NHS Delivery Consultation Response
EXECUTIVE SUMMARY
SASW welcomes the opportunity to respond to this consultation on NHS Delivery. We recognise the Scottish Government's ambition to transform health and social care services through improved digital capabilities, workforce development, and streamlined national structures.
However, we have significant concerns about the consultation's approach to social care and social work. The proposals risk perpetuating a health-dominated model that fails to recognise the distinctive nature, complexity and scale of the social work and social care sector. They also risk undermining the existing statutory regulatory functions of the SSSC, overlooking the fundamental differences between NHS and social care workforce development needs, and imposing top-down integration rather than enabling collaborative, co-created approaches to partnership working.
KEY RECOMMENDATIONS
We make five key recommendations to Scottish Government. First, any extension of NHS Delivery's remit into social care must be co-designed with social work and social care stakeholders, not imposed. Second, the SSSC's statutory role as regulator and national lead for workforce development in social services must be protected and properly resourced. Third, investment should focus on addressing barriers to accessing qualifications and training, not creating new structures. Fourth, social work must be visible throughout the framework. Currently it is barely mentioned. Fifth, partnership working should build on existing successful collaborations rather than assuming integration equals improvement.
We strongly support the "Once for Scotland" principle where it genuinely adds value, but this must mean collaboration between equals, not absorption of social care functions into an NHS-led body.
SECTION A: ESTABLISHING THE NEW ORGANISATION
Question 1: Do you agree that creating a new national organisation to drive forward digital transformation and system change, beginning with the consolidation of NES and NSS into one organisation, is the right approach to deliver the ambitions set out in Scotland's Population Health Framework and Service Renewal Framework?
RESPONSE: Partially Agree
We support the principle of reducing fragmentation and duplication in national health functions. The merger of NES and NSS may deliver benefits for NHS Scotland's digital transformation and workforce development.
However, we have fundamental concerns about the implications for social work and social care.
The consultation document makes virtually no reference to social work, despite social care featuring prominently throughout. This is deeply concerning. Social work is a distinct profession with statutory functions in child protection, mental health, justice, and adult support and protection. It has professional registration and regulation through SSSC, degree-level education and ongoing professional development requirements, and a value base rooted in social justice, human rights and relationship-based practice.
The consultation's failure to distinguish between "social care workforce" and social work suggests a fundamental misunderstanding of the sector. Social work is not simply one component of the social care workforce. It is a distinct profession with its own identity, values, knowledge base and regulatory framework. Any organisation claiming a role in workforce development in this space must understand and respect these distinctions.
The consultation repeatedly refers to NHS Delivery having a role with "the social care workforce" but provides no clarity on what this role would entail, how it relates to SSSC's statutory functions, whether it includes social work, children's services and justice social work, or how it would work with the mixed market of public, private and voluntary sector employers.
This ambiguity is concerning given the scale and complexity of the sector. Social services employ more people than NHS Scotland, operate in fundamentally different ways across diverse settings, and have different regulatory requirements. The consultation appears to assume that social care can simply be added to NHS Delivery's remit without proper consideration of these fundamental differences.
While the Population Health Framework and Service Renewal Framework speak to integration, there is a clear risk that an NHS-led body will prioritise health workforce needs over social care, fail to understand the distinctive nature of social work practice, impose NHS-style solutions that do not fit social care contexts, and undermine existing successful frameworks such as SSSC registration, continuous professional learning requirements, and the MyLearning platform.
This is not merely a theoretical concern. We have seen repeatedly in integration contexts how health priorities and approaches can dominate, how social work perspectives can be marginalised, and how distinctive social care needs can be overlooked. An NHS board, however well-intentioned, will inevitably be shaped by NHS culture, priorities and ways of working.
Significant investment has already been made in social care workforce development infrastructure. The SSSC MyLearning platform supports over 60,000 users. There are well-established mandatory qualifications and continuous professional learning frameworks. The National Occupational Standards are currently under comprehensive review. There is successful interoperability between SSSC systems and TURAS.
Any changes must build on, not replace, these established systems. The consultation gives no recognition to this existing investment and infrastructure, creating a real risk that successful frameworks could be dismantled in favour of untested alternatives.
If NHS Delivery is to have any role in social care, it must be co-designed with social work and social care stakeholders from the outset, not imposed after the fact. It must be clearly defined and bounded, respecting existing statutory functions. It must be based on genuine partnership, not top-down integration. It must be properly resourced to ensure social care receives equal status and investment, not treated as an afterthought. And it must be subject to ongoing oversight by social work and social care representatives, ensuring accountability to the sector it purports to serve.
