Dear Ms Schofield We write in response to Ms Hamilton-Deeley's Regulation 28 Report, dated 28 June 2021, following the inquest into the death of Mr Nicholas Spooner. We were saddened to learn of Mr Spooner's death, and the surrounding circumstances, and extend our sincere condolences to his family. Following receipt of the Regulation 28 Report, we collaborated to establish what changes would be needed to address the concerns raised, and how we, as interdependent Social Care, NHS and charitable services, work together to effect improved services. Accordingly, this response is made jointly by:
• Brighton and Hove City Council (BHCC);
• Brighton and Hove Clinical Commissioning Group (part of Sussex NHS Commissioners) (CCG);
• Sussex Partnership NHS Foundation Trust (SPFT); and
• Change Grow Live (CGL). We acknowledge and understand Ms Hamilton-Deeley's concerns and are clear that, as commissioners and providers of services, we have a joint responsibility to work collaboratively to meet the needs of those with co-occurring substance misuse and mental ill-health. We wholly recognise that there is an ongoing need for more to be done and that those with co-occurring conditions can experience difficulties in accessing the care and support they need. We understand and agree with Ms Hamilton-Deeley that outreach facilities, including drop-in and day centres, are necessary. Currently, the CCG commission a Staying Well (Crisis Cafe service) which commenced in January
21. The service provides an out of hours (05:30- 22:30 Weekdays, 3:30-22:30 Weekends) community space, where anyone on the verge of, or experiencing, a mental health crisis (self­ defined) can access non-clinical mental health support. The aim of the service is to prevent an escalation of mental health need and/or to avert further crisis, to provide an alternative provision to attending A&E or accessing other urgent care services and to provide a step down from clinical services. Also, the CCG is in the process of commissioning a new crisis house that will provide support to people in a mental health crisis who require 24/7 support and would otherwise be admitted to hospital. The tender for this service will be issued in October 2021 and the new service will start in the summer of 2022. The service will be for individuals with support needs for their mental health 1

• Change Grow rc1:PJ Live Sussex Partnership NHS foundation Trust Brighton & Hove City Council however individuals may have a range of other support needs, including substance misuse, which is specifically recognised as one of five priority groups. Additionally, currently, CGL provide substance misuse services which are designed to improve service users' mental health and well-being, where dual diagnosis has been identified. Specialist recovery co-ordinators support clients living in supported accommodation and benefit from the support of the CGL dual diagnosis nurses to improve access to specialist mental health services. These workers offer outreach support and harm minimisation interventions to those living in supported housing or who are homeless. In June 2021, SPFT, set out its Co-occurring Substance Use and Mental Health (COSUMH) Conditions 5 year strategy. That strategy recognises that more needs to be done and adopts the principles of 'everyone's business', 'no wrong door', integrated care plans, clinical leadership and facilitating access to mutual aid. BHCC have also recently produced a joint strategic needs assessment (JSNA) for "adults with complex needs"; this definition includes 2 or more of the following:
• Homelessness
• Mental health problems
• Domestic violence
• Alcohol/substance misuse
• Offending. BHCC and the CCG are establishing a joint group to oversee the strategic implementation of the recommendations. This group will seek to develop a more inclusive approach to supporting people with multiple complex needs, including patients with both mental health needs (at all levels of need) and substance misuse needs. BHCC and the CCG are also currently jointly re-commissioning mental health supported accommodation services with the intention of providing greater flexibility in the model of care. The timeline for this tender is the same as the crisis house and the same arrangements for people with substance misuse needs will apply. It should also be noted that Brighton and Hove has been awarded national funding to support the homeless and rough sleeping population within the city to tackle underlying mental ill health and reduce rough sleeping in the city. The additional services form part of co-ordinated efforts to ensure that rough sleepers have better access to NHS mental health support - joining up care with existing outreach, accommodation, drug and alcohol and physical healthcare services. Although this work is not specifically targeted at patients with a dual diagnoses of mental illness and substance misuse it is recognised that a significant number of those supported by this service will also experience issues with substance misuse. In the future and, as a result of the further collaboration that has taken place following receipt of the Regulation 28 Report the CCG/BHCC will:
• review the existing co-existing conditions group and make changes to include: o assurance that the group has a direct link in to the commissioning governance structures of the CCG/BHCC o assurance that is an appropriate strategic fit with the proposed new governance structures to implement the JSNA; 2

Change Grow rcz:~l Live Sussex Partnership ~1~1<• NMS foundation Tm,t Brighton & Hove City Council
• ensure that there is continued information sharing and awareness of all existing and new service provision across the system so that all stakeholders know how to access the provision that is there; and
• ensure that all new commissioned services for both substance misuse and mental health conditions specifically considers co-existing needs. We believe that the above plans and actions will lead to a substantial improvement in the provision of services for those patients in the City of Brighton who are managing co-occurring conditions. We will monitor those improvements to ensure they meet the needs of our community and will write to provide you with an update in 6 months' time. In the meantime, if you have any questions regarding the content of this response or if we can further assist please do not hesitate to contact any one of us.

