Substance misuse treatment framework for children and young people: integrated impact assessment

A key theme within the 'Substance misuse delivery plan 2019 to 2022' is to provide further support for families and carers of people who misuse substances. The delivery plan was revised in 2021 to take account of coronavirus (COVID-19), Area Planning Boards (APBs) and other stakeholders are currently working to this. Consideration will be given to future substance misuse priorities and discussions will take place with stakeholders at the appropriate time.

The delivery plan aligns to five ways of working in the Well-being of Future Generations Act and we have ensured that the substance misuse outcomes we are seeking to achieve are clear in the contribution they make to the Wellbeing of Future Generation Act goals. Throughout the priorities and commitments set out in the delivery plan, including those in relation to children and young people, there is a focus on having a long-term impact on individuals and families and the prevention of substance misuse is a focus in much of the work to be undertaken.

Substance use and misuse amongst children and young people aged up to 25 represents a particular societal focus and challenge in Wales and the wider UK, with many harms remaining hidden from support and treatment services. Harms associated with substance use include, and are not limited to:

• those impacting on physical health including acute toxicity, infection and premature deaths from poisoning, suicides, accidents or violence and assault
• psychological harms, both acute and chronic, particularly amongst those with multiple and complex needs including mental health disorders
• contact with the criminal justice system

Longer term harms include loss of opportunity due to lack of complete education, employment, financial and health inequalities. Children and young people may be at increased vulnerability due to their own or parental substance misuse and are at a higher risk of physical, emotional and sexual abuse, exploitation and organised crime.

This Substance Misuse Treatment Framework (SMTF) is a guidance document and is designed to inform and assist health, social care and criminal justice planners and providers to design and deliver high quality, sustainable and equitable prevention and treatment services for those at risk of, or experiencing, substance misuse issues.

The intended audience for this guidance includes service planners, commissioners, substance misuse and wider health, criminal justice and social care providers working with those at risk of initiation, or experience of historic or current problematic drug or alcohol use.

The SMTF provides an overview of the existing situation in Wales and the wider UK and outlines the evidence to inform improvements. Links to relevant strategy and policy documents are provided along with a summary of the evidence relating to required development of services aimed at improving the health and wellbeing of children and young people.

1.1 Long term

Developing the SMTF - integrated substance misuse service provision for children and young people is a priority in the 'Substance misuse delivery plan 2019 to 2022'.

The long-term aim is to:

• create a pathway, from early engagement to transitional and exit planning for both alcohol and drugs; as an individual may have both problematic drug and alcohol use, the assessment process and pathway will be designed to be flexible and inclusive through to follow-on support and exit planning
• ensure a focus on the required workforce developments including realignment and training
• identify the key indicators to measuring progress, performance and the delivery of an ‘excellent, safe and equivalent service’ in relation to substance misuse and related health and social care requirements, and required technological innovation, information governance and information systems covering both community and criminal justice settings

1.2 Prevention

The Welsh Government has defined prevention as working in partnership to co-produce the best outcomes possible, utilising the strengths and assets people and places have to contribute.

Improved outcomes for children and young people in relation to substance use and misuse can only be achieved through early and credible engagement, integrated assessment and joint working with a harm reduction and needs-based approach. Providing targeted educational interventions, prevention and treatment services for children and young people are key components of safeguarding and improving their health and wellbeing. Providing effective engagement and interventions with integrated and bespoke support in the earlier years and up to the age of 25 will reduce the population of individuals developing life-long substance misuse issues and the inherent harms associated with entrenched use.

The focus of services offering early engagement aims to delay or reduce the likelihood of young people moving from using to misusing substances, limiting the harms associated with use, and avoiding progression to dependency.

1.3 Integration

There are several cross-cutting frameworks that highlight the joint responsibilities for children and young people and these have been considered with relevant schedules highlighted within the SMTF. These include:

a) NHS (Wales) Act 2006
b) Well-being of Future Generations (Wales) Act 2015
c) The Socio-economic Duty Equality Act 2010
d) Social Service and Wellbeing (Wales) Act 2014
e) The Children Act 1989
f) Children Act 2004
g) Children and Families Wales Measure (2010)
h) The United Nations Convention on the Rights of the Child
i) The Equality Act 2010
j) Welsh Language (Wales) Measure 2011
k) The Mental Capacity Act 2005
l) The Mental Capacity (Amendment) Act 2019: Liberty Protection Safeguards (LPS)
m) The Mental Health (Wales) Measure 2010
n) UK Drug Laws

Programme for government (PfG) - substance misuse is a cross cutting issue so whilst not specifically mentioned as a PfG commitment, it impacts on a number of key PfG commitments which will not be achieved for the most vulnerable without support for substance misuse services, these broadly are, mental health, housing and homelessness and children and families. This will help achieve PfG commitments in relation to:

• providing additional specialist support for children with complex needs who may be on the edge of care
• exploring radical reform of current services for looked after children and care leavers
• prioritising service redesign to improve prevention, tackle stigma and promote a no wrong door approach to mental health support
• reforming primary care, bringing together GP services with pharmacy, therapy, housing, social care, mental health, community and third sector
• delivering better access to doctors, nurses, dentists and other health professionals

1.4 Collaboration

To ensure the actions set out in this SMTF are achievable, the Welsh Government will continue our work in supporting substance misuse services through our substance misuse APBs and heath boards. APBs are responsible for the commissioning of services based on local need and we will continue our work with them to ensure they continue to provide services that meet the needs of the population, including children and young people.

