NHS boards play a crucial role in addressing the ethnicity pay gap. This section outlines how NHS leaders can drive meaningful change, considering the unique context of the health service and its regulatory environment.
NHS boards must operate within the following legal and regulatory context:
- Equality Act 2010
- Public Sector Equality Duty (PSED)
- NHS Standard Contract requirements
- Care Quality Commission (CQC) Well-Led framework
Boards need to understand their obligations in relation to the above and how they relate to addressing the ethnicity pay gap. Key areas for consideration include:
Maintain strategic oversight
- Set a clear vision for diversity and inclusion, integrating it into the organisation's overall strategy.
- Establish Specific, Measurable, Achievable, Relevant and Timely (SMART) measurable goals for reducing the ethnicity pay gap, aligned with the NHS People Plan and the NHS Equality, Diversity and Inclusion (EDI) Improvement Plan (the Plan). The Plan mandates NHS organisations need to "eliminate total pay gaps with respect to race, disability and gender".
- Ensure adequate resources are allocated, considering budget constraints and competing priorities.
Policy development
- Oversee the creation and implementation of inclusive policies ensuring they address NHS-specific challenges (for example clinical vs. non-clinical roles and Agenda for Change pay banding).
- Implement the actions outlined under high impact action (HIA) 2, "overhaul recruitment processes and embed talent management processes" from the Plan.
- Regularly review existing policies to eliminate potential biases, for example salary differences on appointment, promotion etc).
Ensuring accountability
- Implement robust processes and systems to monitor progress, leveraging existing NHS data collection methods (for example the Workforce Race Equality Standard and NHS Staff Survey).
- Hold senior leaders accountable through performance reviews and the implementation of HIA 1 of the Plan, "measurable objectives on EDI for chairs, chief executives and board members".