if I could. I completely agree with what colleagues have said. I do think we need to involve key clinical stakeholders in the consultation as well in terms of the implementation within clinical settings so that we can actually see what their understanding is of the best way of making sure that they've got efficacy in their clinical environment in this situation.

We've got a patient representative board, and I think that what we know we need to do is increase the representation from the deaf community on that board, but that board in itself can then really work effectively with us as an organisation. Similarly, then, we need to do something similar with donor panels sitting in the Welsh Blood Service to make sure that we involve the deaf community in that. So, I think that's how we can grow our opportunity within the organisation. We'd be very, very keen to learn from best practice elsewhere, absolutely.

Thank you. So, we've held public meetings with our deaf community, which has helped to form some of the actions and the plans that we've taken forward. We've made our complaints process very accessible to our deaf community. We developed a video with them in BSL explaining the current process in place, and that was shared across Wales. We also, on our patient management system, identify people who are BSL users with their choice of interpreter and record it on there. So, those have all been helpful, but it's not gone far enough, I don't think, for what we need to do.

Representation, I think, in planning and development is really important. So, I'd agree with Sarah's comments there. And I think, taking on board Michelle's comments, it's appealing to the wider community. So, all of our patient surveys, for example, go out in BSL as well. So, we make sure that—to me—it's giving people the same access that they would have as anybody who's hearing, and that's always the aim that we start from, really, taking this forward. But it's certainly something we'd want to do with our communities.

So, I've got my thinking cap on with that. I'm not aware of specific bodies that work across in relation to the deaf community. We have very strong networks in terms of equality diversity and inclusion more generally—Michelle described earlier the equality leadership group and so on—but not specifically looking at the deaf community, or working with the deaf community. But others may know of other things.

And Michelle. 

I’m sure other health boards have, maybe, good practice guides, or something like that, that they use for their local community. But, obviously, my area is working with staff members who work with patients and donors. But how to implement the service to make sure it meets the needs of the deaf community, along the lines of English or Welsh speakers, is something I would work on with a member of staff to implement.

Thank you. We have existing networks across Wales, such as heads of patient experience and service user experience, which do share good practice. They're not specifically around the needs of the BSL community, but it certainly features on their agendas when there is good practice to be shared. So, for example, I know the Welsh Ambulance Services University NHS Trust brought in some of the work that they've done, which has been really helpful.

So, there are existing networks where that practice could be shared, and that's probably where we need to be linking in more, so it features, following this Bill, as part of that regular agenda, really, on those networks. That would be my suggestion, as well as the equality ones that have already been mentioned.

Sioned Williams, would you like to come in?

Thank you. I think you can make a system accessible, which we have done for a number of years. However, you're working with a community who have a very fractured trust within healthcare, and I think that's something that we need to overcome before people raise concerns. So, you could take false assurance to say, 'We don't have many concerns.' I wouldn't take that assurance. I would say, actually, 'Have we made it accessible enough?' Yes, I think it's accessible. Have we communicated that well enough? I'm sure we could always do better. Actually, 'Do people feel they will be listened to?' is an important question, and, 'Will that result in things being done?' We are working with a fractured trust in the community that I think we need to rebuild. And, often, communities that don't feel listened to or engaged won't necessarily raise concerns. So, I think it's far bigger than just having an accessible service. That's important, but I think there's lots of other work to do as well around it.

My view is: we have the new regulations coming in from next year, in line with this legislation. That process should be accessible for all. And somebody who is deaf should be able to raise an enquiry, should be able to go through a panel service, should be able to raise a complaint, because that is their right to do so. But I think we then need to work with them, so that they realise that they can do that, that they won't be lost in the system and that they will be listened to. So, I think there's lots of trust to rebuild.

I just want to respond to Angela's point, and I think she's put it really, really well about engagement and getting things right. Engagement with the community is fundamental. That trust has been lost and does need to be rebuilt with the deaf community. But it's about educating as well, on how to respond to that, because the community like to see examples of things, so that they can gather more information about something like, for example, 'If you make a complaint or raise a concern, this is what will happen next.' So, it's giving them that visual pathway, but just making sure of things like access to the internet as well, because lots of information is on the internet, but it's all English based. So, there's no information in BSL. Obviously, if somebody wants to access it in Welsh, they can access it in Welsh, but they can't access it in British Sign Language. So, those fundamental building blocks need to be put in place first, because it is exhausting when people are trying to find that information. And also, the community like to see things that are easy to watch—so, things that aren't five, six or seven-minute long videos in British Sign Language, because the information won't stick. It needs to be short, sharp and to the point as well, and well publicised, to make sure that people can access that service.

Shall I come in first on that? I think the role of the adviser is welcome. Clearly, there was a commissioner talked about earlier on in the process, which would have given additional credence and powers, I believe. But I think that the role of the adviser needs to be further fleshed out, so that there's a very clear relationship and that that relationship doesn't—. Well, it will evolve, but that it is absolutely clear that the terms of reference are there from the start, because that person will be crucial to bringing to life the guidance and actually then holding people to account for actually implementing against the guidance. So, that's absolutely essential that that is clear.

Am I able to add something? I just want to add and be clear as well that when we're talking about the BSL adviser, I would advocate strongly that it is a deaf British Sign Language signer, because they have that lived experience. If you have a hearing person who's learnt British Sign Language, their experience and lived experience of living in a hearing world is going to be completely different. So, we would advocate quite strongly as the community that a deaf person who uses sign language themselves is in place, because at least, then, it means they have that lived experience.

Yes, thank you. I do think it's a really key role, but I'd agree with Sarah—I think it needs a little bit more information around, I suppose, what their power will be and what the consequences are as well, I think, for organisations. It just needs to be made very, very clear. But I think it's a key role, and I'd agree with Michelle's comments around the importance of having the right person with the right lived experience in that role. It's key.

Yes, can I come in there first, if I may? I think that sounds very non-specific would be my concern, because actually the exercising of its duties, if we think of health, could be wide-reaching. And obviously, when it comes to confidentiality, that has primacy, doesn't it? So, we need to be really clear that the information that's being asked for doesn't contradict that requirement for confidentiality. So, how do we overcome that needs to be clarified.

Yes. I think that could be very open to interpretation, and I think that's dangerous, to be too open to interpretation. So, I'd agree with the feedback that you've received.

Yes.

Yes.

I think so. I think—[Interruption.] Sorry. Obviously, we need to comply with information governance. It all needs to be considered in that context, but I think the more specific we can be, without being so specific, actually, then that it excludes other things—. I know it's very difficult, isn't it, to get the right balance there, but I think it needs more than we have now.

We'll now take a short break to enable the interpreter in the studio to have some time out.

Thank you. Can I now call Altaf Hussain to ask his questions?

Thank you very much, Chair. My area of questions is barriers to implementation. The Bill's regulatory impact assessment, the RIA, estimates overall costs of up to £2.5 million to listed public bodies over a 10-year period to comply with the planning and reporting duties. Do you think additional funding will be required to cover the cost of developing and reporting local BSL plans?

Shall I—?

I think Angela would be great, yes.

Angela, shall we go to you first, then?

