The Queen’s Speech

Social care reform

My ministers will seek cross-party consensus on proposals for long term reform of social care. They will ensure that the social care system provides everyone with the dignity and security they deserve and that no one who needs care has to sell their home to pay for it.”[1]

 

There is already a duty to promote dignity and security (Care Act 2014 section 1); already a right not to have to sell your home in order to pay for care (ie a deferred payment – Care Act 2014 sections 34-36); and the last time a Government tried to seek a cross-party consensus on sensible proposals for reform (2010), they were torpedoed by the party of the current Government.[2]

 

Principle

Necessary social care support should be provided free at the point of need.  All the arguments for (and against) a free at the point of need NHS apply with equal force to social care.  ‘Free at the point of need’ social care was the reform recommended by the 1999 Royal Commission.[3] For a recent update on the feasibility of this approach – see the 2019 report of the Institute for Public Policy Research. [4]

 

Provision

The New Economics Foundation (NEF) has published an important paper entitled Ownership in Social Care.[5]  It highlights a key social care reform challenge – namely:

to move away from short-termist, cost-driven competitive tendering towards public-social partnerships between the state and diverse, decentralised providers with ownership structures that enable people to have a greater stake and control over the care that is provided.

The reforms of social care that took effect in 1993 may have been intended to privatise social care but at least they spoke of a ‘mixed economy’:[6] a mixture of public and private care provision.  In the succeeding years the ‘public’ element has dwindled to the point that (as the NEF report makes clear) social care services in England are almost entirely outsourced – very often to ‘chain companies with an ownership model that concentrates power among shareholders’.[7]

One hears so much about the innovation of private businesses – but in reality in this sector it has been the innovation of debt and tax leverage, offshoring and ‘sweating the labour’ – in terms of wage reductions, zero hours contracts and electronic monitoring.[8]  NEF characterises social care in much of England as ‘extractive’ – driving inequality through low-paid, insecure jobs, and putting downward pressure on the quality of care.   Low wages, poor terms and conditions result in high staff turnover which is almost three times higher for private providers than public ones.[9] One of the most often heard complaints by disabled people and their families about the quality of care concerns constant changes in the care assistants delivering the care.

NEF presents an alternative vision – ‘shifting to more co-operative models in which services are owned and run by employees and / or people receiving support and their families’ and where there is a ‘much more significant role for local authorities, as public bodies that are democratically accountable to their local communities’.  Social care funding should benefit the local economy: should support secure, decent, well-paid work with the profits remaining locally – supporting disabled people, the providers of care and in consequence the local economy itself.  The NEF report is important and deserves reading / adopting.[10]

 

Paying for it

The Labour Government’s 2010 proposals to raise extra social care funding via an increase in inheritance tax represented (and continues to represent) a sensible way of finding additional funds needed to cover a long-term care settlement.  The funding required is relatively modest (an increase of less than 1 per cent of total government expenditure[11]) – and pales into the far distance the moment one hears mention of HS2.  It should also be remembered that 20 years ago Scotland embarked on a programme to make social care free at the point of need and this has proved to be a generally popular policy.  20 years ago a Royal Commission also came up with the same suggestion.[12]

Funding some of the additional costs through the medium of inheritance tax has the merit of pooling risk among those with significant estates and avoids the current system which Andrew Dilnot (who chaired one of the formal social care funding reviews – in 2011[13]) has condemned as ‘the most pernicious means-test in the whole of the British welfare state’.[14] Although there is much hype about inheritance tax being the UK’s most hated tax[15] one has to wonder if this has any basis (or any rational basis).  Taxing the dead seems to be a more attractive option than the alternatives and it is a tax that only kicks in for individual estates over £325,000 (and £650,000 for a married couple[16]) and even then the beneficiary retains 60% of the surplus.

And to close – a quiz question. 

