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Equality and Diversity

Equality, Inclusion and Human Rights

Bedfordshire CCG is committed to designing and implementing policies and procedures, and commissioning services that meet the diverse needs of our local population and workforce, ensuring that no one is placed at a disadvantage over others.

Our equality and diversity strategy sets out our approach to reducing health inequalities across Bedfordshire. However, in line with national directive, Bedfordshire CCG is working towards becoming one organisation with Luton CCG and Milton Keynes CCG. The current strategy is, therefore, being extended while we work together to develop a single approach to equality and reducing health inequalities.

The CCG published its EDS2 report in 2016. This report sets out the CCG’s commitment, key actions and annual progress update. Previous reports can also be found in the relevant section below. Each report includes an update on progress against the Equality Delivery System 2 (EDS2) framework and the CCG’s Equality Objectives.  The CCG has set its own five-year plan following the NHS Five Year Forward View. This strategy, combined with the CCG’s Equality Commitment, details our intention to place equality, diversity, inclusion and human rights at the heart of what we do. By doing so, the CCG ensures the best possible outcomes for the local community, CCG staff and those seldom heard groups who experience health inequalities.

The CCG has an obligation to understand and take action to reduce health inequalities for the population it serves as required under the Health and Social Care Act 2012. 

Equality objectives

In April 2014 BCCG’s executive team agreed the following equality objectives, as required by the Equality Act 2010 and in response to the publication of data relating to staff and health inequalities in Bedfordshire. These objectives set the strategic focus for the CCG’s work on equality and diversity over the next four years. Setting such a focus enables greater accountability and clarity on where the CCG expects to go. Subsequently these have been extended until 2021.

Key Equality Objective patients:

Addressing Health Inequalities

By 2021 to reduce the proportion of women in Bedfordshire who cannot speak English and report not being in good health from 50% to 30%

Other Objectives to be considered:

  • By 2021 to reduce the "poor or bad health" reported by the Irish community in Bedfordshire to equal that of the Bedford Borough average (i.e. from 8.4% and 7% in Bedford Borough and Central Bedfordshire respectively to 4.5%)
  • To examine what can be done to reduce the disproportionality of disability at birth between boys and girls
  • To investigate the establishment of a countywide "one-stop-shop" for the lesbian, gay, bisexual and transsexual community
  • To reduce the disproportionality in infant deaths between different ethnic groups
  • To reduce the disproportionality between some ethnic minority groups (Asian, black, Chinese, mixed ethnicity) and the white community in A&E admissions
  • To look at removing barriers for patients in getting appointments with GPs
  • Improve awareness about out-of-hours GP services among identified equality groups
  • Mental health services need to be planned recognising that certain groups with protected characteristics are reporting higher levels of mental health issues. In particular black/Caribbean/African groups report disproportionate high levels of forcible detention and disproportionately lower levels of preventative contact with services. Asian women are less likely to report mental health issues. Lesbian, gay, bisexual and trans communities also report higher levels of mental health problems

Workforce equality objective:

  • Workforce information suggests that action is required to attract more men to work for the CCG. The only exception to this trend is in the non-AFC grades, that is non-executive directors, GP leads and executive team members, where males are the majority.
  • Positive action is undertaken to (1) encourage more men to apply for positions with the CCG and (2) support more women to consider positions as non- AFC grades.
  • It appears that there is a significant under-representation of ethnic minorities being appointed to jobs (28%), compared to those applying (45%).
  • Further work is undertaken to investigate this disparity with a view to proposing action to address it.
  • Only five out of 175 employees declared having a disability. Six per cent of applicants declared a disability. No new starters or applicants declared a disability. Although the "Two Ticks" positive about disability scheme has been in operation, it may be an area for further work.
  • To increase disability disclosure among new starters and employees to at least 5% within two years.
  • The low disclosure rates for sexual orientation among employees may indicate that the CCG is perceived as unfriendly to LGBTQ issues.
  • We joined the Stonewall Diversity Champions programme to raise awareness of issues relating to sexual orientation.

These objectives should be seen in context with and as part of the CCG’s Equality Strategy.

Meeting our equality and health inequalities legal duties

CCGs and NHS England play key roles in addressing equality and health inequalities – as commissioners, employers and local and national system leaders – in creating high quality care for all.

CCGs and NHS England have two separate key duties, one on equality and one on health inequalities. Both require informed consideration by decision makers, but it is important to appreciate that they are two distinct duties. 

Public Sector Equality Duty (PSED)

As an authorised public sector organisation, Bedfordshire CCG is required by the Equality Act 2010 and Human Rights Act 1998 to work in ways that ensure equality and inclusion is embedded into all of its functions.

