Their review “Putting Health into the Policy Picture” looked at over 300 government impact assessments – all of which had been commissioned as part of the process of developing policy or piece of legislation.
The study discovers significant variation in quality; a small number of impact assessments do have a good health focus but a lot show little evidence of systematic consideration of health impact positive or negative.
The report also expresses concern about the capability that exists within government to ensure that high quality health impact assessments are consistently carried out.
I do think that one area that the review does not address properly is the relationship between the impact assessment and those outside of government. There seems to be an assumption that impact assessments are primarily an internal process – through which technically astute, professionally trained ‘experts’ can bring their technology to bear to stress test policy change.
We need to challenge this assumption.
Territory to fight over
Impact Assessments should provide an important place for stakeholders outside government – local authorities, the voluntary sector etc to challenge and debate with government – this is territory to fight over. I do not get any impression that Government – in particular the Department of Health – pro-actively encourages key stakeholders to use the material in impact assessments to have a public debate about policy impact. Similarly I am not aware of public lobbying using impact assessments as a mechanism to challenge and influence policy makers.
I think that this is because Impact Assessments and Health Impact Assessments in particular remain obscure and rather technical documents – rather than a key lever to improve policy through widening and strengthening democratic engagement.
What can be done.
While it would be great if Government were to improve the way it does impact assessments – we can’t wait – action needs to be taken outside government – national voluntary organisations, local government and academia all need to become more proactive in challenging impact assessments that relate to their areas of special interest.
Engagement must not just be through formal government channels – but publicly through the media. That way we will have better informed debate and will empower those civil servants within government who want to deliver better policy that improves wellbeing.
Housing Benefit cap
Is this such all such a big deal? Well – the government is pursuing an aggressive set of policies which have the potential to hit the poorest hardest. The proposals in the Welfare Reform Bill to cap Housing Benefit – which could lead to a large number of people having to leave their homes has hit the press recently. If you look at the relevant Impact Statement linked to the cap on Housing Benefit – it says that there are NO impacts on Health and Wellbeing.
As we now know on the 2nd of July the Observer published a leaked letter by Nico Heslop (private secretary to Eric Pickles Secretary of State for Communities and Local Government) where he writes to the Prime Minister and says
“……our modelling indicates that we could see an additional 20,000 homelessness acceptances as a result of the total benefit cap. This on top of the of the 20,000 additional acceptances already anticipated as a result of other changes to Housing Benefit. We are already seeing increased pressures on homelessness services. I understand that there may be a suggestion around requiring families to divert a percentage of their non-housing (benefit) income to cover housing costs. It is important not to underestimate the level of controversy that this would generate (likely to dwarf anything already seen on the HB only caps) and the difficulty of justifying this in policy terms as well as implementation.”
No impact on health and wellbeing? You’re having a laugh!