Marnie Hill

From Maria Caulfield MP 
Parliamentary Under Secretary of State 
Department of Health & Social Care 

39 Victoria Street 
London 
SW1H 0EU 

28 March 2024 

Ms Rachael Griffin 
Senior Coroner for Dorset 
BCP Council Civic Centre 
Bourne Avenue 
Bournemouth 
BH2 6DY 

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. 

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 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: 
https://www.gov.uk/government/consultations/healthcare-regulation-deciding-when-
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 

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 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. 

Yours sincerely, 

MARIA CAULFIELD 

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Vespasian House 
Barrack Road 
Dorchester 
Dorset 
DT1 1TG 

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. 

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 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 
post, or email -

Many thanks 

Yours sincerely 

Chief Executive Officer, NHS Dorset 

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Monday, 30 October 2023 

Mrs R. Griffin 
HM Senior Coroner for Dorset 
Coroner’s Office for the County of Dorset 
Town Hall 
Bournemouth 
Dorset 
BH2 6DY 

Dear Mrs Griffin 

Trust Headquarters 
Abbey Court 
Eagle Way 
Exeter 
Devon 
EX2 7HY 

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 

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 approval has been given by the SJA clinical and IT teams to access and use the SWASFT 
version of the Clinical App when working on behalf of SWASFT. Accounts for their staff are 
currently being set up. 

For your assurance, following a previous inquest in June 2023, the Trust introduced a new 
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 
within the Scribe ECS. I have been advised by our Clinical Information Systems Manager 
that this is being worked on within the next update by the provider. Although I am unable to 
give you a timeframe on this currently, I would be happy to provide you with an update on 
the position in due course. 

Electronic Care System 

I am pleased to confirm that our ECS was successfully reintroduced on Tuesday 10th 
October 2023. We are also reviewing and updating our Business Continuity Plans which is 
looking at adopting the Scribe ECS as a secondary fall-back system. This will significantly 
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. 

Yours sincerely 

Deputy Head of Clinical Development (Organisational Learning) 

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