Chief Executive Brighton & Hove City Council

Chief Nursing Officer Brighton and Hove Clinical Commissioning Group

Chief Executive Sussex Partnership NHS Foundation Trust

CEO Change Grow Live 3

Dear Ms Hamilton-Deeley Thank you for your letter of 28 June 2021 about the death of Nicholas Spooner. I am replying as Minister with responsibility for mental health services and I am grateful for the additional time in which to do so. I would like to start by saying how greatly saddened I was to read the circumstances of the death of Mr Spooner. I can appreciate how upsetting his death must be for his family and loved ones. Your report raises important concerns regarding the availability of mental health services for those who need support for coexisting substance use. I would like to assure you that we are committed to ensuring that anyone with a drug problem and a mental health condition can access the help and support they need. Evidence based, high-quality treatment is the most effective way of tackling illicit and other harmful drug use. It enables people to recover from dependence, improves their physical and mental health and reduces the harm caused to themselves and people around them. Local authorities are responsible for commissioning drug treatment services to meet the needs of their population and we are providing support through the provision of data, guidance and targeted support and funding via the Public Health Grant. The Public Health Grant will be £3.324billion for 2021/22, representing a £45million increase from 2019/20. An additional £8Dmillion has been allocated to addiction treatment from January 2021 as part of a wider crime package. We are clear that commissioners and providers of services have a joint responsibility to work collaboratively to meet the needs of people with co-occurring conditions.

Public Health England has developed guidance to support the commissioning and provision of joined up services for people with a dual diagnosis of mental health and substance misuse problems1. The guidance sets out principles for how services should work, including that each person should have access to a care co-ordinator to help ensure all their needs are addressed and a 'no wrong door' approach when people present to services with co-occurring conditions. Commissioning guidance encourages services to respond collaboratively, effectively, and flexibly offering compassionate and non­ judgemental care centred around the person's needs which is accessible from every access point. I am assured that local organisations have reflected carefully on current service provision following your report on Mr Spooner's death. I am aware that local health and council leaders in Brighton have written to you outlining the range of measures they have undertaken locally to improve access to services for people with co-occurring substance misuse and mental ill health, and note that they will update you on progress locally. Nationally, you may wish to note that Part Two of independent Review of Drugs was published on 8 July 2021 2. The review focussed on prevention, treatment, and recovery services. The report includes recommendations on what can be done nationally and locally to tackle drug misuse, and specifically the support needed for those who experience drug misuse and co-existing mental health issues. These recommendations cover training requirements for all staff working with people with co-existing mental health problems and drug and/or alcohol dependency; the need for integrated commissioning of mental health and substance-misuse services to be part of the next stages of Integrated Care System development; and, the need for NHS England and NHS Improvement (NHSEI) to publish an action plan by the end of 2021 that improves the provision of mental health treatment to people with drug and alcohol dependency. The Government has looked closely at these recommendations and on 27 July 2021, published an initial response on the urgent action we can take to turn the tide on drug­ related deaths and get more people access to higher quality services3. A commitment has been made in the initial Government response to publish a high-level drug strategy by the end of the 2021. In addition, I would like to assure you that we are absolutely committed to our ambitions in the NHS Long Term Plan to expand and transform mental health services in England and to investing an additional £2.3billion a year by 2023/24. Under the NHS Long Term Plan, by 2023/24, we will invest almost £1 billion extra in community mental health care for adults with severe mental illness. This funding will give 370,000 adults and older adults with severe mental illnesses greater choice and control over their care and support them to live well in their communities by 2023/24. 1 People with co-occurring conditions: commission and provide services - GOV.UK (www.gov.uk) 2 Review of drugs: phase two report - GOV.UK (www.gov.uk) 3 Independent review of drugs by : government response - GOV.UK (www.gov.uk)