Yes, of course. Thank you. I think the reporting of the plans will be a challenge. I still think the biggest barrier is the lack of availability of BSL interpreters in Wales. I think that is a huge issue. So, you can write a plan—whether you can deliver it, because of the resources available, will be challenging. I think there's work collectively that could be done across Wales to look at the online interpretation and other services that would be available, but this will have a resource implication within organisations, undoubtedly. But my biggest concern would be the other resources available to deliver the plan, if I'm absolutely honest.

Thank you. Sarah.

Yes, thank you. I would completely agree with what Angela has said. I think it is definitely that lack of interpreters, but then when we overlay that with the need to train and teach people BSL to a certain standard—. Because, actually, if we had that in place across the workforce, that could make a significant difference to the experience of deaf service users. So, I think that some resource devoted to that would be extremely beneficial.

We have had, a number of times, actually, in my years in Velindre, opportunities for people to learn BSL to a certain standard and people have been enthusiastic about doing that. But I think one of my colleagues said earlier that then starts to wane if you don't maintain that impetus. Similarly, now we're doing something similar. So, we had the first tranche of that about five or six years ago, and that then lost some of its momentum. So, I think some resources actually devoted to that, both maybe a national communications campaign but then also how we employ the skills but develop the skills locally, would be really beneficial.

Also, in terms of resources, then, it is about that need to consider all of those things. We don't know what we don't know. So, by actually working with the deaf community, are there other elements of things we could put in place that, together, would put all the jigsaw pieces together? It's very hard to identify the resources that might be necessary. But I also think that, if we go into organisations with the need to develop implementation plans, where there is resource available, that can only be of benefit. Because often what happens is that new things are put in place and there's no consideration for the impact on local organisations about what that's actually going to mean in terms of resources. So, a recognition of that up front I think would be very, very welcome.

Thank you very much. And how about Michelle?

No, I've got nothing to add to add. I think Sarah's managed to cover everything. Thank you.

Right, okay. Thank you very much. Thanks a lot. Now, the RIA does not do an estimate of the cost of additional measures that listed public bodies may decide to undertake as part of local BSL plans. To what extent will those costs be met from existing budgets, and in what circumstances might additional funding be required?

I think it's very difficult to answer that til you've developed your implementation plan and you've done a review of the resources that are nationally available and how do we use those. It's very difficult when you write an RIA, to be honest; it's very hypothetical. It's far easier to write an RIA when you're six months into looking at the implementation plans. If I'm going to be honest, I think that's a far more honest RIA in these sorts of circumstances, because I agree with Sarah that we don't know what we don't know. We don't know the good practice we can already pull on, and there are lots of things that we can do that aren't so resource intensive, but there are still particular issues with the number of interpreters available, and online just doesn't work, because of the visual element of BSL that is often needed.

So, I think that is a challenge, and I agree with Sarah's comments. You can train people; the problem is people need to maintain their skills in BSL. It's something you have to be doing every day to maintain those skills with it. So, it's not a quick-fix solution, I suppose, is what I would say. Actually, even if we train more people, that will take some time to develop and embed.

Thank you very much. Sarah, you wanted to comment.

Yes, I completely agree with what Angela says. Whilst we do have resources in organisations that are responsible for looking at our broader inclusion agenda and our broader patient experience or donor experience agenda, we can call on that expertise and resource, clearly, but they are extremely busy people. This is something that we would need then expert bolt-on support to actually fully implement would be my interpretation of that. Without that, we're not going to be able to reach the full potential of the Bill.

Thank you very much, Sarah. You have already touched on the interpreters, but some stakeholders have raised concerns that existing services that provide BSL interpretation and translation will struggle to meet the increased demands that will arise as a result of this Bill. How do we overcome this challenge? 

I think this is why it's going to take a long time to fully implement, because, to my mind, this goes back to the education sector. How do we build the need to upskill large numbers of people in the population to actually fulfil the need? This is a fantastic opportunity for people in terms of a career, but, actually, that's a long-term development plan, and that's only one plank of that. But that's absolutely where we've got to devote time, resource, energy and effort, whilst at the same time actually then looking at all of those other more technical elements. This has got to be a long-term systemic change, because we can't just grow people overnight, and if we start pulling on the resources of our neighbouring countries then there are similar issues there.

We know this from looking at how we've responded to Welsh language standards, that the demand for Welsh language translation has gone up significantly and that has led to a massive shortage of translators. We're a number of years down the line with that, aren't we, and we're still really struggling as those standards are further implemented to actually be able to meet that demand. So, we already know that in advance. We've got a bit of a case study there, if you like. So, how do we rise to the challenge of that from day one of the Bill, or of the Act, as it would be?

Angela, your thoughts about it. 

Yes, I think—. I agree with what Sarah said. I think it's understanding what's available, then looking at that you've got a limited resource, where do you utilise that resource with the best effect? I think there's something about if you make services—and I'm talking about all public body services now—more accessible, you overcome some of the need, because actually you can address issues at source, if you like, right at the beginning, because you make it accessible to people who are BSL users. You almost need some sort of triaging then, don't you: where do you actually need to use what is a very limited and precious resource of a BSL interpreter, and where should you be using other resources? And there are needs, confidentiality, cost efficiency—you need to consider all of that, I think, when you're looking at all of those tools available. And then you have to have some guidance for public bodies around what is the best tool to use in particular circumstances. But I think we are starting from a very limited resource that we have available at the moment, and that will have implications on the plan that we can deliver, which may not be as aspirational as the plan we would like to deliver. That could be a longer term aspiration.

Thank you very much. Chair, let me ask the last question, thank you. Do you see a role for the NHS Wales Shared Services Partnership to help health bodies access BSL interpreters and video relay services? Yes, Angela, thank you.

Yes, I absolutely do see a role. I think there's some power in the all-Wales procurement here as well, which I think is something that we should certainly consider when we look at the once-for-Wales solutions around it. But I certainly think that's an area we should be exploring going forward.

Thank you very much. Sarah, your thoughts.

The more we can do together, the better. NWSSP clearly could play a role there. Where we've attempted to do that for Welsh language translation, there wasn't an appetite by all health bodies to actually use that system. So, that's something we need to think about: where people feel that local ownership of the team, of the resource, however we want to describe it, would be better. I do think we'd have to go back around that in terms of the best way of providing BSL interpretation. It depends whether interpreters want to work within that system, as well. Clearly I'm stating some of the obvious, but I definitely think that needs to be looked at as an option.

Thank you very much. Thank you, Chair.

Thank you. Can I just ask an additional question around the level of interpretation required? I've just done mynediad in Welsh, but I'm now on sylfaen. So, how easy would it be, with your idea, Sarah Morley, to have a national communications campaign? How easy would it be to get those who have a receptionist role to have some basic BSL, to understand that somebody needs to have a BSL interpreter—what time their appointment is, that sort of thing—as opposed to the much more complex information that a doctor would need to transmit to somebody who was, perhaps, facing terminal care, which obviously occurs in Velindre? How easy is it to do that sort of basic-level communications with staff who have that front-of-house role?

I think I'll defer to Michelle, if I may, because she'll have a much better answer.

Yes, I understand.

