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    Reconfiguring Hospital services in Shropshire.

    Keeping it in the County Dec. 2010.

    Response prepared by D. Sandbach.

    The argument for rational configuration and long term sustainability.

    Rational Configuration.

    The policy of maintaining two main hospital sites in Shropshire at RSH and PRH is in my opinion the

    least rational option available to the people of Shropshire, mid Wales and the local NHS TrustBoards.

    The consultation document, under option 3 and 4, makes it perfectly clear that:

    A) A single DGH is the best option see option 3 page 10.

    B) The second best option is option 4 all major inpatient and emergency activity occurring on

    one site.

    Both these options are dismissed in the consultation document due to the current financial climate.

    I believe dismissing these two rational options is not in the best long term interest of health care in

    Shropshire.

    I am sure that setting a single site hospital as a strategic goal and delivering this goal over a period of

    years is the right thing to do and is possible even though the UKs current economic climate is not as

    good as it has been in the recent past.

    The consultation document states:

    In many ways, this would be an ideal solution. We would be able to design new facilities from

    scratch. We would have the most up-to-date equipment in purpose-built accommodation.

    We would also have all our staff and services together on one site, which would make it easier for us to usethem where they are needed most at any time.

    1

    SaTH and the PCTs were formally notified that the idea of a single site was technically and financially

    viable in September 2009:

    Recommendation 3: To NOTE that all three options for the 2020 single site have the potential to be

    technically and financially feasible2

    1Source Keeping it in the County page 10.

    2Source Agenda Item 4. 22 September 2009 T&W PCT Board meeting.

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    The consultation document fails to give a comprehensive reason as to why a single site DGH in

    Shropshire is a sound idea. An idea that is supported by local clinical personnel and by external

    clinical advisors.3

    By avoiding this issue the public are kept in the dark about the wider health care

    benefits of such a strategic policy.

    Sustainability.

    The financial climate in the UK is not as good as it has been in the past. The need to deliver

    effective stewardship of scarce public resources is vital to keeping hospital services in the

    County.

    Demographic change will continue to place ever greater pressure on financial allocations.

    Pressure to deliver clinical improvements and improved labour productivity in the NHS will

    increase.

    Pressure to have increased medical specialisation will continue.

    The potential for the private and voluntary sector to increase their involvement in treating

    publically funded patients will put pressure on SaTH to rationalise services in order to

    compete and provide a modern 21st century service for the public.

    Given the factors noted above I have concluded that a two site hospital system in Shropshire is not

    a sustainable clinical or financial proposition in the medium to long term.

    If we can all agree that a programme of centralising services on one site is in all our interests

    (clinical, public health and political) then we can rest assured that our hospital service in Shropshire

    is in a strong position to weather the up coming changes in the way health services are delivered in

    this country.

    The case for one DGH.

    Option 3 Page 10 Keeping it in the County-

    In many ways, this would be an ideal solution. We would be able to design new facilities from

    scratch. We would have the most up-to-date equipment in purpose-built accommodation.

    We would also have all our staff and services together on one site, which would make it easier for us

    to use them where they are needed mostat any time.

    In order to provide some context to this statement I have prepared, using published Annual Reports

    for 2009/10, a high level analysis of SaTHs performance i.e. a two site hospital service compared

    with two centralised acute hospital services.

    The assessment compares similar but not identical organisations.

    3

    National Clinical Advice Team received in January 2009Sourcehttp://www.sath.nhs.uk/Library/Documents/ournhs/090917-NCAT%20Final%20Report.pdf

    http://www.sath.nhs.uk/Library/Documents/ournhs/090917-NCAT%20Final%20Report.pdfhttp://www.sath.nhs.uk/Library/Documents/ournhs/090917-NCAT%20Final%20Report.pdfhttp://www.sath.nhs.uk/Library/Documents/ournhs/090917-NCAT%20Final%20Report.pdfhttp://www.sath.nhs.uk/Library/Documents/ournhs/090917-NCAT%20Final%20Report.pdf
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    The assessment is broad brush approach but taken as a whole confirms what is only common sense

    i.e. that to run two hospitals doing more or less the same core activity on each site is more

    expensive and less clinically efficient than running one hospital.