A new community-based offer will include access to psychological therapies, improved physical health care, employment support, personalised and trauma-informed care, medicines management and support for self-harm and coexisting substance use. This includes maintaining and developing new services for people who have the most complex needs and proactive work to address racial disparities. Local areas will be supported to redesign and reorganise core community mental health teams to move towards a new place-based, multidisciplinary service across health and social care aligned with primary care networks. We will also expand services for people experiencing a mental health crisis. As part of our COVID-19 response work, for those with severe needs or in crisis, all NHS mental health providers have established 24/7 urgent mental health helplines. In addition, under the NHS Long Term Plan, we will increase alternative forms of provision for those in crisis. Sanctuaries, safe havens and crisis cafes provide a more suitable alternative to A&E for many people experiencing mental health crisis, usually for people whose needs are escalating to crisis point, or who are experiencing a crisis but do not necessarily have medical needs that require A&E admission. These alternatives are commissioned through the NHS and local authorities, provided at relatively low cost and to high satisfaction, and usually delivered by voluntary sector partners. While these services now exist in a number of areas, we will work to improve signposting, and expand coverage to reach more people and make a greater impact As part of the NHS Clinically-led Review of Standards programme of work, on 22 July 2021, NHSEI announced a consultation on the potential to introduce five new waiting time standards4. The proposed new standards define expectations for patients of all ages accessing community mental health services as well as those requiring urgent or crisis support. Some of the proposals being consulted include:
• For an 'urgent' referral to a community based mental health crisis service, a patient should be seen within 24 hours from referral, across all ages;
• For a 'very urgent' referral to a community based mental health crisis service, a patient should be seen within four hours from referral, for all age groups;
• Patients referred from Accident and Emergency should be seen face to face within one hour, by mental health liaison or a children and young people's equivalent service; and,
• Adults and older adults presenting to community-based mental health services should start to receive help within four weeks from referral. This may involve the start of a therapeutic intervention or a social intervention, or agreement about a patient care plan. The consultation closed on 1 September 2021 and NHSEI will analyse the consultation responses which will inform a recommendation to Government on whether and how to implement any new standards in due course. 4 NHS England » Mental health clinically-led review of standards: Models of care and measurement

In addition to the funding we are providing through the NHS Long Term Plan, as part of the Government's commitment to build back better, we have published our Mental Health Recovery Action Plan, backed by a one-off targeted investment of £500million, to ensure that we have the right support in place this year. £58million of this extra £500million announced will be invested to bring forward the expansion of integrated primary and secondary care for adults with severe mental illness and £ 13million will be used for crisis support to sustain and enhance operation of 24/7 crisis lines in 2021/22. I hope this response is helpful. Thank you for bringing your concerns to my attention. GILLIAN KEEGAN

Dear Ms Schofield We write to provide you with an update as to the Regulation 28 report response we sent in October
2021. As highlighted in our response at the time, following receipt of the Regulation 28 report we collaborated to establish what changes would be needed to address the concerns raised, and how we, as interdependent Social Care, NHS and charitable services, work together to effect improved services. We acknowledged and understood the concerns raised, and in our response gave details of some of the current and planned work in regard to our responsibility to work collaboratively to meet the needs of those with co-occurring substance misuse and mental ill- health. In our response we said that after a 6-month period we would provide an update on the planned work. We would like to apologise that we have not been able to provide this in April as we had anticipated, but we hope that this update, though beyond our desired timescale, will provide continued reassurance as to the improvements in the provision of services for those patients in the City of Brighton who are managing co-occurring conditions. In our original response we noted that NHS Sussex (formerly Brighton and Hove CCG) is in the process of commissioning a new crisis house to provide support to people in a mental health crisis who require 24/7 support and would otherwise be admitted to hospital. We want to update you that the procurement process has completed, the contract has been awarded to Mental Health Matters and the service will start on 01 November 2022. We also noted that Brighton & Hove City Council and NHS Sussex are jointly re-commissioning mental health supported accommodation services with the intention of providing greater flexibility in the model of care. The timeline for this tender is the same as the crisis house, we want to update you that the procurement process has completed, the contract has been awarded to two experienced providers and the services will start on 01 November 2022. In our original response we noted that Brighton & Hove City Council and NHS Sussex were planning the establishment of a joint group to oversee the strategic implementation of the recommendations and review of the existing co-existing conditions group and implement changes. Our update is that Brighton and Hove, along with East and West Sussex, has been awarded a three-year 'Changing Futures' grant to focus on supporting individuals with multiple disadvantages. To manage this programme and oversee implementation Brighton and Hove City Council and NHS Sussex have created the Brighton & Hove Changing Futures Multiple Disadvantage Transformation Programme - Place Based Steering Group. The aims of the Steering Group are to set the strategic direction for addressing health inequalities for those with multiple disadvantage in Brighton and Hove as follows; 1