Patients within a doctor setting, et cetera, definitely would need an interpreter. If you're just meeting a receptionist, asking your name, what your appointment time is—that type of thing, basic information—then an everyday BSL course would be fine. But going into an actual consultation with somebody who is a doctor or somebody in that clinical setting would definitely need a qualified interpreter.

But we also have to think about carers as well, because in that situation, it could be that a deaf carer is attending with a hearing family or friend, who they have been looking after, and so they will need the access to information as well. So, for that situation, where they're going into a consultation with a clinical member of staff, then obviously a qualified registered interpreter would need to be had. But things like asking if they would like a drink, or what time their appointment is, or what their name is, their address, that type of thing, receptionists would be able to do a course to be able to do that. Learning the basics would be just fine.

Thank you. Sioned Williams, you had an additional question.

I am aware of the number of staff who, following the training that we did about three years ago, went on to undertake further BSL training. I'm also aware of one who is fully fluent in BSL, and also a midwife whom we have employed who is deaf and who is a BSL user. So, we know about some of our staff.

It's a bit like Welsh speaking, though. Whether people who have done some training would feel skilled enough to do that every day, I think, is another issue, but I am aware of some of our staff who are fluent. Probably, that's something you have to ask regularly to maintain that: have they moved, have they still got their skills, et cetera?

Also, going back to Michelle's point of people asking basic questions—again, when you look at the 2,000 BSL users in Cardiff and Vale, how many of those are in health at any one time? How often would they get to use those skills? There's something about how you maintain it, so that people have the confidence even to ask the simple questions.

I think that there is something that we need to work on with our communities, around what would work for them, how they would best like to communicate their needs. I wouldn't like to put an answer on that, I don't think, without having those conversations, really. I think that that's really important, because that's what we've done in the past— done to, not done with. That's not, to me, what this Bill is all about.

I think that it's important that the BSL community are engaged with, about whether or not something works well. It may be worth learning from their feedback and their experiences about what has worked well and what hasn't worked well for them.

In terms of staff competencies, we don't currently record staff competencies in terms of BSL. What we would need to do is define levels of competency. We can then add that to the employee staff record. For example, as an organisation, over 90 per cent of our staff have actually told us what their Welsh competency is against a number of set levels. So, it's a similar kind of task—collecting that information—but it's absolutely one of our key performance indicators for staff in our organisation.

A similar approach, I think, would be hugely beneficial, because unless we know who we've got and where we've got people, we can't actually involve or use that information to support workforce planning. To my mind, this goes to the heart of our workforce plan, and what skills we need at any time—in certain areas of the organisation more than others, maybe. But we absolutely need to plan that as we take this forward. I see that as the best way of achieving success.

And just to add as well, I think that we have to think along the lines of the Welsh language service as well. That's how we need to take the BSL aspect of it, along the lines of Welsh language, specifically for staff.

Thank you. If there are no further questions from Members, I'd like to thank you very much indeed for your evidence—really useful evidence from the grass roots of delivering health services. We will send you a transcript of what you've said. Obviously, if any of it is inaccurate, please do correct it.

We may also have some further questions about things that you have mentioned in your evidence, after we've heard from the Wales ambulance trust and Digital Health and Care Wales. They may be able to answer some of the more technical things, but it would be very useful to be able to get some of the specific information that you've mentioned that has been going on in both of your organisations.

The committee will now take a short break until 15:15, and then we'll come back to meet the ambulance service and Digital Health and Care Wales. 

Welcome back to the Equality and Social Justice Committee. I'm very pleased to welcome our next witnesses on the Stage 1 scrutiny of the British Sign Language (Wales) Bill. We've got Rhidian Hurle from Digital Health and Care Wales, who is joining us online, and Liam Williams and Kathryn Cobley from the Welsh Ambulance Services University NHS Trust. Thank you very much indeed for coming in.

I'd just like to start—to both of your organisations, but the responses are going to be somewhat different—by asking how you accommodate the needs of BSL users at the moment. Obviously, the ambulance trust is an emergency service, so you may or may not be aware. If so, how are you made aware if somebody is only a speaker of BSL? Would you, when you first speak, like to just say what your role is in your organisation?

Thank you. I'm Kathryn Cobley and I'm head of inclusion and engagement at the Welsh ambulance service. It depends which part of our service that you're looking at. We do have provisions already at the moment to accommodate the needs of BSL service users. If it's an emergency and somebody needs to call 999 and they're a BSL service user, we have an agreement in place with the telecoms companies, and that's right across the UK, so it's the same service that they get. They can contact 999 in an emergency, and that will be relayed to us through almost like a text relay type service.

We're also responsible for NHS 111, which is predominantly a digital front-end service in terms of healthcare and advice. We have some provision at the moment on our 111 website in terms of patient videos that we now have with BSL interpretation. We have built-in accessibility functions such as auto captions, subtitles on videos, that type of thing.

The third part of our service is the patient transport element. If somebody is pre-booking patient transport to transport them back and forth to appointments, that's the area of our service that I feel will probably need the most attention in terms of making a provision for a BSL service interpreter. Similar to 111, when we are triaging and there are call-backs involved in terms of whether it's booking an appointment or having a specialist clinician to call back somebody who's a BSL service user, that can be tricky in terms of how do we do that, because we are dependent upon some form of BSL interpretation, whether that's a BSL interpreter or whether that is a digital technology app or a video call, that type of thing. So, that can be a little bit more tricky, and I think that's the area that we will need to focus on going forward.

Do you keep any data on non-emergency services where you have or have not been able to obtain the services of an interpreter?

I don't believe that we routinely collate that information, and I'm thinking particularly about other languages as well. We will become aware of an issue when a service user raises a concern. For example, if they've pre-booked an ambulance to take them to and from the hospital for an appointment and that ambulance has then been cancelled, a voicemail might have been left on a telephone number that we have. If that's a BSL service user or if that's somebody who doesn't speak English, Welsh or BSL, it's very difficult, because they can't understand the voicemail that's been left. But again, there are solutions for that out there. It's about us being smarter—using text messaging, for example. That would have been much more useful. I think then that comes down to us really looking at our systems, because our systems do allow us to flag communication needs of service users. That is an area that we're improving upon all of the time in terms of flagging learning disabilities, communication needs. So, it's about us using the systems that we've got to implement suitable solutions for people who are unable to access services as everybody else does.

Before I move to Rhidian, is there anything you'd like to add, Liam Williams?

I guess the thing that I would focus on is the register that we have in place. We've been building registers where people have got particular needs, and we've become far more adept at using them, both in the emergency medical service—the 999 service—and in the 111 service. And just to complement what Kat was saying, we've now adopted, in the last few months, SMS as a form of communication, so it isn't down to voicemails for all of our communications out of the non-elective patient transport service. We are using SMS in increasing volume.

The final comment then is on how we are working with commissioners in Wales at the moment to think about what the future communication architecture looks like. So, we've had some support with the digital front ends of our website, our interface with the NHS Wales app, and thinking about how we can use those platforms to better aid communication in the routine sense, even if that doesn't necessarily help us in the first instance in the emergency sense.

What is your role in the organisation?

Apologies. I'm Liam. I'm the executive director of quality and nursing.