Question 2A: Do you agree with the proposed strategic objectives for the new organisation (driving innovation, delivering Once for Scotland services, and streamlining structures)?
RESPONSE: Partially Agree
We support these objectives for NHS Scotland functions. However, SASW has considerable reservations about their application to social care.
Innovation in social work is fundamentally about people, relationships, and practice wisdom, not primarily about technology. While digital tools can support practice, they cannot replace the human elements that make social work effective. Social work innovation requires dedicated time and space for reflective practice, opportunities for peer learning and communities of practice, research-informed practice development, co-creation of value with people with lived experience, and protection of relationship-based approaches that are central to effective social work.
An NHS-led organisation may not understand or prioritise these distinctively social work approaches to innovation. The consultation's emphasis on digital transformation and technology-enabled solutions suggests a model that may work well for health but fails to capture what innovation means in social work contexts. When social workers talk about innovation, they talk about new ways of building relationships with people, new approaches to co-production/co-creation of value, new methods of addressing structural inequalities, and new forms of community-based support. These cannot be reduced to digital solutions or standardised processes.
We strongly support "Once for Scotland" where it delivers genuine value. However, this must mean collaboration between equal partners with distinctive expertise, not the imposition of a single approach regardless of the context. It must include recognition that "national" solutions must be adaptable to local contexts and needs. It requires building on existing successful frameworks rather than imposing new ones. It demands understanding that social care's mixed market of public, private and voluntary sector employers require different approaches than the NHS's unified employment model. And critically, it must ensure that "Once for Scotland" does not mean "designed for health, then adapted for social care as an afterthought".
The principle of national consistency is valuable, but it must not be pursued at the cost of local responsiveness, professional autonomy, or recognition of legitimate diversity in approaches to practice.
Streamlining should not mean centralising everything into one organisation. The SSSC's statutory independence as regulator is crucial for public protection and must not be compromised in the name of structural tidiness. Different organisations can work efficiently together without merging, and indeed often work better when they retain distinctive identities and purposes. The issue is often about funding, clarity of roles, and genuine partnership working, not structures. Merging organisations can sometimes create new problems while solving old ones, and structural change always carries transaction costs and risks of unintended consequences.
Question 2B: Should the organisation consider additional strategic objectives?
RESPONSE: Yes
If NHS Delivery is to have any role relating to social care, it must adopt additional strategic objectives that reflect the distinctive values and purposes of social work and social care.
Social work is fundamentally concerned with social justice, human rights, and challenging structural inequalities. These are not peripheral concerns but core to social work's identity and purpose. They must be explicit strategic objectives, not afterthoughts or assumed values. Social work exists to work alongside people experiencing oppression, disadvantage and marginalisation. It challenges systems that perpetuate inequality. It advocates for human rights and social justice. An organisation claiming a role in social work workforce development must embrace these commitments explicitly.
Any workforce development in social care must be genuinely co-created with people with lived experience of social work and social care services, with practitioners across all sectors and settings, with professional bodies including SASW, with regulatory bodies including SSSC, with trade unions representing the workforce, and with employer representatives from public, private and voluntary sectors.
Co-production is not consultation. It is not seeking views on pre-determined proposals. It is genuine shared decision-making and shared power. It means people with lived experience and practitioners helping to set the agenda, not just responding to it. It requires time, resources and commitment. It is central to social work values and must be central to any organisation working in this space.
Social work and social care development must prioritise reflective practice, critical thinking, and relationship-based approaches, not just knowledge transfer and competency checking. The consultation's references to "knowledge checks" and digital learning platforms suggest a model focussed on outputs rather than critical thinking and as such, they are insufficient for social work development.
Social workers need opportunities to reflect critically on their practice, to consider ethical dilemmas, to examine the use of power and authority, to understand the impact of structural inequalities on the people they work with, and to develop professional judgment and wisdom. These capabilities cannot be developed through multiple-choice tests or standardised modules. They require dialogue, reflection, supervision, peer learning and practice wisdom.
There must be a clear commitment that social care will receive equal priority, resourcing and status as health, not be treated as an add-on or afterthought. This must be demonstrated in governance arrangements, resource allocation, staffing, visibility in communications and strategy documents, and influence over organisational priorities and direction.
