Marnie Hill
PFD Report
All Responded
Ref: 2023-0388
All 3 responses received
· Deadline: 12 Dec 2023
Response Status
Responses
3 of 1
56-Day Deadline
12 Dec 2023
All responses received
About PFD responses
Organisations named in PFD reports must respond within 56 days explaining what actions they are taking.
Source: Courts and Tribunals Judiciary
Coroner’s Concerns
1. During the inquest evidence was heard that: i. There is no regulation of counsellors in England and Wales and this could lead to future deaths.
ii. is a private counsellor with 30 years’ experience who provided support to Marnie prior to her death. She confirmed that counselling is not a regulated professional and there are courses available at a cost of £29 for a 6 week course, after which a person can receive a diploma and call themselves a counsellor. There is no requirement for them to do further training or continual professional development. There are no rules or regulations about how counsellors should operate, for example how they keep and share records.
iii. Information shared by an individual to a counsellor may disclose a risk of self harm or suicide, or harm to another and there is no requirement for a counsellor to report that information to any third party.
iv.
gave evidence that the lack of regulation and licensing of counsellors could lead to a lot of damage being done to individuals seeking help and that this could present a risk to life as there is no regulation around informing medical professionals or others who can provided further support and care to the individual.
v. Evidence was also given by , one of the GPs who provided care to Marnie, that receipt of records from others such as counsellors, especially at the end of the counselling, would assist her in providing care to patients.
2. I have concerns with regard to the following: i. There is a risk of future deaths occurring due to the lack of regulation of the counselling profession.
ii. is a private counsellor with 30 years’ experience who provided support to Marnie prior to her death. She confirmed that counselling is not a regulated professional and there are courses available at a cost of £29 for a 6 week course, after which a person can receive a diploma and call themselves a counsellor. There is no requirement for them to do further training or continual professional development. There are no rules or regulations about how counsellors should operate, for example how they keep and share records.
iii. Information shared by an individual to a counsellor may disclose a risk of self harm or suicide, or harm to another and there is no requirement for a counsellor to report that information to any third party.
iv.
gave evidence that the lack of regulation and licensing of counsellors could lead to a lot of damage being done to individuals seeking help and that this could present a risk to life as there is no regulation around informing medical professionals or others who can provided further support and care to the individual.
v. Evidence was also given by , one of the GPs who provided care to Marnie, that receipt of records from others such as counsellors, especially at the end of the counselling, would assist her in providing care to patients.
2. I have concerns with regard to the following: i. There is a risk of future deaths occurring due to the lack of regulation of the counselling profession.
Responses
South Western Ambulance Service has contacted Private Ambulance Providers (PAPs) to remind them of GP referral requirements, referred them to the Appropriate Care Pathway Policy, and introduced a new process for policy sharing. The Electronic Care System (ECS) was successfully reintroduced, and the Trust is reviewing Business Continuity Plans to adopt Scribe ECS as a secondary fall-back.
AI summary
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Dear Mrs Griffin Inquest touching on the death of Marnie Hill- GP Referrals and SWASFT Electronic Care System I write in relation to the inquest of the above-mentioned Marnie Hill following your request for assurance around GP referrals made by the Trust’s Private Ambulance Providers (PAP’s) and the challenges recently encountered with the Trust’s Electronic Care System (ECS). GP Referrals I can confirm that we have contacted the central contract leads for all PAPs that are contracted on behalf of SWASFT, reminding them of the current situation regards GP referrals when utilising paper Patient Clinical Records (PCR) or the Scribe ECS system. Specifically, we have referred them to SWASFT’s Appropriate Care Pathway Policy, which all PAPs are required to adhere to, and the requirement for clinicians to make a direct referral to the GP or Out of Hours (OOH) GP service if their patient requires input within 72 hours. They have also been reminded to pass information on to the GP surgery verbally via the GP surgery, OOH GP or 111 where needed. Additionally, the availability of the GP Alert service run by Dorset Integrated Urgent Care Service (IUCS) for passing information to GPs within Dorset has also been brought to their attention. We have requested that the PAPs disseminate this information to all their staff and confirm back to us both acknowledgement of this information and confirmation it has been disseminated. All Trust PAPs have replied and provided assurances regarding this. During communications with the PAPs, it has been identified that St John Ambulance (SJA) are commissioned directly by the National Ambulance Co-ordination Centre (NACC), which is hosted by West Midlands Ambulance Service University NHS Foundation Trust. The consequence of this is that we do not have direct contract with them, rather the Trust is allocated resources as part of the national NACC contract. SJA currently have between one and four ambulances supporting SWASFT per day across the South West. As a Trust, we have discussed this directly with SJA who have confirmed that
currently being set up. process and document sharing system with the PAPs. They are now informed and have access to all our updated policies on their release. Furthermore, I have also asked all Clinical Leads across SWASFT to ensure that this is included within their Local Clinical Update documents available via the Clinical App. I would also like to take this opportunity to update you on the automation of GP referrals the position in due course. Electronic Care System I am pleased to confirm that our ECS was successfully reintroduced on Tuesday 10th reduce the possibility of adopting paper PCRs in response to an outage in our primary ECS in the future. I hope this addresses your concerns but please do not hesitate to get in contact if you need further information.