To achieve this, we will ensure our interventions are ‘joined up’ across government as demonstrated in the integration section, recognising the needs of individuals go beyond their substance use, by developing a whole person approach to support them.

Good partnership working is critical if the best possible support is to be provided to individuals and communities. We recognise that a key element of delivering substance misuse services is that APBs work closely with other partnerships and structures, such as regional partnership boards, public service boards and other structures, in order to provide the best support possible to the individual and wider community.

1.5 Involvement

To oversee development of this SMTF for children and young people, a steering group was established in 2018. In addition, national stakeholder groups were invited to attend two engagement days to agree amendment and final recommendations of the SMTF following initial engagement.

The Welsh Government also held a 12-week consultation which ran from 30 September to 23 December 2022 to seek further stakeholder and partner feedback.

The evidence within the SMTF is drawn from a range of sources including bibliographic databases, personal communication with leading academics, stakeholder and evidence gathering events and key informant interviews. The databases and website sources included MEDLINE, MEDLINE Daily Update, AMED, BNI and EMBASE. Websites included NICE, Health Protection Agency, Welsh Government, Department of Health and Social Care.

1.6 Impact

Implementing the main recommendations within the SMTF should see:

• all services for children and young people provide an inclusive and adaptive service for all those aged up to 25 years
• implementation of an electronic unified and modular assessment tool across services in Wales working with children and young people aged up to <25
• development of comprehensive specialised intervention services delivered by creating a single agency, or bringing together separate agencies, to act as a single entity to support those with multiple or complex vulnerabilities including substance use, mental health and learning difficulties or risk of offending and reoffending aged 15 to 25 years

1.7 Costs and savings

It is anticipated the implementation of the actions within the SMTF will be met through existing funding for substance misuse services in Wales. The Welsh Government will continue to prioritise funding for these services and in 2024 to 2025 are investing over £67m in the substance misuse agenda. This includes over £41m directly to support substance misuse APBs who commission services locally based on need. Ring fenced funding is provided for children and young people’s services and this has risen by £1m in 2024 to 2025, taking the total ring fenced investment to £6.25m.

There is a significant body of evidence to support the social return on investment and the recent Dame Carol Black review found that “[e]very £1 currently spent on harm reduction and treatment gives a combined health and justice return on investment of £4”.

1.8 Mechanism

The Welsh Government, health boards, substance misuse APBs, criminal justice, local authorities and third sector organisations will be responsible for ensuring delivery of this SMTF for children and young people.

2.1 People and communities

The SMTF should have a significant positive impact on those who are at risk of the harms associated with substance misuse by ensuring children and young people receive the right support at the right time in the right place, improving better outcomes for them, their families and wider communities. The SMTF aims to positively impact on children and young people’s lives by delaying or reducing the likelihood of young people moving from ‘using’ to ‘misusing’ substances, thus limiting the harms associated with use, and avoiding progression to dependency.

2.2 Children’s rights

A Children's Rights Impact Assessment (CRIA) has been completed.

2.3 Equality

An equality impact assessment has been completed.

2.4 Rural proofing

The SMTF aims to positively impact on all services involving children and young people, including those within the rural community in Wales. The SMTF aims to ensure those who need support and treatment are able to access where and when they need it. Substance Misuse APBs are responsible for ensuring appropriate services are available in rural locations, particularly including the provision of outreach services, integration with primary care and use of digital technologies.

2.5 Health
2.5a How (either positively or negatively), and to what extent (significant / moderate / minimal impact), will the proposal impact health determinants?

The SMTF will help significantly improve the health outcomes for children and young people and the family members of those who misuse substances. Children and young people receiving the right support should see a significant positive impact to both physical and mental health.

2.5b. Could there be a differential health impact on particular groups?

Substance misuse is a health and social care issue that affects the whole population of Wales, be it directly or indirectly. The aim of the SMTF will help ensure children and young people receive the right support at the right time in the right place, improving better outcomes for them, their families and wider communities.

2.6 Privacy

The following privacy notice will be issued as part of the consultation:

UK General Data Protection Regulation (UK GDPR)

The Welsh Government will be data controller for any personal data you provide as part of your response to the consultation. Welsh Ministers have statutory powers they will rely on to process this personal data which will enable them to make informed decisions about how they exercise their public functions. Any response you send us will be seen in full by Welsh Government staff dealing with the issues which this consultation is about or planning future consultations. Where the Welsh Government undertakes further analysis of consultation responses then this work may be commissioned to be carried out by an accredited third party (such as a research organisation or a consultancy company). Any such work will only be undertaken under contract. Welsh Government’s standard terms and conditions for such contracts set out strict requirements for the processing and safekeeping of personal data.

In order to show that the consultation was carried out properly, the Welsh Government intends to publish a summary of the responses to this document. We may also publish responses in full. Normally, the name and address (or part of the address) of the person or organisation who sent the response are published with the response. If you do not want your name or address published, please tell us this in writing when you send your response. We will then redact them before publishing.