    Please note the assessment in no way implies that the staff of SaTH are not doing their very best to

    deliver good clinically sound hospital services for the benefit of their patients, they are where theyare working in an inefficient two site system.

    The table on the next page is a comparison between three Acute Hospital Trusts:

    Shrewsbury and Telford Hospitals NHS Trust (SaTH)

    The Countess of Chester Foundation Trust (CoCH)

    Royal Wolverhampton Hospitals NHS Trust (RWH).

    All three organisations are in the same service area i.e. the provision of District General Hospitalservices. There are some differences e.g. RWH is a designated Regional Heart and Lung centre. The

    catchment area for RWH is 330,000 the catchment area for CoCH is 250,000 where as the catchment

    area for SaTH is 500,000.

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    Performance analysis of one split site DGH SaTH and two single site DGHs CoCH / RWH.

    Comparator SaTH CoCH RWH Comment

    Income from

    Treating

    Patients

    242,156,000 158,148,000 264,077,000

    Income from patient care activity at RWH is 9%

    higher than SaTH

    Activity

    508,547 427,000 750,000

    SaTH produces 32% less service than RWH. If

    SaTH were on one site the public could expect

    an activity rate of 675,000p.a.

    Beds

    890 600 706

    SaTH has the highest number of beds. As a

    single site organisation SaTH could reduce its

    bed compliment.

    Staff

    4201 3000 5000

    Calculations prepared for SaTH show that it has

    around 120 too many beds this is because the

    beds are on two sites.

    Average cost

    per item of

    activity

    476 370 352

    The average price of service activity from SaTH

    is around 28- 34% more than the CoCH and

    RWH.

    Ratio of staff to

    activity 1 : 121 1 : 142 1 : 150

    SaTH labour productivity is 18% below that of

    the CoCH and 19% of the RWH. This is becausethey are not concentrated on one site.

    Ratio of staff

    per bed 4.72 : 1 5 : 1 7 : 1

    SaTH has the worst staff to bed ratio, 5.6% less

    than CoCH and 33% less than RWH.

    Activity per bed

    ratio 571 : 1 711 : 1 1062 : 1

    SaTH has the worst utilisation ratio by at least

    20%.

    Ratio of

    catchment pop.

    to beds

    561.79 : 1 416.6 : 1 467.2

    SaTH has the highest ratio of beds per

    population 34% more than CoCH 20% more

    than RWH

    Ratio activity to

    catchment pop. 1.017 : 1 1.70 : 1 2.27

    People in the SaTH catchment often get their

    hospital services out of county the cross

    border leakage is around 10% or from

    providers other than SaTH in Shropshire.

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    The figures above clearly show what is instinctively obvious i.e. that the operation of a twin site

    acute hospital services is not in the best interest of people living in the SaTH catchment area because

    having two hospitals in the county doing similar work is:

    clinically is inefficient

    expensive and wasteful of resource

    an impediment to delivering more and better health care.

    The difference in the unit cost of service provision shows how much more expensive a dual site

    service is; this is very important since it translates into money being spent on fixed and semi variable

    over heads rather than staff, clinical quality and increased over all service productivity / delivery

    levels.

    Translated into activity terms these figures suggest that a single hospital site in Shropshire could

    provide the population with between 67.8 and82.3 million pounds worth of extra health care (28- 34% of 242,156,000) this translates into 183,000-231,830 extra health service contacts in the

    acute hospital service or some extra resources for other health related activity e.g. community and

    mental health care.

    Put another way, the pay and non pay cost of the community service in Shropshire e.g. Community

    hospitals, community nursing etc is around 38 million per annum4. If the Acute hospital service was

    centralised Shropshire as a community could afford to have more community based beds and

    community based, in home, services provided by community doctors, nurses and therapists caring

    for people in or close to their home.

    Capital Funding to support change.

    In the near future SaTH will become a Foundation Trust in its own right or become part of an existing

    Foundation Trust. Access to capital for developing services will become simpler because Foundation

    Trusts are not subject to Delegated Limits for Capital Investment:

    NHS Foundation Trusts are not subject to delegated limits for capital investment set by the

    Department of Health.

