nhs west lancashire clinical commissioning ......2016/09/27 · nhs west lancashire clinical...
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NHS WEST LANCASHIRE CLINICAL COMMISSIONING GROUP
GOVERNING BODY MEETING
27 September 2016, 9.30 – 11.30 am
Evermoor Community Hub, 1 Birleywood, Skelmersdale, WN8 9HR
15 minutes to be allocated for questions from members of the public based on agenda items. Item WLCCGB Time Agenda item Action Presenter
09/16/1 9.30 Welcome Chair 09/16/2 9.35 Declaration of Interests All 09/16/3 9.40 Minutes of previous meeting held on 26 July 2016 DR Chair 09/16/4 9.45 Matters arising - Action sheet DR Chair Communication 09/16/5 9.55 Chair’s update I Chair 09/16/6 10.05 Chief Officer’s update I Mike Maguire Governance 09/16/7 10.15 BAF and risk register I Paul Kingan Operational Management Section 09/16/8 10.30 Integrated business report D Paul Kingan 09/16/9 10.45 Process for managing individual funding requests DR Claire
Heneghan 09/16/10 10.55 EPPR statement of compliance I Mike Maguire 09/16/11 11.00 Conflict of interest policy DR Paul Kingan Consent items 09/16/12 11.15 Minutes of sub-committees:
- Quality and Safety Committee – July 2016 - Executive Committee – 12 July – 8 September 2016
Other minutes: - System Resilience Group – June 2016 - Lancashire Health and Wellbeing Board – June 2016
I
Chair
Other Business 09/16/13 11.25 Any other business I Chair Date and Time of Next Meeting – 29 November 2016, 9.30 – 11.30 am, Boardroom, Hilldale
I – Information D-Discussion DR – Decision Required
Members of the governing body will be available after the close of the meeting for
informal discussion, time permitting
West Lancashire Clinical Commissioning Group Governing Body meeting – 26 July 2016 Page 1 of 7
Minutes D R A F T
Meeting Title: West Lancashire Clinical Commissioning Governing Body Meeting
Date: 26 July 2016
Time: 9.30 – 11.30 am Venue: The Boardroom, Hilldale, Ormskirk
Present: Greg Mitten, Vice-Chair / Lay Member Paul Kingan, Chief Finance Officer/Deputy Chief Officer Douglas Soper, Lay Member Dr Adam Robinson, Secondary Care Consultant Dr John (Jack) Kinsey, GP Executive Lead Dr Rakesh Jaidka, GP Executive Lead
In attendance: Cathy Ashcroft, Executive Assistant Ian Crabtree, Head of Services Policy Information and Commissioning, Lancashire County Council Sakthi Karunanithi, Director of Public Health and Wellbeing, Lancashire County Council Sheralee Turner-Birchall, Chief Officer, Healthwatch Lancashire
Apologies: Dr John Caine, Chair Mike Maguire, Chief Officer Claire Heneghan, Chief Nurse Dr Bapi Biswas, GP Executive Lead Dr Vikul Mittal, GP Executive Lead Dr Peter Gregory, GP Executive Lead Jackie Moran, Head of Quality, Performance and Contracting (in attendance)
Agenda
Item WLCCGB/
Summary of Discussion Action
07/16/01 Welcome and apologies for absence The meeting of the West Lancashire Clinical Commissioning Group Governing Body was opened by Greg Mitten, Vice-Chair, in the absence of Dr John Caine. Introductions were made to the members of the public present. No questions had been received from the public in respect of the agenda.
07/16/02 Declarations of interests No declarations were made which were pertinent to the agenda.
07/16/03 Minutes of previous meeting held on 24 May 2016 The minutes of the meeting held on 22 March were agreed as an accurate and correct record with one minor type correction. The governing body: approved the previous minutes.
07/16/04 Matters arising The action sheet was updated.
COMMUNICATION 07/16/05 Chair’s update
The report provided members with an update on both strategic and operational issues since the last meeting. Greg Mitten highlighted key areas of interest: • Urgent care – following a reconfiguration, the Ambulatory Emergency
Care Unit had moved to Southport and Ormskirk Hospital NHS Trust. The unit now contains more bays and a new phone line for GPs to contact clinicians on the unit during daytime hours. In Cheshire and Mersey, an Ambulance Turnaround concordat has been developed which
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aims to reduce ambulance delays. Discussions concerning relatively poor local blue light performance continue with the lead commissioner of the ambulance service.
• MacMillan programme – Dr Simon Frampton has been appointed to lead the local Macmillan programme that supports West Lancashire patients, families and carers in living beyond cancer. Dr Jack Kinsey, was thanked for his work in starting the project. A Macmillan Cancer Information and Support Centre will be opened in the community in 2016. The Move More physical activity had been presented to the Membership Council.
• Medicines waste campaign – the CCG is looking to reduce medicines waste through a campaign which is supported by the Membership Council. Nicola Baxter, head of medicines optimisation, will lead the campaign and an action plan will be presented at a future Governing Body meeting. Patients will be encouraged to order their own medicine and ways of supporting those patients without the capability to do so must be considered carefully.
The governing body: Noted the content of the report
07/16/06 Chief Officer’s update The report provided members with an update on both strategic and operational issues since the last meeting. Paul Kingan highlighted key areas of interest: • House of Commons – two members of the CCG were invited to attend
the All Party Parliamentary Group in acknowledgement of the fantastic work taking place in cancer survival rates.
• Community health services procurement – the process continues with competitive dialogue discussions taking place with providers for community and urgent care services. The plan is for the successful bids to be awarded in Autumn and start delivering services in April 2017. The process is subject to national procurement guidance ensuring it is open to public and private providers to compete to deliver the services. More information is available on the CCG website. Providers who have contacted Lancashire County Council have been provided with a standard information pack regarding the services available in West Lancashire. The CCG will ensure that engagement with the public continues and that Healthwatch services are being utilised. The CVS has also provided regular updates through their Health Network events. Some vendor due diligence information has not been received from Southport and Ormskirk NHS Trust. The CCG is chasing this information. Members stressed the need for the procurement process to have adequate time for both the preparation and full consideration of bids. The decisions around the future provision of these services was critical to the future of local Healthcare Provision and therefore the Governing Body needed assurance around both the Value for Money and the quality of services to be provided.
• Transfer of Calderstones – in July the organisation transferred to Merseycare NHS Foundation Trust.
• Well Skelmersdale – collaborative work continues following Skelmersdale’s successful selection as a Well North pathfinder site. Mike Maguire is involved in looking at ways to develop Skelmersdale. A further update will be available at the meeting in September. Links have been made with Lancashire County Council.
• Sustainability and Transformation Plans (STP) – NHS England are keen to working together to implement collaboration at scale to address the gaps in health and wellbeing, care and quality, and finance and
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efficiency. The CCG is a full member of the Lancashire and South Cumbria STP (focussing on ‘out of hospital’ workstreams) and is an associate member of the Cheshire and Mersey STP (focussing on sustainability of Trusts). A draft plan submitted to NHS England at the end of June will be refined and return for approval by the CCG possibly to the September meeting. Discussion continued about the current NHS provider market and pressures of individual high cost cases. Health prevention will be paramount and will be developed through leadership and self-care in neighbourhoods. Public health input will be beneficial, as demonstrated in the recognition of cancer survival rates in West Lancashire, with investment in community centres and to link in with the Voluntary Community Faith Sector.
• CCG Annual Assessment by NHS England – NHS England have published the results of the assessment for the 209 CCGs for the Financial Year 2015/16. West Lancashire CCG was assessed as good across the range of categories and only 13 CCGs were assessed higher as outstanding. This reflects the hard work of the CCG team and stakeholders in West Lancashire. The oversight and monitoring of quality and Well North was commended.
The governing body: Noted the content of the report
GOVERNANCE 07/16/07 Board Assurance Framework and Risk Register
The Board Assurance Framework (BAF) is a key part of the CCG’s governance arrangements. The CCG risk register has been reviewed to reflect the up to date position. The BAF now includes all risks scoring 12 and over. There are 12 risks which have been placed on the BAF and Paul Kingan highlighted the three most recently added which are: Risk 50 – this relates to the case management arrangements for those individuals who may have been subject to domestic deprivation of liberty (DoL). A health and quality lead has been appointed and a working group established to put in place measures to ensure risks are mitigated. Risk 51 – there are limited quality assurance arrangements around the domiciliary health packages of care. A paper to the Collaborative Commissioning Forum will highlight the risk and agree future actions. Risk 42 – the failure to achieve financial balance 2016-17. This is a common risk for most NHS organisations. An ongoing review of the financial position will continue. A regulated care workstream within the Lancashire and Cumbria STP will look to manage the future for care home packages. The governing body noted the report and were assured that reasonable efforts were being made to manage those High Level risks appearing on the Board Assurance Framework
OPERATIONAL MANAGEMENT SECTION 07/16/08 Integrated Business Report (IBR)
The report provided summary information on the financial position and activity performance of the CCG to May and the financial positon for June 2016. It also included quality and performance analysis for community based targets for Southport and Ormskirk Hospital NHS Trust. Paul Kingan highlighted some key areas within the report:
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• The CCG is on track to meet its financial duties this year. However, it is early in the year and if all possible risks occur this will adversely affect the position significantly. NHS England are aware of the level of net financial risk for the CCG.
• Planned care – is currently under plan compared with the same period last year.
• Unplanned care – there has been significant overperformance with Wrightington, Wigan and Leigh and Ramsay Healthcare in the first few months.
• At this point in time the CCG is overspent, with almost 50% of its 0.5% contingency reserve being utilised. If all the reserve is used, evasive action would need to take place. This is a similar position for other CCGs.
• Referrals – there is little change from this period last year for GP referrals. Other referrals have increased slowly and will continue to be monitored.
• Prescribing – there has been an increase of 10% from same time last year. The finance team are looking at this carefully.
A new prescribing system called Optimize should result in some savings. GPs are pleased with the new system. A discrepancy was raised around the level of the e-referrals which varied depending on which monitoring data was used ie. SUS data or monthly activity report. This will be checked and returned to the next meeting. A national increase of 40% in nursing home rates for patients in funded nursing care will result in an increase of approximately £400,000 for the CCG. NHS England have stated that a reduction in category M prescribing costs later in the year may mitigate some of this pressure. This information about the increase in funded nursing care will be shared with Ian Crabtree. No additional funding is available for the increased cost and it was suggested that the 1% (£1.5m) which the CCG are required the ring-fence be used to cover this risk. However, the CCG must currently progress without accessing the fund. The Governing Body requested the Quality Innovation Productivity Prevention (QIPP) savings programme be populated with leads for the schemes and what is going to be delivered. The QIPP information is being uploaded to Aspire, a new toolkit. To ensure the internal mechanisms are robust around finance and QIPP a standing item should be included on the Executive Committee agenda with input from the scheme leads. Scrutiny of finances is prominent in terms of Right Care, which demonstrates how CCGs are different in terms of their spends. The highlights of the performance section of the report were presented: • A target of over 95% is being achieved in Improved Access to
Psychological Therapies. • 18 week waiting times are currently at 96% at Southport and Ormskirk
Hospital NHS Trust and are amongst the lowest in the country. Credit was given to the Trust on this achievement.