Thank you. Rhidian Hurle, obviously, all health boards and trusts rely on your services to be able to maximise the use of technology for identifying BSL users. What services are you able to provide at the moment?

Afternoon. Hopefully you can hear me. Apologies, I'm not there in person. My name is Rhidian Hurle. I'm the medical director of Digital Health and Care Wales. I'm also the chief clinical information officer for Wales.

We—'we' as in Digital Health and Care Wales—provide software that supports both acute and elective pathways across all health boards. Our major product that clinicians use, the Welsh clinical portal, provides access to a number of modules that contain information regarding patients' accessibility needs. And although we are not patient facing and we don't deliver direct services ourselves, as I said, we support services.

I did some statistical review of the software that we provide. We've got 44,000 users across Wales in NHS Wales. That includes some primary care and also the clinical hub in the Welsh ambulance service. The Welsh nursing care record and the Welsh patient administration system have facilities to record the accessibility need of British Sign Language. Currently, we have a completion rate of 0.05 per cent of all our patient population, which is in line with the 2021 census survey of NHS Wales, which was 0.03 per cent. We record that information with international coding of SNOMED, so that it's reusable across any of our software applications. Thank you.

To be clear, when you talk about 5 per cent of patients, are you talking about 5 per cent of patients being deaf or 5 per cent being BSL users? 

Of the patients that we recorded on our system, 0.05 per cent had an accessibility need of sign language. As I said, that fits with the census prevalence of 0.03 per cent of the population in Wales who use British Sign Language, or at least registered that in the census as being their primary form of communication.

Thank you for that information. Okay. I'll stick with you, Rhidian, just for my next question, which is: what involvement, if any, have you or your organisation had in the development of this Bill? 

We submitted a written statement in response to the request by the Welsh Government, which I believe you have. Our workforce and organisational development lead, Samantha Morgan, completed it on behalf of the organisation.

[Inaudible.]—Mark Isherwood, the Member in charge of the Bill.

I didn't quite catch that, sorry.

Yes, we seem to have a slight sound problem. So, that information was requested by the Welsh Government rather than the Member, Mark Isherwood, who's in charge of this Bill.

I haven't submitted anything directly to him, no.

Right, that's fine. So, if I come to Liam and Kathryn, what involvement, if any, have you had in the development of this Bill?

We've had some involvement, not necessarily in the drafting of the Bill, but once the Bill had been drafted, we did submit a response to Mark Isherwood on our views on how practical the Bill could be in terms of its implementation across NHS Wales organisations. We've also held some internal conversations and consultation amongst equality, diversity and inclusion leads across NHS Wales. We meet regularly every other month and there have been some tabled discussions around the Bill there, which we've used to inform individual health board and trust responses to Mark Isherwood.

And overall, what are your views on the Bill and its provisions that will affect your organisation? 

I think it would be very, very difficult for any organisation to disagree with the principles outlined within the Bill. It's definitely something that I think is very, very important to BSL service users in terms of striving to create equality and improve health outcomes, more importantly from an NHS Wales perspective for our BSL service users. I think, listening to the previous session on the call for evidence, what Sarah Morley and Michelle Fowler have said in terms of some of the barriers to implementation in terms of resources, capacity and competing priorities in large and complex organisations, I think all of those comments were relevant, and are relevant from a Welsh ambulance service perspective as well.

But, equally, I was heavily involved in the implementation of and consultation on the Welsh Language (Wales) Measure 2011 and the Welsh language standards, so I think there are definitely comparisons to be made. We are talking about two very different communication needs, though, when we're talking about Welsh speakers and BSL service users. There are definitely comparisons to be made, and I think overall in terms of the Bill, it will drive improvements.

It's a long road ahead, I think, as Sarah Morley said, and nothing is going to change overnight. It is a progressive path to creating those improvements. I think the only comment that I would perhaps make is we've got other pieces of legislation that I think attempt to achieve the same thing. They might not be solely focused on BSL, but when you look at the public sector equality duty, the Equality Act, reasonable adjustments, human rights, the accessible communication and information standards that were published on 22 September, I think we've got multiple pieces of legislation, statutory requirements and action plans that are aiming to achieve the same thing, but they might not be solely focused on BSL service users. So, there's just a little bit of a question from me about: do we really need another piece of legislation when we've got existing pieces of legislation that perhaps are aiming to do the same thing? But in terms of the Bill, I completely agree with the principles of the Bill.

Okay. And Jane Dodds.

I just want to follow up on what you said about the importance of the all-Wales standards that have been published last month. So, in your view, even if this legislation doesn't reach the statute book by the end of this Senedd, do you think we could achieve the same impact by using this guidance, plus other things that we're going to discuss a bit later down the agenda?

Because the standards originally—. The accessible communication and information standards, they were previously standards for people with sensory loss. I think the majority of people have been used to dealing with those previous set of standards, where they were very much focused on people who were deaf and people who were blind. So, I think that is an ethos and a grounding principle of the standards, which have now gone further, which include anybody with a communication need.

I think there is a slight risk, because the new standards encompass all different communication needs, that the BSL might lose a little bit of focus, whereas a specific BSL piece of legislation will provide that sole focus just on communicating with people who use BSL. They both aim to do the same thing for BSL service users, but I do think that the individual Bill will have more focus there, and it may slip in terms of the standards.

But I think my main concern—and I think it's already been raised as a concern—is then how we will be expected to report against it, whether we're going to have a set of BSL standards similar to the Welsh language standards, when we've got the reporting mechanisms already in place for the all-Wales accessible communication and information standards. So, I think that the general consensus amongst equality, diversity and inclusion leads, who are predominantly the lead persons in each organisation who are responsible for drafting and producing those reports, that we don't want multiple reporting procedures against two different pieces of legislation and statutory requirements that are aiming to do the same thing. I think that's very important and should be considered at the outset.

Good to have that on the record.

Yes, if I may, just to complement that. From a trust board perspective, when we're taking significant decisions, we would expect all pieces of work to have an equality impact assessment undertaken, and that's quite an important piece of work that takes place throughout the organisation. It complements the quality impact assessment for service delivery, and as part of that we seek advice, support and guidance to ensure that the changes that we're proposing are not going to disadvantage any particular part of the community, and if there are risks of disadvantage, then we understand what the mitigations may be and how we may be able to do things differently.

So, I think there are multiple pieces of legislation that, through the EQIA, we would look to present to our board, and demonstrate our consideration to the duty of quality and quality-informed decision making, but also recognising that quality-informed decision making is complemented by a full understanding of the population that we're serving.

So, I think there's an awful lot that goes in to try and make sure we do things in a way that is equitable across the population. Legislation helps because it provides focus. All of us would recognise that. I think it's ensuring that what comes forward genuinely enables us to do the right things for the people we're seeking to support and enable, and not get ourselves into a situation where you find yourself trying to balance off different parts of legislation or different parts of policy and regulation, and actually you miss the point of what we're trying to achieve.

Okay. I can go to Rhydian. When Digital Health and Care Wales does its equality impact assessment, how does your prioritisation of your work—? How is it informed by how we are able to meet the needs of the BSL community, many of whom have only BSL as their language?