“How many estates pay inheritance tax each year?” See footnote for the answer.[17]

 

For previous posting on social care reform see:

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[1] Prime Minister’s Office The Queen’s Speech 2019 19 December 2019  p.37
[2] Nicholas Watt Spectre of ‘death tax’ haunts Andy Burnham’s care revolution Guardian 30 Mar 2010.
[3] The Royal Commission on Long Term Care With Respect to Old Age: Long Term Care Rights and Responsibilities [Chairman: Professor Sir Stewart Sutherland] Cm 4192-I  (The Stationery Office 1999)
[4] Harry Quilter-Pinner and Dean Hochlaf Social Care: Free at the Point of Need (Institute for Public Policy Research 2019) p.4 and only marginally more expensive (£2 billion in 2030) than the Conservative party’s 2017 election pledge of a cap and floor system.
[5] Daniel Button and Sarah Bedford Ownership in Social Care (New Economics Foundation 2020).
[6] Department of Health Caring for People: Community Care in the Next Decade and Beyond Cm 849 (Stationery Office 1989).
[7] See for example D Burns et al Where does the money go? Financialised chains and the crisis in residential care CRESC Public Interest Report March 2016.
[8] See for example UNISON Suffering along at home: A UNISON report on the lack of time in our homecare system (2017) and L.J.B. Hayes ‘Work-time Technology and Unpaid Labour in Paid Care Work: A Socio-legal Analysis of Employment Contracts and Electronic Monitoring’ (chapter 9) in Sian Beynon-Jones & Emily Grabham (eds) Law and Time (Routledge 2018) pp. 179-195.
[9] J Dromey and D Hochlaf Fair Care: A workforce strategy for social care (IPPR 2018).
[10] As does Reclaim Social Care Taking Private Social Care Provision Back into the Public Sector (2019).
[11] Harry Quilter-Pinner and Dean Hochlaf Social Care: Free at the Point of Need (Institute for Public Policy Research 2019) p.4. and only marginally more expensive (£2 billion in 2030) than the Conservative party’s 2017 election pledge of a cap and floor system. There would of course be substantial savings to the NHS budget – see ADASS Sort out social care, for all, once and for all (ADASS 2019) points out that investment in social care reduces pressures on the NHS due to the preventative nature of much of the work of care as well as benefiting the economy.
[12] The Royal Commission on Long Term Care With Respect to Old Age: Long Term Care Rights and Responsibilities [Chairman: Professor Sir Stewart Sutherland] Cm 4192-I  (The Stationery Office 1999)
[13] Commission on Funding of Care and Support Fairer Care Funding (2011).
[14] Amelia Hill Social care reviewer condemns UK system and calls for new tax Guardian 6th April 2017.
[15] See for example E Agyemang  Inheritance tax: what does the future hold? Financial Times July 11 2019.
[16] If the first person to die leaves their entire estate to their partner.
[17] Very few people are currently within the scope of Inheritance Tax, with fewer than 25,000 estates being liable each year. This is less than 5% of all deaths, even though ten times as many estates need to complete and submit forms (out of 590,000 deaths) – see Office of Tax Simplification Inheritance Tax Review –second report: Simplifying the design of Inheritance Tax July 2019 p.4.

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NHS Personal Health Budgets: new rights and new guidance

NHS England has issued new guidance to coincide with the extension[1] of the right to a Personal Health Budget (PHB) to cover people eligible for section 117 Mental Health Act 1983 after-care support as well as for people in need of wheelchair services.  These new rights came into force on 2 December 2019.  The 27 page guidance (NHS England Personalised Care:  Guidance on the legal rights to have personal health budgets and personal wheelchair budgets (2019)) can be accessed by clicking here.

A right to have a PHB (which can be paid as Direct Payments) now exists in England for:

  • Adults eligible for NHS Continuing Healthcare funding (NHS CHC);
  • People eligible for after-care services under section 117 of the Mental Health Act 1983;
  • People assessed as in need of a wheelchair (for more than short-term use); and
  • Children and young people eligible for NHS funded continuing care.

The guidance states that there are six key features of a PHB ‘that ensure people experience the best outcomes possible’.  These are that a person should:

Be central in developing their personalised care and support plan and agree who is involved;

  • Be able to agree the health and wellbeing outcomes (and learning outcomes for children and young people with education, health and care plans) they want to achieve, in dialogue with relevant health, education and social care professionals;
  • Know upfront an indication of how much money they have available for healthcare and support;
  • Have enough money in the budget to meet the health and wellbeing needs and outcomes agreed in the personalised care and support plan;
  • Have the option to manage the money as a direct payment, a notional budget, a third-party budget or a mix of these approaches;
  • Be able to use the money to meet their outcomes in ways and at times that make sense to them, as agreed in their personalised care and support plan.