    5

    4Source

    http://www.shropshire.nhs.uk/Documents/docs_common/Publications/Board%20Papers/2011/25%20January

    %202011/9.1%20Board%20Report%20-%20Financial%20Performance%20-%20combined.pdf

    5Source

    http://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/@dh/@en/documents/digitalasset/dh_080865.pdf

    http://www.shropshire.nhs.uk/Documents/docs_common/Publications/Board%20Papers/2011/25%20January%202011/9.1%20Board%20Report%20-%20Financial%20Performance%20-%20combined.pdfhttp://www.shropshire.nhs.uk/Documents/docs_common/Publications/Board%20Papers/2011/25%20January%202011/9.1%20Board%20Report%20-%20Financial%20Performance%20-%20combined.pdfhttp://www.shropshire.nhs.uk/Documents/docs_common/Publications/Board%20Papers/2011/25%20January%202011/9.1%20Board%20Report%20-%20Financial%20Performance%20-%20combined.pdfhttp://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/@dh/@en/documents/digitalasset/dh_080865.pdfhttp://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/@dh/@en/documents/digitalasset/dh_080865.pdfhttp://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/@dh/@en/documents/digitalasset/dh_080865.pdfhttp://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/@dh/@en/documents/digitalasset/dh_080865.pdfhttp://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/@dh/@en/documents/digitalasset/dh_080865.pdfhttp://www.shropshire.nhs.uk/Documents/docs_common/Publications/Board%20Papers/2011/25%20January%202011/9.1%20Board%20Report%20-%20Financial%20Performance%20-%20combined.pdfhttp://www.shropshire.nhs.uk/Documents/docs_common/Publications/Board%20Papers/2011/25%20January%202011/9.1%20Board%20Report%20-%20Financial%20Performance%20-%20combined.pdf
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    Having spoken to Mr. J. Mann from the Department of Healths Capital Investment Branch I

    understand that a Foundation Trust can access capital as long as the project can be afforded, FTs

    have the autonomy to proceed with capital projects.

    The statement in the consultation document In the financial climate now facing the nation, that

    money (350450 million) is not available is a defeatist and very pessimistic position given:

    a) A Foundation Trust access to private capital is a possibility.

    b) The Government is committed to capital spending remaining higher in real terms than ithas been on average over the last three Spending Review periods.

    6

    I believe that we should aspire to a single site DGH in Shropshire and I think the public should be

    asked to give their views on the following three models of care:

    Model 1.

    As proposed in the consultation document.

    Possibly with Women and Childrens services

    staying at RSH and surgery transferring to PRH

    from RSH. NB the 60 million price tag quoted in

    the consultation document for relocating the

    Women and Childrens service at RSH is OTT7/

    8.

    Model 2.Concentrate all major inpatient and emergency

    activity on one hospital site and deal with

    planned activity at the other.

    If executed over a period of several years this isan achievable goal.

    Model 3.

    Provide one DGH for the county at RSH / PRH or

    new build between the two existing sites.

    Best option needing vision and perseverance to

    achieve.

    6Source HMG Treasury Departmental settlements:http://cdn.hm-treasury.gov.uk/sr2010_chapter2.pdf

    7Sourcehttp://www.pat.nhs.uk/uploads/20100603_231%20New%2032m%20w&C%20building%20complete

    %20DRAFT1.pdf8Sourcehttp://www.pat.nhs.uk/uploads/20101021_A3%20NMGH%20generic%20poster%20new.pdf

    http://cdn.hm-treasury.gov.uk/sr2010_chapter2.pdfhttp://cdn.hm-treasury.gov.uk/sr2010_chapter2.pdfhttp://cdn.hm-treasury.gov.uk/sr2010_chapter2.pdfhttp://www.pat.nhs.uk/uploads/20100603_231%20New%20%C2%A332m%20w&C%20building%20complete%20DRAFT1.pdfhttp://www.pat.nhs.uk/uploads/20100603_231%20New%20%C2%A332m%20w&C%20building%20complete%20DRAFT1.pdfhttp://www.pat.nhs.uk/uploads/20100603_231%20New%20%C2%A332m%20w&C%20building%20complete%20DRAFT1.pdfhttp://www.pat.nhs.uk/uploads/20100603_231%20New%20%C2%A332m%20w&C%20building%20complete%20DRAFT1.pdfhttp://www.pat.nhs.uk/uploads/20101021_A3%20NMGH%20generic%20poster%20new.pdfhttp://www.pat.nhs.uk/uploads/20101021_A3%20NMGH%20generic%20poster%20new.pdfhttp://www.pat.nhs.uk/uploads/20101021_A3%20NMGH%20generic%20poster%20new.pdfhttp://www.pat.nhs.uk/uploads/20101021_A3%20NMGH%20generic%20poster%20new.pdfhttp://www.pat.nhs.uk/uploads/20100603_231%20New%20%C2%A332m%20w&C%20building%20complete%20DRAFT1.pdfhttp://www.pat.nhs.uk/uploads/20100603_231%20New%20%C2%A332m%20w&C%20building%20complete%20DRAFT1.pdfhttp://cdn.hm-treasury.gov.uk/sr2010_chapter2.pdf
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    I believe that the consultation process in 2009 and 2010 was / is inadequate because both

