SMMGP - Substance Misuse Management Good Practice

Substance Misuse Management Good Practice

Supporting good practice in drug and alcohol treatment

Clinical & Policy Updates:
SMMGP Policy Update May 2010

This Policy Update is a collaborative one between SMMGP and FDAP (Federation of Drug and Alcohol Professionals) and outlines the important regulation changes which are currently being implemented in the field.

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Adobe Acrobat DocumentDownload the PDF version of this Update here! (PDF*, 120K)


Regulation and inspection changes which affect the drugs and alcohol field

The drugs and alcohol field is subject to a number of regulation and inspection changes which are currently being implemented. Employers will find themselves subject to regulatory changes which can lead to criminal procedures if they fail to comply. The following is an over view of three regulatory changes prepared by Carole Sharma of the Federation of drug and alcohol professionals (FDAP) and David Finney - substance misuse and registration expert, former policy lead for substance misuse services in the Commission for Social Care inspection.

Further information from


The Independent Safeguarding Authority (ISA) is charged with implementing and maintaining the vetting and barring system for all of those who work with vulnerable adults and children. This system will replace the other barred lists such as POVA and list 99.

The ISA works in partnership with the Criminal Records Bureau (CRB) to ensure there is "no known reason" why individuals who wish to work or volunteer with children or vulnerable adults shouldn't do so.

The ISA's role is to make independent barring decisions and place or remove individuals on either the ISA children barred list, the ISA vulnerable adult barred list, or both.

SMMGP comment

The information above helpfully summarises some significant changes which will affect employees in the drugs and alcohol field. Some people employed in drug and associated services have a history of drug use and sometimes of offending. Until now the decision on whether to employ has rested with local service providers.

The introduction of the ISA introduces a new layer of decision making on employability and SMMGP hopes that the ISA displays a level of understanding of the links between substance misuse and offending, whilst protecting vulnerable children and adults. On the plus side, once registered we will not have to keep doing those CRB checks! Refer also to the NTA guidance at

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The Health Professions Council (HPC) - The White Paper: Trust Assurance and Safety The Regulation of Health Professionals in the 21st Century

The white paper stated the following in respect of counsellors and psychotherapists:

Criteria for entry of new professions to the HPC are:

What does this mean for me?

Will I lose my job if I can't register?

To use the title when unregistered is a criminal offence.

Will being accredited help?

How do I know if my course is or will be an approved qualification?

What if I do not hold an approved qualification?

When will it happen?

What will it cost?

What does this mean for the drugs and alcohol counsellors?

SMMGP comment

This system should provide added support and strengthen the position of the existing network of counsellors - attractive in the current economic and political climate, whilst ensuring that the service clients receive is regulated and SMMGP believe it is in your best interest to become accredited with an appropriate professional body such as FDAP or BACP.

For more information go to and

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Registration of Substance Misuse Services with the Care Quality Commission

The world of registration is about to change for many drug and alcohol treatment providers in the coming months. The Care Standards Act 2000 is being repealed and the Health and Social Care Act 2008 has set up the Care Quality Commission (CQC) which will register an increasing range of health and social care services. In their publicity CQC point out that "it is a serious offence to carry out a regulated activity without being registered", so as this carries the force of law it is essential that treatment providers are registered in order to continue operating legally.

The five big changes about to happen in the substance misuse sector are:

The overall aim of statutory registration is to provide protection for people who are vulnerable and to establish essential standards of quality and safety which will be found across the board in health and social care settings.

Additionally many commissioners of services now insist on purchasing only services which are registered and as the CQC reviews the performance of NHS trusts and Local Authorities it holds them accountable for the status and quality of the services they purchase.

So what does all this registration look like? And when is it all going to happen?

Under section 20 of the Health and Social Care Act 2008 there are:

The timetable for implementation is that applications will need to be completed by 31 July 2010, with the 1st of October 2010 being the date on which registration will become effective. It may be useful to specifically highlight issues that impact on the substance misuse sector:

Furthermore it clarifies that a service is registerable if "treatment is a condition of the provision of the accommodation" This means that if accommodation is on a separate site from the treatment but is contractually linked to the treatment provision then it should be registered. Services which are purely Tier 3 day services do not yet come into the scope of registration although it is something which the Department of Health are actively considering for the future.

There is also a new "service type" called residential substance misuse treatment/rehabilitation service.

Interestingly this can include treatment for withdrawal from drugs or detoxification from alcohol and can employ a broad range of health and social care professionals. This service type is distinct from care homes or care homes with nursing and importantly the same standards for room sizes and physical accommodation do not apply. This will allow more flexibility for services to configure themselves appropriately to meet the needs of their client group.

Treatment of disease, disorder or injury must be under the supervision of a health care professional, or a multi disciplinary team which includes a health care professional, or a social worker where treatment is for a mental disorder.

"Mental disorder" means "any disorder or disability of the mind, including dependence on alcohol or drugs."

"Treatment" One aspect is defined as "the ongoing assessment of a service user's mental or physical state".

Many community prescribing or drug and alcohol treatment services will come under this definition and be required to register for the first time.

Space doesn't permit a full description of the "Essential Standards of Quality and Safety", however these can be downloaded from the CQC website or hard copies can be ordered from their publications department (03000 616161). In essence the standards aim to focus on the individual needs of the service user and come under such outcome headings as:

The stated aim of these new standards is to put the experience of the service user at the centre of the provision of services.

SMMGP comment

CSC registration is here and many people are spending much time fulfilling the requirements to register. SMMGP hopes the registration does put the experience of the service user at the centre of the provision of services.

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A new era

May brought the elections and a change in Government. The new Government has announced its intention to restructure the NHS including the establishment of an independent NHS Board to allocate resources and provide commissioning guidance.

Secretary of State for Health is Andrew Lansley and the following portfolios have been allocated to the ministerial team:

Paul Burstow (Care Services) - Long Term Care Reform; Adult Social Care; Carers; Personal Health Budgets; Safeguarding Vulnerable Adults; End of Life Care; Long Term Conditions, including cancer & diabetes; Dementia; Mental Health; Physical Disabilities; Autism; Learning Disabilities.

Simon Burns (Health) - Legislation; NHS Performance; Health Services; Reconfiguration of Services; Patient Safety; Application of Quality Regulation; NHS Workforce; Mixed Sex Accommodation; Connecting for Health.

Anne Milton (Public Health) - Public Health, including sexual health, tobacco, drugs & alcohol; Vaccination & Immunisation; Blood & Transplants; Fertility & Embryology; Fluoridation; Food, diet & nutrition; Children's Health; Maternity Services; Nursing & Midwifery; Health Visiting; Professional Regulation; Medical Education & Training

Earl Howe (Quality) - NHS Constitution; NHS Commissioning Reform; Primary Care; Dentistry; Medicines, Pharmacy & Industry; NICE; Research & Development; Innovation; Finance; Review of Arm's Length Bodies.

SMMGP comment

There is no policy detail available publicly as yet. It is likely that changes to the structure of Department of Health and NHS will be made before policy detail is sketched out. No further details will be available about, for example, where the NTA will fit into the new NHS structure until a government White Paper is published in July.

So, for most of us it is - for the moment - business as usual.