NHS England has published the NHS’s first ever equality, diversity, and inclusion improvement plan (EDI).
“This improvement plan sets out targeted actions to address the prejudice and discrimination – direct and indirect – that exists through behaviour, policies, practices and cultures against certain groups and individuals across the NHS workforce.”
The plan covers how EDI is central to the future of the NHS, explains the actions required to make necessary changes, and outlines accountability and responsibility for delivery of the proposed changes.
Intended to support the NHS Long Term Workforce Plan in promoting positive workplace culture and positive workforce experiences, the plan also aims to achieve the following strategic EDI outcomes:
- to address discrimination
- to increase accountability of all leaders to embed inclusive leadership and promote equal opportunities and fairness of outcomes
- to support the levelling up agenda, improving the NHS’s reputation as a “model employer” and thus continuing to attract diverse talent
- to make opportunities for progression fair and equitable, “facilitating social mobility” in the communities served
In achieving these outcomes, the plan covers six “high impact actions” in order to “address the widely-known intersectional impacts of discrimination and bias”. These are summarised below.
High impact action 1
“Chief executives, chairs and board members must have specific and measurable EDI objectives to which they will be individually and collectively accountable.”
To ensure that principles of EDI are embedded as the personal responsibility of every leader and every member of staff, “all chief executives, chairs and board members should have distinct objectives on improving inclusion in their organization and have a personal commitment to mainstream EDI as the responsibility of all, such that the provision of an inclusive and fair culture should become a key metric by which leadership at all levels is judged”.
The following actions must be completed by NHS organisations and ICBs:
- every board and executive team member must have EDI objectives that are specific, measurable, achievable, relevant and timebound (SMART), which should be assessed as part of their annual appraisal
- board members should demonstrate how organisational data and lived experience have been used to improve culture
- NHS boards must review relevant data to establish EDI areas of concern and prioritise actions, and progress will be tracked and monitored through the Board Assurance Framework
High impact action 2
“Embed fair and inclusive recruitment processes and talent management strategies that target under-representation and lack of diversity.”
The plan identifies that senior teams across the NHS are “less representative of their organisation’s workforce”, with BAME people making up 24.2% of the NHS workforce but only 13.2% of board members. Further, “85% of people with a disability do not believe that their trust provides equal opportunities for promotion and women represent 77% of the NHS workforce but only 37% of very senior managers”.
NHS organisations and ICBs should complete the following actions:
- create and implement a talent management plan “to improve the diversity of executive and senior leadership teams”, evidencing progress of implementation
- implement a plan “to widen recruitment opportunities within local communities, aligned to the NHS Long Term Workforce Plan”, including apprenticeship programmes and graduate management training schemes.
High impact action 3
“Develop and implement an improvement plan to eliminate pay gaps.”
The plan specifically notes gender, disability and ethnicity pay gaps, commenting that although it is relatively small for the 88% of NHS staff employed on Agenda for Change (AfC), it is 47% for the remaining 12% of NHS staff.
NHS organisations should complete the following actions:
- implement the recommendations from the Mend the Gap review for medical staff, and develop a plan to apply them to senior non-medical staff
- use data to understand pay gaps by protected characteristics and put in place improvement plans. “Reflecting the maturity of current data sets, plans should be in place for sex and race by 2024, disability by 2025 and other protected characteristics by 2026.”
- implement an effective flexible working policy and incorporate this into recruitment campaigns
High impact action 4
“Develop and implement an improvement plan to address health inequalities within the workforce.”
The plan recognises the influence of the NHS as one of the largest employers in local communities.
“This creates an opportunity to positively impact population health by addressing health inequalities in the workforce.”
The plan sees the NHS’s responsibility henceforth as promoting a safe workplace environment free of bullying and discrimination, and offering good routes into employment, good work, and career development.
Organisations should complete the following actions:
- line managers and supervisors should have “regular effective wellbeing conversations with their teams, using resources such as the national NHS health and wellbeing framework”
- work in partnership with community organisations such as the NHS Race and Health Observatory, to “support social mobility and improve employment opportunities across healthcare:
High impact action 5
“Implement a comprehensive induction, onboarding and development programme for internationally-recruited staff.”
The plan puts forth the need for the NHS to provide a comprehensive induction and pastoral support package for internationally recruited healthcare professionals, which “will make them feel valued from the start and help retain this staff group”.
In line with this, NHS organisations should complete the following actions:
- ensure all international recruits receive guidance and support on conditions of employment, immigration policy, conditions for accompanying family members, financial commitment and future career options
- “create comprehensive onboarding programmes for international recruits, drawing on best practices”
- provide international recruits with the same development opportunities as the wider workforce, using personal development plans and available training to promote development
High impact action 6
“Create an environment that eliminates the conditions in which bullying, discrimination, harassment and physical violence at work occur.”
The plan outlines how bullying and harassment at work affects productivity and wellbeing, as well as negatively impacting patient safety. 18.7% of NHS staff reported they had experienced bullying from colleagues; 11.1% from line managers; and 27.8% from patients or their relatives.
To avoid this, NHS organisations are to complete the following actions:
- review data by protected characteristic on bullying, harassment, discrimination and violence
- review disciplinary and employee relations processes, taking immediate steps to address inconsistencies across protected characteristics
- ensure “safe and effective policies and processes are in place to support staff affected by domestic abuse and sexual violence (DASV)”
- create an environment where staff feel able to speak up and raise concerns
- provide psychological support for those reporting victimisation
- have mechanisms in place to ensure staff who raise concerns are protected by their organisation
Making change happen
The plan sets out the backdrop to ensuring change happens, emphasising the role of leadership across the NHS and NHS employing organisations, the need for accountability, and the critical nature of effective measurement of progress.
In support of change, NHS England will be working alongside systems and organisations, creating a repository of good practice using the FutureNHS platform, and developing a national EDI dashboard of key EDI metrics, which will help monitor progress.
“There is currently a range of EDI information datasets and we intend the dashboard to provide one source of information that both organisations and regulators, such as the CQC, can use to track the impact and outcomes of the NHS EDI improvement plan. “
Data will also be a key feature in monitoring progress, with NHS England committing to “improve the range and quality of data, working with DHSC and other partners”, as well as “to develop a new mandated workforce standard on gender identity and sexual orientation”.
The plan sets out interventions across 9 protected characteristics as defined by the Equality Act of 2010, including age, disability, race, religion or belief, sex, pregnancy and maternity, sexual orientation, gender reassignment and marriage and civil partnership.
“Our organisations must be more inclusive and our leadership more diverse. We have an obligation to improve the experience of staff so that they feel like they belong. This plan articulates meaningful action to transform the lived experience of our staff and realise the benefits that we know come from greater equality, diversity and inclusion.”
To read the plan in full, please click here.