We have seen too often in integration contexts how social care becomes the junior partner, how resources flow to health priorities, how social work voices are marginalised in decision-making. Any organisation with a remit spanning health and social care must have structural protections ensuring genuine equality.
There must be explicit recognition that NHS Delivery would work in partnership with, not replace or subordinate, existing statutory bodies with social care responsibilities. The SSSC, Care Inspectorate, local authorities, and the National Social Work Agency all have distinctive roles and statutory responsibilities. NHS Delivery must respect and work with these bodies as equal partners, not seek to absorb their functions or override their decisions.
Question 3: Are there services or functions currently delivered by other Health Boards that should be delivered only by NHS Delivery to improve consistency and reduce duplication?
RESPONSE: No Comment
This question relates to NHS Scotland's internal arrangements. SASW has no view on the appropriate distribution of functions within NHS Scotland.
However, we emphasise strongly that social work and social care functions should NOT be included in any such consolidation without full consultation with affected stakeholders, clear evidence of benefit to social care (not just to NHS efficiency), protection of existing statutory frameworks and responsibilities, and genuine co-design of any changes with social work and social care stakeholders.
The question's framing assumes that consolidation automatically improves consistency and reduces duplication. This is not always the case. Sometimes a diversity of approach reflects legitimate differences in context, values or purpose. Sometimes what appears as duplication is actually necessary redundancy or reflects different accountabilities. Consolidation can create new problems including loss of specialist expertise, reduced responsiveness to diverse needs, and creation of monopoly providers. Any proposals for consolidation must be evidence-based and co-designed, not driven by assumptions about structural efficiency.
Question 4: What areas of national delivery could be improved by NHS Delivery to make services more efficient or better joined-up?
We believe there may be scope for NHS Delivery to contribute to making better use of data and digital tools, and to strengthening workforce development and training, but both come with significant caveats when applied to social care.
Digital tools can support social work practice, but only if they are designed with social work input from the outset, not adapted from health models after the fact. They must support relationship-based practice rather than attempting to replace human judgment and interaction with automated processes. They must be accessible to small employers in the social care sector who may lack technical infrastructure and IT support. They must protect privacy and confidentiality appropriately, recognising the particularly sensitive nature of social work information about families, relationships and safeguarding. And critically, they must interoperate with existing systems such as SSSC MyLearning rather than attempting to replace successful infrastructure.
The consultation's emphasis on "knowledge checks" and standardised digital learning, as noted, is concerning. Social work requires reflective practice, critical analysis, ethical reasoning and professional judgment, not just factual knowledge that can be tested through multiple-choice questions. Digital platforms have their place in supporting learning, but they cannot replace the dialogue, reflection, supervision and peer learning that develop professional wisdom and judgment.
Evidence from SSSC registrant surveys consistently shows that social care workers value qualifications, registration and professional development. Their key challenges are not a lack of digital platforms or national programmes, but practical barriers to accessing learning. These include difficulty accessing funding for qualifications, challenges getting time off work for training, limited availability of courses especially in rural areas, and backfill costs that employers struggle to meet.
Investment should focus on addressing these barriers rather than creating new platforms or national programmes. Decisions about training priorities are best made locally, where employers and workers understand their specific contexts and needs. National frameworks can provide standards, quality assurance and some shared resources, but they cannot replace local decision-making about workforce development priorities.
The SSSC already provides national frameworks, standards, qualifications and resources. What is needed is adequate funding to enable workers and employers to access these, not new national structures that may duplicate or undermine existing successful approaches.
Question 5: Are there any existing services, programmes, or functions currently delivered by NES or NSS that you believe could be stopped, scaled back, or redesigned?
RESPONSE: Partially Agree
We cannot comment in detail on NES and NSS internal functions as we lack the comprehensive knowledge needed to make informed judgments about the full range of their activities and their effectiveness.
However, we note that the National Induction Framework for Adult Social Care, developed by NES in partnership with SSSC, is valued by the workforce but needs sustainable funding to enable employers to release staff to undertake it. The issue is not the framework itself but the resources to support access.
Similarly, TURAS Learn modules work well where they complement rather than replace SSSC's MyLearning system. The interoperability between the two systems should be enhanced and built upon, not replaced with a single platform that may lose the strengths of each system. Different systems can work together effectively when properly connected.
Any "redesign" of services must involve social care stakeholders from the outset, not be imposed after decisions have been made. Social care workers and employers are best placed to judge what works well and what needs improvement. Co-design ensures that changes reflect actual needs and build on existing strengths rather than creating solutions in search of problems.