• Infections – MRSA and C. Difficile are on target. • Cancer – there are still issues for patients receiving treatment at the
correct time. A root cause analysis is taking place. • Ambulance – there are plans at the Trust to improve flow to assist
Ambulance turnaround times at A&E. Stakeholders at the Collaborative Commissioning Forum (CCF) continue to
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West Lancashire Clinical Commissioning Group Governing Body meeting – 26 July 2016 Page 5 of 7
meet with partner CCGs, the CQC and NHS England with meeting minutes shared at the Quality and Safety Committee. The CCF are focussing on the delay in the Trust producing the overarching action plan. An audit report on quality, which was reviewed in November 2015, had received limited assurance. Improvements had been achieved to date with any quality issues being escalated where appropriate. The governing body: Noted the performance to date and the actions in place to improve performance.
07/16/9 Budget paper The paper provides an update on how the CCGs 2016-17 financial plan translates to operational budgets. There is an overall increase in the allocation of £334,000 which relates to specialist wheelchairs and eating disorders. The control total has increased with all changes to budget lines explained in the paper. In response to questions it was confirmed that currently negative budgets will be allocated to the other budget lines in the near future to reflect the value of current QIPP savings schemes, for example £265,000 additional QIPP savings are required in the prescribing budget The governing body: approved the revised budgets.
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07/16/10 Annual public health – Securing our Health and Wellbeing Sakthi Karunanithi presented the report which would be presented at all Governing Body meetings within Lancashire. The report examines the whole health agenda including community, outcomes and finances. There are three main issues: we have been adding years to our lives but not necessarily life to our years; addressing health inequalities needs action across the social gradient and not just deprived areas; and, protecting and promoting good health is not just a social issue but also crucial for the local and national economy. The average healthy life expectancy is 65 years across Lancashire, but babies born now will be working to 68 years. The funding cuts to the local authority and absence of future increases mean that funding will not meet the needs of the changing demography. Quality and finances are being stretched both locally and nationally. It is estimated that around 40% of morbidity across the country is due to lifestyle. Care for complex patients’ costs £80,000,000 across the county for approximately 400 people. The resulting funding gap will not allow services to be delivered as they are and therefore there is more emphasis on local communities to improve lifestyle. A multi-agency group is required to look at health and social issues together with solutions delivered in local communities at a lower cost. There is a need for collaborative working with leads on areas for the whole of Lancashire, not just the local area. The report findings do reflect the work taking place in West Lancashire, but further study will take place to ensure projects are aligned. Kathryn Kavanagh is the link between the CCG and local authority. In response to a question about the senior staff who remain at the council dealing with infection disease outbreaks, it was confirmed that resources are adequate with an NHS England team based in the council building and two more infection prevention nurses have been employed.
West Lancashire Clinical Commissioning Group Governing Body meeting – 26 July 2016 Page 6 of 7
The governing body: noted the content of the report.
07/16/11 Declaration of Interest Revised national guidance on Conflict of Interests had recently been published which will require significant work to implement the changes in a short timescale. The Governing Body were asked to familiarise themselves with the policy. The changes will also require amending the constitution, training for staff, more detailed actions recorded when a conflict is raised. A revised draft policy should be presented at the Audit Committee in September before consideration by the Governing Body
07/16/12 Healthier Lancashire Terms of Reference Healthier Lancashire are setting up a Joint Committee of Clinical Commissioning Groups (JCCCGs) and CCG Governing Bodies are requested to approve the committee’s revised draft terms of reference (ToR). Once the decision has been made and noted, the inaugural meeting of the joint committee will be arranged. Gerard Hanratty from Capsticks Solicitors LLP had been advising the Lancashire CCGs. Eight CCGs will form the JCCCGs, but more could be added by NHS England. The ToR state that each CCG has an equal vote and recommendations will only be approved by more than 75%. A working group will take forward decisions. The ToR will require changes to the constitution to reflect this joint working. A committee chair is yet to be appointed and a list of Trusts (hospitals in Lancashire) will be added to the ToR which will remain in draft. The implications and risks were discussed in addition to the changes to the constitution in terms of model clauses, on which advice will be available. It was agreed the two voting representatives to be included on the JCCCGs are: Paul Kingan, deputy chief officer / chief finance officer and Doug Soper, lay member for governance. The governing body: • Considered and agreed the revised draft JCCCGs ToR and noted the
amendments. • Noted the ToR and the notes on creating the JCCCGs which offers
definitions and an explanation which remain draft, but these are not detrimental to establishing the JCCCGs.
• A minute of the decision and a list of the names of the voting representatives to be included on the JCCCGs and will allow a first meeting to be called.
• To take the necessary steps required in relation to the actions to amend the CCG constitution (where necessary)
CONSENT ITEMS 07/16/13 Minutes of sub-committees:
The minutes from the following meetings were noted by the Governing Body: - Quality and Safety Committee – June 2016 - Audit Committee – May 2016 - Executive Committee – 10 May to 5 July 2016
Other minutes: - System Resilience Group – May and June 2016 - Lancashire Health and Wellbeing Board – April 2016
West Lancashire Clinical Commissioning Group Governing Body meeting – 26 July 2016 Page 7 of 7
The governing body: Noted the papers. Other business 07/16/14 Any other business
None raised.
Meeting closed at 11.43 am Date and time to next meeting: 27 September 2016, 9.30 – 11.30 am, Evermoor Community Hub, 1 Birleywood, Skelmersdale, WN8 9HR. The Annual General Meeting will take place at the venue on this date.
Page 1 of 2
Agenda item no: WLCCGB 09/16/4
West Lancashire CCG Governing Body meeting Action sheet
Action Lead Date required by Action completed 07/16/08 Integrated Business Report (IBR) A discrepancy was raised around the level of the e-referrals which varied depending on which monitoring data was used ie. SUS data or monthly activity report. This will be checked and returned to the next meeting.
A national increase of 40% in nursing home rates for patients in funded nursing care will be shared with Ian Crabtree. The Governing Body requested the Quality Innovation Productivity Prevention (QIPP) savings programme be populated with leads for the schemes and what is going to be delivered.
Paul Kingan
Paul Kingan
Paul Kingan
27 September 2016
27 September 2016
27 September 2016
07/16/09 Budget paper In response to questions it was confirmed that currently negative budgets will be allocated to the other budget lines in the near future to reflect the value of current QIPP savings schemes,
Paul Kingan
27 September 2016
01/16/10 Integrated Business Report (IBR) Ambulance turnaround time - A letter will be sent to NWAS to highlight the delays in ambulance turnaround times with regards to a specific incident. Also, to ask if the number of calls for ambulances to A&E has increased since 111 commenced.
Paul Kingan
27 September 2016
Monitoring continues on the impact of 111 on A&E attendance levels. This information will be added to the IBR.
Page 2 of 2
The 111 response form was felt to be inadequate. Charlotte McAllister will email GPs to inform them their feedback on 111 can be sent to [email protected] and copy the CCG for records.
Charlotte McAllister
27 September 2016 GPs feedback patient’s experience of
calls to 111. Discussed feedback escalated to national contracts. The data and themes will be presented in the IBR
in September.
05/16/07 Chief Officer’s update – Better care fund Ian Crabtree confirmed that the disabled facilities grant has doubled this year to £10 million. The fund is used to make changes for the community via the district council. The allocation for West Lancashire will be identified and shared. Ian Crabtree will also establish if the funding has increased to address a backlog of work.
Ian Crabtree
27 September 2016
The Department of Social Security are aware of the disabled facilities grant, but the publics’ awareness was questioned. Ian Crabtree will enquire in the council
and provide a briefing which can be circulated via the CCG GP newsletter.
A poster will be provided for practices to inform all patients of the grant.
05/16/09 Integrated Business Report (IBR) The IBR report will be refreshed and Paul Kingan would be pleased to receive any comments or suggested changes. There was discussion around e-referral performance as part of the quality premium. Paul Kingan will report back to the governing body.
All
27 September 2016
A new business analyst will redesign the IBR in September. Views are welcome from members, staff etc. The Quality
and Safety Committee found the current IBR to be timely and consistent. Action will continue to be taken in respect of
data and lessons learned will be shared. A new member of the committee
provides input on infection control items in the IBR.
Paul Kingan
27 September 2016 Performance of e-referrals in the IBR is
on track to deliver the target by March. Two different ways of scoring produce
two different results.
Chair’s Update West Lancashire Clinical Commissioning Group Governing Body Meeting – 27 September 2016
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Agenda number: WLCCGGB 09/16/5
WEST LANCASHIRE CLINICAL COMMISSIONING GROUP GOVERNING BODY REPORT
DATE OF BOARD MEETING: 27 September 2016 TITLE OF REPORT: Chair’s Update BRIEFING POINTS:
Does this report / its recommendations have implications and impact with regard to the following:
A. Commissioning Board’s Aims and Objectives 1. Quality (including patient safety, clinical effectiveness and patient
experience) – please outline impact No
2. Commissioning of hospital and community services – please outline
impact
No
3. Commissioning and performance management of GP Prescribing –
please outline impact Yes
4. Delivering Financial Balance – please outline impact No 5. Development of the commissioning group as a commissioning
organisation – please outline impact
Yes
B. Governance – 1. Does this report:
• provide the Commissioning Board with assurance against any of the risks identified in the assurance framework (identify risk number)
• have any legal implications • promote effective governance practice
Yes
2. Additional resource implications
(either financial or staffing resources) No
3. Health Inequalities No
4. Human Rights, Equality and Diversity Requirements No
5. Clinical Engagement
Yes
6. Patient and Public Engagement Yes
REPORT PREPARED BY: Meg Pugh, head of communication and engagement
REPORT PRESENTED BY: Dr John Caine, chair
Chair’s Update West Lancashire Clinical Commissioning Group Governing Body Meeting – 27 September 2016
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WEST LANCASHIRE CLINICAL COMMISSIONING GOVERNING BODY CHAIR’S UPDATE
PURPOSE
This report provides an update on both strategic and operational issues of interest to governing body members in the months since the last meeting. ISSUES ARISING URGENT CARE 1. NHS England has set 5 urgent care priority areas for the NHS in England. To ensure
these priorities are met A&E Boards will be formed to oversee the delivery of the priorities locally. West Lancashire CCG will join other CCGs and trusts to form the North Mersey A&E Board, which will be chaired by Aiden Keogh from Aintree Trust.