We would look at the user interface that we provide for our healthcare professionals across Wales, and the signposting and, for want of a better word, nudging those healthcare professionals to understand that the individual with whom they have contact requires BSL. We do this for a number of other things, and a good example would be complying with the language Act, in that we use an icon associated with the demographic of the individual within the user interface that's in front of the clinician, so that they're aware that the preferred language of that individual is Welsh. So, we have the ability within the software to provide iconography or imaging agreed, whatever that may be, to nudge users, so that they will be aware of the requirement of the patient, the individual they're serving.

In the earlier session with Velindre and Cardiff and Vale health board, they did say that it wasn't always the case that somebody whose main language is BSL is being flagged up at any level of the health service, even Velindre, which is obviously a highly specialist service. I wondered if you could explain why the technology is not yet implemented in quite the way we obviously would all like.

The applications contain the data entry points to record the needs of an individual. The contact of the patient to the system requires that to be recorded by someone at some point. The integration, for example, from, perhaps, the primary care system into the different patient administration systems across Wales is not there. However, as I said, the ability to record at an individual local health board is there within the software that we provide. But, ultimately, if someone doesn't put it in, it's not visible.

Now I'd like to call Julie Morgan to have a look at some of the specifics of the duties under the Act.

Just to follow up that issue for a moment, we were told by Velindre, I think it was, that referring from one care body to another was not signalled. Are you saying there is the means to do it digitally, or not?

If you look at the Welsh nursing care record, which is a single instance, that means it's the same everywhere across Wales, that application records the accessibility needs of an individual, and should a patient transfer from one organisation across a health board boundary to another, then that is visible to the nursing staff and healthcare professionals who are looking after that patient. That's different to the patient administration systems, which no doubt Velindre and many other organisations have some frustration about, for want of a better word. Consider these tills that are configured differently across health boards, and therefore your ability to stock control, as it might be, is inhibited by the fact that not everyone records everything in the same way.

Right. It's complicated. I'll go on and ask these other questions. How confident are you that your organisations will be able to implement the requirements set out in the Bill, and how much time do you think it will take to make it fully compliant? I'll start with you.

How long is a piece of string? It's going to take some time. I'm confident that what the Bill outlines will drive improvements, and I think those improvements are much needed for our BSL communities. Very similarly, we saw it with the Welsh language standards. I know the comparisons have been made in previous sessions, but it definitely has driven forward improvements. But as you said, the Welsh language standards have been in place now for some years, and we're still not fully compliant because of, I think, the many, many barriers and the challenges I see to implementing this type of legislation in terms of communication.

They can be very much dependent upon a number of things, including the will of the organisation to implement them. I would like to think that for all NHS Wales organisations, the will is definitely there to implement them, and create and drive those improvements. But I think the biggest barrier and challenge is the resource and the capacity that might be required to implement elements of the BSL Bill and a set of standards that might come afterwards. But equally, I think there are solutions out there, but they will take time to implement.

My personal view is that we're not, perhaps, using digital technology advancements as best as we can in this space in terms of communication in general, but again, there are limitations upon NHS Wales, whether that's financial implications in terms of cost, whether that's compatibility with different pieces of software that are out there, that type of thing. So, I think it's just overcoming all of those challenges.

We've had a discussion as well around competing priorities. This is one area that we would like to improve in terms of hundreds of other areas that we would like to improve. When we've got limited capacity and resource given the current economic climate and the demand upon healthcare services, I think that will make it extremely challenging to make this particular set of standards and requirements a true priority for the organisation. I think that's where then the time aspect comes into it. I think we will be looking at a continual path to progression and improvements, rather than something that we can say, 'Within 18 months, we will have solved this and we will be fully compliant.'

I think there are layers. I think there will be more that we can do in the public health, public information space. I think we'll be able to move more swiftly in that space, because we can do that preemptively. We can work with partners and we can create content that is available and usable across the NHS and beyond the NHS for Wales.

There are digital technical solutions that are coming on stream, and some of those solutions will work for some elements of care, but there is an important differentiation between general conversational care, for want of a better phrase, and that which is related to clinical care, diagnosis and treatment plans. At that point, you need to be working at a particular grade to ensure that you are giving accurate information and doing so in a way that is understandable, and that will be different. Implementation will feel different in different settings.

For our remote care service, we may be able to find a mechanism by which we can make that more accessible. However, at this point in time, for our crews who are responding on the front line in a rural area, that's going to be more complex, because we wouldn't necessarily be able to rely on a digital remote solution, and we certainly wouldn't be able to have a workforce that is fully representative of the whole of society in that form. So, I think we'll find that there are some thresholds around how we can adapt technology. I'm a big advocate of what we could do from a technology perspective, but we need to make sure that we're doing it in a way that is safe and regulatory compliant, particularly to clinical communication and clinical standards.

A final area just to note is that, as healthcare bodies across multiple countries, one of the things that we've sought to do is ensure that we've got independence and consent in how we are working with individuals who are supporting communication. We've quite often in the past relied on family members, friends, people who were communicating, but there's been a shift away from that to ensure that we have the confidence that the communication that we're giving is of a high standard, that everything that is being communicated is truly being communicated, and ensuring that we've got informed consent from the recipient to the conversation that is taking place and that is two-way between the lead clinician and the individual.

I think, in that pathway that Kat has just set out, which is going to be an extended one, there will be some things where I think we will be able to work as an all-Wales NHS to move forward with a little bit more ease, but there are going to be areas where this is actually going to be more complex and require significant investment in one form or another, be that in human interpreter or be that in some of the digital solutions that are emerging at the moment.

Thank you. Rhidian, have you got any comments on this?

My comment would be that it's probably easier for us as a non-patient-facing organisation to enable changes in the technology and the software that we provide to contain information that helps healthcare professionals be aware of the accessibility needs. I'd probably divide it into three areas for simplicity with the committee. One would be the NHS app, for which DHCW are an integral delivery partner. The ability for a patient to enter their communication needs into the app may be one mechanism to increase the availability and visibility of the needs of the individual. There’s national software that DHCW provides, including a patient administration system and a portal. And, of course, we, as a statutory organisation, could respond to the legislation relatively easily to include that in the user interface.

But I would point out that there are electronic healthcare systems that are used throughout NHS Wales that are managed at a local level, that are not integrated into the national systems. Therefore, that information that you might record once—and we would wish them to comply with a 'tell us once' approach—about the needs of the individual may not flow along that patient journey. I’m articulating that because the situation is that we don’t have a common platform across NHS Wales that is configured in the same way everywhere, and it’s that complexity that might take some time to unravel.

Thank you for that. We need to take a break now for five minutes, to enable the interpreter to have some respite.

Julie Morgan, would you like to ask your question?

Right. Thank you very much. Before we went into the break, Rhidian, you were telling us that there is no unified system throughout the NHS. Could you tell us how difficult it would be to get a unified system?

It's not necessarily difficult. It requires the key stakeholders to align to a certain pathway. The cost involved in a single electronic record across Wales would be considerable. I believe current policy leads are exploring options. The analogy I used of tills being configured in a different way across different organisations could be resolved through direction, and that would require, again, policy instruction. These things always take time because there's a change management process, particularly in the health records departments across NHS Wales. These are the departments that are responsible for aligning appointments, particularly in the out-patients. I'm sure all of you are aware of the demand across NHS Wales and the long waits relating to out-patients. So, it's not necessarily difficult, but it does require direction.