You should also be aware of our responsibilities under freedom of information legislation.

If your details are published as part of the consultation response then these published reports will be retained indefinitely. Any of your data held otherwise by Welsh Government will be kept for no more than three years.

Your rights

Under the data protection legislation, you have the right:

• to be informed of the personal data held about you and to access it
• to require us to rectify inaccuracies in that data
• to (in certain circumstances) object to or restrict processing
• for (in certain circumstances) your data to be ‘erased’
• to (in certain circumstances) data portability
• to lodge a complaint with the Information Commissioner’s Office (ICO) who is our independent regulator for data protection

For further details about the information the Welsh Government holds and its use, or if you want to exercise your rights under the GDPR, please see contact details below:

Data Protection Officer
Welsh Government
Cathays Park
Cardiff
CF10 3NQ
e-mail: Data.ProtectionOfficer@gov.wales
The contact details for the Information Commissioner’s Office are:

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 01625 545 745 or 
0303 123 1113
Website of the Information Commissioner's Office.

3.1 Cultural well-being

The Well-being of Future Generations (Wales) Act 2015’s goal for culture is 'A society that promotes and protects culture, heritage and the Welsh language and which encourages people to participate in the arts and sports and recreation'. Culture includes museums, archives, libraries and the arts; heritage includes the built historic environment as well as intangible heritage such as traditions; arts encompasses performance and creative sectors including music, literature, theatre and art, whilst sports and recreation include both elite and community sports as well as opportunities to participate in wider outdoor recreation.

3.1a How can the proposal actively contribute to the goal to promote and protect culture and heritage and encourage people to participate in the arts sports and recreation? (For Welsh language see section 3.2).

Part of the work to support children and young people who have substance misuse issues could involve arts, sport and various related activities, in particular as part of a programme of diversionary activity.

3.1b Is it possible that the proposal might have a negative effect on the promotion and protection of culture and heritage, or the ability of people to participate in arts, sport and recreation? If so, what action can you take to avoid or reduce that effect (for example by providing alternative opportunities)?

No, the policy will not have a negative impact.

3.2 Welsh language

A Welsh language impact assessment has been completed.

Supporting growth in the Welsh economy, and through this tackling poverty, is at the heart of the Welsh Government’s programme for government.

4.1 Business, the general public and individuals

Longer term harms of children and young people misusing substances include loss of opportunity due to lack of complete education, employment, financial and health inequalities. Children and young people may be at increased vulnerability due to their own or parental substance misuse and are at a higher risk of physical, emotional and sexual abuse, exploitation and organised crime.

There is a wealth of evidence that shows employment is vital to good mental health whilst unemployment leads to a deterioration in health and well-being. Completing education and finding employment can be a hugely important step to recovery, improving self-esteem and confidence, and reducing stress and anxiety. Yet it is widely recognised that those receiving unemployment benefits who have substance misuse problems often face significant barriers when trying to find work.

4.2 Public sector including local government and other public bodies

Children and young people with substance misuse problems often present with complex needs impacting on the public sector in many ways such as housing and homelessness, families on the edge of care and anti-social behaviour. The SMTF aims to better support children and young people, and it is therefore felt the public sector will not negatively be affected by this SMTF.

4.3 Third sector

The third sector provides crucial support for those affected by substance misuse. The SMTF aims to better support children and young people and it is therefore felt the third sector will not negatively be affected by this SMTF.

4.4 Justice impact

The SMTF does not bring forward new primary legislation, create, remove or amend an offence nor does it impact on the justice system, a justice impact assessment is therefore not considered necessary.

Under Section 9 of the Environment (Wales) Act 2016, the Welsh Ministers are required to prepare, publish and implement a natural resources policy and to take all reasonable steps to implement it and to encourage others to take such steps. The natural resources policy was published in August 2017.

5.1 Natural resources
5.1a How will the proposal deliver one or more of the national priorities in the Natural Resources Policy (NRP)?

This is not applicable in relation to the ‘SMTF - integrated substance misuse service provision for children and young people’.

5.1b Does the proposal help tackle the following national challenges and opportunities for the sustainable management of natural resources?

The SMTF will help meet key priorities within the substance misuse delivery plan 2019 to 2022 (updated in 2021 and currently being worked to), which supports action to tackle health and economic inequalities and will have a positive impact on both areas. Harm reduction, employability and recovery are at the core of the delivery plan which is aligned to ‘A healthier Wales: our plan for health and social care’ and sees a whole system approach to health and social care, anticipates health needs, prevents illness and reduces poverty and health inequalities.

5.2 Biodiversity

The Welsh Government’s Nature Recovery Action Plan (NRAP) aims to reverse the decline in biodiversity, and it restates a commitment to halting the loss of biodiversity by 2020. Having considered the ‘SMTF - integrated substance misuse service provision for children and young people’ against the objectives of the NRAP, there are no direct impacts on biodiversity. Similarly, there will be no likely direct significant impacts on any special area of conservation or special protection area for birds, and so no need to undertake a habitats regulations assessment. A strategic environmental assessment and an impact assessment on carbon budgets are considered not to be required.