Question 6: Do you agree that NHS Delivery should lead the development of national digital capabilities (e.g., Electronic Health Records, digital inclusion, data architecture) for Scotland's healthcare system?
RESPONSE: Yes, for healthcare system
We agree that NHS Delivery should lead digital development for the healthcare system. However, we have critical caveats regarding any extension into social care.
Social work and social care records are fundamentally different from health records in nature, purpose and legal framework. They contain sensitive information about families, relationships, safeguarding, domestic abuse, and child protection that requires different handling than medical information. They are subject to different legal frameworks including the Social Work (Scotland) Act 1968, Children (Scotland) Act 1995, and Adults with Incapacity (Scotland) Act 2000, not primarily health legislation. They require different levels of access and security, reflecting different professional relationships and accountabilities. And critically, they serve different purposes: supporting people's social functioning, protecting vulnerable people, and promoting social justice, rather than diagnosing and treating illness.
These differences matter. Health records focus on diagnosis, treatment and clinical outcomes. Social work records document relationships, circumstances, risks, strengths, professional judgment about complex family situations, and plans for supporting people's wellbeing and safety. They cannot simply be subsumed into Electronic Health Record systems which are designed for clinical purposes. There is a risk that attempts to consolidate data will result in breaches of GDPR as health workers access social care data unnecessary for medical treatment.
Local authorities and social care providers already have case management and recording systems, many representing significant investment over many years. These systems are designed for social work purposes and integrated into local authority functions and accountabilities. Any "national" approach must interoperate with these existing systems, not replace them with a one-size-fits-all solution that may not meet diverse needs.
Replacing existing systems is hugely costly and disruptive, and history shows that large-scale IT projects frequently fail to deliver promised benefits. Evolution and interoperability are generally safer than wholesale replacement.
If NHS Delivery is to have any role in social care digital development, it must include social work and social care expertise from across the profession, including professional organisations such as SASW, in leadership and design teams, not rely on health professionals making assumptions about social care needs. It must involve genuine co-design with practitioners, people with lived experience, and employers who will use the systems. And it must have clear accountability to social care stakeholders, not just to NHS Scotland or Scottish Government health directorates.
Social care is not a subset of health that can be served by adapting health solutions. It requires distinctive approaches, and that requires social care expertise at the heart of design and development.
"Integration" of health and social care data sounds positive but can mean several problematic things in practice. It can mean loss of social care's distinctive voice and concerns as health perspectives dominate. It can lead to inappropriate sharing of sensitive information, particularly where health and social care have different thresholds for information sharing. It can result in NHS priorities dominating decisions about data systems and digital development. And it can lead to the erosion of local authority accountability for statutory social work functions, as data systems centralise control.
Integration must be carefully designed to preserve appropriate boundaries while enabling appropriate sharing. It must respect different legal frameworks, professional standards and accountability structures. It cannot be pursued simply on grounds of efficiency or “tidiness”.
Question 7: Should NHS Delivery be tasked with improving data sharing, data access and interoperability across health and social care?
RESPONSE: Partially
Data sharing and interoperability are important goals, but they must be pursued with care and proper safeguards.
This must respect different legal frameworks, confidentiality requirements, and purposes. Health and social care operate under different legislation with different provisions for information sharing. Local authorities remain accountable for social work and social care functions, so they must retain control over their data and decisions about how it is shared. "Improving data sharing" must not mean automatic sharing or loss of professional judgment about what should be shared in particular circumstances. The social care sector, especially small private and voluntary providers, needs support and investment in digital infrastructure before increased data sharing becomes feasible. And critically, people with lived experience must be involved in decisions about how their information is shared, not have sharing protocols determined without their voice.
Any body responsible for health and social care data sharing must have representation from local government, not just NHS representatives making decisions on behalf of councils. It must include social work and social care expertise at senior levels, including professional associations and unions. It must have independent oversight to ensure appropriate safeguards. And it must have clear accountability for protecting sensitive information, particularly information about vulnerable people, families and children.
Data sharing gone wrong can have severe consequences. People's safety can be compromised. Trust between practitioners and the people they support can be damaged. Legal and regulatory requirements can be breached. And disadvantaged people can be further marginalised when their information is shared inappropriately. These risks must be taken seriously in governance arrangements.
Question 8: Do you believe NHS Delivery should be tasked with the lead national support role in innovation development and adoption, service redesign, change management, improvement, and commissioning of health services?
