Written evidence submitted by The NHS Race and Health Observatory (DHS0038)

The NHS Race and Health Observatory (RHO) responses are from an ethnic/race equality perspective. that the below comments apply to all nine of the proposed government commitments.

• If they are to be successful, these evaluations must check if there is demographics data being collected and analysed for each commitment. The quality of the data should also be considered, especially ethnicity recording, which we know to be of variable quality across the NHS. Our own research has shown there to be inconsistency in the collection of ethnicity coding across the system – more information on this can be found in our research here: https://www.nhsrho.org/wp-content/uploads/2021/06/Nuffield-Trust-Ethnicity-coding_WEB.pdf
• When evaluating the success and/or impact of each commitment, considerations should be given to differences in the access, outcomes and experiences of each commitment by people from different ethnicities. This should include data comparing ethnic representation of people accessing and benefiting from each commitment and the overall ethnic makeup of the country. Where significant differences are noted, these should be an in-depth investigation and appropriate mitigations put in place.
• Any such evaluation must look at the quality of demographics data including ethnicity coding (see above). Data quality is important for secondary use and planning. Having high quality data is crucial in identifying inequalities/inequities and monitoring trends over time.
• For all commitments, the evaluations should investigate if appropriate Equality Impact Assessments had been carried out. The evaluation must also consider the quality of the EIA and whether it was published and widely shared with appropriate stakeholders.
• The evaluation should also check if equality, diversity and inclusion (EDI) principles have been considered and informed decision making for each commitment.
• For each commitment, the evaluation much find out if there is a named person or organisation who is responsible for the EDI. Does the person or organisation have the appropriate knowledge and experience to fully understand the often complicated and nuanced issues around inequalities, especially ethnic inequalities?
• The evaluation must explore whether organisations are prioritising the creation of one source of truth for demographic data including ethnicity.
• For each commitment, what EDI standards are being used? Are these evidence based?

Nov 2022