09^th October 2002

Dr. John Owens
Chairman - Mental Health Commission
c/o Ms. Adele Gannon
Mental Health Services
Floor 5, Hawkins House
Hawkins Street
Dublin 2

 
Dear Dr. Owens

At the recent Committee meetings of the Irish College of Psychiatrists, the role of the Mental Health Commission and the new Mental Health Act have been discussed. We are keen to hear about the state of development of the Commission at this stage and also to set up a meeting with members of the Commission as soon as it is operational.

As the main representative body of the psychiatric profession in Ireland we would be very keen to work in partnership with the Mental Health Commission to ensure the effective operation of the Mental Health Act and to assist in the matter of promoting quality in mental health care in Ireland.

Psychiatrists are in support of the Mental Health Act and are eager to see it operational. However, as you are aware there are serious concerns about the resource implications and operational issues. The Law Sub-Committee of the Irish College of Psychiatrists is presently preparing a submission on a Code of Practice for the Mental Health Act. This is in draft form at present and as soon as it is finalised we will be approaching yourself and the Commission with a view to holding discussions around it.

We wish to discuss progress and developments in relation to the new Mental Health Services Inspectorate. We are also interested in knowing what views the Commission have on the shape of the new Inspectorate. The College would certainly welcome a reformed Inspectorate and would take the view that this Inspectorate should be involved in the full range of mental health services.

Given the amount of specialisation that has taken place in the last 20 years within psychiatry it would be our view that the composition of the new Inspectorate should reflect the various specialties and subspecialties. We would wish to have an Inspectorate that takes a standardised approach to the inspection of mental health services. This would include measuring standards against professionally and internationally recognized acceptable standards of service delivery. The profession would also be keen to see the Inspectorate’s Report as a tool that is used to lobby for improvements in mental health service delivery.

Generally speaking the profession welcomes the new Mental Health Commission and changes to the Inspectorate - and are willing to work in a spirit of partnership. We are also acutely aware of the need to avoid any adversarial relationships between the profession and the Commission.

At our recent meeting there was some concern expressed around comments attributed to you in the Irish Medical Times on July 26^th 2002. I have also received numerous representations of concern from members of the profession in relation to these comments, especially with regard to the Commission’s role in regard to the prescription of ECT and psychotropic drugs. The profession rejects the notion that the Commission would have a role in drawing up protocols for ECT or the prescription of drugs.

The College would advocate an evidence-based approach to the use of drugs and ECT in psychiatry. As you are aware the American Psychiatric Association and the Royal College of Psychiatrists already have evidence-based protocols on the use of ECT which can be referenced by the profession. The notion that individual psychiatrists would be answerable to the Mental Health Commission for their practice in the use of ECT or drugs is not acceptable to our members. There are already structures in place, which will deal with these various matters i.e. Competence Assurance structures which will be dealt with by the Medical Council, Continuing Professional Development and Education which is being addressed by the Colleges, and contractual matters relating to clinical independence, which is the consideration of the IMO and IHCA.

I would be seriously concerned about a perception emerging that the Mental Health Commission would have a role in the policing of the practice of the profession. This perception would prove unhelpful as we endeavor to establish positive working relationships.

Again, I would like to reiterate our support for the Mental Health Commission and the Act - obviously taking into account our above concerns. I believe it would be very helpful if we could meet as soon as possible in order to clarify matters and to set a working agenda.

With kind regards.

Dr. Colette M Halpin
Chairman