• Pre-legislative Scrutiny of the Mental Health (Amendment) Bill 2022
• Almost one third of consultant psychiatry posts are unfilled or occupied on a temporary basis – highest proportion of any specialty
• Public Spend on mental health in Ireland is significantly behind that of other countries

Tuesday 8^th February 2022.  The Irish Medical Organisation (IMO) has told an Oireachtas Committee  that long-term underfunding and the decade long recruitment crisis amongst Consultants of all disciplines were key factors in the crisis in CAMHS services in Co. Kerry.

 

Representatives from the IMO are today meeting with the Oireachtas Sub-Committee on Mental Health as part of the pre-legislative scrutiny of the Mental Health (Amendment) Bill 2022.

 

Professor Matthew Sadlier, Consultant Psychiatrist and former President of the IMO told the Committee that the Irish mental health services were “woefully” underfunded and underresourced

 

Professor Sadlier highlighted areas of particular concern including.

 

• Funding for mental health now stands at just 5.5% of healthcare funding compared to 10% in the UK and Canada, 13.5% in Norway and 15% in France. 
• We have a consultant recruitment and retention crisis.  136 out of 485 consultant psychiatry posts are unfilled or are filled on a temporary locum basis.  That is almost one third of posts and the highest for any specialty.
• Particular deficits arise in our CAMHS Services where in excess of 3,300 children are waiting for a consultant appointment – 6% of these are waiting in excess of a year.
• We have an over-reliance on non-training NCHDs to deliver services when services should be delivered by consultants and NCHDS in training.
• The NDTP estimate that 628 additional consultants are required over the next ten years to cope with additional demand and to replace those retiring or leaving the service.
• There are also significant shortages of key support staff including psychiatric nurses, counsellors, psychotherapists, occupational therapists and social workers.
• Ireland has 33.5 inpatient psychiatric beds per 100,000 population which is less than half the EU average of 68 inpatient psychiatric beds per 100,000 population.
• Acute adult psychiatric units operate at almost 90% occupancy, well above the 85% safe occupancy levels.
• There is no dedicated or resourced time within General Practice do deal with mental health issues and in many cases the only option is to refer.

 

Professor Sadlier said that given the failure to adequately resource mental health care to date,  we must be sure that in amending our legislation we are not further lowering the standard of care provided in our health services nor creating additional barriers to access.

The IMO set out key concerns in terms of the current review as follows:

 

Legislating for an interdisciplinary approach to care and treatment

 

The draft Bill seeks to legislate for an interdisciplinary approach (whereby the consultant must consult with at least one other Mental Health Professional before certifying an admission order or other key directives) without sufficient evidence to support its effectiveness nor reference to existing clinical and legal governance.

While a consultant psychiatrist may consult, and frequently does, with other members of the multidisciplinary team with regard to aspects of a patient’s treatment any legal requirement to do so, poses a risk to patient safety,  undermines the contractual responsibility of the consultant and blurs the lines of accountability.

Authorised Officers

The IMO has concerns that a requirement that Authorised Officers (which the HSE define as a Local Health Manager, Grade VIII General Manager, Psychiatric Nurse, Occupational Therapist, Psychologist or Social Worker) be the only people allowed to make an application to a medical practitioner for involuntary detention. The IMO is concerned that unless authorised officers are available on a 24/7 basis, this will add an additional layer of bureaucracy and lead to delays in treatment for patients.

 

Definition of a Child

 

Under the Mental Health Act 2001, for the purpose of admission to CAMHS Services, a child is defined as a young person under the age of 18 (unless married). On the other hand paediatric emergency departments (including the New Children’s Hospital) are only accessible to children under the age of 16 years. Therefore emergency presentation of children between the ages of 16-17 years occurs at the adult general hospitals, most of which, if not all, have no child psychiatry cover, yet admission of this age category to adult psychiatric units is a cause for national scandal.

 

In relation to the draft legislation the IMO  recommends:

 

• The Role of the consultant in providing clinical governance, leadership and expertise to the multi-disciplinary team must be valued and respected. This is of paramount importance if we are to provide safe, quality care and attract highly qualified psychiatrists to our mental health services.
• Unless we can guarantee that authorised officers will be available nationwide on a 24/7 basis then we should not introduce a requirement that they be the only category persons allowed to make an application for voluntary detention.
• Provide a clear and unambiguous definition of “A Child” that is consistent across all health care services, so that 16-17 year olds receive care appropriate to their needs;

 

The IMO welcomes amendments to the legislation to expand the role of the Mental Health Commission, but believes it does not go far enough.

 

• In a first instant we would call on the Mental Health Commission to engage an independent body to carry out an in depth analysis of the role of community multi-disciplinary teams and to assess if the current model of community based mental health teams is the best model for the provision of mental health services in Ireland.

• When inspecting Mental Health Services, the Mental Health Commission should assess the budget allocation received by that service to ensure that services are adequately funded, and identify areas of national policy where the recommended services have not yet been delivered.
• Finally given the proliferation of private and voluntary organisations providing mental health services to the public, the IMO is of the view that all agencies providing mental health care in Ireland should be required to achieve accreditation to international standards.

Opening statement can be found here