RESPONSE: Yes, for health services
STRONGLY NO for social care, unless the approach is fundamentally reconceived
The question reveals the consultation's health-centric assumptions. Social work and social care require distinctive approaches to each of these functions.
Social work innovation is about relationship-based practice, co-creation of value with people with lived experience, critical reflection on the use of power and authority, addressing structural inequalities that create the problems people face, and community-based solutions that build on people's strengths and connections. It is not primarily about the adoption of technology, process standardisation, or efficiency gains, though these may play a supporting role.
When social workers talk about innovation, we mean new approaches to working alongside people experiencing multiple disadvantages, new methods of engaging with people who distrust services, new ways of addressing poverty and inequality, new forms of community-based support, and new approaches to co-production and shared decision-making. Our members are very concerned that an NHS-led organisation focused on clinical innovation and digital transformation may not understand or value these distinctive forms of social work innovation.
Social work and social care service redesign must be led by local authorities who hold statutory responsibilities for these services and are accountable to local communities through democratic processes. It must involve people with lived experience as equal partners, not consultees responding to professional proposals. It must recognise the mixed market of provision across public, private and voluntary sectors. It must respect social work values including self-determination, social justice and anti-oppressive practice. And critically, it must be accountable to local democratic structures, not imposed by national bodies.
The NHS model of service redesign, often led by clinicians and managers with public involvement, does not transfer straightforwardly to social care where user-led approaches and co-creation of value are more developed, and where local democratic accountability operates differently.
Social care change management requires significant understanding of small employer contexts where many services operate with fewer than 25 staff. It must recognise the mixed workforce of registered and unregistered staff with different qualifications, experience and development needs. It must support relationship-based practice that depends on continuity and trust, not just processes and procedures. It must reflect person-centred and rights-based approaches that put people who use services at the centre. And it must respect local democratic accountability and the role of elected members in decision-making.
NHS change management approaches, often focused on large organisations with professional hierarchies and clinical governance, may not translate effectively to these diverse social care contexts.
Commissioning of social work and social care services is a local authority function, reflecting local democratic accountability for these services. NHS Delivery should have NO role in this unless specifically requested by local authorities as equal partners, not as a national body directing local authorities.
Social care commissioning is fundamentally different from health commissioning. It must be person-centred, promoting choice and control. It must enable diverse provision across public, private and voluntary sectors. It must support co-production with people who use services. It must reflect local priorities determined through democratic processes. And it must be accountable to local communities through elected members. These requirements sit uncomfortably with national direction from an NHS board.
IF NHS Delivery were to have any role in social care improvement and innovation, it would need to be completely reconceived. It would need to be a partnership body with joint governance between NHS and local government, not an NHS board with social care added to its remit. It would need to be co-governed with local government and social care stakeholders as equal partners in decision-making. It would need to be properly resourced for social care as a distinct function, not treated as an extension of health with marginal additional funding. And it would need to be accountable to social care sector representatives, people with lived experience and local government, not just to Scottish Government health directorates.
Without this fundamental reconception, extending NHS Delivery's remit into social care improvement and innovation would be inappropriate and risky.
SECTION B: LONGER TERM OPPORTUNITIES AND FUTURE EVOLUTION
Question 9: As NHS Delivery evolves in the longer term, what additional capabilities, functions or bodies should be considered for integration into a single national delivery capability?
SASW has significant concerns about this question's framing. It assumes that integration into a single body is automatically desirable. We fundamentally disagree with this assumption.
The Scottish Social Services Council's statutory independence as regulator is crucial for public protection and must not be compromised. The SSSC's functions include professional registration of social work and social care workers, setting and maintaining standards for practice and conduct, investigating and determining fitness to practise cases, approving and quality assuring qualifications, setting mandatory continuous professional learning requirements, and publishing workforce data and statistics. These regulatory functions require independence from service delivery bodies to maintain public confidence and proper accountability. Compromising this independence would be a serious backward step for public protection.
The consultation makes no mention of the Care Inspectorate's improvement functions, which is a significant omission. The Care Inspectorate has developed considerable expertise in social care improvement that must not be overlooked or absorbed into an NHS-dominated structure. Their understanding of social care contexts, relationships with providers across all sectors, and improvement approaches designed for social care settings are valuable assets that should be built upon, not dismantled.
Local authorities hold statutory responsibilities for social work and social care services. These must not be centralised into a national body. Local democratic accountability is essential for social work and social care, reflecting diverse local needs and priorities, enabling elected members to fulfil their accountability to local communities, and ensuring that services respond to local circumstances rather than national standardisation.