    documents lacked detail e.g. no comprehensive demographic or epidemiological assessment, lack of

    detail in terms of an impact assessment.

    In short no one in their right mind would make a judgement call as to the wisdom of the favoured

    option verses the alternatives. If these documents were a prospectus for investors on the stock

    market they would bomb no one would put their money in because of lack of basic information.

    Public Transparency and a Modern consultation process.

    In line with the Governments views on Localisation I feel we should try to widen the process of

    participation beyond the public meeting road show method and focus group meetings.

    I think that the following consultation programme would be better:

    Prepare a consultation document with all necessary public health, demographic,

    epidemiological clinical and financial information in one place agreed before hand with

    Shropshire Council and Telford and Wrekin Council. This document to be put on line as a

    reference source and made available in public libraries.

    Prepare an option appraisal of the three principle options noted above. NHS management to

    leave out any reference to a preferred option. Issue as a paper and online consultation

    document.

    Place all working documents used by NHS planners on line for the public to view.

    Place all written consultation comments and any NHS replies on line.

    Provide a moderated online public discussion area plus a Q & A Facility.9

    Tap into the massive democratic resource we have in the county and ask each parish / town

    council Chair person to:

    a) Have the consultation document discussed at a public parish / town council meeting.

    b) Attend a NHS run meeting to give verbal and written feed back from their community.

    At the end of the process the SaTH Board will:

    Not be in a position where anyone can claim a done deal / fix has been agreed.

    Have a good idea of what ideas and concerns people have.

    Have open public evidence to show SC and T&W scrutiny committee what people think.

    9The NHS has an on line facility which is more about giving the party line e.g. Mr. Cairns letter to the press

    than sharing corporate the knowledge and public views.http://www.ournhsinshropshireandtelford.nhs.uk/news/News-Archive.aspx

    http://www.ournhsinshropshireandtelford.nhs.uk/news/News-Archive.aspxhttp://www.ournhsinshropshireandtelford.nhs.uk/news/News-Archive.aspxhttp://www.ournhsinshropshireandtelford.nhs.uk/news/News-Archive.aspx
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    Have use the Internet to engage as widely as possible with the public (68% of Shropshire

    people have home access to the Internet. 100% have access via the library service.)

    Be in a position to make an informed decision which is transparent and is as fair as possible.

    bring people and communities with them through the process of change so that they have a

    strong mandate to act and take difficult decisions on behalf of local people and

    communities10

    10Page 6

    http://www.shropshire.nhs.uk/Documents/docs_common/Have%20Your%20Say/FINAL%20Involvement%20toolkit%20Nov%2010.pdf

    http://www.shropshire.nhs.uk/Documents/docs_common/Have%20Your%20Say/FINAL%20Involvement%20toolkit%20Nov%2010.pdfhttp://www.shropshire.nhs.uk/Documents/docs_common/Have%20Your%20Say/FINAL%20Involvement%20toolkit%20Nov%2010.pdfhttp://www.shropshire.nhs.uk/Documents/docs_common/Have%20Your%20Say/FINAL%20Involvement%20toolkit%20Nov%2010.pdfhttp://www.shropshire.nhs.uk/Documents/docs_common/Have%20Your%20Say/FINAL%20Involvement%20toolkit%20Nov%2010.pdfhttp://www.shropshire.nhs.uk/Documents/docs_common/Have%20Your%20Say/FINAL%20Involvement%20toolkit%20Nov%2010.pdf
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    The remainder of this paper is a critique about SaTH and the PCTs approach to consultation and lack

    of openness. It gives some insight as to why I have made the comments I have on page 7 and 8

    above.