 

Importantly the guidance stresses that

Any agreed budget must be sufficient to ensure the health and wellbeing outcomes required for a person can be realistically met. For example, if a CCG decides, when planning a personal health budget, to release money based on a monetary valuation of a person’s expected quantity of continence products as would have been provided by the NHS, they must be satisfied that this amount is sufficient to enable the purchase of the products in the open retail market so as to meet someone’s identified continence needs. An exception to this is the provision of wheelchairs. For personal wheelchair budgets holders, this right to have does not affect the existing ability to add to the cost of the wheelchair of their choice.

The guidance concerning the working of the new scheme for wheelchairs is brief – but includes (page 16):

For personal wheelchair budgets the amount in the budget should be based upon what it would cost the NHS to meet the person’s assessed postural and mobility needs via the wheelchair service currently commissioned by their CCG. The introduction of personal wheelchair budgets builds upon the existing regulatory framework which enables people to contribute to the cost of a wheelchair. For people who have additional health and social care needs, the personal wheelchair budget can be pooled with funding from other statutory services (if this is agreed as meeting the person’s assessed needs by all services and is cost effective). With personal wheelchair budgets, people can also choose to access non-statutory funding that may be available via voluntary, charitable organisations both nationally and locally.

 

And at page 17:

For personal wheelchair budgets, manual, powered chairs and specialist buggies are included. CCGs need to consider repair and maintenance and how this will either be supported by existing services or made available as part of a personal wheelchair budget. CCGs need to consider specialist seating and pressure-relieving equipment as it remains a statutory duty to provide these, either as part of a personal wheelchair budget or via existing commissioned services. Decisions on how these are provided will need to be made locally on a case by case basis, based on clinical assessments.

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[1] By amendment of the National Health Service Commissioning Board and Clinical Commissioning Groups (Responsibilities and Standing Rules) Regulations 2012, reg 32A.

NHS Continuing Healthcare statistics

The latest NHS CHC statistics for England show a small increase in overall numbers of people eligible for funding – up from 55,872 at the end of June to 57,016 in September (the figure stood was 63,000 in December 2014). Fast-track funding is now almost 36% of this total.

During the same period the number of NHS overnight beds in England fell by 1,396 to 127,225 (the figure was 134,573 in December 2014).

This means that in the last five years the number of people eligible for NHS CHC has fallen by 5,984 (9.5%) and the number of NHS beds has fallen by 7,348 (5.5%).

Unacceptable delay:

Complaints procedures for disabled children and their families

The Cerebra Legal Entitlements and Problem-Solving (LEaP) Research Project at Leeds University has published a report concerning serious (and systemic) failings in the way that a number of English councils investigate children’s social service complaints.

Key findings included:

  1. The current complaints’ regime rewards councils that maintain dysfunctional systems, as the penalties for poor behaviour are either minimal or non-existent.
  2. Central Government and the ombudsman’s guidance fail to give emphasis to the fact that delay, when it impacts on the life of a child, is to be treated as damaging and requiring a special response.
  3. The current complaints system discriminates against children and families with low incomes and / or poor support networks.
  4. In over 60% of the cases where the ombudsman found fault with the council’s complaint handling his office remitted the complaint back to the council without a recommendation for compensation for the delay – despite the average time (from the initial complaint to the ombudsman’s report) being 345 days. In the remainder of cases, where compensation was recommended, the average time amounted to 572 days and the average compensation was 30p per day.

Recommendations include:

  • The relevant guidance should formally recognise that delay in relation to children’s services complaints is a substantive harm, for which there is a presumption that appropriate compensation should be paid.
  • The Secretary of State should demonstrate a willingness to use his default powers to require recalcitrant authorities to exercise their functions in a way that complies with the law.

The full report (including a Summary) can be accessed by clicking here.

 

Anniversary quotes

Two quotes: one published a year ago and the other 175 years ago.

14 million people, a fifth of the population, live in poverty. Four million of these are more than 50% below the poverty line and 1.5 million are destitute, unable to afford basic essentials. The widely respected Institute for Fiscal Studies predicts a 7% rise in child poverty between 2015 and 2022, and various sources predict child poverty rates of as high as 40%. For almost one in every two children to be poor in twenty-first century Britain is not just a disgrace, but a social calamity and an economic disaster, all rolled into one.

