Stakeholder submissions

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Overview Note

Forty-four submissions were received from stakeholder organisations as part of the formal Public Consultation. Submissions came from a wide variety of organisations spanning health and social care, business and workers, and social aspects, including education and rights perspectives.

Generally, the focus was less on critiques of the overall pandemic response, but rather thematic observations aligned to the organisations sector or cohort that it represents or advocates for. A number of submissions also highlight the impact restrictions had on service delivery and portray the flexibility and agility of staff in rapidly developing or pivoting services online.  

A number of points routinely raised from these submissions, included that many stakeholders felt their members/sectors interests were disproportionately affected in comparison to the general population, with many commending their staff and members for their resilience and dedication during the pandemic.

The overview below gives an outline of some of the key issues raised including, sectoral impacts; differing levels of input and engagement with decision makers; overall approach and restrictions, and related oversight, protocols and communication; and internal organisational mitigation efforts, reflections and research. It also outlines some related suggested recommendations. The overview also includes further details categorised by health and social care, and wider societal and economic considerations.

(Additional stakeholder submissions were sought where there were gaps and in relation to the consulation on the response in long term residential care faciltieis for older persons. These will be published in due course.)

1: Disproportionate impacts

Submissions highlighted that pre-existing inequalities in terms of health and social inequalities faced prior to the pandemic, led to disproportionate impacts.

Many organisations felt that their members, or the community or cohort they represent, were more adversely affected than other sectors of society. This is particularly evident for minority communities, such as people with disabilities and the Travelling Community, but also feature in submissions related to children and young people and those related to older people.

For example, the Irish Deaf Society raised the issue of barriers in terms accessing health related information and support; the National Women’s Council focused on women’s health, domestic, sexual and gender-based violence (DSGBV), and economic equality; and the National Disability Authority noted how changes such as to the out-door built environment had adverse access consequences for disabled people.

The INMO, which represents over 50,000 nurses, highlighted the centrality of the large number of frontline workers they represent. Nursing Homes Ireland (NHI), representing many nursing homes in  a sector particularly impacted, outlined key recommendations for the future. Sage Advocacy highlighted the negative impacts of ‘cocooning’ on older people and the needs of those living alone, in nursing homes or in isolated communities.

2: Feedback on overall response

Criticisms of the overall government strategy to combat the spread of the virus is limited. Instead, many offered specific critiques or observations on response improvements relating to their remit and areas of focus.

Many sectors felt they were detached during the decision-making process, with some specialist groups highlighting that they were not included in the early information process and as a result the services they provide, or groups they advocate for, were overlooked.

For example, the Irish Dental Association took the view that oral healthcare was overlooked; Nursing Homes Ireland (NHI) highlighted that hospital capacity was prioritised over nursing homes residents; and INOU (Irish National Organisation of the Unemployed) commended many mitigation efforts taken but raised issues regarding the Pandemic Unemployment Payment (PUP).

3: Communication

Some organisations felt that official communication could have been clearer. For example, FODO Ireland, sought future clear guidelines to support all healthcare professions. There was a similar recommendation by the Irish Episcopal Conference for their sector. Likewise, the Irish College of Funeral Directing and Embalming said there was confusion over key services at certain times.

4: Government/official engagement

There are differing opinions on the extent to which stakeholders felt included and consulted with.

Galway Simon Community was one of several organisations that felt not enough assistance was given to carry out their essential work. In contrast, Fórsa and the INTO felt engaged by Government, with the former describing the benefits of what they term ‘Social Dialogue’ on ensuring society adhered to Government advice.

There appears to be a pattern with larger organisations more likely to have felt engaged by Government than organisations representing smaller sectors/cohorts of society.

5: Mitigation efforts and Research/Consultation 

Many stakeholders outlined the internal mitigation efforts their organisation took. Several organisations, such as Cork & Kerry Regional Traveller Accommodation, the Irish Lung Fibrosis Association, the National Parents Council, and others, carried out their own evaluations, and their submissions contained research, including interviews.

6: Essential Service

Multiple stakeholders commended the efforts and resilience of their members; this is particularly true of representatives for frontline workers. 

Some argued that their sectors should have been better recognised and considered essential. For example, catholic religious order for lay people and also diocesan clergy, noted distress relating to the designation of religious worship as non-essential.

7: Main Proposed recommendations

Improved communications & engagement

Stakeholders offered a variety of recommendations to improve communications and engagement. More inclusive structured government engagement or dialog processes were called for by many stakeholders, to ensure broader societal inclusion in the decision-making process, emphasising the centrality of the voices of those most impacted. 