c~l~;,~l<~ Change ri!l:f;j Brighton & Hove Grow Sussex Partnership NHS Foundation Trust City Council Sussex Live
• To use data, intelligence and JSNA to inform programme plans
• To inform our plans to develop and deliver our Population Health Management (PHM) approach and capability at scale to stratify population risk
• To maintain oversight of place-based activities around the transformation of services for individuals experiencing Multiple Disadvantage
• To inform the commissioning and provision of services across the wider health and social care system to tackling health inequality across Brighton and Hove
• To use public engagement insight to inform decision making and ongoing service improvement. The group will be chaired by Brighton & Hove City Council. The first meeting of the steering group was held in July 2022. In our original response we noted that NHS Sussex and BHCC will review the existing co-existing conditions group and make changes to include assurance that the group has a direct link in to the commissioning governance structures of NHS Sussex and BHCC and assurance that is an appropriate strategic fit with the proposed new governance structures to implement the JSNA. Our update is that the Co-existing Conditions Steering Group is being redefined and will sit within the Brighton and Hove Changing Futures Multiple Disadvantage Transformation Programme Place Based Steering Group mentioned previously. In our original response we noted that Brighton and Hove had been awarded national funding to support the homeless and rough sleeping population within the city to tackle underlying mental ill health and reduce rough sleeping in the city. The additional services form part of co-ordinated efforts to ensure that rough sleepers have better access to NHS mental health support - joining up care with existing outreach, accommodation, drug and alcohol and physical healthcare services. We want to provide an update that the expansion of the Mental Health Homeless Team is fully staffed, the expanded roles include a Clinical lead, psychiatrist, psychologist, and a clinical practitioner. The enhanced team allows for increased support to individuals sleeping rough or in emergency accommodation. The psychologist within the team will be facilitating the Complex Risk Management Meeting (CRMM) which will increase coordination efforts between rough sleeping, mental health, substance misuses, and physical health services. Previously we also set out the principles which underpin SPFT's Co-occurring Substance Use and Mental Health 5-year strategy. Since then, we are pleased to be able to update you on the recruitment of two Dual Diagnosis Workers into SPFT's Assessment and Treatment Services (ATS) in Brighton. This has arisen as a result of additional funding being obtained, through the transforming community care plan, and has resulted in a Dual Diagnosis Worker for both East and West Brighton ATSs. Change Grow Live have made progress integrating the work of their Mental Health Liaison nurses with the newly appointed SPFT Dual Diagnosis nurses. Strategic meetings have taken place between Change Grow Live and SPFT managers and the nurses are working jointly to support some clients with dual diagnosis. We also committed to ensuring that there is continued information sharing and awareness of all existing and new service provision across the system so that all stakeholders know how to access the provision that is there. Our update is that timely and efficient information sharing and awareness of services is facilitated by a network of groups to which all partners and stakeholders are invited, including the Changing Futures Multiple Disadvantage Steering Group and the emerging trends and harm reduction group. Regular newsletters and email updates are circulated 2

Brighton & Hove City Council Sussex Change rel:§ Grow Sussex Partnership Live NHS Foundation Trust to ensure that all staff members across mental health, substance misuse, and homelessness services, including outreach teams, have access to up-to-date information regarding service provision We committed to ensuring that all new commissioned services for both substance misuse and mental health conditions specifically considers co-existing needs, and our update is that NHS Sussex and the City Council continue to be committed to involving and working with each other in the development of commissioning plans to best meet the needs of people with co-existing needs, and this will be a requirement of all providers of services across mental health and substance misuse. All service developments will be informed by the government guidance on providing better care for people with co-occurring mental health and alcohol/drug use conditions, Better care for people with co-occurring mental health, and alcohol and drug use conditions (publishing.service.gov.uk) We hope this letter provides you with the detail needed to update you on our joint plans and actions set out in the Regulation 28 report response. If you have any further questions regarding this update please do not hesitate to contact any of us.

Chief Executive Brighton & Hove City Council

Chief Nursing Officer NHS Sussex

Chief Executive Sussex Partnership NHS Foundation Trust

CEO Change Grow Live 3