currently being set up. process and document sharing system with the PAPs. They are now informed and have access to all our updated policies on their release. Furthermore, I have also asked all Clinical Leads across SWASFT to ensure that this is included within their Local Clinical Update documents available via the Clinical App. I would also like to take this opportunity to update you on the automation of GP referrals the position in due course. Electronic Care System I am pleased to confirm that our ECS was successfully reintroduced on Tuesday 10th reduce the possibility of adopting paper PCRs in response to an outage in our primary ECS in the future. I hope this addresses your concerns but please do not hesitate to get in contact if you need further information.
Dorset Integrated Care Board describes its well-established 24/7 "Access Mental Health" service and explicitly disputes the claim that Dorset residents lack 24/7 mental health support. They are actively discussing and exploring ways to enhance inter-service referrals and implement a trusted assessor model with partners like SWASFT.
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Dear Rachael 14th November 2023 Thank you for your letter dated 23rd October in relation to the inquest of Marnie Emma Hill. Having reviewed your particular query concerning the provision of mental health care within the South West Ambulance Service, I am able to respond as follows: Dorset has a well-established service in place to support its residents who are in crisis, namely the “Access Mental Health” service provided by Dorset HealthCare. Access Mental Health has been operational since 2017/18 and offers the following:
• Connection Service which is 24/7 crisis line with links through 111
• Psychiatric Liaison 24/7
• Home treatment teams as an alternative to hospital
• Crisis spaces called Retreats or Community Front Rooms
• Two Crisis Houses for short respite for people who are heading towards crisis. Access Mental Health provides a crisis offer that was fully coproduced with many partners and stakeholders including SWASFT. However, we recognise there are still some challenges relating to referring patients between services and that these are not operating as consistently as we would like; to re-assure, these issues are being actively discussed including, as set out below, how we might further enhance this through our approach to the trusted assessor model. Dorset HealthCare, SWASFT and the police are in discussion about operational processes and how they work together when supporting individuals. The trusted assessor model is one way of doing this and we are actively working through what this model might look like. We can certainly see how it could work between SWASFT and Dorset HealthCare and how both organisations could trust the assessments of the other. The discussions will hopefully ensure that all partners, with responsibility for the care of patients, can work together to enhance the local crisis offer and provide a service that works every time for people suffering a mental health crisis in Dorset. It is the case that the SWASFT Mental Health Desk is not firmly embedded in the Dorset System. This is because of the Access Mental Health services we have locally, as well as the challenge of the Desk being located operationally and geographically at some significant distance away from Dorset. In practice, we find that this means there is a greater incidence of people being referred to the local Emergency Department because call handlers are not aware of the services, models and approaches we have available in Dorset. These services include a range of locally placed Crisis Retreats, Community Front Rooms and Recovery Houses which all support people with a rising mental health crisis.