5.3 Climate change

Having considered the ‘SMTF - integrated substance misuse service provision for children and young people’ there are no direct impacts on decarbonisation and climate change.

5.4 Strategic Environmental Assessment (SEA)

See section 5.2.

5.5 Habitats Regulations Assessment (HRA)

See section 5.2.

5.6 Environmental Impact Assessment (EIA)

See section 5.2.

6.1 The socio-economic duty

The socio-economic duty requires relevant public bodies, including Welsh Ministers to have due regard to the need to reduce inequality of outcome that results from socio-economic disadvantage. This duty applies only to decisions which are of a strategic nature.

To access statutory guidance and further resources please visit the dedicated website page for Wales's socioeconomic duty.

To demonstrate that that ‘due regard’ has been given, an audit trail of evidence is kept for all decisions made under the duty. This impact assessment will form part of this evidence trail.

A socio-economic duty impact assessment has been completed.

7.1 How have people most likely to be affected by the proposal been involved in developing it?

To oversee development of this SMTF for children and young people, a steering group was established in 2018. National stakeholder groups were later invited to attend two engagement days to agree amendment and final recommendations of the SMTF following initial engagement. In addition, the Welsh Government ran a 12-week consultation seeking views of those who may be impacted by the SMTF. The consultation ran from 30 September to 23 December 2022.

7.2 What are the most significant impacts, positive and negative?

Implementing the main recommendations within the SMTF should see:

• all services for children and young people provide an inclusive and adaptive service for all those aged up to 25 years
• implementation of an electronic unified and modular assessment tool across services in Wales working with children and young people aged up to <25
• development of comprehensive specialised intervention services delivered by creating a single agency, or bringing together separate agencies, to act as a single entity to support those with multiple or complex vulnerabilities including substance use, mental health and learning difficulties or risk of offending and reoffending aged 15 to 25 years

The SMTF supports key priorities within the substance misuse delivery plan 2019 to 2022, (which was revised in 2021 to take account of COVID-19; APBs and stakeholders are currently still working to this plan), which positively approaches dealing with substance misuse in a preventative manner with harm reduction at the heart of its approach. It seeks to positively impact on health, education, employability and recovery.

The policy proposals as set out in the consultation document have no effect on the well-being of future generations goals or ways. They have been developed, however, in line with the five ways of working in the Well-being of Future Generations (Wales) Act 2015.

There are no negative issues associated with the social well-being of people and communities in Wales or on Wales’s cultural well-being or on the Welsh language. There are no negative issues on the economic well-being of businesses and the public, the environment, the United Nations Convention on the Rights of the Child or the tackling poverty agenda.

7.3 In light of the impacts identified, how will the proposal:

• maximise contribution to our well-being objectives and the seven well-being goals?
• avoid, reduce or mitigate any negative impacts?

The Well-being of Future Generations (Wales) Act 2015 provides a unique opportunity to coordinate effective multi-sector action on the devastating effects of substance misuse. The act places statutory responsibilities on public sector bodies to act in a manner which seeks to ensure that the needs of the present are met without compromising the wellbeing needs of future generations. The case to improve service provision for children and young people through this SMTF will help address the harms associated with substance misuse and will have both positive impacts on wellbeing, as well as the wider Welsh economy.

7.4 How will the impact of the proposal be monitored and evaluated as it progresses and when it concludes?

The Welsh Government, health boards, substance misuse APBs, criminal justice, local authorities and third sector organisations will be responsible for ensuring delivery of this SMTF for children and young people. The monitoring of substance misuse services is currently being reviewed as part of the development of a Welsh substance misuse outcomes framework and the needs of children, young people and families will form part of this.

The Rights of Children and Young Persons (Wales) Measure 2011 places a duty on the Welsh Ministers to pay due regard to the United Nations Convention on the Rights of the Child (UNCRC) and its Optional Protocols when exercising any of their functions.

1. Policy objectives

A key theme within the Substance Misuse Delivery Plan 2019 to 2022 (which was revised in 2021 to take account of COVID-19; APBs and stakeholders are currently still working to this plan), is to provide further support for families and carers of people who misuse substances.

Substance use and misuse amongst children and young people aged up to 25 represents a particular societal focus and challenge in Wales and the wider UK, with many harms remaining hidden from support and treatment services. Harms associated with substance use include, and are not limited to, those impacting on physical health including acute toxicity, infection and premature deaths from poisoning, suicides, accidents or violence and assault; psychological harms, both acute and chronic, particularly amongst those with multiple and complex needs including mental health disorders; and contact with the criminal justice system.

Longer term harms include loss of opportunity due to lack of complete education, employment, financial and health inequalities. Children and young people may be at increased vulnerability due to their own or parental substance misuse and are at a higher risk of physical, emotional and sexual abuse, exploitation and organised crime.

This Substance Misuse Treatment Framework (SMTF) is a guidance document and is designed to inform and assist health, social care and criminal justice planners and providers to design and deliver high quality, sustainable and equitable prevention and treatment services for those at risk of, or experiencing substance misuse issues.

The intended audience for this SMTF includes service planners, commissioners, substance misuse and wider health, criminal justice and social care providers working with those at risk of initiation, or experience of historic or current problematic drug or alcohol use.