Instead of pursuing integration into a single body, we need clearer articulation of which body does what, with memoranda of understanding where functions overlap or interface. We need adequate resourcing of existing bodies, because the key problem is often financial not structural. The SSSC, for example, needs adequate resources to support workforce development without having to create new structures or compete for funding with service delivery priorities.
We need formal partnership frameworks between NHS Delivery for health functions, SSSC for social services workforce regulation and development, local authorities for service delivery, Care Inspectorate for improvement support, and National Social Work Agency for social work practice leadership. These frameworks should clarify roles, accountabilities and ways of working together.
We need robust co-production mechanisms that enable people with lived experience to shape workforce development priorities, practitioners to inform improvement activities based on their professional judgment and experience, and democratic oversight of national bodies to ensure accountability to the public they serve.
We need careful consideration of how the National Social Work Agency should relate to NHS Delivery, ensuring social work voice and practice leadership is not lost in an NHS-dominated structure but has a clear platform and influence.
The consultation's approach seems to assume that structural integration automatically improves services. This is not supported by current evidence. What matters for effective services is clear purpose and accountability, adequate resources, genuine partnership working, co-production with people with lived experience, and respect for different professional and organisational cultures. These can be achieved through partnership without structural integration, and are often achieved better that way.
Question 10: What principles should guide decisions about future expansion of NHS Delivery's remit and structure?
RESPONSE: Partially Agree with additions
We agree with the principles suggested in the consultation but would strengthen them significantly and add additional principles essential for social care.
We agree that alignment with the Service Renewal Framework and Public Service Reform Strategy should guide decisions. However, these frameworks must explicitly include social work and social care with equal status to health, not treat health as primary with social care as secondary or derivative. The frameworks should recognise social work's distinctive values, purposes and approaches, not assume that health and social care are interchangeable or that solutions designed for health will work for social care.
We strongly agree that evidence of benefit should be required. However, evidence must come from social care stakeholders including practitioners, people with lived experience, and employers. Evidence must demonstrate benefit to social care specifically, not just efficiency gains for NHS or Scottish Government. And evidence must include potential harms and unintended consequences, not just assumed benefits.
We agree that duplication should be avoided where it adds no value. However, this means building on existing successful systems such as SSSC frameworks, MyLearning platform, and continuous professional learning requirements, not replacing them with new structures that may be less effective. Sometimes what appears as duplication reflects different purposes, accountabilities or contexts, and removing it would create problems rather than solving them. Avoiding duplication requires understanding why current arrangements exist before changing them.
We strongly agree that stakeholder consensus should guide decisions. However, stakeholders must be properly defined to include people with lived experience of social work and social care services, professional bodies including SASW and Social Work Scotland, trade unions including UNISON and GMB representing the workforce, regulatory bodies including SSSC and Care Inspectorate, local government represented through COSLA and individual councils, and employers across public, private and voluntary sectors. Consensus means genuine agreement, not consultation where views are sought but decisions are predetermined.
We strongly agree that legislative clarity and accountability must be maintained. This means respecting local authority statutory responsibilities for social work and social care, protecting SSSC regulatory independence established through the Regulation of Care (Scotland) Act 2001, maintaining social work professional standards, and preserving democratic accountability through elected members for social care services.
Beyond the principles suggested in the consultation, we believe eight additional principles are essential.
First, co-production/co-creation of public value must be central to any expansion into social care. Changes must be genuinely co-designed with affected stakeholders including people with lived experience, not imposed after consultation where views are noted but decisions are predetermined.
Second, there must be absolute commitment to equality of status between health and social care. Social care must receive equal priority, equal resources, equal voice in decision-making, and equal visibility in communications and strategy. It cannot be an afterthought or junior partner.
Third, there must be respect for difference. Social care is not simply community health or non-clinical health services. It has distinctive purposes rooted in social justice and human rights, distinctive values including self-determination and anti-oppressive practice, and distinctive approaches including relationship-based practice and co-production. These differences must be understood and valued, not eroded.
Fourth, changes must do no harm. Expansion should not undermine existing successful frameworks, weaken statutory protections, reduce quality of services, or damage professional identity and morale.
Fifth, social justice must be an explicit commitment. Workforce development must address structural inequalities, challenge oppressive practices, promote human rights, and work towards social justice. These are core to social work and must be core to any organisation working in this space.