2. The 5 priorities are: - Streaming at the Front Door - Increasing NHS 111 calls that go to a clinical advisor - Ambulance services - Patient Flow - Discharge
3. A new EMS data service has been trialled throughout the Summer. The system sends updates throughout the day on the status of A&E so that Trust and CCG staff are kept up to date with any system pressures.
PRIMARY CARE DEVELOPMENT 4. Ernst & Young has been supporting the Healthier Lancashire programme by undertaking
a piece of work around Primary Care Development within West Lancashire.
5. In early September, all West Lancashire GPs and practice managers were invited to attend and the findings were presented covering the key areas of focus:
- Supporting general practice resilience - Developing primary care at scale - Exploring new models of care - Understanding options for organisational form
6. Following on from discussions with the GPs around the presentation, areas of focus are to be taken forward to September’s GP Membership meeting.
7. Dr Sir Sam Everington presented at the event (Sam has been a GP in Tower Hamlets since 1989 and is chair of NHS Tower Hamlets Clinical Commissioning Group and a board member of NHS Clinical Commissioners. He is part of the Bromley By Bow GP partnership).
8. Dr Sir Sam Everington also spoke separately to the Skelmersdale GPs regarding the work around Well Skelmersdale.
Chair’s Update West Lancashire Clinical Commissioning Group Governing Body Meeting – 27 September 2016
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CLINICAL POLCIES 9. As part of our pan Lancashire work with other CCGs on clinical policies, two focus groups
regarding cosmetics two policies have been advertised locally in September. These have been publicised through our My View group, CCG website, social media, e-bulletins and via local partners.
10. The public have been invited to have their say on two policies – Assisted Conception Services and Cosmetic Procedures.
11. For anyone interested in these policies that was unable to attend the focus groups, please
visit our website and complete the relevant survey or contact the CCG directly for more details.
AGM
12. Our Annual General Meeting will take place today following this board meeting. We are
again hosting this in collaboration with West Lancashire CVS, and welcoming members of the public and local community groups to hear first-hand about our accounts and plans for the year ahead.
13. We will welcome questions from the audience, and all presentation slides and a write up of the Q&A session will be available on our website after the event: www.westlancashireccg.nhs.uk
MEDICINE WASTE
14. To tackle the ongoing issue of the cost of wasted medicines in West Lancashire, the CCG
is launching a medicines waste campaign in October 2016.
15. This is a national problem being experienced by every CCG across the country. Locally we are working with our GP membership, pharmacies, the local public and many more to try and work together to reduce this waste so we can use these funds on other crucial services in West Lancashire.
16. We will be welcoming views from the public on this issue. BREATHLESS EVENT 17. The CCG held two drop in events at The Concourse, Skelmersdsale on Friday and
Saturday last week, focusing on breathlessness.
18. Experts the CCG, Well Skelmersdale and West Lancs CVS, offered advice and breathing tests. Further support and information from local support groups and services, e.g. smoking cessation, was also available.
19. The subject of breathlessness and its link to a number of health conditions including COPD, heart disease and lung cancer has been prominent over recent months with Public Health England (PHE) and the British Lung Foundation (BLF) both running separate national campaigns, with PHE launching the latest ‘Be Clear on Cancer’ campaign and BLF launching their ‘Listen to your Lungs’ campaign.
Chair’s Update West Lancashire Clinical Commissioning Group Governing Body Meeting – 27 September 2016
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Recommendation 20. Members are asked to note the content of the report. Dr John Caine Chair September 2016
Chief Officer’s Update West Lancashire Clinical Commissioning Group Governing Body Meeting – 27 September 2016
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Agenda item no: WLCCGB 09/16/6
WEST LANCASHIRE CLINICAL COMMISSIONING GROUP GOVERNING BODY REPORT
DATE OF MEETING: 27 September 2016 TITLE OF REPORT: Chief Officer’s Update BRIEFING POINTS:
Does this report / its recommendations have implications and impact with regard to the following:
A. Commissioning Board’s Aims and Objectives 1. Quality (including patient safety, clinical effectiveness and patient
experience) – please outline impact Yes
2. Commissioning of hospital and community services – please outline
impact
Yes
3. Commissioning and performance management of GP Prescribing –
please outline impact No
4. Delivering financial balance – please outline impact Yes 5. Development of the commissioning group as a commissioning
organisation – please outline impact
No
B. Governance – 1. Does this report:
• provide the Commissioning Board with assurance against any of the risks identified in the assurance framework (identify risk number)
• have any legal implications • promote effective governance practice
Yes
2. Additional resource implications
(either financial or staffing resources) No
3. Health Inequalities Yes
4. Human Rights, Equality and Diversity Requirements No
5. Clinical Engagement
Yes
6. Patient and Public Engagement Yes
REPORT PREPARED BY: Meg Pugh, head of communication and engagement REPORT PRESENTED BY: Mike Maguire, chief officer
Chief Officer’s Update West Lancashire Clinical Commissioning Group Governing Body Meeting – 27 September 2016
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WEST LANCASHIRE CLINICAL COMMISSIONING GOVERNING BODY CHIEF OFFICER’S UPDATE
Purpose This report provides an update on both strategic and operational issues of interest to governing body members in the months since the last meeting. SUSTAINABILITY AND TRANSFORMATION PLANS
1. The CCG is a full member of the Lancashire and South Cumbria Sustainability and
Transformation Plan (STP) and an associate member of the Cheshire/Mersey STP. There are currently 44 STP areas across the country.
2. STP’s (Sustainability and Transformation Plans) allow for greater joint working across wide geographical areas. At the July Governing Body meeting, the CCG approved draft terms of reference for a joint committee of CCG’s as part of the Healthier Lancashire and South Cumbria programme. This will be the main vehicle for delivering the key joint decisions from the STP work. The CCG is currently in the process of updating its constitution as part of these change.
3. So far plans have only been developed in draft with a view to making a full submission on 21st October 2016. Importantly this will include greater information on how, alongside our partners, the CCG will meet the challenges ahead in respect of finance and workforce, as well as maintaining quality and performance targets. The plans will cover a number of joint work-streams that are starting to take place across Lancashire and South Cumbria. This includes integration of health and social care, ill-health prevention, the regulated care sector, mental health, acute and specialist care and urgent care.
4. The Cheshire/Mersey STP is operating to the same timescales and the CCG is an associate member of the mid-Mersey “Alliance” group. Here the CCG’s focus will be around hospital care.
COMMUNITY HEALTH SERVICES PROCUREMENT
5. We have now completed our dialogue discussions with four shortlisted bidders. These are –
Lancashire Care NHS Foundation Trust, Optum Health Solutions (UK) Ltd, Virgin Care Services and Bridgewater Community Healthcare NHS Foundation Trust.
6. We are currently carrying our full evaluation and moderation of any bids received.
7. Following a decision due to be made in Autumn 2016, the CCG will enter a legal standstill
period in which the outcome of the decision has to remain confidential. Once we are through this period, all stakeholders will be notified of the new provider(s). The mobilisation phase will then begin until the estimated ‘go live’ date of 1 April 2017.
8. The CCG continues to issue regular stakeholder briefings, which are also available on our website for anyone external to the CCG to read. These are also available on request.
9. As part of our engagement, we have also held both positive and informative meetings with many of our local stakeholders who understand how the process works and remain supportive of our vision for joined up care.
10. The CCG invited representatives from the campaigning group 38 Degrees in to meet with the procurement team and held an open discussion, which included answering questions about this process. The CCG will ensure 38 Degrees receives our regular stakeholder briefing and will also continue to engage with the group.
Chief Officer’s Update West Lancashire Clinical Commissioning Group Governing Body Meeting – 27 September 2016
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11. A media announcement was issued by Rosie Cooper MP on 24 August 2016 which
suggests the CCG is under additional scrutiny in relation to this process. It is important that the board and wider public note the CCG is not under any additional scrutiny as claimed by the MP and printed in local newspapers.
NHS England and the Department of Health remain assured and fully satisfied that the CCG is carrying out this procurement in line with national guidance.
Our full holding statement in reaction to this announcement is as follows: A spokesperson for NHS West Lancashire Clinical Commissioning Group (CCG) said: “Like any healthcare commissioner, we are monitored on an ongoing basis, but we are currently unaware of any additional scrutiny taking place around this procurement process as the MP claims. Since the Uniting Care procurement the MP’s story mentions, a review document was produced including a set of recommendations for CCGs, which we address fully during this procurement. As the process is ongoing, according to legal advice we are unable to release information that relates to individual organisations’ bids as this is confidential and commercially sensitive. Everything relating to this procurement that we can share has been shared. “This process is standard CCG business; we have a responsibility to review all NHS services we commission, not least when contracts come to an end. This re-procurement of local community health services, which includes walk-in and out of hours services, is therefore standard practice for CCGs. This process follows a national model and is subject to national procurement legislation which requires the CCGs to enable both NHS and independent sector providers to compete, and only proceed if they are successful following evaluation against set criteria.
“Our local hospital Southport & Ormskirk Hospital NHS Trust will continue to be a major part of local health services and will remain integral as we move towards achieving our vision for joined up care. The aim is to develop and enhance community and local walk-in and out of hour’s services, helping to prevent avoidable acute hospital attendance, relieving pressure on such a vital resource. We will continue to enable and support the local hospital to do what it does best, in addressing the needs of those residents who need acute and specialist care. Any services commissioned will continue to be delivered as part of the NHS and will remain free at the point of contact as with any provision of NHS care. During this process our stakeholders, including local people and community staff have been kept informed and also invited to have their say. Useful resources can be found at our website: www.westlancashireccg.nhs.uk/have-your-say/community-health-services or contact us via email [email protected] or 01695 588 000 12. Our chair Dr John Caine responded to a reader’s letter published in The Champion this
month which linked his remuneration with this procurement process. The CCG responded correcting the member of the public of the inaccuracies stated in the letter, while also highlighting the two matters are completely unrelated.
13. We continue to work with Southport & Ormskirk Hospital NHS Trust on many collaborative programmes and also to ensure smooth transition of services. The hospital will remain an integral part of the future model of care.
