Nicholas Spooner

Change 
Grow 
Live 

Sussex Partnership 
NHS foundation Trust 

Date: 

5th  October 2021 

Brighton & Hove 
City Council 

Private & Confidential 
Penny Schofield 
Acting Senior 
Coroner 
Coroner's Office 
Woodvale 

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 

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Brighton & Hove 
City Council 

Change 
Grow 
Live 

rc1:PJ 

Sussex Partnership 
NHS foundation Trust

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; 

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Brighton & Hove 
City Council 

Change 
Grow 
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Sussex Partnership
NMS  foundation Tm,t

•  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

• 

Department 
of Health & 
Social Care 

From Gillian Keegan MP
Minister of State for Care and Mental Health

39 Victoria  Street
London 
SW1H0EU

Ms Veronica Hamilton-Deeley 
HM Senior Coroner,  Brighton and  Hove 
H M Coroner's Office 
Woodvale 
Lewes Road 
Brighton BN2 3QB 

26 October 2021 

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 problems 1.  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 
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. 

 independent Review 

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

ci.lt:~1~ 

Brighton & Hove 
City Council 

Sussex 

Change 
Grow 
Live 

l.!.l:bj 
Sussex Partnership 
NHS  foond:,ti(m Tn,n 

Private & Confidential 
Penny Schofield 
Acting Senior 
Coroner 
Coroner's Office 
Woodvale 

Dear Ms  Schofield 

Date: 

29th  July 2022 

Our 
Ref: 

AC-SA-GR-MM 

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 
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. 

 raised,  and in  our response 

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; 

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Brighton & Hove 
City Council 

Sussex 

Change 
Grow 
Live 

ri!l:f;j 
Sussex Partnership 
NHS  Foundation Trust 

•  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 

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 Brighton & Hove 
City Council 

Sussex 

Change 
Grow 
Live 

rel:§

Sussex Partnership 
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 

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