Sixth, professional identity must be protected. Social work professional identity is important for attracting and retaining talented people, maintaining professional standards, providing clear accountability, and preserving the distinctive contribution social work makes. It must not be absorbed into generic "health and social care workforce" that loses what makes social work distinctive.
Seventh, local accountability must be preserved. Social work and social care services are accountable to local communities through elected members. This democratic accountability is precious and must not be eroded through centralisation of functions into national bodies.
Eighth, the pace of change must be realistic. Trust takes time to build, especially where there are concerns about power imbalances and different organisational cultures. Any expansion into social care should be phased carefully, evaluated rigorously based on evidence not assumptions, and adjusted based on experience and feedback from those affected.
Question 11: What mechanisms should be put in place to review and adapt NHS Delivery's remit and performance post-launch?
RESPONSE: Agree with qualifications
For NHS functions, the suggested mechanisms seem broadly appropriate. Formal review after 12 to 24 months would enable evidence-based assessment of whether intended benefits are being realised. Stakeholder engagement and feedback loops would ensure ongoing input from those affected by changes. Independent evaluation or audit would provide objective assessment. And legislative review or amendment would enable adjustments to the legal framework if needed.
However, for any social care functions, additional mechanisms are essential to ensure proper accountability and protection of social care interests.
The NHS Delivery board must include substantial representation from beyond NHS Scotland if it has any social care remit. This must include representatives nominated by COSLA representing local government's statutory responsibilities, representatives from the social work profession nominated by bodies including SASW and Social Work Scotland, independent members from social care sector representing private and voluntary sector employers, people with lived experience of social work and social care services as full board members not just consultees, and representation from SSSC reflecting its regulatory role and workforce development leadership.
This representation must be substantial, not token. Social care representatives must have genuine influence over decisions, not be outvoted by health representatives on matters affecting social care.
A formal sub-committee of the board should be established with majority non-NHS membership, power to review and challenge decisions affecting social care, regular reporting requirements to board and Scottish Government, and ability to commission independent reviews of specific issues or concerns.
This committee would provide focused oversight of social care functions, ensuring they receive proper attention and are not marginalised within a larger health-focused organisation.
Formal partnership agreements should be established with the SSSC protecting its regulatory independence and clarifying working relationships, with the Care Inspectorate regarding respective improvement functions, with COSLA on behalf of local authorities regarding their statutory responsibilities and democratic accountability, and with National Social Work Agency regarding social work practice leadership.
These agreements should include clear roles and responsibilities so that everyone understands who does what, dispute resolution mechanisms for when disagreements arise, regular review and renewal to ensure they remain fit for purpose, and explicit ability to withdraw from agreements if they are not working, ensuring partnerships remain genuine not imposed.
NHS Delivery should be required to produce separate annual reporting on social care workforce development outcomes including qualifications achieved, continuous professional learning completion, and workforce satisfaction, resource allocation to social care compared to health demonstrating genuine equality of investment, stakeholder satisfaction from social care sector including employers, practitioners and professional bodies, lived experience perspectives gathered through robust engagement not token consultation, and comparison with previous arrangements to demonstrate whether changes have delivered promised benefits.
This separate reporting is essential because social care can easily be invisible within overall reporting dominated by health activities and priorities.
Evaluation should be conducted by social care experts, not health consultants or generalists who may not understand social care contexts. Evaluation should occur after 18 months to provide early assessment, and again after three years for more comprehensive review. Results must be published in full, not summarised selectively, and must be acted upon with clear responses to recommendations.
Independent evaluation provides accountability and enables evidence-based decisions about whether arrangements are working or need adjustment.
Mechanisms must be established for frontline social workers and social care workers to provide feedback directly, not filtered through management. This should include annual workforce surveys asking about impact on practice, professional development and service quality, regular focus groups in different areas and settings, practice learning forums where practitioners share experience and learning, and direct reporting routes to board members so concerns can be raised without going through management chains.
Frontline practitioners see most clearly what works and what doesn't in their daily practice. Their voice is essential for meaningful accountability.
Formal involvement of people with experience of social work and social care services must include representation in governance structures as full members not consultees, involvement in service design decisions from earliest stages, meaningful participation in evaluation and review processes, and genuine influence over priority-setting and resource allocation decisions.
People with lived experience bring perspectives that professionals cannot have, and their involvement is central to social work values. It must be resourced properly, not reliant on goodwill and unpaid time.