The SMTF provides an overview of the existing situation in Wales and the wider UK and outlines the evidence to inform improvements. Links to relevant strategy and policy documents are provided along with a summary of the evidence relating to required development of services aimed at improving the health and wellbeing of children and young people.

2. Gathering evidence and engaging with children and young people

Substance misuse affects people of all ages, including children and young people, both as a result of their own use and that of their parent/carer.

As at 31 March 2022, there were 4,960 children receiving care and support due to parental substance misuse. The number of children receiving care and support whose own substance misuse was identified as a problem was 630, representing 3.8 per cent of all children receiving care and support.

There were a total of 869 school exclusions as a result of alcohol or drugs amongst school aged children, an increase of 119 per cent from 2021 to 2022.

There were 401 admissions involving young people aged under 25 with an alcohol-specific condition in 2022 to 2023, a decrease of 34.6 per cent compared with 2021 to 2022. There was a decrease in admissions for illicit drugs of 11.1 per cent amongst this age cohort in 2022 to 2023 to a total of 692.

In particular we know through the work on adverse childhood experiences that children who are raised in homes where substance misuse is an issue are, potentially, more likely to have adverse outcomes in later life.

During the consultation on the substance misuse delivery plan, one of the key priority areas for action that became apparent from feedback received was the need to provide further support for families and carers of people who misuse substances. The Welsh Government is currently consulting on a draft child poverty strategy for Wales 2023. This sets out the commitment that everything we do across government should have tackling poverty and inequality as a central driver. Households where there is parental substance misuse are often low-income households for a variety of interrelated reasons, increasing the risks of children in these households experiencing poverty. This means that delivery of the substance misuse delivery plan is likely to make a positive contribution to tackling child poverty.

We have engaged with a range of professionals to ensure the views of young people are considered and will further strengthen this as the framework is implemented.

3. Analysing the evidence and assessing the impact

The Welsh Government previously provided match funding to the Wales police schools programme. However, Ministers had to make difficult decisions for 2024 to 2025 with a focus on protecting front-line services and saving lives. Ministers therefore ended the Welsh Government’s contribution to the programme on 31 March 2024. The impact of this is difficult to predict as the programme was mainly measured in terms of outputs of lessons. The programme has been a partnership approach with the police as they also fund the programme. The police are currently considering what role they see the police playing in schools in the future. As part of this work, we understand that they will be taking views from stakeholders around their future model of engagement with the education sector. It is believed the ‘SMTF - integrated substance misuse service provision for children and young people’ will have a positive effect on children, young people and their families to help mitigate any potential impacts.

The SMTF aims to ensure they receive the right support at the right time in the right place, improving better outcomes for them, their families and wider communities.

Implementing the main recommendations within the SMTF should see:

• all services for children and young people provide an inclusive and adaptive service for all those aged up to 25 years
• implementation of an electronic unified and modular assessment tool across services in Wales working with children and young people aged up to <25
• development of comprehensive specialised intervention services delivered by creating a single agency, or bringing together separate agencies, to act as a single entity to support those with multiple or complex vulnerabilities including substance use, mental health and learning difficulties or risk of offending and reoffending aged 15 to 25 years

How does your proposal enhance or challenge children’s rights, as stipulated by the UNCRC articles and its optional protocols? Please refer to the UNCRC articles to see which ones apply to your own policy.

UNCRC articles or optional protocol, Article 3

All organisations concerned should work towards what is best for the child.

Enhances (X)

X

Challenges (X)

None.

Explanation

Substance misuse is a major health issue which affects individuals, families and communities. The SMTF provides guidance to help providers design and deliver high quality, sustainable and equitable prevention and treatment services for those at risk of or experiencing substance misuse issues.

Providing early engagement aims to delay or reduce the likelihood of young people moving from ‘using’ to ‘misusing’ substances, limiting the harms associated with use, and avoiding progression to dependency.

Tacking substance misuse needs commitment from across government and key partners delivering frontline services to ensure we reach and support everyone who is in need so that they get the right level of support, at the right time and in the right place.

UNCRC articles or optional protocol, Article 6

All children have the right of life. Governments should ensure that children survive and develop healthily.

Enhances (X)

X.

Challenges (X)

None.

Explanation

There is an increasing body of international evidence about the negative long-term impact on health and well-being outcomes which can result from exposure to childhood trauma before the age of 18. The evidence also links exposure to Adverse Childhood Experiences (ACEs) to an increased risk of adopting health harming behaviours in adolescence, including substance misuse. Substance misuse is therefore both an issue and risk factor.

Children of those affected by ACEs are at increased risk of exposing their own children to ACEs, creating a cycle of harm, which early intervention needs to focus on breaking.

The SMTF aims to delay or reduce the likelihood of young people moving from ‘using’ to ‘misusing’ substances, limiting the harms associated with use, and avoiding progression to dependency.

UNCRC articles or optional protocol, article 12

Children have the right to say what they think should happen, when adults make decisions that affect them, and to have their opinions taken into account.

Enhances (X)

X.

Challenges (X)

None.

Explanation

All people accessing substance misuse services should have their views considered as part of treatment and care planning these principals are set out in the 'Orange book of clinical guidelines'.