And will from the stakeholders—is that what you were saying?

Yes, you could say willingness. My view would be that previous reviews sponsored by the Welsh Government—. I'm thinking of Eric Gregory who did the parliamentary review. He was in charge of John Lewis, for example, and he said, 'When you come and work for John Lewis, we don't ask you to bring your own till.' We should really align our administration systems across Wales in a unified, standard way.

Sioned Williams, you wanted to follow up.

Yes, Sioned. It's due to local choice and how things are implemented at a local level. It's as simple as that. Change management is difficult. Configuring software to fit a local process is probably easier than changing the process. This would be a choice thing. Yes.

One last question, then. The Bill would require listed public bodies to report on the implementation of the BSL plan within 12 months of its publication. What are your views on these timescales?

I'm happy to go. Again, referring back to my previous comment, when you're working within this space, I know we're focusing on BSL here today, but, for me, BSL is one of many of the protected characteristics under the Equality Act, and we are coming increasingly under pressure to develop an individual plan for each individual protected characteristic, and you lose then the joined-up approach to creating equity and fairness for all by almost putting people into different boxes, and it creates multiple reporting, multiple action plans, multiple publications, and then the role of EDI leads within NHS Wales becomes quite bureaucratic in terms of preparing papers, because every time we publish a plan or a report there is a governance structure that they need to go through internally, which often involves multiple committees before it’s approved by the board. The bureaucracy then overtakes the principles, I think, of an action plan.

I think most EDI leads would advocate for one singular action plan, which we have already got under the strategic equality plan. So, the public sector equality duty sets out a list of requirements that public sector organisations have to comply with. We all have to have a set of published objectives. They are broad, they are overarching. I think we would prefer a system where we can include BSL actions or a requirement for us to include BSL action plans in that overarching strategic equality plan and use our annual strategic equality plan reporting mechanisms to report progress against the BSL action plan. It’s something that we find challenging in terms of the 'Anti-racist Wales Action Plan', in terms of having a separate local action plan for the 'Anti-racist Wales Action Plan', and then a set of reporting against that action plan. Then, within that action plan, you have also got your workforce race equality standard, and there’s another report for that. So, you can see how we end up in a situation where we’ve got multiple publications, plans and reporting systems for each of the individual protected characteristics.

If you break that down further, for example, disability, BSL, under the Equality Act 2010 would be classed under that sort of disability protected characteristic. Do we then separate out into other disabilities and have local action plans for varying disabilities? So, it becomes quite complex and places an onus, I think, on organisations to have these multiple reporting systems in place, when I think we could be clever here and use an opportunity to start aligning those reports and report under the strategic equality plan under the public sector equality duty. That would be my preference, and I think that would be the preference of equality leads across Wales as well, following the discussions that we have had in our equality leadership group meetings.

Right. Thank you. Do you have anything to add to that?

No, I think that Kat said it perfectly.

Yes, okay. Fine. I don't know whether you've got anything to say on that, Rhidian.

My clinical experience—and for 30 years, I've been working in NHS Wales, and I operate every Tuesday in the hospital—is that anything that prevents a patient from fully understanding the advice that they've come for and stops them from making an informed decision is a barrier to good care. It's been pointed out that the accessible communication and information standards outline the barriers to good communication. Communication is key to better medicine. So, I'd fully support anything that's put in place. I would point out to the committee that, where there is direction, for example in Welsh health circulars, they carry less weight than legislation, but the problem here will always be: how does one measure compliance and what mechanisms are in place to measure compliance?

In terms of the time frame, depending on the ask from a technical software point of view, we would look at the options and we would give feedback as to what could be implemented with the resources that we have in-house. But, as always, if there is additional resource to prioritise a particular function within the national software, that would be prioritised appropriately. 

Thank you.

Thank you. Can I now bring in Mick Antoniw?

You've answered a number of the points that I was going to ask about, really, with regard to the national BSL strategy and guidance, so I'm not going to go into detail on that. You did say 'complexity'—I'm really addressing this to you, Rhidian, I suppose, because you said complexity might take some time to unravel—and what is meant to be a relatively clearly understood piece of legislation, as we go into it, clearly has an enormous amount of complexity to it, depending upon the detail of implementation and the guidance and so on. There's already a lot of guidance that's in place, but, of course, you have to engage with a whole variety of different public sector bodies to get some form of consistency in the way which you engage with them on this. How exactly will that work? I'm just thinking, Rhidian, this is very much a sort of process issue. What problems do you anticipate or what difficulties do you anticipate? How can we make things simpler?

Thank you for that question. The way to make things simpler is to have a single instance of an application across NHS Wales. When you have more than one, then interoperability and data standards and messaging standards become a debate. And once there's debate, then there often is compromise, and standards are not met. So, Digital Health and Care Wales, as the organisation that provides software for clinical care across Wales, has a number of subject matter expert stakeholder groups. These range from doctors and nurses to allied healthcare professionals—and of course, audiology is a good example of the AHP community. We would work with subject matter experts groups in that area to understand what their need is to provide better care, and we would also engage with those organisations that represent patient bodies, particularly if we were instructed to make functionality available within the NHS app that allows an individual to record their requirement of British Sign Language. So, that would be recording it. The issue, of course, is the availability of the service at the point of care. That is something that Digital Health and Care Wales can't really comment on.

Okay. Thank you for that. I do sort of get increasing concerns about what you're saying, because we know that other attempts to implement simple cross-body technology have turned out to be not only very expensive, but also incredibly complex to implement because of the varying standards and compatibilities that exist. I notice, for example, we still have difficulty transporting medical records from someone moving from England to Wales, for example, and vice versa. Has any work been done on this? Do you think this is actually quite a major piece of work that would need to be done to actually do this? Can you give me an idea as to really how difficult, how complex, how expensive what you're suggesting could be done actually would be?

Mick, apologies. Could you just go into a little bit more detail as to what you are asking me to answer?

Okay. We're talking about trying to have a simple system that goes across bodies, that is compatible with different systems, and my understanding is that we don't really have that technology there at the moment, so we would have to create it to get a sort of consistent application of guidance and accessibility. Does any of that work exist? How complex a process is that?

The ability already exists to record something specific to the patient, and I referred earlier to the Welsh Language Act and the ability to record patient preferences, but that is in the national software. The Welsh clinical portal provides clinical information to 44,000 users across Wales in all health boards. So, through the applications that are controlled directly through the Welsh Government and the instructions that come to Digital Health and Care Wales, that's relatively simple. To reiterate my comment, the interoperability with systems that are outside of that governance and those standards, and the legacy and the age of that software, for example, that becomes a barrier to, 'Tell us once and, wherever you go, that information about you will be available in that software that's used for that particular condition care event.'