14. This procurement process is subject to national procurement legislation which requires CCGs to enable all NHS and private providers to compete. All bidders are evaluated against set criteria within a stringent process.
15. The CCG has started to publish a series of blogs which deliver key messages about this
procurement process. These can be found on our website.
Chief Officer’s Update West Lancashire Clinical Commissioning Group Governing Body Meeting – 27 September 2016
4
16. We continue to work closely with neighbouring commissioners, NHS Southport & Formby
CCG.
17. We continue to welcome views on this procurement by contacting us directly or by completing a patient story form which are available via our website/on request.
18. Anyone with an interest in this process is encouraged to visit our dedicated webpage: http://www.westlancashireccg.nhs.uk/have-your-say/community-health-services/
CHRONIC PAIN SERVICES 19. The CCG is currently addressing the Pain Management Model and how it currently performs
in preparation for the commissioning of cost-effective chronic pain services to reduce costs and improve quality and outcomes.
20. The current pathways with services and how they may best and cost-effectively be managed are being discussed.
21. Data analysis and audit are planned in order to facilitate moving the services forward. This is an ongoing piece of work and more updates will follow.
CONTRACT EXTENSIONS
22. PDS medical provides a Tier 2 Cardiology service as well as a direct access diagnostic
service. The contract was due to expire at the beginning of September. Following recommendation made by the membership the executive committee agreed that the contract should be extended for 12 months.
23. Fairfield provide a Direct Access MRI service to a limited number of practices. The contract was due to expire at the beginning of September. The executive committee agreed that the service be extended for 2 months while a further review of service take place. At this point a paper will be presented to board with recommendations. More work is also being carried out in terms of the relationships between scanning and the improved MCAS service.
QUALITY ISSUES 24. At the time of this report for the board being published, Southport & Ormskirk Hospital NHS
Trust is awaiting the final report from Care Quality Commission (CQC), which will address various quality issues at the trust that need to be improved. (A verbal and more up to date report on this issue will be provided to the board at the meeting).
Recommendation 25. Members are asked to note the content of the report Mike Maguire Chief Officer September 2016
Corporate Risk Regsiter & Board Assurance Framework West Lancashire Clinical Commissioning Group Governing Body – 27 September 2016
1
Agenda item: 09/16/7
WEST LANCASHIRE CLINICAL COMMISSIONING GROUP GOVERNING BODY REPORT
DATE OF MEETING: 27 September 2016
TITLE OF REPORT: Risk Register & Governing Body Assurance Framework
BRIEFING POINTS: Outlines key risk areas
Does this report / its recommendations have implications and impact with regard to the following: A. Commissioning Board’s Aims and Objectives 1. Quality (including patient safety, clinical effectiveness and patient experience)
– please outline impactNo
2. Commissioning of hospital and community services – please outline impact No
3. Commissioning and performance management of GP Prescribing – pleaseoutline impact
No
4. Delivering Financial Balance – please outline impact No
5. Development of the commissioning group as a commissioning organisation –please outline impact
Yes
Part of governance arrangements
B. Governance – please outline impact 1. Does this report:
• provide the Commissioning Board with assurance against any of the risksidentified in the assurance framework (identify risk number)
• have any legal implications• promote effective governance practice
Yes
Provides overview and updates on all strategic and operational risks 2. Additional resource implications
(either financial or staffing resources)No
3. Health Inequalities No
4. Human Rights, Equality and Diversity Requirements No
5. Clinical Engagement No
6. Patient and Public Engagement No
REPORT PREPARED BY:
REPORT PRESENT BY:
Elizabeth Dalton, CSU Corporate Governance & Risk Manager Paul Kingan, Chief Finance Officer
Corporate Risk Regsiter & Board Assurance Framework West Lancashire Clinical Commissioning Group Governing Body – 27 September 2016
2
Risk Register & Governing Body Assurance Framework
Introduction
The Board Assurance Framework (BAF) is a key part of the CCG’s governance arrangements. It is the principal way by which the CCG holds itself to account; it helps to clarify and quantify risks that could compromise delivery of our strategic objectives.
The CCG Risk Register has been reviewed to reflect the up to date position as at 30 August 2016. The CCG Risk Register has 24 risks categorised as follows:
1 Low Risk Unlikely to cause problems 4 Moderate Risk Needs to be resolved or accepted at Departmental level 16 High Risk Needs to be resolved or accepted at Departmental level 3 Extreme Risk To be resolved or accepted at CCG Level
A separate risk register has been created in respect of the community services re-procurement exercise. This is discussed on a regular basis as part of the Community Procurement Programme Board meetings. The Clinical Executive receives updates on the Community Re-procurement on a regular basis.
Board Assurance Framework
The GBAF includes those risks which have a risk score of 12+. The CCG Corporate Risk Register includes 11 risks with a score of 12+ and are included on the Board Assurance Framework.
8 High Risk Needs to be resolved or accepted at Departmental level 3 Extreme Risk To be resolved or accepted at CCG Level
Contracts
Risk 51 – There are no quality assurance arrangements or contracts in place for individuals in receipt of a CHC funded domiciliary health package of care. The risk is a commissioning gap resulting in a lack of governance arrangements impacting from a safeguarding perspective. There is an increased risk of harm to individuals due to a lack of quality assurance. The CCG safeguarding team work closely with multi agency partners, individuals, and commissioned agencies when safeguarding risks are identified. This is with the aim to improve longer term outcomes and quality for individuals.
Risk 42 – Failure to Achieve Financial Balance 2016/17. The CCG maintain robust financial controls and budget monitoring. Budget holders have been assigned. The CCG will maintain an on-going review of the financial position but pressures on planned care budgets need careful monitoring as they have the potential to have a significant impact on the CCG financial positon.
The overall risk rating for contracts is Amber due to the lack of quality assurance arrangements for contracts for individuals in receipt of CHC funded domiciliary health care packages.
Corporate Risk Regsiter & Board Assurance Framework West Lancashire Clinical Commissioning Group Governing Body – 27 September 2016
3
Delivery
This is the main area of concern for the CCG. There are 8 risks with regards to the achievement of the CCCG Critical Outcome for Delivery.
Risk 44 – Risk of main ICO provider failing to meet required levels of delivery and performance. The CCG is working closely with Southport and Formby CCG and Southport and Ormskirk NHS Hospitals Trust on the clinical and financial sustainability of patient services going forward. The governing body will be kept informed as this work progresses.
Risk 50 – No clear case management arrangements for those individuals who may be subject to a domestic deprivation of liberties. The CSU have appointed a lead for quality and safety who will take the lead on the safeguarding arrangements for these individuals. A working group has been established and has involvement of the CSU, CHC and the CCG safeguarding team.
Risk 35 – Service users are potentially at risk of harm due to unlawful deprivation of liberty within hospital care home and supported living. There is a Pan Lancashire action plan in place with LCC being bench marked against national plan held by NHS England. MCA/adult leads of CCGs providing training to CSU staff on DoLS.
Risk 29 – IPA process - financial instability, increasing costs, and assurances on quality of assessments. Reviews are being undertaken of high cost complex cases. In-depth examination of the information sent to the CCG by MLCSU is undertaken. The CCG is a member of the IPA Programme Board meetings where Pan Lancashire scrutiny of the IPA process is undertaken.
Risk 40 – Patient safety issues in relation to the cardiology services at Southport and Ormskirk Trust having a significant backlog of follow up patients not being offered appointments. Urgent cases have appointments but the majority are still to have their appointments made. Cost of the alternative provision is rising and needs to be managed. The CCG is liaising with the provider to obtain a clear position statement.
Risk 41 – Increasing financial risk in relation to the CCG taking on specialist services co-commissioning and the associated budget remains a high financial risk to the CCG and an action plan is being developed. The financial year 2016/17 will be about preparation and transition to establish understanding and controls and monitor the impact of delegation commissioning responsibilities.
Risk 43 - Reduced services provision leading to increase demand on NHS services as a result of £4M cut in public health funding in Lancashire. LCC Cabinet took a paper considering the impact of scaling back to statutory services. This is an area that we are monitoring in terms of LCC decisions and the impact on the CCG. The Council has reserves for 2 years which helps to mitigate against various service budget cuts in the near future.
Risk 52 - There is no specialist out of hours mental health support and advice for Ormskirk paediatric patients and staff. An updated action plan was provided in August 2016 and is under review.
Given the current situation the overall risk rating for Delivery is Amber, however this is under constant review as more data on the in-year position for QIPP and financial position becomes available.
Corporate Risk Regsiter & Board Assurance Framework West Lancashire Clinical Commissioning Group Governing Body – 27 September 2016
4
Engagement
Risk 8 - The risk in relation to the lack of engagement of providers in the quality agenda remains at a risk score of 16. Although the CQPG has been reinvigorated by the Trust Executive, engagement from the Trust has been poor and the attendance from Trust Clinicians and GPs has been sporadic.
The overall risk rating for Engagement remains at Red.
Operational Systems
There are currently no risks in relation to operational systems.
Downgraded Risks
The following risks were reported on the GBAF in July 2016 but have now been downgraded.
Risk 32 - Patients in receipt of NHS funded care potentially at risk of harm as their health and care needs may not be addressed due to gaps in the commissioning of the CHC service in respect of care planning and case management. Lack of capacity in CHC team resulting in routine reviews behind scheduled. The review process is due to be completed and work with the chosen provider has commenced. West Lancashire CCG and BWD are the first CCG areas to be targeted; reviews are expected to be completed by end March 2016. In light of the addition resources the risk is reduce to moderate. Following additional resources being secured, the reviews process is near completion and this has resulted in a reduced level of risk.
Risk 47 – Risk in relation to unauthorised deprivation of liberty upon discharge when the application is required to go to the Court of protection where significant backlog of applications are being experienced further to a resource being available to manage the volume of applications to the court. A Pan Lancashire working group has been established with multi agency representation. An interim manager is now in post to focus on learning disability patients.
Recommendations
The Governing Body is asked to note the board assurance framework and corporate risk register and continue to support the risk management arrangements.