UNCRC articles or optional protocol, Article 19

Governments should ensure that children are properly cared for, and protect them from violence, abuse and neglect by their parents or anyone else who looks after them.

Enhances (X)

X.

Challenges (X)

None.

Explanation

We know through the work on ACEs, as indicated above, that children who are raised in homes where substance misuse is an issue are, potentially, more likely to have adverse outcomes in later life. In light of this, early engagement is needed to delay or reduce the likelihood of young people moving from ‘using’ to ‘misusing’ substances, limiting the harms associated with use, and avoiding progression to dependency.

This SMTF was a key priority in the Welsh Government’s substance misuse delivery plan 2019 to 2022. This delivery plan also states that:

• APBs to ensure that specialist services are available to children and families to provide support
• ensure there are joint systems in place for the early identification and preventative action to help reduce the numbers of children taken into care as a result of substance misuse
• provide accessible, timely services to parents with substance misuse problems so they are helped to keep the family unit together by managing risk
• jointly ensure that services are easily accessible to care experienced children and young people whose lives are affected by substance misuse
• APBs and local authority social services to ensure easy access to dedicated transition services for young people who have substance misuse issues and care experience

UNCRC articles or optional protocol, Article 24

Children have the right to good quality health care and to clean water, nutritious food and a clean environment so that they will stay healthy. Rich countries should help poorer countries achieve this.

Enhances (X)

X.

Challenges (X)

None.

Explanation

The overarching aim of the SMTF is to delay or reduce the likelihood of young people moving from ‘using’ to ‘misusing’ substances, limiting the harms associated with use, and avoiding progression to dependency.

This will help achieve a reduction in the harms caused by drugs and alcohol to the individual and wider society, which includes the deterioration of physical and mental health.

UNCRC articles or optional protocol, Article 33

The government should provide ways of protecting children from dangerous drugs.

Enhances (X)

X.

Challenges (X)

None.

Explanation

The overarching aim of the SMTF is to delay or reduce the likelihood of young people moving from ‘using’ to ‘misusing’ substances, limiting the harms associated with use, and avoiding progression to dependency.

The SMTF notes social and educational measures to protect children from the illicit use of narcotic drugs and psychotropic substances as defined in the relevant international treaties and aims to prevent the use of children in the illicit production and trafficking of such substances.

4. Ministerial advice and decision

The then Deputy Minister for Mental Health and Wellbeing was advised this impact assessment has been completed and that the work is consistent with the requirements of the UNCRC, particularly the articles outlined above.

5. Publication of the CRIA

The CRIA will be published along with the final SMTF on the Welsh Government website as part of the integrated impact assessment.

6. Communicating with children and young people

We have engaged with a range of stakeholders to develop the SMTF and taken into account the views of children and young people. As part of our consultation process and the ongoing monitoring and implementation we will continue seek the views of children and young people both at a regional level, through our APBs, and through national engagement.

7. Monitoring and review

This CRIA was kept under review during the consultation period and has been re-visited prior to publication of the document. Consideration has also been given to this CRIA as a result of Welsh Government ending its contribution to the Wales police schools programme on 31 March 2024. A child friendly version of the SMTF has also been produced.

The Equality Act 2010 puts a responsibility on public authorities to have due regard to the need to eliminate discrimination and promote equality of opportunity. This applies to the process of identification of need and risk faced by the individual child and the process of assessment. No child or group of children must be treated any less favourably than others in being able to access effective services which meet their particular needs. The ‘SMTF - integrated substance misuse service provision for children and young people’ aims to improve service provision for children and young people and is expected to see positive impact on those with protected characteristics.

Protected characteristic or group: age

What are the positive or negative impacts of the proposal?

Positive.

Reasons for your decision (including evidence)

There is an increasing body of international evidence about the negative long-term impact on health and well-being outcomes which can result from exposure to childhood trauma before the age of 18. The evidence also links exposure to ACEs to an increased risk of adopting health harming behaviours in adolescence, including substance misuse. Therefore, substance misuse is both an issue and risk factor.

Children of those affected by ACEs are at increased risk of exposing their own children to ACEs, creating a cycle of harm, which early intervention needs to focus on breaking.

Providing early engagement aims to delay or reduce the likelihood of young people moving from ‘using’ to ‘misusing’ substances, limiting the harms associated with use, and avoiding progression to dependency.

How will you mitigate impacts?

N/A.

Protected characteristic or group: disability

What are the positive or negative impacts of the proposal?

Positive.

Reasons for your decision (including evidence)

Substance misuse is a health and social care issue that affects the whole population of Wales, be it directly or indirectly from all characteristics. The aim of the SMTF will help ensure all service users, regardless of disability, receive the right support at the right time in the right place, improving better outcomes for individuals, their families and wider communities.

How will you mitigate impacts?

N/A.

Protected characteristic or group: gender reassignment

What are the positive or negative impacts of the proposal?

Positive.

Reasons for your decision (including evidence)

The SMTF will not impact gender reassignment. It will support an effective service provision for all children and young people.

How will you mitigate impacts?

N/A.

Protected characteristic or group: pregnancy and maternity

What are the positive or negative impacts of the proposal?

Positive.