I think that's partly where I was going, but I don't really want to take that any further with you, because, obviously, there are other public bodies that should be relevant too. Guidance will, clearly, be issued, and I would take it that there would be an agreement that this would be something that would need to be consulted on—that is, it would have to incorporate, ultimately, the views of various groups and users and so on. The Bill might also potentially include—well, it will include—direction by Welsh Ministers, the power to do that. What would you see as specifically the role of Welsh Government in actually seeing that they run out this legislation and its proper implementation? Is there a specific role that Welsh Government should be having within that?

Is that directed at me, Mick?

It's directed at you, but then also at Kathryn and Liam as well.

So, the process of delivery for Digital Health and Care Wales currently comes through a remit letter and instruction from Welsh Government. So, if the remit letter included the requirement to do a particular thing, then DHCW would respond appropriately.

Okay. Did anyone else want to elaborate on any of the complexity of problems that they envisage?

Just on behalf of the Welsh ambulance service, I'd say that the prioritisation for us—. So, the legislation would get passed, we would receive instruction through the joint commissioning committee as to what they are prioritising for us in the coming period, and, against those priorities, we would agree with them how we might go about implementing it.

On the first part of your question, I think, for public sector organisations, it's understanding the priority on which Welsh Government is placing this amongst other priorities that we are being requested to address, and there are many, which is right and proper. But there would be something then about helping us to ensure that we're meeting the priorities of Government accordingly, and subsequently then, leaning a little into Kat's earlier comments, it's then about having proportionate assurance that we are doing everything we can to meet those Government priorities in the round. So, I think that the assurance process is probably what I would anticipate we would need to agree with colleagues here and elsewhere.

If I may, I'll just make one further comment in the data field. I have worked in Wales now for far less than Rhidian—I've been here just over three years—but I've worked in systems where data flows far more cleanly. I just would reinforce Rhidian's point that the opportunity here is to ensure that there is direction over some of the information data standards and how that then drives local organisations with the technology, the digital suppliers they are using, to secure seamless transfer of information.

So, as a trust, we use the Welsh demographic system, we use the Welsh clinical portal. That primarily feeds our remote settings—so, our clinical contact centres and our remote clinicians—and that in turn then drives the information that our paramedics and our emergency medical technicians receive in the field. We are able to do that because we have been able to build our information flows in that form. So, it comes in through DHCW, we understand how they are producing the information, we've worked with our suppliers to then be able to receive that information effectively, and we've then worked with our suppliers to think about how that information can transfer on to front-line crews. So, there are solutions that are achievable, but I think, as Rhidian stated earlier in his evidence, there is a need to create the will for us to achieve that.

Okay, thank you. I don't have any further questions, Chair.

Okay, thank you. Can we now move on to Jane Dodds? 

You're on mute, Rhidian.

I think, Rhidian, the sound engineer will unmute you.

He's not doing anything.

Oh, okay, he's not. Okay. So, Rhidian, do you think you could unmute yourself, please? 

Yes, I can. Can you hear me now? 

Yes.

Apologies, the screen was flashing up with a task and, when I did it, it muted me. 

Going back to where I was, we don't provide patient-facing services, however, regarding the NHS app, we have both key stakeholder engagement with service users, and that includes public consultation at a local and regional level, and we take advice in our collaboration with NHS England. You may be aware that we originally took the code from NHS England for the app. I'd have to come back to the committee with the finer details of, specifically, engagement with the deaf community, as I don't have that information to hand, I'm afraid.

I'll take that and Kat will, I'm sure, fill in further, but, from an accountability perspective, one of the comments I was going to come in on, on the back of Kat's earlier evidence, was that, at trust board level and at trust committee level, there is a very clear line of sight to the work that goes on at the front line, and the work that the PECI team, the patient experience and community involvement team, undertake. So, we will frequently have thematic reviews, deep-dive reviews, that pick up on particular protected characteristics, but also clinical presentations and conditions, quality of care, and often what we will do is look to supplement the deep-dive evidence and data-driven insights with a video that shares the story, the experience, of somebody who has been in use of our services, and I can absolutely say that, having taken those now through our quality committee, our people and culture committee and into our trust board, they have a very profound effect on ensuring that we are, as a trust board, prioritising those that are most in need and those experiences that give us the most cause for concern. An example I will lean into in that space is that we, over the last couple of years, have had increasing numbers of experiences shared where people living with a learning disability have been approaching us who have found some of our systems quite difficult to work with—they can be quite challenging when you've got lots of different complex conditions and different communication needs. So, one of the things that we have done is move to employ an advanced clinical practitioner with a specialty in that field. That's really to help us understand how we can do things, particularly for people living with learning disabilities, but actually what that will also do is really drive a better understanding of how effective communication might better be drawn across the organisation.

So, I feel quite confident sitting here as the executive that is often held to account for how we are meeting the experience of people, the diverse needs of our people, that my trust board, my non-executive colleagues and non-exec chair, particularly, of the quality committee are very challenging of me and of my teams to make sure that we are doing the reach out, that we are thinking about how we innovate, that we're looking at the technology and looking at different solutions that we can adopt. I'm just thinking about Leanne, who is in our PECI team, who works very closely with Kat, works very closely with colleagues across Wales, and I think the most important thing that Kat and Leanne do in equal measure is to collaborate. There is an awful lot that we gain from learning across the NHS from communities, from different third sector organisations and bodies, which means that, actually, we can shortcut things, sometimes, in a positive way. If somebody's done something really well, let's just think about how we can adopt that and learn from that ourselves.

Just to add, within the past 12 months we've actually had a patient story be presented to some of our committees that came from a British Sign Language service user, which was quite powerful, quite impactful, because I think it really did give an insight into this is this person's lived experience, these are the challenges, and there were definitely some lessons learned from that person's experience with Welsh ambulance service. Also as well, we have a patient network, and I think the majority of health boards as well would have something similar, in terms of our patient experience and community involvement teams across NHS Wales.

However, I think the majority of NHS Wales organisations recognise that BSL communities cannot participate in those patient voice networks in the same way that the majority of other communities can participate, and they do need something specialised. I think there may be some inconsistencies across organisations in Wales in terms of how they communicate and engage and consult directly with deaf communities. Co-production and co-design is definitely at the heart of all of our patient experience and community involvement teams, so there is definitely a willingness, but equally as well I think we have to bear in mind that we are fortunate, I think, in WAST because we are an all-Wales, a pan-Wales organisation, which means that our PECI team are spread out across Wales and go into all of our communities. I'm just thinking in particular of the health boards, where they cover certain geographical areas. Obviously, the deaf communities will be very different depending which health board you are in, in terms of it being difficult in terms of them reaching out then. Because I think there is definitely an onus upon the organisation to reach out to those communities, and not the other way around, and I think that may be more difficult in certain geographical parts of Wales.

But again, as Liam has just said, Leanne, our patient experience and community involvement team leader, is very much linked in as well to those other health board networks there, and I think, yes, there's definitely an element of sharing experience when one person learns something or has a patient story to share that can be shared right across Wales, because the outcome is very much the same.

Diolch, Cadeirydd.

We need to take a break, I'm afraid.

Sioned Williams, would you like to ask your questions?

Happy to answer the first question on raising concerns. So, I think that most people will already be aware that, across NHS Wales, we have a 'Putting Things Right' policy. It is, to the best of my knowledge, quite accessible to all online.