Paul Kingan Chief Finance Officer September 2016
West Lancashire CCG - GBAF - Aug 2016
West Lancs CCG - GBAF V1.4 - Aug 2016 1
Assurance Framework 2016/17 - V1.4 August 2016Ri
sk ID
Dat
e Ad
ded
Critical Outcome/Strategic Objective
Description of Risk
These are the specific areas where failure will risk a critical outcome
Controls to Mitigate
Processes and plans in place or actions being taken to mitigate risk in principle areas
Gaps in Control
Areas where controls are not in place or are ineffective
Assurance on Controls
Internal or external reporting arrangements that provide assurance to the Governing Body that controls are effective
Gap in Assurance
Areas of insufficient evidence to assure the Governing Body that controls are being effective Cu
rren
t Con
sequ
ence
Curr
ent L
ikel
ihoo
d
Curr
ent R
isk
Scor
e
Action Plan
Key actions being taken to mitigate the risk La
st R
evie
w D
ate
Assu
ranc
e Le
vel*
51
16.0
6.16
Contracts - Failure to effectively manage
contracts to ensure high quality services
There are no quality assurance arrangements or contracts in place for individuals in receipt of a CHC
funded domiciliary health package of care. The risk is a commissioning gap resulting in a lack of governance
arrangements impacting from a safeguarding perspective. There is an increased risk of harm to
individuals due to a lack of quality assurance.
The CCG safeguarding team work closely with multi agency partners,
individuals, and commissioned agencies when safeguarding risks are
identified. This is with the aim to improve longer term outcomes and
quality for individuals.
CSU complex cases team are sign off individual packages of care once a care
plan has been presented and meets needs.
Lack of governance arrangements when monitoring the ongoing packages of care
or when an individual needs change.
CSU Safeguarding team work closely with multi agency partners.
Limited resource available to provide the ongoing review of
packages from the complex cases team.
5 4 20
Paper to be submitted to the collaborative commissioning board
to highlight the risk and agree future actions to minimise.
Aug-16
42
01.0
4.16
Contracts - Failure to effectively manage
contracts to ensure high quality services
Failure to achieve Financial Balance 2016/17
Robust financial controls (ledger) and budget setting.
Budget holders assigned.Budget allocation agreed by DoH for
2016/17.
None identified at presentMaintain an on-going review of
financial position.
Planned Care Budgets need careful monitoring due to potential impact
on CCG financial position. 4 3 12
Continuous monitoring of financial position. Successful implementation
of QIPP Schemes.Aug-16
44
11.0
8.50
15
Delivery - Failure to Deliver CCG Service Priorities
Risk of main ICO provider failing to meet required levels of delivery and performance due to a number of issues including service quality, financial outlook
and senior staff changes.
Discussions at Quality Committee, discussions with Chair of hospital and
Board to Board meetings. Achievement of contract performance
targets.
Performance data often retrospective and time lag exists. Queries and letters
not responded to on time.
CCG continues to meet regularly with the Trust at a number of meetings (around quality and
contractual performance), as well as a dedicated health economy wide group which meets regularly and
looks at clinical and financial sustainability of services going
forward. This includes NHS England, the TDA and fellow CCG
commissioners. This work has been given a high priority in each
organisation.
Some services difficult to performance monitor on timely basis e.g. Community Services
4 4 16
Regular bi-weekly meetings of the Trust sustainability programme
which involves all key stakeholders. The risk score will likely stay the
same until longer term solutions are found.
Aug-16
West Lancashire CCG - GBAF - Aug 2016
West Lancs CCG - GBAF V1.4 - Aug 2016 2
Risk
ID
Dat
e Ad
ded
Critical Outcome/Strategic Objective
Description of Risk
These are the specific areas where failure will risk a critical outcome
Controls to Mitigate
Processes and plans in place or actions being taken to mitigate risk in principle areas
Gaps in Control
Areas where controls are not in place or are ineffective
Assurance on Controls
Internal or external reporting arrangements that provide assurance to the Governing Body that controls are effective
Gap in Assurance
Areas of insufficient evidence to assure the Governing Body that controls are being effective Cu
rren
t Con
sequ
ence
Curr
ent L
ikel
ihoo
d
Curr
ent R
isk
Scor
e
Action Plan
Key actions being taken to mitigate the risk La
st R
evie
w D
ate
Assu
ranc
e Le
vel*
50
16.0
6.16 Delivery - Failure to Deliver
CCG Service Priorities
There are no clear case management arrangements for those individuals who may be subject to a domestic DoL There is no
oversight of individuals resulting in potential safeguarding risks and people being subject to an unauthorised DoL.
The CSU have appointed a lead for quality and safety who will take a lead on the safeguarding arrangements for
these individuals.
No clear documented case management. Appointment of CSU lead for quality
& safety to ensure safeguarding arrangements are in place.
Resource requirements need to be established.
4 4 16
Working Group to establish resource requirements, documentation
support and training arrangements for staff.
Aug-16
35
31.1
0.20
14
Delivery - Failure to Deliver CCG Service Priorities
Services users are potentially at risk of harm due to unlawful deprivation of liberty within hospital care home and supported living following the Cheshire
West Judgement in March 2014.
Pan Lancashire action plan in place with LCC being bench marked against
national plan held by NHS England. MCA/adult leads of CCGs providing
training to CSU staff on Dolls.
Timely notification and management of cases where application to Court of
Protection may be required. CSU has no access to Broadcare to
identify patients.
Minutes from Pan Lancs Group to feed into S/G Assurance Group; Pan
Lancs S/G Collaborative and Advisory Group (now ceased)
LA Plan to be shared with health interaction into this plan agreed.
CSU Broadcare Reports. Action plan re management of fall-
out from Cheshire West to be developed.
Pan Lancashire Group established.
Case Management with CHC function to undertake required
reviews. No legal expertise and capacity
within the CCG to make applications to the Court of
Protection. Legal advise being sought on a case
by case basis.
3 4 12
Seek assurance that the care and treatment plans for CCG
commissioned packages of care for individuals lacking capacity to
consent have been reviewed and where a DoLs is identified full
exploration of alternative ways of providing care/treatment have been
undertaken to enable the least restrictive option of care. Seek
assurance from care homes where there are CHC funded patients that
DoLs applications have been made or are in the process of being
authorised. CCG to determine which service is best placed to be
commissioned to case manage CHC patients residing in their own homes
and supported tenancy to ensure compliance with Cheshire West
Aug-16
West Lancashire CCG - GBAF - Aug 2016
West Lancs CCG - GBAF V1.4 - Aug 2016 3
Risk
ID
Dat
e Ad
ded
Critical Outcome/Strategic Objective
Description of Risk
These are the specific areas where failure will risk a critical outcome
Controls to Mitigate
Processes and plans in place or actions being taken to mitigate risk in principle areas
Gaps in Control
Areas where controls are not in place or are ineffective
Assurance on Controls
Internal or external reporting arrangements that provide assurance to the Governing Body that controls are effective
Gap in Assurance
Areas of insufficient evidence to assure the Governing Body that controls are being effective Cu
rren
t Con
sequ
ence
Curr
ent L
ikel
ihoo
d
Curr
ent R
isk
Scor
e
Action Plan
Key actions being taken to mitigate the risk La
st R
evie
w D
ate
Assu
ranc
e Le
vel*
29
31.0
7.20
14
Delivery - Failure to Deliver CCG Service Priorities
IPA process - financial instability, increasing costs, and assurances on quality of assessments
Reviews of high cost complex cases.Examining the information MLCSU
sends to CCG.Undertaking further training for GPs
on process.Participation at IPA Programme Board
meetings
None identified at present IPA Programme BoardTesting of new Governance
Structure to see if assurance is relevant and being managed.
4 3 12
Continued scrutiny of CSU Broadcare data. Development of new
commissioning process. The CCG has accepted the CSU's QIPP proposal - this will increase the capacity of the CSU IPA team and the frequency of case reviews. The CCG's investment is anticipated to be more than offset by the savings made. Following the
recent procurement of the CHC Framework Agreement the CCG is
anticipating a significant increase in the weekly rates care homes charge
(the median increase across Lancashire is 10.5%)
Aug-16
40
11.0
2.20
15
Delivery - Failure to Deliver CCG Service Priorities
Patient safety issues in relation to the cardiology services at Southport and Ormskirk Trust having a significant backlog of follow up patients not being
offered appointments.
Alternative provider commissioned to resolve backlog.
No oversight of discussions with providers.
Urgent cases have appointments but the majority are still to have
their appointments madeCost of the alternative provision is rising and needs to be managed.
Detail of discussions with the provider is still not clear and needs
to be confirmed. 4 3 12
Cardiology clinics have been taken off choose and book therefore limited new referrals are being
received. The additional capacity is being used
to keep the backlog of follow up numbers downs.
However of the two new consultants who should have been appointed
only one has taken up post. Post is being re-advertised.
Community cardiology services are being developed to deflect work
away from secondary care as more cardiology work can be managed in
the community.
Aug-16
41
30.0
6.20
15
Delivery - Failure to Deliver CCG Service Priorities
Increasing financial risk in relation to the CCG taking on specialist services co-commissioning and the
associated budget.
2016/17 will be about preparation and transition to establish understanding
and controls.
Impact of specialist services co-commissioning not fully known
Issue around bariatric is still not resolved. A solution is being worked up across CCG’s in Merseyside and Lancashire. This is being managed via the Lancashire Collaborative
Commissioning Board of which the CCG is a member. Still remains a
high financial risk to the CCG. The NHS will provide a procurement
proposal and project plan which is likely be on a North West footprint.
NHS Procurement Plan 4 3 12Action plan need developing as likelihood that financial risk will
increase during 2016/17. Aug-16
West Lancashire CCG - GBAF - Aug 2016
West Lancs CCG - GBAF V1.4 - Aug 2016 4
Risk
ID
Dat
e Ad
ded
Critical Outcome/Strategic Objective
Description of Risk
These are the specific areas where failure will risk a critical outcome
Controls to Mitigate
Processes and plans in place or actions being taken to mitigate risk in principle areas
Gaps in Control
Areas where controls are not in place or are ineffective
Assurance on Controls
Internal or external reporting arrangements that provide assurance to the Governing Body that controls are effective
Gap in Assurance
Areas of insufficient evidence to assure the Governing Body that controls are being effective Cu
rren
t Con
sequ
ence
Curr
ent L
ikel
ihoo
d
Curr
ent R
isk
Scor
e
Action Plan
Key actions being taken to mitigate the risk La
st R
evie
w D
ate
Assu
ranc
e Le
vel*
43
18.0
6.20
15
Delivery - Failure to Deliver CCG Service Priorities
Reduced services provision leading to increase demand on NHS services as a result of £4M cut in
public health funding in Lancashire
Chair of HWN Board has written to the Secretary of State on behalf on the
Board.None identified at present
Lancashire Health & Wellbeing Board to have discussion to
determine what it will mean for the future of Public Health.
That any soft evidence on the impact of local authority cuts should
be forwarded to Director of Public Health
None identified at present 3 4 12
LCC Cabinet took a paper considering the impact of scaling back to
statutory services. This is an area that we are monitoring in terms of LCC decisions and resulting impact.