Stakeholders representing minority and vulnerable groups also advocated for specialised communication aimed at the communities they represent.

Greater oversight, clearer protocols & human rights approach

There was a broad call for greater oversight and protection for vulnerable groups such as older people, carers, the traveller community and disabled people. For example, Age and Opportunity, which advocates for older people called for an independent commissioner for ageing and older people.

Numerous organisations called for a rights-based approach to decision making, including IHREC and the Irish Council for Civil Liberties, who called for an Equality and Human Rights Assessment as an integral part of the overall process.  The importance of ensuring laws and policies proportionate and considered differing needs  was also highlighted, as was the point that better data would underpin a greater understanding of disproportionate impacts for certain groups, and related necessity for targeted mitigating supports.

The Policing and Safety Community Authority reflected on a variety of actions that were taken during the pandemic and since, including relating to oversight, engagement and rights.

Healthcare submissions placed a focus on the need for better and clearer protocols around the provision, procurement and delivery of healthcare in future emergencies. Recommendation included that clear protocols be in place that can be activated and implemented quickly in an emergency.

Sectoral Focus

Multiple health related submissions commended staff and members for their resilience and work during the pandemic. Many left that while restrictions were necessary, related communication could have been better and clearer.  The health sector provided numerous recommendations, including relating to: Staffing (safe levels and appropriate skills mix); resources and integration; capacity (future focused approach to bed capacity and emergency department levels); recognition (commitment, professionalism and leadership of workers during the pandemic); and preparation and future pandemic planning (incorporating international guidelines and risks and impacts for staff). 

Submissions related to long term residential care (LTRC) emphasised that the pandemic had a disproportionate impact on this sector, not just on workers and residents, but also on families of residents. Representatives perceived the State to have underprepared for the crisis, contributing to the high level of infections and in-turn mortalities. Much of the sectoral feedback focused on the prioritisation  of acute hospitals over LTRC, which has implications for timely access to PPE, testing, and tailored guidance in the critical early weeks. The Irish Hospice Foundation highlighted the impact that restrictions had on the families of those in LTRC. They emphasised end-of-life care experiences, the significant impact on those whose loved ones died alone, and related distress for bereaved families.

Numerous recommendations on LTRC, included: Clearer evidence-based emergency protocols; adequate staffing and planning; use of technologies for family/residence connectivity; adequate bereavement support; and prioritising compassionate inclusive end-of-life care in future crises.

Social

Mental Health

The need for better mental health supports was a common theme. While the impact on mental health was evident across sectors and age groups, it was notably a focus for advocates for older and younger people. Alone, for example, highlight a need to expand mental health supports and capacity for older people, highlighting loneliness as a significant issue.

For younger people, the closure of schools, lack of socialising and other factors impacted not only their mental health but also their development. For example, Jigsaw noted how key components of positive mental health were impacted by necessary restrictions, including personal relationships and autonomy.

Education

The main issues raised by the National Parents Council were that children in special classes were particularly affected and overlooked, with the loss of support services, causing further setbacks. They saw a need for better preparation and alignment between schools and government with greater flexibility in learning delivery, as well as clearer communication. There was significant divergence of opinion from parents surveyed by the NPC on matters such as mask wearing in schools and the effectiveness of online education support provided by schools during lock-down.  AsIAm reflected on how the removal of education supports, services and therapies had a regressive impact on Autistic individuals and families.

Wider feedback relating to education centred primarily on engagement between the sector and government. The submission by the INTO highlights mitigation efforts by the sector, such as the move to remote working/learning and school re-opening. They raise issues with the latter regarding confusion arising from communication relating to schools re-opening and the burdens placed on school leaders. 

Other submissions highlighted the particular impacts on education and young people, as part of the wider effects across society, including in the areas of mental health and human rights.

Economic (Businesses & Workers)

Many business representatives felt restrictions gave considerable weight to public health without sufficiently balancing the need for economic considerations, including the viability of businesses. For example, IALPA detailed the disproportionate and prolonged impact of restrictions on pilots and the wider aviation industry, and insufficient consultation.

However, unions and other organisations, gave some positive feedback relating to the prioritisation of workers negatively impacted by closures and changes to working arrangements. Larger bodies felt more included and engaged in the decision-making process. For example, the Restaurants Association of Ireland, Chambers Ireland and sectoral unions engaged with government throughout the pandemic, in contrast to the experiences of smaller businesses.

Mitigating supports made available during the pandemic were broadly welcomed. Key lessons highlighted in economic related submissions included a need for clearer communication, including relating to supports; evidence-based restrictions; and balanced policy decisions, that weigh public health against economic sustainability, with accompanying tailored accessible supports.