As we touched upon, we did have a patient story within recent months that did go to the board, which was as a result of a concern being raised. So, I think that that did demonstrate—particularly, on behalf of the Welsh ambulance service—that, when somebody wishes to raise a concern, whether they are a BSL service user or not, we are able to communicate effectively with that person when they wish to raise a concern, and also take some lessons learnt and take some action off the back of that concern.

So, I think, in terms of people being able to raise concerns, I don't see it as an issue. I'm sure that there is always room for improvement, but in terms of our mechanisms within NHS Wales for raising concerns, I don't anticipate that being a particular problem, especially if we are moving towards increasing our engagement with our deaf communities. I think that will open up communication channels for people to raise concerns informally as well, without having to go through that formal process.

I would just acknowledge that there are currently changes to the regulations being taken forward across the NHS in Wales. The 'Putting Things Right' regulations have been amended; they come into force in April 2026, and they are setting a range of expectations to ensure that we are meeting all of the inclusivity duties that you would expect. They also ensure that some of the barriers that anybody in the population might feel in terms of raising a concern, seeking redress—. Actually, there are some really strong measures within those changes for us to work directly with families, and hopefully to be able to put things into a better place. As the accountable person for 'Putting Things Right', I would be really clear that I have a set of duties already set out from within Welsh Government and NHS policy that I am required to meet that have been adjusted of late, and it would probably be quite difficult to have a competing set of legislation or regulation in that space.

Yes, we would welcome a national—

Yes, I just want to put a little bit of clarity into that answer. So, in terms of us being held to account as a statutory organisation within Wales, we are held to account by the NHS Wales Joint Commissioning Committee, which operates under the auspices of NHS Wales Performance and Improvement. That's the accountability line that we would have. We would demonstrate to them how we are meeting the various regulatory and legislative requirements. It's a subtle difference to the accountability that may flow through other public sector entities, but I think it's important for us just to clarify that that's the accountability line for our trust.

I think, as a trust, we often seek to, or we almost always seek to, work to the spirit of the legislation, and the regulation as well, to the absolute black and white. I am accountable for producing a number of annual reports, in one form or another, that service different parts of the NHS and the wider public sector. And I would expect that to be the case for our trust going forward. So, if there was a request that came through the appropriate routes, I would expect us to comply with that in spirit, as well as within the black and white, as a public sector organisation. We don't look for loopholes to get out of reporting. I think we are an incredibly transparent organisation, and we seek to learn at every opportunity from where we could do things differently, where we know we're not doing things as well as we could. So, I would give some assurance to the committee that we wouldn't be seeking those loopholes and that we would be reporting in a way that we do currently.

Thank you. Can I now call in Altaf Hussain? 

Thank you very much, Chair. I will come to the last section, really, and that is the barriers to implementation. The Bill's regulatory impact assessment, RIA, estimates overall costs of up to £2.5 million to listed public bodies over a 10-year period to comply with the planning and reporting duties. Do you think additional funding will be required to cover the costs of developing and reporting on local BSL plans?

We would always welcome more funding in order for us to create more resource in order for us to meet any set of standards or requirements. I think that's a given in the current economic climate.

In terms of the barriers and challenges, I can recall—I was heavily involved in doing the RIA for the Welsh language standards—a similar figure was estimated when we did that RIA. Yes, a lot of money has been spent on implementing the Welsh language standards across NHS Wales. No additional funding was made available at the time the Welsh language standards were implemented, but organisations have found a way, I think, gradually to meet those standards and create systems where it allows them to implement that set of standards. I would anticipate something similar happening with the BSL Bill, which is why I said I think any additional funding that was made available would be welcomed in order for us to progress the requirements of the Bill more quickly, more swiftly.

But as I said, it's not just all about the money. We've talked about the shortage of BSL interpreters, but, for me, this BSL Bill isn't just about the number of interpreters that we have, training more BSL interpreters, which obviously will take some considerable resource, funding and capacity as well, I think it's about what else we can do to meet the needs of our deaf community. So, it's about utilising that technology, but recognising, then, that some of that technology, especially some of the solutions, the digital solutions that Rhidian has spoken about today, could be at an even greater cost, and I think in times where we are being asked to save money as NHS organisations, it will become increasingly difficult, I think, for us to allocate dedicated resource to implementing the BSL Bill. I think it's going to be a matter of being creative, as we have seen in the past with the Welsh language standards, but that is not to say that that creativity cannot be found to find a way to implement them.

Any other thoughts, Liam?

No, it's a prioritisation exercise. I think there will be things that we can do collaboratively across the public sector and across the NHS, particularly in some of those core resources. There will need to be investment in some form or other to meet the standards and the degree to which it is additional, that is dedicated to supporting us to meet the standards, and the degree to which we are in negotiations and discussions by reprioritising existing resource. That will be the journey that we will take as this Bill progresses.

Fine, thank you very much. Let me come to the last question, really. Do you see a role for NHS Wales Shared Services Partnership to help health bodies access BSL interpreters and video relay services?

Honestly, possibly. Again, I feel like I've referred back to my experiences with the Welsh language standards several times this afternoon. There were discussions around Welsh Government creating a central Welsh language translation service, and those discussions went on for a long time and there was a lot of consultation. I think at one point they were very, very close to establishing that centralised Welsh language interpretation service in Welsh Government, but at the very last hurdle, it didn't really materialise.

I think it's definitely worth consideration and discussion that we would have this centralised resource, whether that was shared services or another organisation that would be responsible for setting up that centralised resource. Again, given the complexities of the different nature of all of these systems that operate within and across NHS Wales, I think it might be more difficult, easier said than done, to just establish that centralised support system within shared services.

Can we hear from Rhidian? 

Thank you. We did learn quite a few lessons during COVID, particularly telemedicine, and the barriers to telemedicine included the technical kit that was available to clinicians. We often, in our current practice, for those with specific language needs, have to use a telephone service. Telephones are relatively common, even within NHS hospitals and primary care. Appropriate video facilities are not. And so, there would be a cost implementation associated with that.

Furthermore, I'm not a fan of a non-digital organisation procuring a digital solution that requires integration. If one was to do this, then my advice would be that it is a digital program from start to finish, held on a once-for-Wales, all-Wales approach, therefore providing equity of service to all our citizens across Wales.

Thank you very much. Thank you, Chair.

Thank you. Thank you to all of you for your patience amidst the one or two technical challenges that we've had this afternoon. We will send you a transcript of your evidence, and obviously you will need to make sure that we've captured your information correctly. We may write to you if there's any additional information that we require, but we thank you all for your participation in this scrutiny of this BSL Act.

Members, there is one paper to note in the correspondence from Rob Jones to myself regarding Welsh justice data. Can we agree to note it? I see no disagreements. Sioned. 

Fine. I see no disagreement with that course of action. I'm sure we can manage to do that.

Could I now ask for your agreement that we exclude the public from the remainder of this meeting and from item 1 on the agenda for the committee meeting on 13 October? Before we go into private session, just to say that, on 13 October, we'll be taking evidence from the Welsh Local Government Association and the Cabinet Secretary for Social Justice, Trefnydd and Chief Whip on the Bill.