    The debate about replacing the Maternity and Paediatric Unit is welcome but a bit late in

    the day. Around four years ago a structural report about the RSH maternity building was

    prepared for the SaTH Board. There were a number of recommendations like do not drill

    holes in the structure, worry about asbestos was noted, as was movement in the building.

    Only now do the public know that this building should be demolished.

    In the consultation document of 2009 the proposed options under consideration were:

    Option 1 RSH - Level 2 A and E with acute surgery, inpatient paediatrics, obstetrics and neonates

    Option 2 PRH - Level 2 A and E with acute surgery, inpatient paediatrics, obstetrics and neonates

    At that time the public were led to believe that option 1 was the right thing to do in the interest of

    all the people in the SaTH catchment area. The tune has now been changed.

    The option appraisal on these two options showed the following:

    Option 1 RSH Option 2 PRH

    Non FinancialBenefit Score

    694 634

    Capital m 18.2 47.1

    RevenueImpact ofcapital m

    0.9 2.2

    Constructionperiod (years)

    2 3

    Of the18.2 million capital in RSH Option 1, 7.5166 million (41.3%) was to be spent on re-providing

    Paediatric services at RSH, the fact that the whole of the Women and Childrens Unit at RSH needed

    demolishing (as now declared by SaTH during public meetings) was hushed up.

    Had the fact about the need to entirely replace the Women and Childrens Unit beendeclared in the 2009 consultation document we would have had a different consultation in

    2009 /10 because the capital figure under RSH Option 1 would have been at least as much

    as under PRH Option 2.

    It now appears that a similar scheme as that which was proposed at PRH in 2009 at a cost of47.1 million will now cost 28 million in 2010.

    Keeping Women and Childrens services at RSH would have cost, in 2009, 18.2 million and

    now in the 2010 consultation document it will cost 60 million.

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    Capital figures quoted in the 2009 and 2010 consultation documents tell diametrically opposed

    stories.

    47 million to move Maternity etc to PRH in 2009 conclusion too expensive.

    In 2010 60 million is needed to keep Maternity services at RSH - conclusion too expensive.

    The numbers and conclusions appear to move in line with what ever party line SaTH et al

    choose to take. On the face of it behaviour like this suggests a behind closed doors decision

    making dynamic as opposed to a public, rational and evidence based dynamic.

    It would be fair to say that the current consultation document has some odd claims aboutwhat is and is not feasible.

    The cost of this scheme (and some other changes to buildings that would be necessary as

    part of the preferred option) is estimated to be 28 million - a figure that can be afforded.

    The cost of rebuilding the maternity unit at the Royal Shrewsbury Hospital site is estimated

    to be close to 60 million, which is not affordable.

    I found the figure of 60 million to be a bit excessive.

    A quick search on the Internet has provided some details of the situation else where in the country.

    Women and Childrens Unit Manchester.

    In Manchester a new Women and Childrens Unit was opened in the summer of 2010 it cost circa32 million

    11.12

    The new development is of a similar size as the one we need to replace the building

    at RSH. The Manchester Unit can cope with a maximum of 5,500 births per annum13

    . The unit in

    Manchester will provide a full range of high quality services to women, children and babies

    including:

    Brand new Childrens Day Surgery Unit

    Kids Observation and Assessment Liaison Area (KOALA)

    Childrens Inpatient Unit

    New antenatal ward

    New postnatal ward

    New delivery suite/labour ward and operating theatres

    New Neonatal Unit/ Special Care Baby Unit (SCBU)

    New midwife-led birth centre

    Artistsimpression of the new Women and Childrens Unit North Manchester Hospital

    11Source

    http://www.pat.nhs.uk/uploads/20100603_231%20New%2032m%20w&C%20building%20complete%20DRA

    FT1.pdf12

    Source http://www.pat.nhs.uk/uploads/20101021_A3%20NMGH%20generic%20poster%20new.pdf

    13Email from E Stringer Interim Head of Midwifery North Manchester General.