Reasons for your decision (including evidence)

It will support an effective service provision for all children and young people.

How will you mitigate impacts?

N/A.

Protected characteristic or group: race

What are the positive or negative impacts of the proposal?

Positive.

Reasons for your decision (including evidence)

It will support an effective service provision for all children and young people.

How will you mitigate impacts?

N/A.

Protected characteristic or group: religion, belief and non-belief

What are the positive or negative impacts of the proposal?

Positive.

Reasons for your decision (including evidence)

It will support an effective service provision for all children and young people.

How will you mitigate impacts?

N/A.

Protected characteristic or group: sex or gender

What are the positive or negative impacts of the proposal?

Positive.

Reasons for your decision (including evidence)

It will support an effective service provision for all children and young people.

Protected characteristic or group: sexual orientation (lesbian, gay and bisexual)

What are the positive or negative impacts of the proposal?

Positive.

Reasons for your decision (including evidence)

It will support an effective service provision for all children and young people.

How will you mitigate impacts?

N/A.

Protected characteristic or group: marriage and civil partnership

What are the positive or negative impacts of the proposal?

Positive.

Reasons for your decision (including evidence)

It will support an effective service provision for all children and young people.

How will you mitigate impacts?

N/A.

Protected characteristic or group: children and young people up to the age of 18

What are the positive or negative impacts of the proposal?

Positive.

Reasons for your decision (including evidence)

The SMTF will have a positive impact on children and young people by providing early intervention so that longer-term harms are prevented, before they occur. This includes preventing exposure to ACEs.

How will you mitigate impacts?

N/A.

Protected characteristic or group: low-income households

What are the positive or negative impacts of the proposal?

Positive.

Reasons for your decision (including evidence)

The SMTF will support children and young people of all households, including low-income households, and the further impacts due to the cost-of-living crisis. There is a wealth of evidence that shows education and employment is vital to good mental health whilst unemployment leads to a deterioration in health and well-being.

Completing education and finding employment can be a hugely important step to recovery, improving self-esteem and confidence, and reducing stress and anxiety.

How will you mitigate impacts?

N/A.

Human rights and UN conventions

The ‘SMTF - integrated substance misuse service provision for children and young people’ is expected to have a positive impact on human rights.

The SMTF supports the substance misuse delivery plan 2019 to 2022 and will help achieve PfG commitments in relation to:

• providing additional specialist support for children with complex needs who may be on the edge of care
• exploring radical reform of current services for looked after children and care leavers
• prioritising service redesign to improve prevention, tackle stigma and promote a no wrong door approach to mental health support
• reforming primary care, bringing together GP services with pharmacy, therapy, housing, social care, mental health, community and third sector
• delivering better access to doctors, nurses, dentists and other health professionals

The ‘SMTF - integrated substance misuse service provision for children and young people’ is considered to be compatible with the European Convention on Human Rights. Specifically, to the reduction of drug and alcohol related deaths in line with 'Article 2: the right to life’, and there are actions to encourage people into work and education in line with 'Protocol 1, Article 2: The right to education'.

EU/EEA and Swiss citizens’ rights

Having considered the ‘SMTF - integrated substance misuse service provision for children and young people’ there are no direct impacts on EU/EEA and Swiss citizens’ rights.

Cymraeg 2050 is our national strategy for increasing the number of Welsh speakers to a million by 2050.

The Welsh Government is fully committed to the new strategy, with the target of a million speakers included in its programme for government. A thriving Welsh language is also included in one of the 7 well-being goals in the Well-being of Future Generations (Wales) Act 2015.

We also have a statutory obligation to fully consider the effects of our work on the Welsh language. This means that any Welsh Government policy should consider how our policies affect the language and those who speak it.

The Cymraeg 2050 strategy has three interrelated themes:

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Welsh language standards placed on the Welsh Government requires it to give full consideration when making policy decisions to any potential impact on the Welsh language, in all policy areas, in order to ensure more robust policies which are in line with the aspiration of having a million Welsh speakers by 2050. It also ensures that there are no unintentional consequences to the Welsh Government’s policies and no harmful impacts on the Welsh language.

Questions regarding the impact of the policy on the Welsh language were also asked as part of the formal consultation process and feedback from those has been incorporated into the SMTF, strengthening the paragraphs relating to the Welsh language.

The SMTF clearly references the Welsh Language (Wales) Measure 2011 and the Welsh language's strategy - Cymraeg 2050. The services outlined in the SMTF should comply with their legal duties in relation to the Welsh language and ensure that the Welsh language is treated no less favourably than the English language.

The SMTF supports key priorities within the substance misuse delivery plan 2019 to 2022 (which was revised in 2021 to take account of COVID-19; APBs and stakeholders are currently still working to this plan), and one of the outcomes is to ensure that ‘Welsh speakers and their families are able to receive support for substance misuse issues through their own language’.

The services outlined in the SMTF should comply with their legal duties in relation to the Welsh language and ensure that the Welsh language is treated no less favourably than the English language. They should also ensure that support is actively offered through the medium of Welsh.

No adverse impacts on the Welsh language have been identified by officials. The SMTF encourages the use of the Welsh language, numbers of Welsh speakers or the sustainability of Welsh speaking communities.