Continue to monitor any impact through comments received by the
CCG.Liaison with LCC commissioning leads to ensure CCG exec and Membership
are briefed on updates regarding mobilisation of newly awarded
contracts.The Council has reserves for 2 years
Aug-16
52
22/0
7/20
16
Delivery - Failure to Deliver CCG Service Priorities
There is no specialist out of hours mental health support and advice for Ormskirk paediatric patients and staff .
Ormskirk paediatrics is a place of safety.
CCG in negotiations with a provider to provide Out of Hours after two other
providers have refused.CAMHS transformation work have a crisis workstream trying to address
issue across Lancashire
None identified at present Executive & Quality Committees None identified at present 4 3 12
CCG in negotiations with a provider to provide Out of Hours after two
other providers have refused.CCG executives aware
Aug-16
8
01.0
4.20
15 Engagement - Failure to Engage Effectively with
Stakeholders
Lack of engagement of providers in the quality agenda leading to a lack of understanding and
consistency between partners regarding outcomes of specific schemes.
CQPG has been reinvigorated but Trust Executive engagement from the Trust
has been poor
New meeting is in place to engage Trust clinicians with GPs. JC attends on
our behalf.
Separate single item QSGs have taken place to focus trust on quality issues
More detailed requirements of funding and scheme outcomes are being
stipulatedSeparate meetings with other providers
have taken place to iron out quality issues
Regular feedback of new “op forum” to membership under chairman’s update
CQPGEngagement of trust staff with GPs in our membership and FTFT events
4 4 16
Continued emphasis on the quality agenda at the QSG meetings and
with formal letters between the CCG and S&OHT on these issues.
Aug-16
Operational Systems No risk recorded
Assurance Status Key:
Green Complete
Amber On track
Red Off target
1 2 3 4 5
Rare Unlikely Possible Likely Almost Certain
5 Catastrophic 5 (Moderate) 10 (High) 15 (Extreme) 20 (Extreme) 25 (Extreme)
4 Major 4 (Moderate) 8 (High) 12 (High) 16 (Extreme) 20 (Extreme)
Likelihood
ence
West Lancashire CCG - GBAF - Aug 2016
West Lancs CCG - GBAF V1.4 - Aug 2016 5
Risk
ID
Dat
e Ad
ded
Critical Outcome/Strategic Objective
Description of Risk
These are the specific areas where failure will risk a critical outcome
Controls to Mitigate
Processes and plans in place or actions being taken to mitigate risk in principle areas
Gaps in Control
Areas where controls are not in place or are ineffective
Assurance on Controls
Internal or external reporting arrangements that provide assurance to the Governing Body that controls are effective
Gap in Assurance
Areas of insufficient evidence to assure the Governing Body that controls are being effective Cu
rren
t Con
sequ
ence
Curr
ent L
ikel
ihoo
d
Curr
ent R
isk
Scor
e
Action Plan
Key actions being taken to mitigate the risk La
st R
evie
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ate
Assu
ranc
e Le
vel*
3 Moderate 3 (Low) 6 (Moderate) 9 (High) 12 (High) 15 (Extreme)
2 Minor 2 (Low) 4 (Moderate) 6 (Moderate) 8 (High) 10 (High)
1 Negligible 1 (Low) 2 (Low) 3 (Low) 4 (Moderate) 5 (Moderate)
Con
sequ
e
West Lancashire CCG - Active Risk Register - August 2016
West Lancs CCG - Risk Register V1.4_Aug 2016 1
West Lancashire CCG Risk RegisterActive Risk Register V1.4 - August 2016
No. Date Added Lead Description ControlsOverall
Risk Score
Change Action Plan (AP) UpdatesResidual
risk
Last Risk Review
DateLink to BAF C L R A G
7BAF Theme:
Delivery01.04.15 PJ
Failure to deliver service priorities to plan including QIPP targets
Monitoring of QIPP linked into financial reporting system
CSU support for comms, finance and business intelligence
Strategic Partnership Board (SPB) (6 key priorities agreed)
National reporting on assurance established. Q1 -Q4 assessment completed with full
assurance received
3 3 9 ↔
Cross reference QIPP programme to redesign programme.
Continuously refresh assumptions around QIPP programme outcomes and
embed services.
QIPP strategy established for 16/17 and operational delivery
detail now being developed.
Matrix designed to monitor impact of QIPP and assist
redistribution of resources.QIPP outcomes clarified and plan amended accordingly
Improvement in systems being maintained with on-going
scrutiny. New project management
system (Aspyre) will assist the CCG in project managing QIPP schemes and measuring their
financial impact.
Moderate Aug-16
8BAF Theme: Engagement
01.04.15 JM/LC
Lack of engagement of providers in the quality agenda leading to a
lack of understanding and consistency between partners regarding outcomes of specific
schemes.
CQPG has been reinvigorated but Trust Executive engagement from the Trust has
been poor
New meeting is in place to engage Trust clinicians with GPs. JC attends on our behalf.
4 4 16 ↔
Separate single item QSGs have taken place to focus trust on
quality issues More detailed requirements of funding and scheme outcomes
are being stipulatedSeparate meetings with other providers have taken place to
iron out quality issues Regular feedback of new “op forum” to membership under
chairman’s updateEngagement of trust staff with
GPs in our membership and FTFT events
Continued emphasis on the quality agenda at the QSG meetings and with formal
letters between the CCG and S&OHT on these issues.
Moderate Aug-16
Status of APScore
West Lancashire CCG - Active Risk Register - August 2016
West Lancs CCG - Risk Register V1.4_Aug 2016 2
No. Date Added Lead Description ControlsOverall
Risk Score
Change Action Plan (AP) UpdatesResidual
risk
Last Risk Review
DateLink to BAF C L R A G
Status of APScore
23BAF Theme:
Delivery15.08.14 CW
Children being discharged from CAMHS too early at 16 when they should remain with service until 18. Leading to risk of no services being received when child needs it – safeguarding issue transition into adult service where staff are
not trained to provide an age appropriate service,
inappropriate placement of children on adult mental health
ward.
Eating Disorder specification for extended service to support 16+ with BMI<17.5 agreed with LCFT and CSU funding flowing. (Service
delivery commenced 25 Feb 2015) 3 2 6 ↔
Safeguarding issue investigated -learning and actions agreed and
discussed.Lancashire wide Transformation
Plan for CYP emotional health and wellbeing will address age
range of CAMHS (0-25 service by 2020)
New Eating Disorders model to be developed for Lancashire in line with National Guidance -
West Lancs preference for all age service. (no transition)
Transformation Plan has been assured for Lancashire.
Lancashire North and Fylde and Wyre CCGs will be piloting new
service model for eating disorders. West Lancashire
detailed plans and actions for Eating Disorders support,
development and roll out of pilot learning discussed with
LCFT team 4.1.16.
Moderate Aug-16
25BAF Theme:
Contracts31.07.14 PJ
Running costs outstrip available resources
Consideration being given to how to achieve 2016/17 running costs target
3 3 9 ↔
Develop plan to achieve running cost target for 2016/17
Requirements reviewed as and when vacancies arise.
Maintaining an on-going review of running costs. Resources
have been “freed up” by not replacing staff like for like.
Moderate Aug-16
27BAF Theme:
Delivery31.07.14 JM
Lack of a Referral Management Centre Strategy
Engagement made with the National C&B2 Team. New strategy developed to move away
from RMC and move to C&B2.New project structure developed with clear
TOR for groups therein.Regular feedback to Executives at least once per month on how this project is performing.
3 3 9 ↔
Implementation and rollout plan developed and updated
e-referral manager in postS&F tie in confirmed
Choose and book programme board taking place 09.01.2015
DOS compiled by CCGAlternative options are being
sought for services supported by RMC
i.e. podiatry, gastroenterology etc.
Regular feedback to Executives at least once per month.
E-referral duties will remain in staff post on a permanent basis to ensure bedding in of project.
Moderate Aug-16
West Lancashire CCG - Active Risk Register - August 2016
West Lancs CCG - Risk Register V1.4_Aug 2016 3
No. Date Added Lead Description ControlsOverall
Risk Score
Change Action Plan (AP) UpdatesResidual
risk
Last Risk Review
DateLink to BAF C L R A G
Status of APScore
29BAF Theme:
Delivery31.07.14 PJ
IPA process - financial instability, increasing costs, and assurances
on quality of assessments
Reviews of high cost complex cases.Examining the information MLCSU sends to
CCG.Undertaking further training for GPs on
process.Participation at IPA Programme Board
meetings
3 4 12 ↔
Undertake reviews and complete training for GPs on process.
CCG scrutinising the accuracy of the financial forecast produced
by the CSU
Developing new commissioning processes in partnership with
CSU and CCS.
Continued scrutiny of CSU Broadcare data. Development
of new commissioning processes. The CCG has accepted the CSU's QIPP
proposal - this will increase the capacity of the CSU IPA team
and the frequency of case reviews. The CCG's investment is anticipated to be more than
offset by the savings made. Following the recent
procurement of the CHC Framework Agreement the CCG
is anticipating a significant increase in the weekly rates
care homes charge (the median increase across Lancashire is
10.5%)
Moderate Aug-16
32BAF Theme:
Delivery30.10.14 PJ
Patients in receipt of NHS funded care potentially at risk of harm as their health and care needs may not be addressed due to gaps in the commissioning of the CHC
service in respect of care planning and case management. Lack of
capacity in CHC team resulting in routine reviews behind
scheduled.
CSU commissioned to manage CHC process. Monthly exception reporting care homes
from CSU. Quarterly reporting on CHC from CSU
4 2 8 ↓
In view of a 16 -20% increase in demand for CHC assessments the CSU Board has made additional funding available to procure the support of an external nursing
company to assist in the complete CHC reviews.
The review process is due to be completed and work with the
chosen provider will commence within the month. West
Lancashire CCG and BWD are the first CCG areas to be
targeted, reviews are expected to be completed by end March
2016. In light of the addition resources the risk is reduce to moderate. following additional resources being secured, the
reviews process is near completion and this has
resulted in a reduced level of risk.
Moderate Aug-16
West Lancashire CCG - Active Risk Register - August 2016
West Lancs CCG - Risk Register V1.4_Aug 2016 4
No. Date Added Lead Description ControlsOverall
Risk Score
Change Action Plan (AP) UpdatesResidual
risk
Last Risk Review
DateLink to BAF C L R A G
Status of APScore
33BAF Theme:
Delivery31.10.14 CH
Decisions taken on referrals into MASH not informed by relevant health information and potential therefore that harm and risks not fully recognised leading to poorer
outcomes for children/families and vulnerable adults. No
agreement for the on-going funding of the Lancashire multi-
agency safeguarding Hub (MASH). Insufficient health contribution
will impact on timeliness of information sharing and decision making and may result in poorer outcomes for children and adults
at risk.