    http://www.pat.nhs.uk/uploads/20100603_231%20New%20%C2%A332m%20w&C%20building%20complete%20DRAFT1.pdfhttp://www.pat.nhs.uk/uploads/20100603_231%20New%20%C2%A332m%20w&C%20building%20complete%20DRAFT1.pdfhttp://www.pat.nhs.uk/uploads/20100603_231%20New%20%C2%A332m%20w&C%20building%20complete%20DRAFT1.pdfhttp://www.pat.nhs.uk/uploads/20101021_A3%20NMGH%20generic%20poster%20new.pdfhttp://www.pat.nhs.uk/uploads/20101021_A3%20NMGH%20generic%20poster%20new.pdfhttp://www.pat.nhs.uk/uploads/20101021_A3%20NMGH%20generic%20poster%20new.pdfhttp://www.pat.nhs.uk/uploads/20100603_231%20New%20%C2%A332m%20w&C%20building%20complete%20DRAFT1.pdfhttp://www.pat.nhs.uk/uploads/20100603_231%20New%20%C2%A332m%20w&C%20building%20complete%20DRAFT1.pdf
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    Had the Manchester capital cost, which is an actual rather than estimated spend, been

    noted in the current consultation document there is a possibility that two options would

    have been put forward for public consideration in the 2010 consultation document i.e.

    Option 1: the favoured option as per the current 2010 consultation document.

    Option 2: the reverse of option 1 with vascular, upper gastro-intestinal surgery and colorectal

    surgery going to PRH with a part day Paediatric assessment ward and out reach Paediatric coverprovided from RSH to PRH

    The fact that Option 1 & 2 above are both viable must raise serious doubts about the rigor

    applied to preparing the 2010 consultation document.

    Both the October 2009 and December 2010 consultation documents were / are inadequate

    for strategic corporate decision making purposes affecting a vital public because they avoid

    and fail to answer the most fundamental question - can we continue to have a dual system

    of Acute services in Shropshire?

    A comparison of the two consultation documents (2009 & 2010) clearly shows that NHS

    management has an emergent approach to strategic planning. The emergent approach tostrategic planning is some times described as flavour of the month planning

    14which can

    be a very risky management approach to planning when dealing with major long term

    decisions with life and death implications for around 500,000 people.

    It is very unfortunate that the picture of what the hospital service should look like in the

    future has not been properly articulated in the current consultation document. Indeed the

    idea of considering or explaining the future beyond a quick fix model is studiously avoided

    and dismissed on the grounds of difficulty in obtaining the necessary capital.

    14Guide to Business Planning. Authors: Friend & Zehle. Pub.- The Economist. 2004. Also know as pick a

    victim planning.

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    I would agree that the latest proposed configuration of hospital services does have some

    internal intellectual logic in it since there is what could be described as a shared pain

    philosophy of planning evident in the 2010 consultation document. The model also helps

    SaTH to secure a solution to some of its immediate safety problems and licensing issues

    whilst, at the same time, positioning it to centralise services further on at some time in the

    future.

    If one DGH is the ideal long term strategic position as noted in Option 3 of the consultation

    document then the democratic process dictates that SaTH should be clear about its

    intentions on this matter. To identify the ideal and not state ones long term position about

    achieving it is a recipe for continued distrust and speculation.1516

    Given that the decisions SaTH and the PCTs want to make will affect the lives of thousands

    of people and involve vast amounts of hard earned tax payer money we must demand to

    know what the end point is to be for the hospital service in Shropshire, Telford and Wrekin.

    If the NHS management does not know where it wants to end up in the longer term how can

    the public give informed consent to a series of tactical departmental moves and be surethese moves are sensible and use scarce resources wisely in the context of a wider plan to

    stop services leaving the county?

    15Please see Code of practice on Openness in the NHS:

    http://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/@dh/@en/documents/digitalasset/dh_402

    9974.pdf

    16Shropshire Star 31

    stJanuary 2011 2Battle to save services needs to be more aggressive

    http://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/@dh/@en/documents/digitalasset/dh_4029974.pdfhttp://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/@dh/@en/documents/digitalasset/dh_4029974.pdfhttp://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/@dh/@en/documents/digitalasset/dh_4029974.pdfhttp://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/@dh/@en/documents/digitalasset/dh_4029974.pdfhttp://www.dh.gov.uk/prod_consum_dh/groups/dh_digitalassets/@dh/@en/documents/digitalasset/dh_4029974.pdf