South African Psychiatry - November 2018

POLICY GUIDELINE
THE SOUTH AFRICAN NATIONAL MENTAL HEALTH ALLIANCE PARTNERS’ RESPONSE TO THE:
POLICY GUIDELINES FOR THE
LICENSING OF RESIDENTIAL AND/
OR DAY CARE FACILITIES FOR
PERSONS WITH MENTAL
ILLNESS AND/OR SEVERE OR
PROFOUND INTELLECTUAL
DISABILITY
Submitted for publication by Dr Lesley Robertson, drafted on behalf of SASOP and the
Mental Health Alliance
As South African citizens and organisations
who are concerned that people living with
mental illness (PLWMI) and/or intellectual
disability (ID) are treated with dignity and
respect in our society, we welcome the initiative
by the National Department of Health (NDOH) to
establish a regulatory process of non-governmental
residential and/or day care facilities (NGOs) for this
vulnerable and marginalised population group.
WE ARE CONCERNED, HOWEVER, THAT
THE GUIDELINES, BEING PUBLISHED IN THE
WAKE OF THE LIFE ESIDIMENI DISASTER,
INAPPROPRIATELY CONFLATE DIFFERENT
TYPES OF SERVICES AND FACILITIES AND
SEEK TO ENSURE THAT NGOS ARE ABLE
TO PROVIDE THE SAME LEVEL OF CARE
AS A CHRONIC CARE FACILITY LIKE LIFE
ESIDIMENI.
This can never be the case and we maintain that a
facility like Life Esidimeni will always be required for
some mental health care users. Some users, however,
can appropriately use community based services
and it is the licensing of these services and this level
of care that the Guidelines should seek to regulate.
In conflating the levels of care, we find the guidelines
to be self-contradictory, not completely relevant to
the role of NGOs, and not implementable. Thus, we
support the press statement made by the South
African Federation of Mental Health on 29 March
and believe that stakeholder consultation was
inadequate.
APPLICATION OF THE GUIDELINES
The Policy Guidelines specify their application is to
facilities which are “not a designated psychiatric
hospital or care and rehabilitation centre” (4.1).
The “group homes, half-way houses, supported
independent living facilities” … and “day care
facilities, include home-based care, protected
workshops and support groups” to which they refer
(4.2) are defined by the guidelines in the context of
a social role in the societal inclusion of PLWMI and/
or ID. Thus, they do not appear to offer a ‘health’,
‘medical’ or ‘psychiatric’ role. In addition, the IUSS
norms and standards for mental health (2.4) states
that these facilities should be ‘homely’ and make no
infrastructure requirements for hospital type care.
Nevertheless, the guidelines seem to subsume all
support services for PLWMI under a healthcare
framework, reflecting an inappropriately medicalised
understanding of mental health and disability and
ignoring the intersectoral nature of communitybased
support. This is at odds with the recovery
model and principles of inclusion which underpin the
Mental Health Strategic Framework, the Framework
and Strategy on Disability and Rehabilitation, and
not least, the United Nations Convention on the
Rights of Persons with Disabilities, which South Africa
has ratified.
86 * SOUTH AFRICAN PSYCHIATRY ISSUE 17 2018