(Statement on Visit to the United Kingdom, by Professor Philip Alston, London, 16 November 2018)

Two nations between whom there is no intercourse and no sympathy; who are as ignorant of each other’s habits, thoughts, and feelings, as if they were dwellers in different zones, or inhabitants of different planets. The rich and the poor.

(Benjamin Disraeli Sybil, or The Two Nations 1845)

________

Two quotes – one a decade after the Poor Law Amendment Act 1834 formalised the misery of workhouses: the ‘most sustained attempt to impose ideological dogma, in defiance of the evidence of human need’ (to quote EP Thompson[1]) and the other a decade after the introduction of (to quote Theresia Degener[2]) the ‘human catastrophe’ of austerity economics.

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[1]    E P Thompson, The Making of the English Working Class, Penguin, 1991, p295.
[2] Professor Theresia Degener, former Chair of the United Nations Committee on the Rights of Persons with Disabilities and Professor of Law and Disability Studies (Protestant University of Applied Sciences, RWL, Germany).

Unfortunately … there is no legal footing to justify us not funding

 

R (CP) v. NE Lincolnshire Council[1] is an important Court of Appeal decision.  On one level the judgment demonstrates the complexity of the care / education arrangements for young people moving into adulthood – and on another it makes the simple point that councils must meet the needs of disabled people.

The case concerned a young adult described in the following terms (para 3):

CP is a 22-year old woman with global development delay, learning difficulties and an autistic spectrum disorder. She does not communicate verbally. She can communicate to an extent by behaviour, gesture and vocalisation. She cannot be left alone at any time, is doubly incontinent and requires assistance with washing and dressing. Her behavioural difficulties can make her challenging. She wakes every night and requires a carer to be with her. She uses a wheelchair when in the community. She lives with her parents in Lincolnshire

The judgment describes the family having to battle at every stage to get an EHC Plan for their daughter post-16 and for the education, health and social care elements. It is stark evidence – if evidence is needed – as to the enormous barriers families experience (not least due to the legal complexities) and of the way councils approach claims of this kind. At para 27 the judgment refers to an email the council sent to relevant staff saying “Unfortunately it transpires that there is no legal footing to justify us not funding this provision”. Lord Justice Haddon-Cave, in his judgment, put this in context, observing (para 67) that the Council resisted the claim ‘at every turn and conducted what turned out to be a fruitless rear-guard action’.

By the time of the Court of Appeal hearing, council funding had been secured for the young adult’s needs and the essential question was whether it should repay her family for the costs of past support (ie prior to the council agreement to fund). The support throughout the relevant period had been at a centre run by a charity which had been set up and was organised by her father.

The court held (para 74) that the centre met both the young adult’s educational and social care needs – noting that ‘the fact that a provision is “education and training” under s.21 of the CFA 2014 does not mean that it cannot also provide an element of social care; and vice-versa. The two matters are complimentary, not mutually exclusive.’

It rejected (at para 85) as ‘misconceived’ and ‘as having no basis’ the council’s claim that the father was the ‘real claimant’ by alleging that he was in effect that he was ‘using the proceedings inappropriately to profit from the claim’ since [the centre) was a charity organised and controlled by him.

From a legal perspective, a particularly welcome finding of the court concerns the council’s argument that the applicant could not recover the sums unpaid because a ‘breach of a public law duty did not give rise to private law rights’. The court rejected this as ‘specious’. What was being asserted were not ‘private law rights’ but like ‘other social security and benefit claimants, she is simply asserting an orthodox public law right to be paid monies due to her under the Care Act 2014 and which the Council has unlawfully failed or refused to pay’.

For good measure the judgment also stated in forceful terms (para 82):

A breach of a statutory duty is a breach of statutory duty. It is, by definition, unlawful conduct. Unlawful conduct by a public body cannot merely be discounted or ignored. Moreover, s. 26 is no minor matter. A local authority’s statutory duty under s. 26 of the Care Act 2014 to provide a personal budget to meet a person’s care and support needs is fundamental to the operation of the care and support scheme which the Care Act 2014 underpins.

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[1] R (CP) v. NE Lincolnshire Council [2019] EWCA Civ 1614 accessible at https://www.bailii.org/ew/cases/EWCA/Civ/2019/1614.html.
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Under 5’s school transport

An excellent report[1] from the ombudsman concerning the legal obligations on a council to provide transport for a disabled child below statutory school age.

