Section three The NPM in 2015–16 Submitting proposals and observations on legislation (OPCAT article 19(c)) NPM members work actively to strengthen government policy that is relevant to the detention settings they monitor and to their own functions. In addition, this year the NPM coordination submitted brief comments to the Law Commission’s consultation on Mental Capacity and Deprivation of Liberty. Members’ involvement in consultations and the development of government policy included the following: • Ofsted, CCE and HMI Prisons made significant contributions to the Ministry of Justice review of youth justice, bringing their inspection evidence and experience to bear with the review team. This included recommendations to move towards the decommissioning of young offender institutions for children and a reorientation of the ethos of secure training centres. • These organisations also engaged with the Medway Improvement Board, with a view to informing the Board’s work and its final report to the Secretary of State. • CCE and HMI Prisons both commented on a consultation about a reduction of the Youth Justice Board’s budget, which had implications for the commissioning of custodial facilities for children and the roll out of a new system for restraint. • CQC gave input to the Department of Health on the Policing and Crime Bill 2015–16, which contains a number of changes to the powers under sections 135 and 136 of the Mental Health Act 1983, including banning the use of police cells for the detention of under-18s and reducing the maximum period of detention. • The CI contributed to a number of consultations relevant to secure settings and deprivation of liberty within the last year, including: Community Justice Scotland (Bill) Call for Evidence (August 2015); Proposals for the creation of an offence of wilful neglect or ill-treatment with regard to services for children under the age of 18; Consultation on working together for people who go missing in Scotland (November 2015); Consultation on the Scottish Law Commission Report on Adults with Incapacity (March 2016); Consultation on the Protection of Vulnerable Groups (Scotland) Act 2007: Sections 35(2) and (3), (March 2016); Consultation on the implementation of the Mental Health (Scotland) Act 2015 and Associated Regulations (Part 1), (May 2016); Consultation on Children and Young People (Scotland ) Act 2014: Part 1, Children’s Rights Reporting and Part 3 Children’s Services Planning ( June 2016); Review of learning disability and autism in Scottish mental health law – a scoping consultation ( July 2016). In its response to a consultation on further extension of coverage of the Freedom of Information (Scotland) Act 2002 to more organisations in September 2015, the CI agreed with the proposals to extend freedom of information coverage to privately managed prisons subcontracted to carry out work for the Scottish Prison Service, and to all five current secure accommodation services for children. • HMIPS contributed to the Scottish Government consultation on the presumption against short sentences, supporting the extension of the presumption for sentences up to 12 months. 33