We note that SWASFT have reported that without the 24/7 help desk people in Dorset are left without MH support that is 24/7; this is not the case. Whilst discussions are ongoing in relation to how we might maximise the benefits for Dorset residents by being partners in the SWASFT MH Desk 24/7, Dorset residents do in fact have access to 24/7 MH support and advice as set out above. All that said, we recognise it is important to continue exploring the SWASFT Mental Health Desk service, especially as this could form an important part of other interdependent workstreams we are aiming to progress - such as a proposed development of mental health ambulance response vehicles. All our stakeholders including SWASFT and Dorset Police are fully committed to developing the right model for the Dorset population and this will help us when deciding on any additional investment and resource to the desk beyond the level currently commissioned. I hope this helps clarify the provision we have available and the work we are doing to ensure people in a mental health crisis have access to the right care at the right time. We would be pleased to keep you informed of developments, should this be of interest. Could I please request that all future correspondence to NHS Dorset is sent to me either via A7 post, or email - Many thanks
• Connection Service which is 24/7 crisis line with links through 111
• Psychiatric Liaison 24/7
• Home treatment teams as an alternative to hospital
• Crisis spaces called Retreats or Community Front Rooms
• Two Crisis Houses for short respite for people who are heading towards crisis. Access Mental Health provides a crisis offer that was fully coproduced with many partners and stakeholders including SWASFT. However, we recognise there are still some challenges relating to referring patients between services and that these are not operating as consistently as we would like; to re-assure, these issues are being actively discussed including, as set out below, how we might further enhance this through our approach to the trusted assessor model. Dorset HealthCare, SWASFT and the police are in discussion about operational processes and how they work together when supporting individuals. The trusted assessor model is one way of doing this and we are actively working through what this model might look like. We can certainly see how it could work between SWASFT and Dorset HealthCare and how both organisations could trust the assessments of the other. The discussions will hopefully ensure that all partners, with responsibility for the care of patients, can work together to enhance the local crisis offer and provide a service that works every time for people suffering a mental health crisis in Dorset. It is the case that the SWASFT Mental Health Desk is not firmly embedded in the Dorset System. This is because of the Access Mental Health services we have locally, as well as the challenge of the Desk being located operationally and geographically at some significant distance away from Dorset. In practice, we find that this means there is a greater incidence of people being referred to the local Emergency Department because call handlers are not aware of the services, models and approaches we have available in Dorset. These services include a range of locally placed Crisis Retreats, Community Front Rooms and Recovery Houses which all support people with a rising mental health crisis.
We note that SWASFT have reported that without the 24/7 help desk people in Dorset are left without MH support that is 24/7; this is not the case. Whilst discussions are ongoing in relation to how we might maximise the benefits for Dorset residents by being partners in the SWASFT MH Desk 24/7, Dorset residents do in fact have access to 24/7 MH support and advice as set out above. All that said, we recognise it is important to continue exploring the SWASFT Mental Health Desk service, especially as this could form an important part of other interdependent workstreams we are aiming to progress - such as a proposed development of mental health ambulance response vehicles. All our stakeholders including SWASFT and Dorset Police are fully committed to developing the right model for the Dorset population and this will help us when deciding on any additional investment and resource to the desk beyond the level currently commissioned. I hope this helps clarify the provision we have available and the work we are doing to ensure people in a mental health crisis have access to the right care at the right time. We would be pleased to keep you informed of developments, should this be of interest. Could I please request that all future correspondence to NHS Dorset is sent to me either via A7 post, or email - Many thanks
The Department of Health and Social Care acknowledges concerns about counsellor regulation, explaining that professional bodies are independently adopting the SCoPEd framework to define competencies and standards. It clarifies that these bodies are not under government oversight and decisions on training standards are their responsibility.
AI summary
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Dear Mrs Griffin, Thank you for your letter of 17 October 2023, to the then Secretary of State for Health and Social Care, Steve Barclay about the death of Marnie Hill. I am replying as Minister with responsibility for mental health. Firstly, I would like to say how saddened I was to read of the circumstances of Mrs Hill’s death and I offer my sincere condolences to her family and loved ones. The circumstances your report describes are very concerning and I am grateful to you for bringing these matters to my attention. The primary purpose of professional regulation is to protect patients and the public from harm by ensuring those providing healthcare are doing so safely. The UK Parliament is responsible for the regulation of health and care professions in England and in Wales where provisions healthcare is devolved (though in practice, Department of Health and Social Care Ministers have not legislated to regulate professions in Wales without the agreement of Welsh Ministers). The regulation of health and care professionals is a transferred matter in Northern Ireland and in Scotland is a devolved matter for health and care professionals who entered regulation after the passing of the Scotland Act 1998. There is an agreement in principle that issues relating to the regulation of healthcare professionals should be taken forward using a collaborative four-nation approach. The UK Government is clear that the professions protected in law must be the right ones and the level of regulatory oversight must be proportionate to the risks to the public. Statutory regulation on its own can only mitigate the risk of harm, not eliminate it, and should only be used where the risks to public and patient protection cannot be addressed in other ways, such as through employer oversight, system regulation, or accredited voluntary registration.