The SMTF references Cymraeg 2050 and notes the importance of recognising the concept of language need. Receiving services in Welsh, especially when people are at their most vulnerable should be an integral component of person-centred care. The SMTF references the Welsh Government’s strategic framework ‘more than just words’ and its aim to strengthen Welsh language provision in health and social care and to support Welsh-speakers to receive services in their first language.

In addition, the workforce strategy for health and social care refers to Welsh language and includes actions for improving the Welsh language skills of the workforce.

What evidence has been considered to understand how the proposal contributes to inequalities of outcome experience as a result of socio-economic disadvantage?

Substance misuse is strongly linked to poor health outcomes, adverse childhood experiences, poverty and early mortality.

Deprivation and disadvantaged groups

The burden of deaths from both drug misuse and alcohol falls most heavily on deprived communities. In 2021 Wales along with the rest of the UK recorded the highest level of alcohol specific deaths.

The relationship between level of deprivation and individuals in Wales admitted to hospital in relation to alcohol or illicit drugs in 2022 to 2023 are clear. The proportion of all patients admitted for alcohol-specific conditions who lived in the 10 per cent of most deprived areas was 2.9 times higher than those from the least deprived areas. Amongst those admitted for conditions related to use of illicit drugs, the contrast was even more striking - admissions were 7.4 times higher amongst those from the most deprived areas compared to least deprived, perhaps reflecting the additional contribution of factors including criminalisation on deprivation and the associated impact on health and risk behaviours. The extreme health inequity identified demands intensive cross-sectoral policy and service action to prevent exclusion and improve health outcomes in individuals who are already marginalised.

Children, young people and families

Substance misuse is a significant factor in child protection proceedings and frequently cited as factor for those children “on the edge of care”.

In 2021 to 2022 there were 17,190 children receiving care and support in Wales, up from 16,675 in 2020 to 2021, an increase of 3.1per cent. Of these, there were 4,960 children, 28.9 per cent, with parental substance misuse listed as a factor in their referral (up from 30.9 per cent in 2021).

As at 31st of March 2022, there were 630 children receiving care and support where their own substance misuse was identified as a problem, representing 3.7 per cent of all children receiving care and support, where data were available.

Adverse Childhood Experiences (ACEs)

There is an increasing body of international evidence about the negative long-term impact on health and well-being outcomes which can result from exposure to childhood trauma before the age of 18. The evidence also links exposure to ACEs to an increased risk of adopting health harming behaviours in adolescence, including substance misuse. Therefore, substance misuse is both an issue and risk factor. Children of those affected by ACEs are at increased risk of exposing their own children to ACEs, creating a cycle of harm, which early intervention needs to focus on breaking.

Whilst being able to prevent substance misuse in the first place is a top priority, we recognise the importance of also taking action to reduce the negative impact of substance misuse and improve the positive outcomes for all those affected.

The aim is to ensure that resources are directed to equitable, effective and cost-effective services and through integration of wider economic and social policies by working across government and the wider public sector. Services should be designed to meet the needs of individuals and the communities they serve and ensure they are accessible to all regardless of background or circumstances.

COVID-19 pandemic

Many children, young people and families are already severely impacted by both the economic impacts but also through the consequences of lockdowns with the inevitable loss of support and schooling. We know these impacts will be felt, hardest and disproportionately, by the most deprived communities and those living in poverty.

The SMTF advises services are required to provide a developmentally sensitive, holistic and an integrated multi-disciplinary, multi-agency response that is culturally appropriate and centred on the young adults’ needs, of which substance misuse is one.

The SMTF also suggests a national ‘professional competencies framework’ should be agreed for multi-disciplinary professionals supporting children and young people up to the age of 25 (and their families) using substances. This framework should include ‘basic wellbeing and resilience that recognises and responds appropriately to cultural sensitivities such as LGBTQ+, ethnic minority, ACEs, homelessness, poverty and trauma informed approaches’, amongst other things.

Data mining Wales: The annual profile for substance misuse 2021 to 2022.

How could the proposal potentially further exacerbate inequality of outcome experienced as a result of socio-economic disadvantage?

The SMTF aims to reduce the inequalities noted above, improving outcomes of those who are socio-economically disadvantaged.

How could the decision potentially improve outcomes for those who experience socio-economic disadvantage?

The SMTF sets out recommendations to improve service provision for children and young people. Improved outcomes in relation to substance use and misuse can only be achieved through early and credible engagement, integrated assessment and joint working with a harm reduction and needs-based approach.

Providing targeted educational interventions, prevention and treatment services for children and young people are key components of safeguarding and improving their health and wellbeing. Providing effective engagement and interventions with integrated and bespoke support in the earlier years and up to the age of 25 will reduce the population of individuals developing life-long substance misuse issues and the inherent harms associated with entrenched use. The SMTF should therefore see improved outcomes for all children and young people.

How will you monitor the impact of this decision?

The Welsh Government, health boards, substance misuse APBs, criminal justice, local authorities and third sector organisations will be responsible for ensuring delivery of this SMTF for children and young people.

Does new monitoring information need to be collected? If so, what?

The Welsh Government is currently developing a substance misuse outcomes framework and monitoring needs will be fully considered as part of this process.