The report provides a helpful statement of the law and the requirements of the relevant statutory guidance.  In the case considered by the ombudsman, the council had misunderstood the law, misunderstood the facts and misunderstood the minimum requirements for a lawful appeals process.  Although by the time the ombudsman prepared his report, the council had adopted a revised policy – this policy was almost certainly unlawful for the purposes of the Equality Act 2010 and amounted to a ‘fettering’ of its discretion.

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[1] Complaint no 18 017 909 against Herefordshire Council,  24 July 2019.

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Education Committee Report on SEND

The House of Commons Education Committee published its report on ‘Special educational needs and disabilities’ on 23rd October 2019. It doesn’t pull its punches and we must all hope that we have a Government that is prepared to take action to implement the Committee’s recommendations.

For the full report – click here.

The ‘Summary’ to the report reads as follows:

The reforms were ambitious: the Children and Families Bill sought to place young people at the heart of the system. However, as we set out in this report, that ambition remains to be realised. Let down by failures of implementation, the 2014 reforms have resulted in confusion and at times unlawful practice, bureaucratic nightmares, buck-passing and a lack of accountability, strained resources and adversarial experiences, and ultimately dashed the hopes of many.

The reforms were the right ones. But their implementation has been badly hampered by poor administration and a challenging funding environment in which local authorities and schools have lacked the ability to make transformative change. The Government has recently taken initial steps to rectify the latter of these two challenges, but there is much left to be done.

There is too much of a tension between the child’s needs and the provision available. The significant funding shortfall is a serious contributory factor to the failure on the part of all involved to deliver on the SEND reforms and meet children’s needs. Ultimately, however, unless we see a culture change, within schools and local authorities and the Government, any additional money will be wasted and make little difference to their lives.

We have found a general lack of accountability within the system. We do not think that the current approach to accountability is sufficient—the absence of a rigorous inspection regime at the beginning set the tone of a hands-off approach. This has been perpetuated by the fact that those required, or enabled, to ‘police’ the system have been limited in part by an apparent unwillingness to grapple with unlawful practice, while others are limited by the narrowness of their remit.

There must be greater oversight—we want to see a more rigorous inspection framework with clear consequences for failure…. 

Parents and carers have to wade through a treacle of bureaucracy, full of conflict, missed appointments and despair…

We heard that many of the eagerly anticipated initiatives are not living up to their ambition and name. The role of health providers is pivotal, but unsurprisingly, the meshing of two systems has not worked. Unless health, and social care are ‘at the table’, we are no further on, and the Education, Health and Care Plan is no more than a Statement by another name. In a similar vein, we want to see greater joint working between the health and education sectors, beginning firmly with the development of a joint outcomes framework to measure how the health aspects of support for children and young people with SEND are being delivered locally. But ultimate responsibility for this monitoring should sit with government, not an inspectorate.

We are seeing serious gaps in therapy provision. We need to see professionals trained and supported so that they are able to support all pupils; these huge gaps in therapy provision across the country are letting down all pupils, but particularly those on SEN Support. We need to know where the gaps are, because children are falling through them, and what is going to be done about it.

Similarly, the local offer’s aims and intentions appear to have moved away from the initial intentions, and in some cases have become unusable and useless, and we call on the Government to review local authorities’ local offers in collaboration with children, young people and their parents and carers.

Special educational needs and disabilities must be seen as part of the whole approach of the Department’s remit, not just an add-on. The Department for Education has an approach which is piecemeal, creating reactive, sticking-plaster policies, when what is needed is serious effort to ensure that issues are fully grappled with, and the 2014 Act works properly, as was intended.

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Post-16 students and free school / college travel assistance

A further ombudsman’s report concerning the duty to provide free travel assistance to school / colleges etc has just been published.[1]

A March 2019 ombudsman’s report[2] concerning the same Council held that its post-16 transport policy was unlawful – not least because it suggested that support of this kind was only ‘discretionary’.

The Council’s criteria stated that a person ‘may be eligible’ for free education transport if they satisfied seven criteria, namely:

  1. The young person is under 25 years of age and they reside or are Looked After by the council;
  2. They have a special educational need or disability, which may be identified in an Education Health and Care Plan (EHCP), or other exceptional circumstances which impacts on their ability to use those public transport arrangements;
  3. The young person lives more than 3 miles away from their learning venue (by the shortest safe walking route), or they live less than 3 miles away;
  4. They have exhausted all available sources of support … ;[3]
  5. Their learning venue is the nearest that can meet the majority of their needs;
  6. Their study programme is full-time – equivalent to a minimum of 18 hours per week;
  7. If the young person is aged 19 or over, they have been in continuous education or training since before their 19 birthday. Unless they have an EHC plan issued.