A4
The Government keeps the professions subject to statutory regulation under review. Bringing a profession into statutory regulation is a lengthy and costly legal process. It is restrictive by its very nature and can act as a barrier to entry and inhibit the flexibility of a profession to grow and develop to meet patient needs. Other important considerations that need to be addressed before bringing a profession into regulation including the impact on the profession, which body should regulate and the geographical extent of regulation across the UK. Failure to undertake this work before legislating to regulate a profession could lead to unintended consequences that run counter to public protection. Between 6 January 2022 and 31 March 2022 the Department of Health and Social Care, on behalf of the UK Government and the devolved administrations, ran a public consultation seeking views on the criteria for determining when statutory regulation of a healthcare profession is appropriate. Further information about this consultation is available at:
statutory-regulation-is-appropriate While we believe that there is no immediate case to change the groups that are regulated, the consultation asked for views on how the powers to introduce and remove professions from regulation might be used in the future and:
• the proposed criteria to make decisions on which professions should be regulated;
• whether there are regulated professions that no longer require statutory regulation; and
• whether there are unregulated professions that should be brought into statutory regulation. We will publish our response to this consultation in due course. People should be able to expect good quality psychotherapy or counselling services, which bring about a positive impact on their mental health and recovery. Although counsellors are not subject to statutory regulation, there are other safeguards in place to support patient safety for people using counselling services. Mental health professionals that are not subject to statutory regulation, including counsellors, can join voluntary registers accredited by the Professional Standards Authority for Health and Social Care (PSA). The Accredited Registers Programme provides assurance to the public when choosing and using health and care services by independently assessing organisations who register practitioners who are not regulated by law. The PSA accredits 12 voluntary registers of mental health professionals. These are available on the PSA website at Find An Accredited Register | Professional Standards Authority To gain accreditation from the PSA, organisations must meet its eight Standards for Accredited Registers. These Standards require organisations to have a focus on public protection to have processes for handling complaints against practitioners; to set appropriate levels of education and training for entry to the register; to require registrants to undertake continuing professional development; and to understand and monitor the
risks associated with the practices of registrants. Any registrant who is removed from an Accredited Register for conduct reasons cannot join another Accredited Register. Whilst there are no mandatory, national standards for counsellors, a framework for the training standards and practice requirements for counsellors and psychotherapists who work with adults has been developed and published by a group of professional bodies including the British Association for Counselling and Psychotherapy (BACP), the UK Council for Psychotherapy (UKCP), the British Psychoanalytic Council (BPC), the Association of Christian Counsellors (ACC), the Association of Child Psychotherapists (ACP), the Human Givens Institute (HGI) and the National Counselling Society (NCS). These bodies represent approximately 75,000 counsellors and psychotherapists in the UK. The development of the framework – referred to as SCoPEd – involved mapping existing competencies, standards, training and practice requirements within counselling and psychotherapy using an evidence-based approach to identify the different and overlapping competences. This has resulted in a set of core competencies and practice standards that are now being considered by the professional bodies leading on SCoPEd, and by the counselling and psychotherapy professions more broadly. In February 2023, the SCoPEd partners jointly announced they will be adopting the SCoPEd framework. Please see https://www.bacp.co.uk/news/news-from-bacp/2023/8- february-scoped-adoption-announcement/ for further information on this announcement. More information about SCoPEd, including FAQs, can be found on the BACP website at: https://www.bacp.co.uk/about-us/advancing-the-profession/scoped/ . All of the organisations utilising the SCoPEd framework are independent, representative bodies for the practice of counselling and psychotherapy. As such, they do not fall under Government oversight and therefore any decisions about the training standards and practice requirements for the professions they represent are a matter for those organisations and their members. Finally, anyone undertaking or seeking employment within a health or care role, whether regulated or unregulated, will also be subject to employer checks. This may include a Disclosure and Barring Service (DBS) check in England or Wales or the equivalent check from Disclosure Scotland or Disclosure Northern Ireland. I hope this response is helpful. Thank you for bringing these concerns to my attention.