Any social care functions transferred to NHS Delivery should include sunset clauses requiring explicit renewal after three years, not automatic continuation. Renewal should require evidence of benefit to social care demonstrated through independent evaluation, stakeholder consent including social care representatives not just government, and parliamentary approval if functions are to continue, ensuring democratic oversight.
Sunset clauses provide protection against arrangements that are not working but prove difficult to change once established.
Local authorities should have ability to opt out of "national" services if they don't meet local needs or represent good value. This respects local democratic accountability and recognises that one size may not fit all.
Regular reporting to Scottish Parliament should involve the Health and Sport Committee for health functions and the Local Government Committee for social care functions, with joint scrutiny where appropriate. This ensures proper democratic oversight through different committees reflecting different accountabilities.
CONCLUSION
SASW supports the Scottish Government's ambition to improve health and social care services for the people of Scotland. We recognise the potential benefits of reducing duplication and improving digital infrastructure within NHS Scotland. We welcome the commitment to Once for Scotland approaches where they add genuine value.
However, this consultation reveals a fundamental misunderstanding of social work and social care that must be addressed before proceeding.
The proposals risk perpetuating health dominance over social care, where NHS priorities, perspectives and approaches marginalise social work and social care needs. They risk undermining existing successful frameworks including SSSC registration and regulation, MyLearning platform, continuous professional learning requirements, and National Occupational Standards. They risk eroding local democratic accountability by centralising functions that should remain accountable to local communities through elected members. They risk damaging social work professional identity by absorbing social work into a generic health and social care workforce. They risk imposing inappropriate NHS models on social care contexts that require different approaches. They risk failing to genuinely co-produce changes with people with lived experience, instead consulting on predetermined proposals. And they risk ignoring the distinctive nature and scale of social services, which employ more people than NHS Scotland and operate in fundamentally different ways.
We need recognition that social services employ more people than NHS Scotland, operate across more diverse settings and sectors, and require approaches designed for social care contexts not adapted from health. We need protection and proper resourcing of SSSC's statutory role as regulator and national lead for workforce development in social services. We need genuine co-design of any changes with social work and social care stakeholders as equal partners from the outset. We need investment focused on addressing barriers to training and qualifications such as funding, time off work, and course availability, rather than creating new structures. We need partnership between equals, where SSSC, NHS Delivery, local authorities, Care Inspectorate and National Social Work Agency work together respecting each other's distinctive roles. We need visibility and voice for social work throughout the framework, not invisibility in a health-dominated consultation. We need respect for local democratic accountability, recognising that social work and social care are accountable to local communities through elected members. And we need explicit commitment to social justice, human rights and co-production as core values, not optional extras.
We make five key recommendations to Scottish Government.
First, proceed with establishing NHS Delivery for health functions as proposed, recognising the potential benefits for NHS Scotland's digital transformation and workforce development.
Second, pause any extension of NHS Delivery's remit into social care until proper co-design can take place with social work and social care stakeholders as equal partners, the SSSC resources and role are clarified and protected, social work visibility throughout the framework is ensured with social work explicitly named and its distinctive nature recognised, and governance arrangements guarantee genuine equality of status between health and social care not token representation.
Third, commission an independent review of what "national" social care workforce development should look like, led by social care experts not health professionals, involving genuine co-production with stakeholders, considering the relationship with SSSC, Care Inspectorate, local authorities and National Social Work Agency, and producing recommendations before decisions are made about NHS Delivery's role in social care.
Fourth, ensure that the National Social Work Agency development is aligned with any workforce development changes, avoiding duplication or confusion about roles while ensuring social work practice leadership has a clear platform.
Fifth, publish a clear statement on how NHS Delivery will relate to SSSC, Care Inspectorate, local authorities and National Social Work Agency, clarifying respective roles, accountabilities and partnership arrangements.
SASW remains absolutely committed to working in partnership with Scottish Government, SSSC, and all stakeholders to improve social work and social care services for the people of Scotland. We recognise the challenges facing our services and the need for change and improvement. We bring considerable expertise in social work practice, policy development, workforce issues and partnership working that we are eager to contribute.
However, this partnership must be genuine partnership, co-produced from the outset and based on mutual respect between equals. It cannot be top-down integration into an NHS-dominated structure where social work and social care become invisible, where existing successful frameworks are dismantled without proper consideration, and where NHS approaches are imposed on social care contexts without understanding their distinctive nature and needs.
We welcome further dialogue on these crucial issues and stand ready to contribute social work expertise to any genuine co-design process.