Interim funding for 2wte band 7s and 1wte admin has been made available until
31.03.15.Options paper currently being developed
which will make recommendations for future commissioning of health service contribution
to MASH
3 2 6 ↔
Options paper to safeguarding collaborative and CCG on future
commissioning of health contribution to MASH
CCG/ AT/ PH agree future funding of health’s contribution
Procure service
Awaiting outcome of options paper.
12 month funding agreed for a MASH service manager to
coordinate across organisations. Long
Term options still to be agreed
Low Aug-16
34BAF Theme:
Delivery30.10.14 CH
Statutory health assessments for children looked after are not undertaken within statutory
timescales and may result in the child not achieving their full
potential as individual health needs not identified and
addressed in a timely manner.
Service specification in place with LCFT which requires them to co-ordinate the health
assessment process and to quality assure assessments. S&O community paeds
commissioned to undertake initial health assessments and adoption medicals for
children 0-18 years. Health visiting and school nursing service specifications include the
requirement for services to undertake statutory review assessments. Contract query
being issued with LCFT re uptake and timeliness of review assessments. LCFT have
put in place action plan to address issues.
2 2 4 ↔
CSU leading work stream on CLA to include developing preferred option for implementing PbR.
will include recommendation of central LCC/ health admins
system. Reporting to Lancashire Children's and Maternity
commissioning network with final report by March 16. To
ensure CLA assessments integral to public health spec for HV/SN.
Improvement in administrative processes has seen an
improvement in the timeliness of assessment. Data still subject
to scrutiny and regular reporting received from
LCC/LCFT
Low Aug-16
West Lancashire CCG - Active Risk Register - August 2016
West Lancs CCG - Risk Register V1.4_Aug 2016 5
No. Date Added Lead Description ControlsOverall
Risk Score
Change Action Plan (AP) UpdatesResidual
risk
Last Risk Review
DateLink to BAF C L R A G
Status of APScore
35BAF Theme:
Delivery31.10.14 LE
Services users are potentially at risk of harm due to unlawful deprivation of liberty within
hospital care home and supported living following the Cheshire West Judgement in
March 2014,
Pan Lancashire action plan in place with LCC being bench marked against national plan held by NHS England. MCA/adult leads of
CCGs providing training to CSU staff on Dolls.
3 4 12 ↔
Seek assurance that the care and treatment plans for CCG
commissioned packages of care for individuals lacking capacity to consent have been reviewed and
where a DoLs is identified full exploration of alternative ways
of providing care/treatment have been undertaken to enable the least restrictive option of care.
Seek assurance from care homes where there are CHC funded
patients that DoLs applications have been made or are in the
process of being authorised. CCG to determine which service is
best placed to be commissioned to case manage CHC patients
residing in their own homes and supported tenancy to ensure
compliance with Cheshire West recommendations.
The CLA work stream continues and the overall performance
continues to be monitored for sustainability. No change to risk
score.
Medium /High
Aug-16
36BAF Theme:
Delivery31.10.14 PJ/JM
Lack of commissioning policies to drive individual patient funding
decisions.Existing legacy policies being utilised. 3 3 9 ↔
Develop a new suite of policies. The CCG needs to establish clear
governance arrangements for adopting polices and needs to
engage in a work stream (either in conjunction with the work in
Greater Preston and Chorley and South Ribble CCGs with which
there is an offer of engagement, or in conjunction with county wide work being promoted by the CSU, or by designating its
own officers) to develop a suite of robust and up to date policies.
Continual review of commissioning policies is being
undertaken.
Awaiting updates from Pan Lancashire work
Medium /High
Aug-16
West Lancashire CCG - Active Risk Register - August 2016
West Lancs CCG - Risk Register V1.4_Aug 2016 6
No. Date Added Lead Description ControlsOverall
Risk Score
Change Action Plan (AP) UpdatesResidual
risk
Last Risk Review
DateLink to BAF C L R A G
Status of APScore
38BAF Theme:
Delivery03.12.14 MM
Inability to deliver corporate objectives as a result of
Lancashire County Council (LCC) budget cuts impacting on CCG in
terms of LCC service provision and the reduction in capacity and
knowledge and relationships with key stakeholders.
Meeting with LCC to understand impact of cuts
3 3 9 ↔Ensure partnership
arrangements are robust
CCG is in regular contact with LCC over the financial impact.
A senior officer from LCC attends the governing body
meetings to provide any updates.
The CCG is also working collaboratively across
Lancashire as part of the BCF and Healthier Lancashire work with LCC and the other CCG’s. Any jointly identified risks are
being identified and monitored, including the impact of budget
cuts.
Medium /High
Aug-16
40BAF Theme:
Delivery11.02.15 JM
Patient safety issues in relation to the cardiology services at
Southport and Ormskirk Trust having a significant backlog of follow up patients not being
offered appointments
Alternative provider commissioned to resolve backlog
4 3 12 ↔
Urgent cases have appointments but the majority are still be have
their appointments madeCost of the alternative provision
is rising and needs to be managed.
Detail of discussions with the provider is still not clear and
needs to be confirmed.
Cardiology clinics have been taken off choose and book
therefore limited new referrals are being received.
The additional capacity is being used to keep the backlog of follow up numbers downs.However of the two new
consultants who should have been appointed only one has
taken up post. Post is being re-advertised.
Community cardiology services are being developed to deflect
work away from secondary care as more cardiology work
can be managed in the community.
Medium Aug-16
41BAF Theme:
Delivery 30.06.15 PK
Increasing financial risk in relation to the CCG taking on specialist services co-commissioning and
the associated budget
2016/17 will be about preparation and transition to establish understanding and
controls.4 3 12 ↔
Action plan need developing as likelihood that financial risk will
increase during 2016/17.
Issue around bariatric is still not resolved. A solution is being worked up across CCG’s in
Merseyside and Lancashire. This is being managed via the
Lancashire Collaborative Commissioning Board of which
the CCG is a member. Still remains a high financial risk to
the CCG.The NHS will provide a
procurement proposal and project plan and this will likely be on a North West footprint.
Medium Aug-16
West Lancashire CCG - Active Risk Register - August 2016
West Lancs CCG - Risk Register V1.4_Aug 2016 7
No. Date Added Lead Description ControlsOverall
Risk Score
Change Action Plan (AP) UpdatesResidual
risk
Last Risk Review
DateLink to BAF C L R A G
Status of APScore
42BAF Theme:
Contracts30.06.15 PJ
Failure to Achieve Financial Balance 2016/17
Robust financial controls (ledger) and budget setting
Some budget holders assignedBudget allocation agreed by DoH for 2016/17
4 3 12 ↔
Continuous monitoring of financial position.
Successful implementation of QIPP schemes
Maintaining an on-going review of financial position.
Pressures on planned care budgets need careful
monitoring as potentially very significant.
Moderate Aug-16
43BAF Theme:
Delivery18.06.15 MM
Reduced services provision leading to increase demand on NHS services as a result of £4M cut in public health funding in
Lancashire
Chair of HWN Board has written to the Secretary of State on behalf on the Board.
3 4 12 ↔
Lancashire Health & Wellbeing Board to have discussion to
determine what it will mean for the future of Public Health.
Chair of HWN Board to write to the Secretary of State on behalf
on the BoardThat any soft evidence on the impact of local authority cuts
should be forwarded to Director of Public Health
LCC Cabinet took a paper considering the impact of scaling back to statutory
services. This is an area that we are monitoring in terms of LCC decisions and resulting impact.
Continue to monitor any impact through comments
received by the CCG.Liaison with LCC commissioning leads to ensure CCG exec and Membership are briefed on
updates regarding mobilisation of newly awarded contracts.
The Council has reserves for 2 years which helps to mitigate against various service budget
cuts in the near future.
High Aug-16
44BAF Theme:
Delivery11.08.15 PK
Risk of main ICO provider failing to meet required levels of
delivery and performance due to a number of issues including
service quality, financial outlook and senior staff changes.
Discussions at Quality CommitteeDiscussions with hospital chair and Board to
Board meetings4 4 16 ↔
CCG continues to meet regularly with the Trust at a number of meetings (around quality and contractual performance), as
well as a dedicated health economy wide group which meets regularly and looks at
clinical and financial sustainability of services going
forward. This includes NHS England, the TDA and fellow CCG
commissioners. This work has been given a high priority in each
organisation.
A finance risk summit has been set up with next meeting on 8th January. There are also
regular bi-weekly meetings of the Trust sustainability
programme which involves all key stakeholders. The risk score
will likely stay the same until longer term solutions are
found.The CCG and other key
stakeholders continue to work on wider acute hospital service
sustainability as part of the Strategic Transformational
Planning Process (STP).
High Aug-16
West Lancashire CCG - Active Risk Register - August 2016
West Lancs CCG - Risk Register V1.4_Aug 2016 8
No. Date Added Lead Description ControlsOverall
Risk Score
Change Action Plan (AP) UpdatesResidual
risk
Last Risk Review
DateLink to BAF C L R A G
Status of APScore
45BAF Theme:
Delivery03.11.15 JM/KT
Failure to deliver the adult community services procurement.
Governance framework and project plan established, including programme-level risk
register. 3 3 9 ↔
Frequent discussions at Community Services Programme Board where risk register for the
programme is discussed and mitigating actions agreed.
The service and financial risk have reduced due to
crystallisation of detail and improved certainty in these
arears
The main risks currently are resource capacity and political
scrutiny both of which have actions in place to mitigate as
far as possible
Moderate Aug-16
46BAF Theme:
Contracts13.03.16 MM
Increasing financial risk in relation to the CCG receiving charges for hospital Anti-coagulation Service
in 2016/17. This service has previously not been charged for
separately.
We are unable to identify which patients are within the therapeutic rage for ICO provided
service.Contractual process for 16/17 will mitigate
the financial risk. The hospital has a monitoring system – DAWN and CCG do not
have access to this system for Secondary Care.
2 5 10 ↔To arrange access with ICO in to
DAWN – monitoring system.
The hospital did not identify this through ‘Code of Conduct’
practice. However they are now charging for this service.
This is a increased financial risk to the CCG.