A4
The Government keeps the professions subject to statutory regulation under review. Bringing a profession into statutory regulation is a lengthy and costly legal process. It is restrictive by its very nature and can act as a barrier to entry and inhibit the flexibility of a profession to grow and develop to meet patient needs. Other important considerations that need to be addressed before bringing a profession into regulation including the impact on the profession, which body should regulate and the geographical extent of regulation across the UK. Failure to undertake this work before legislating to regulate a profession could lead to unintended consequences that run counter to public protection. Between 6 January 2022 and 31 March 2022 the Department of Health and Social Care, on behalf of the UK Government and the devolved administrations, ran a public consultation seeking views on the criteria for determining when statutory regulation of a healthcare profession is appropriate. Further information about this consultation is available at:
statutory-regulation-is-appropriate While we believe that there is no immediate case to change the groups that are regulated, the consultation asked for views on how the powers to introduce and remove professions from regulation might be used in the future and:
• the proposed criteria to make decisions on which professions should be regulated;
• whether there are regulated professions that no longer require statutory regulation; and
• whether there are unregulated professions that should be brought into statutory regulation. We will publish our response to this consultation in due course. People should be able to expect good quality psychotherapy or counselling services, which bring about a positive impact on their mental health and recovery. Although counsellors are not subject to statutory regulation, there are other safeguards in place to support patient safety for people using counselling services. Mental health professionals that are not subject to statutory regulation, including counsellors, can join voluntary registers accredited by the Professional Standards Authority for Health and Social Care (PSA). The Accredited Registers Programme provides assurance to the public when choosing and using health and care services by independently assessing organisations who register practitioners who are not regulated by law. The PSA accredits 12 voluntary registers of mental health professionals. These are available on the PSA website at Find An Accredited Register | Professional Standards Authority To gain accreditation from the PSA, organisations must meet its eight Standards for Accredited Registers. These Standards require organisations to have a focus on public protection to have processes for handling complaints against practitioners; to set appropriate levels of education and training for entry to the register; to require registrants to undertake continuing professional development; and to understand and monitor the
risks associated with the practices of registrants. Any registrant who is removed from an Accredited Register for conduct reasons cannot join another Accredited Register. Whilst there are no mandatory, national standards for counsellors, a framework for the training standards and practice requirements for counsellors and psychotherapists who work with adults has been developed and published by a group of professional bodies including the British Association for Counselling and Psychotherapy (BACP), the UK Council for Psychotherapy (UKCP), the British Psychoanalytic Council (BPC), the Association of Christian Counsellors (ACC), the Association of Child Psychotherapists (ACP), the Human Givens Institute (HGI) and the National Counselling Society (NCS). These bodies represent approximately 75,000 counsellors and psychotherapists in the UK. The development of the framework – referred to as SCoPEd – involved mapping existing competencies, standards, training and practice requirements within counselling and psychotherapy using an evidence-based approach to identify the different and overlapping competences. This has resulted in a set of core competencies and practice standards that are now being considered by the professional bodies leading on SCoPEd, and by the counselling and psychotherapy professions more broadly. In February 2023, the SCoPEd partners jointly announced they will be adopting the SCoPEd framework. Please see https://www.bacp.co.uk/news/news-from-bacp/2023/8- february-scoped-adoption-announcement/ for further information on this announcement. More information about SCoPEd, including FAQs, can be found on the BACP website at: https://www.bacp.co.uk/about-us/advancing-the-profession/scoped/ . All of the organisations utilising the SCoPEd framework are independent, representative bodies for the practice of counselling and psychotherapy. As such, they do not fall under Government oversight and therefore any decisions about the training standards and practice requirements for the professions they represent are a matter for those organisations and their members. Finally, anyone undertaking or seeking employment within a health or care role, whether regulated or unregulated, will also be subject to employer checks. This may include a Disclosure and Barring Service (DBS) check in England or Wales or the equivalent check from Disclosure Scotland or Disclosure Northern Ireland. I hope this response is helpful. Thank you for bringing these concerns to my attention.
Report Sections
Investigation and Inquest
On the 18th May 2022, an investigation was commenced into the death of Marnie Emma Hill, born on the 14th April 1973.
The investigation concluded at the end of the Inquest on the 6th October 2023.
The Medical Cause of Death was:
Ia Suffocation
& overdose
The conclusion of the Inquest was suicide.
The investigation concluded at the end of the Inquest on the 6th October 2023.
The Medical Cause of Death was:
Ia Suffocation
& overdose
The conclusion of the Inquest was suicide.
Circumstances of the Death
On the 15th May 2022 Marnie Emma Hill was found in a collapsed and unresponsive condition lying on the bed, in the bedroom at the property she was temporarily residing at, namely 40 Moorlands Road, West Moors, Ferndown.
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Copies Sent To
NHS England
Dorset Healthcare NHS Foundation Trust
South West Ambulance Service NHS Foundation Trust
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Data sourced from Courts and Tribunals Judiciary under the Open Government Licence.