As with many such policies (it appears) Councils seem to suggest that the provision of transport for post-16 students is simply a ‘discretion’.  This is wrong.  There is a duty to provide support from some students and even for students who don’t have a ‘right to support’ the Council’s discretion is one it that has to be taken seriously (ie it must take into account all relevant facts, not ‘fetter’ this discretion, reach a reasoned decision etc[4]).

Commenting on the Council’s policy the ombudsman stated that:

It was ‘poorly written and does not reflect the law that applies to school and college transport for young people, including young people with special educational needs, in post-compulsory education’.

It failed to ‘take account of the different legal powers and duties the Council owes to different groups of young people. Different duties apply to:

  • young people of sixth form age;
  • adult learners; and
  • adult learners with an Education, Health and Care (EHC) Plan’.

Criteria 2), which restricts transport to those young people for whom exceptional circumstances impact on their ability to use public transport, does not reflect the law. The law requires the Council to consider whether it is necessary to make transport arrangements to facilitate a young person’s attendance at college, not whether there are exceptional circumstances.

Criteria 3), does not make sense.

Criteria 5), the requirement a young person attends the nearest establishment that can meet ‘the majority of their needs’ would be unlawful if applied to a young person with an EHC Plan. The Council has a duty to arrange provision to meet all the assessed needs of a young person with an EHC Plan, not ‘the majority’. The Council also has a duty to promote choice for adults with EHC Plans. Requiring a student to attend the nearest college does not promote choice.

Criteria 6), which requires a young person to follow a full-time programme of study, has no legal basis.

The ombudsman held that the travel assistance policy for post-16 students (and the Council’s use of it) was maladministration and recommended (and the Council agreed) that the policy be re-written.

For an earlier ‘post’ that considers an ombudsman’s report concerning post-19 education transport costs – click here.

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[1] Complaint no 18 015 84 against Bexley LBC 30 May 2019.
[2] Complaint no 18 012 904 against Bexley LBC 12 March 2019.
[3] A separate document listed travel assistance offered by external organisations.
[4] See generally L Clements Accessing Public Services Toolkit (Cerebra 2017 pages 24 and 28) and Staffordshire County Council v JM [2016] UKUT 246 (AAC) para 35 – 36.

So what do you do?

You are a health / social care professional. You have read up on the lawfulness of funding panels – but you now find yourself required to attend a panel to agree funding on a large package for someone with a substantial need for care and support. The panel has some esoteric title – but it is really a ‘rationing’ panel. Cases are often delayed (often sent back for more information) and care packages generally reduced (never increased).

You have in the past raised issues about risk and questions about urgency however these have been stonewalled. This causes you significant personal and professional concern – not least the risk posed to the persons in need, who are being left in dangerous unmanaged circumstances. Not only are people who don’t have first hand knowledge of the individual’s circumstances questioning / disputing packages of care you consider necessary, but they are also questioning your assessment and leaving you holding the risk.

 

What should you do?

It’s a difficult situation. You are working within an organisation that does not appear to be acting in a reasonable or, indeed, in a lawful way. Clearly the people you are assessing (and for whom you are care planning) are able to complain – but you know full well all the reasons why they are unlikely to do this. You could point them in the direction of an advice agency – but that could put you in an invidious position and there is a considerable shortage of support of this kind.

What do you do if senior officers are actively challenging you – when all you are doing is trying to follow your judgment and the law? In the case of a complaint’s investigator who considered she was being bullied – she contacted the ombudsman – without success (see ‘Omg … will it never end’).

This website focuses on the rights of disabled people, carers and their families, but it is patently obvious that day in day out countless front line workers in many (but not all) local authorities and the NHS face these challenges. It would be good if someone was able to write a piece explaining what can be done. This is a subject that the School of Law at Leeds Univeristy (Cerebra LEaP project) hopes to research but pending this it would be valuable to have ideas about what can be done. It may have to be an ‘authors name withheld’ piece, for all the predictable reasons.

Suggestions – in confidence – would be welcome.