Wellbeing and Mental Health Service Providers Checklist
Wellbeing and Mental Healthcare Service Providers (‘Providers’) are expected to address a range of well-being and mental health issues along a spectrum of severity.
A multi-disciplinary team that includes medical doctors, psychologists, psychotherapists, counsellors, occupational therapists and physical and psychological wellbeing practitioners is best placed to provide a professionally reliable, effective and comprehensive level of care. In addition, the choice of practitioner and professional approach involved in the care of an individual should be determined by their identified needs rather than by an approach, as it does often occur, based on adapting identified needs to the available practitioner and professional approach.
Core professional standards
Providers should be preferably either medically-led or include the services of a named medical consultant in the capacity of Medical Director, even when Providers offer only well-being or counselling and psychotherapy services. This is because the Medical Director has the professional duty of making sure that all health services offered by the Provider are in keeping with General Medical Council (GMC) guidelines, which represent the gold-standard in healthcare. Most importantly, by adopting the GMC‘s gold-standard, both commissioning employers or insurers and Providers are on much firmer footing, for example when legal challenges are made regarding the employers’ or insurers’ responsibility regarding their duty of care and due diligence in commissioning services for employees or policy holders and the Providers’ clinical and corporate governance obligations. (Please see also Note: 1 below).
Providers should provide a copy of their Clinical Governance Policy.
Providers should clarify ‘who among their staff is accountable to whom’ and how the accountability process works in practice.
Providers should provide evidence of Risk Assessment Guidelines and professional lines of accountability regarding Risk.
Providers should provide a list of the Professional Registration Bodies their staff are registered with (Please see also Note: 2 below).
Providers should provide evidence of their registration as Data Controllers with the Information Commissioner’s Office (ICO).
Access to clinical records
Providers should provide a copy of their guidelines on Access to Clinical Records.
Providers should provide a copy of their Consent Policy, Consent Guidelines and Consent Form.
Providers should provide a copy of their Health Notes Recording Policy and Guidelines (Please see also Note: 3 below).
Providers should provide a copy of their Complaints Procedure. The Complaints Procedure should include a reference to the involvement (as required) of an independent medical consultant.
Providers should provide details of:
- well-being and mental health services
- disciplines providing the services
- qualifications and level of experience of staff, including their NHS experience, as appropriate (Please see also Note: 4 below)
- qualification and experience of staff providing occupational therapy/vocational rehabilitation (Please see also Note: 5 below)
Private healthcare insurance
Providers should provide information on (Please see also Note: 6 below):
- professional approval status of clinical staff, as granted by private healthcare insurers (e.g., BUPA, AxaPPP, CIGNA, etc.)
- approval status of professional disciplines, as granted by private healthcare insurers
- overall percentage of staff approved by private healthcare insurers
Providers should provide evidence of the following:
- well-being/mental health pathway – from triage, to discharge, to follow up
- triage system, including non-face-to-face triage, as provided by a senior clinician
- well-being/mental health assessment, as appropriate (Please see also Note: 7 below)
Occupational Mental Health
Providers should provide the following information:
- disciplines, qualifications and level of experience of clinicians providing occupational mental health assessments (Please see also Note: 8 below)
- features to be covered by Occupational Mental Health Reports:
- referral’s background
- ‘the brief’
- ‘the visit’
- current circumstances
- personal and family history
- work-related history
- medical history
- mental health history
- mental state
- diagnostic formulation
- clinical impression
- reference to Disability Under the Equality Act 2010
- return-to-work prospects
- recommendations, including:
– medical treatment
– psychological treatment
– occupational therapy input
– advice on return to work/end of employment process
– advice on reasonable adjustments
– general advice to employers/insurers
- Two anonymised occupational mental health report samples: psychiatric report and occupational therapy in mental health report
- clarify the features covered in reports
- provide two anonymised report samples: psychiatric report and psychological report
Providers should provide:
- details of service, objectives and pathway
- qualification and experience of organisational consultants
Providers should provide:
- details of service, objectives and pathway
- qualification and experience of executive coaches
Note 1: in terms of training standards and qualifications, Providers often refer to the British Association for Counselling and Psychotherapy (BACP). Please note that the BACP standards should not be regarded as representing the ‘gold-standard’ in healthcare, whereas the GMC standards should. For example, the current publicly-stated BACP approach is that BACP-registrants are not professionally equipped to carry out the clinical assessment and formulate diagnoses of mental health conditions, whilst at the same time the BACP regards its registrants as professionally equipped to treat mental health conditions (i.e., which they are unable to assess and diagnose) in their capacity as counsellors and psychotherapists.
Note 2: in the UK psychotherapists and counsellors are not regulated by government statutory agencies but only by voluntary self-regulatory professional bodies, unless the clinicians concerned also belong to statutorily-regulated professions, such as medical doctors, psychologists, occupational therapists etc.. Furthermore, training requirements for registration with self-regulatory professional bodies vary considerably. Therefore, the professional standards and clinical experience of clinicians practicing psychotherapy and counselling are not homogeneous.
Note 3: it is essential that accurate health records are kept, particularly as written evidence on risk to self or others is regularly scrutinised in case of Untoward Incidents. Inaccurate, incomplete or missing health records are regarded as evidence of poor practice, negligence, or malpractice.
Note 4: evidence of NHS work experience is normally an excellent indicator for high clinical standards, as well as solid knowledge of the wider system of care.
Note 5: some ‘Vocational Rehabilitation’ consultants do not have any experience in mental health, as they may be career counsellors/advisers. Therefore, when dealing with an occupational mental health matter, it is in general more appropriate and clinically sound to require the services of adequately trained professionals such as Occupational Therapists in Mental Health.
Note 6: whereas substantive medical consultants and clinical psychologists tend to be approved by all private healthcare insurers, many psychotherapists and counsellors are not approved. Therefore, treatments provided by the latter may not have the funding approval of private healthcare insurers (BUPA, AxaPPP, CIGNA, etc.).
Please also note that in recent years some counsellors and psychotherapists have been approved by some private healthcare insurers, albeit in relation to the provision of seemingly non-specialist treatments.
Furthermore, it is important to obtain clarification from Providers about the number/percentage of healthcare insurance-approved clinicians working for them, as it can occur that Providers may have only very few insurance-approved clinicians among their staff. In turn, this could mean that employers may be expected to fund treatments provided by non-insurance-approved clinicians, whereas such funding would not be necessary if the Provider’s clinical staff were insurance-approved.
Note 7: please note that psychotherapists and counsellors are not formally trained to carry out counselling/psychotherapy assessments – with the exception of a very small number of counsellors and psychotherapists who have received special assessment training as part of their work in the NHS.
Note 8: it is important to establish the disciplines, qualifications and level of experience of clinicians carrying out occupational mental health assessments, as it is not unheard of that non-mental health clinicians carry out occupational mental health assessments.