It is the intention of the CCG to eliminate unfair and unlawful discriminatory practices in line with current equality and human rights legislation. There are a number of duties which the CCG must address:

1. In the exercise of its functions Bedfordshire CCG must have due regard to the need to:

a.      eliminate discrimination, harassment and victimisation and any other conduct that is prohibited by or under the Equality Act 2010

b.      advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it

c.       foster good relations between persons who share a relevant protected characteristic and persons who do not share it.

2. The CCG must prepare and publish one or more equality objectives at intervals of not greater than four years and each objective must be specific and measurable.

3. The CCG must publish information, not later than 30 March each year, to demonstrate compliance with the PSED. The information published must relate to persons who share a relevant protected characteristic who are:

a.      Its employees (only when employing 150 people or more)

b.      Other persons affected by its policies and practices

The characteristics which are protected under the Equality Act 2010 are:

  • Age
  • Disability
  • Gender
  • Gender reassignment
  • Pregnancy and maternity
  • Race
  • Religion or belief
  • Sexual orientation
  • Marriage and civil partnership (but only in regard to the first aim - eliminating discrimination and harassment)

Health inequalities duty

The Health and Social Care Act 2012 introduced the first legal duties on addressing health inequalities, with specific duties on NHS England and CCGs. Under the Act, Bedfordshire CCG has duties to:

  • have regard to the need to reduce inequalities between patients in access to health services and the outcomes achieved
  • exercise its functions with a view to securing that health services are provided in an integrated way that would improve quality, reduce inequalities in access to those services or reduce inequalities in the outcomes achieved
  • include in an annual commissioning plan an explanation of how they propose to discharge their duty to have regard to the need to reduce inequalities
  • include in an annual report an assessment of how effectively they discharged their duty to have regard to the need to reduce inequalities.

More information about meeting the equality and health inequalities legal duties can be found here https://www.england.nhs.uk/about/equality/equality-hub/legal-duties/

Annual equality reporting (including Equality Delivery System2 (EDS2)

The EDS was developed as a product by the Equality and Diversity council of the NHS Commissioning Board (now NHS England). More information about the EDS can be found here. https://www.england.nhs.uk/about/equality/equality-hub/eds/

The Equality Act 2010 requires NHS Clinical Commissioning Groups to publish information annually which demonstrates the progress being made by CCGs against equality, inclusion and human rights.

The goals and outcomes of EDS2

EDS Goal 1: Better Health outcomes for all
EDS Goal 2: Improved patient access and experience
EDS Goal 3: Empowered, engaged and well support staff
EDS Goal 4: Inclusive Leadership for all levels

Workforce Race Equality Standard (WRES)

The NHS Workforce Race Equality Standard has been in place for a number of years and places obligations on both commissioners and providers of services. CCGs and provider organisations are required to publish an annual date template showing outcomes for White and BME staff and develop action plans to address any issues that emerge. The CCG is also required to monitor and assure itself that those organisations providing services on its behalf have met their duties.

The CCG’s reporting template and action plans can be found below:

The WRES technical guidance document and all other WRES resources are available via the following link. Further information can be found by following the link here to the NHS England WRES webpage. http://www.england.nhs.uk/ourwork/gov/equality-hub/equality-standard/

Workforce Disability Equality Standard (WRES)

The Workforce Disability Equality Standard (WDES) is a set of ten specific measures that will enable NHS organisations to compare the experiences of disabled and non-disabled staff. This information will then be used to develop a local action plan and enable NHS organisations to demonstrate progress against the indicators of disability equality. The WDES came into force across NHS trusts and foundation trusts on 1 April 2019 and is restricted to those organisations for the first two years.

The implementation of the WDES will enable NHS organisations to better understand the experiences of their disabled staff. It will support positive change for existing employees and enable a more inclusive environment for disabled people working in the NHS. Like the Workforce Race Equality Standard on which the WDES is in part modelled, it will also allow Bedfordshire CCG to identify good practice. More information about the WDES can be found here. https://www.england.nhs.uk/about/equality/equality-hub/wdes/ 

List of documents available on Bedfordshire CCG’s website

  • Bedfordshire CCG 2020 WRES reporting template
  • Joint BLMK Action Plan 2020/21
  • Workforce Information Analysis (2016)
  • Workforce Analysis (2017)
  • Equality Impact Assessment template
  • Equality and Diversity Policy (2017)
  • Equality objectives to reduce Health Inequalities in Bedfordshire
  • Information on Health Inequalities (2015)
  • Equality and Diversity Action Plan (2015) progress Report
  • Equality and Diversity Strategy 2015-2018
  • Equality and diversity Report 2016
  • EDS2 Report (2016)


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