Moderate Aug-16
West Lancashire CCG - Active Risk Register - August 2016
West Lancs CCG - Risk Register V1.4_Aug 2016 9
No. Date Added Lead Description ControlsOverall
Risk Score
Change Action Plan (AP) UpdatesResidual
risk
Last Risk Review
DateLink to BAF C L R A G
Status of APScore
47BAF Theme:
Delivery26.02.16 LE
There are concerns around MCA and DoLs quality assurance
arrangements & compliance in relation to those patients diagnosed with learning
disabilities currently detained in secure settings where
arrangements are being made for discharge as directed by
Transforming Lives agenda. The risk is around unauthorised deprivation of liberty upon
discharge when the application is required to go to the Court of protection where significant
backlog of applications are being experienced further to a resource
being available to manage the volume of applications to the
court.
Patients currently remain under section of the mental health Act whilst arrangements
are being considered. Previously the Lancashire County Council had not agreed to fund some patients on discharge. An interim
agreement had been reached with healthcare funding the patients and social care felt it inappropriate for social workers to submit
the application to the court of protection. It is now agreed that where best placed, the application to court of protection will be
submitted by social care
4 2 8 ↓An interim manager is now in
post to focus on learning disability patients.
The CCG Safeguarding Team are involved in a Task & Finish
Group with the Quality & Effectiveness Team. Work plan
and priorities to be agreed.
Moderate Aug-16
48BAF Theme:
Delivery29.01.16 LE/JB
There is no case management of individuals allocated a personal
health budget (PHB) with a package of care resulting in potential safeguarding risks.
There is no oversight of individuals in receipt of PHB’s where the local authority have
transferred care arrangements to the CCG for a CHC package
resulting in potential safeguarding risks
CSU have appointed a lead for quality and safety who will lead on the personal health budget work stream which will incorporate
safeguarding arrangements for these individuals
3 2 6 ↔
Working group to be implemented with involvement of the CCG, safeguarding team
and contracts. Group to establish audit arrangements, resource
requirements and training arrangements for staff.
NHS England are participating in End of Life Care PHB
programme which will enable the CCG to resolve some issues
locally.
Moderate Aug-16
49BAF Theme:
Delivery14.06.16 LB
Arrangements are currently in place with a Lancashire County
Council respite facility for children with complex needs where the
CCG funds Interserve, predominantly a provider of
domiciliary packages of care to deliver a higher health
component of support, which this current facility is not able to provide. CSU have not been
involved in any assessment of need and the care package is
funded without any oversight or quality assurance.
CSU have requested that a health needs assessment is completed by provider services
in the short term 2 3 6 ↔
CSU have requested that a health needs assessment is completed by provider services in the short
term
A need has been highlighted for a more robust pathway and contractual arrangement for
procurement and management of the nursing healthcare of
children who utilise the respite care provision. Interim
measures are required to mitigate potential safeguarding
risks.
Moderate Aug-16
West Lancashire CCG - Active Risk Register - August 2016
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No. Date Added Lead Description ControlsOverall
Risk Score
Change Action Plan (AP) UpdatesResidual
risk
Last Risk Review
DateLink to BAF C L R A G
Status of APScore
50BAF Theme:
Delivery16.06.16 LE
There are no clear case management arrangements for those individuals who may be
subject to a domestic DoL There is no oversight of individuals
resulting in potential safeguarding risks and people being subject to
an unauthorised DoL.
The CSU have appointed a lead for quality and safety who will take a lead on the safeguarding arrangements for these
individuals.
4 4 16 ↔
Working group has been implemented with involvement
of the CSU, CHC and safeguarding team.
Group to establish resource requirements, documentation
support and training arrangements for staff.
Moderate Aug-16
51BAF Theme:
Contracts16.06.16 JR
There are no quality assurance arrangements or contracts in
place for individuals in receipt of a CHC funded domiciliary health
package of care. The risk is a commissioning gap resulting in a lack of governance arrangements
impacting from a safeguarding perspective. There is an increased risk of harm to
individuals due to a lack of quality assurance.
The CCG safeguarding team work closely with multi agency partners, individuals, and
commissioned agencies when safeguarding risks are identified. This is with the aim to improve longer term outcomes and quality
for individuals.
CSU complex cases team are sign off individual packages of care once a care plan
has been presented and meets needs.
5 4 20 ↔CSU Safeguarding team work
closely with multi agency partners.
Paper to be submitted to the collaborative commissioning
board to highlight the risk and agree future actions to
minimise.
Moderate Aug-16
52BAF Theme:
Delivery22/07/2016 CH
There is no specialist out of hours mental health support and advice for Ormskirk paediatric patients
and staff .
Ormskirk paediatrics is a place of safety.CCG in negotiations with a provider to provide Out of Hours after two other
providers have refused.CAMHS transformation work have a crisis workstream trying to address issue across
Lancashire
4 3 12 ↔
CCG in negotiations with a provider to provide Out of Hours after two other providers have
refused.CCG executives aware
Update to the action plan provided in August 2016 to be
reviewed. Moderate Aug-16
Green CompleteAmber On Track
Red Off Target
1 2 3 4 5
Rare Unlikely Possible Likely Almost Certain
5 Catastrophic 5 (Moderate) 10 (High) 15 (Extreme) 20 (Extreme) 25 (Extreme)
4 Major 4 (Moderate) 8 (High) 12 (High) 16 (Extreme) 20 (Extreme)
3 Moderate 3 (Low) 6 (Moderate) 9 (High) 12 (High) 15 (Extreme)
2 Minor 2 (Low) 4 (Moderate) 6 (Moderate) 8 (High) 10 (High)
1 Negligible 1 (Low) 2 (Low) 3 (Low) 4 (Moderate) 5 (Moderate)
Likelihood
Con
sequ
ence
West Lancashire CCG Risk RegisterCLOSED Risks - as at 06.11.15Risks removed from the active register
Lead Description ControlsOverall
Risk Score
Action Plan (AP) Updates Residual risk
Link to BAF C L R A G
1BAF Theme: KW
The Central Support Unit (CSU) do not the have the capacity /capability to ensure the CCG can fulfil statutory duties
i) Regular discussion with CSU regarding the on-going position
Continue to manage on a week by week basis during transition
Regular liaison with CSU maintained. Low
ii) CSU seeking specialist advice to address gaps in service offer
Maintain contract for specialist cover in the interim
Operational Systems
Interim specialist staff recruited by CSU for health and safety, fire and risk management.
ii) CCG have contracted specialist support directly in short term
Development of suite of policies.
Robust CSU support now in place
Inspections completed and reported to Audit Committee. No significant issues
Development of suite of policies nearing completion
2BAF Theme: JW
Impact of shortfall in recruitment to the CSU in terms of specific support posts
i)Good liaison with CSU regarding gaps in recruitment
Continue to manage on a week by week basis
Embedded team is now fully established and residual issues regarding hub functions are resolved
Low
Operational Systems
When vacancies arise any short term pressures are covered
3BAF Theme:
Contracts/Delivery
JM
The business intelligence information provided by the CSU is
insufficient for the CCG to make informed decisions. Monitoring of key performance indicators inc resilience & recovery planning.
i) KPIs are agreed and monitored for each contract. Quality Improvement Committee
collecting information from various data streams
ii) Direct feedback reports from secondary providers re trends
iii) Informal GP sharingiv) Lead Nurse in post
3 2 6
Data flows are established but still not
yet embedded.Non specific gaps as
follows: i) Lack of clarity of
future role of NHSE in managing and
influencing the system
Establish clarity of reporting activity
arrangements - quality processes now working
wellFeedback to CSU on the areas that we require
making more robust. On-going review – Jan 15
Low/Moderate
4BAF Theme: KW
Limited GP capacity to the CCG results in increased management
costs and/or limited involvement in local meetings and groups
i) Specific GP portfolios supported by CCG managers 3 2 6
Planned improvements to communications
pathways to improve efficiency,
Planned improvements to communication pathways to improve efficiency. On-
going development of engagement strategy will target better use of GP capacity – Facing the Future Together has
produced a strategy – Risk Closed – Jan 15
Low/Moderate
Score Status of AP
33 1
33 1
Operational Systems/
Engagement
ii) Planning of GP engagements to ensure maximum benefit for
CCG
On-going development of engagement strategy will target better use of
GP capacity.Continue watching brief
5BAF Theme: PJ 2013/14 Financial shortfall possible
due to:
i) On-going verbal assurances regarding the system wide allocation issues
Regular dialogue and updates on a weekly basis
CCG confident of operating within budget for 2013/24
Low
Contracts/Delivery
i) Reduction in allocation following redefinition of specialised services may compromise ability to meet contract costsi) Disaggregation of budgets from CLPCT
ii) Agreement with Chorley and Gtr. Preston CCGs regarding reallocation of resources
Lancs wide agreement achieved regarding allocation for 2013/14
Status reduced to low for this financial year
6BAF Theme: PJ
Limit on running costs resulting in lack of flexibility to manage staff shortages in financial dept.
i) Establishment is considered appropriate to meet current needs
Regular monitoring of staffing levels and capacity
Finance team fully established Low
Operational Systems
ii) Staff encouraged to work flexibly to ensure adequate cover
Examine development of matrix working to mitigate impact of staff shortages
No current pressures status remains satisfactory
Continue watching brief Risk reduced to low
For 2013/14 only
9BAF Theme:
MM(KW)
On-going pressure from MPs and interested parties to provide
information
Websi8te & Media Coverage. Public Board Meetings & joint
networking.
Additional target group contacts obtained via AGM and on-going engagement work.
Contacts continue to be gathered for the
stakeholder database.
Engagement Patient Participation Groups
Patient Focus GroupsMg View Group
Stakeholder Database established and MP relationship good at present time – Risk
Closed Jan 15
10aBAF Theme: JM
Unclear system and process to ensure the CCG receives critical timely information relating to SUIs.
i) Existing systems established in providers for management of SUIs.
Increase understanding of existing structures & systems within commissioning and providers
Information flow arrangements agreed
Contracts/Operational
Systems
ii) Handover meetings in place
Establish systems to ensure appropriate information flows and governance arrangements are in place
Chief Nurse and Quality Assurance Manager now in post
3 1 3
Low
Moderate
33 1
3 2 6
Co-ordination of information flow
between key stakeholder groups needs improving
4 1 4
10aBAF Theme:Contracts/Operational
Systems
JM
Individual Funding Request and Continuing Healthcare Requests involving WL patients.(REPLACED WITH RISK 29)
i) Existing systems established for management of IFRs & CHRs 3 3 9
Ensure appropriate data is in place for IFRs and CHCs so that the CCG can appropriately monitor process and performance
Information flow arrangements need to ensure adequate data regarding IFRs and CHRs.
Low/Moderate
10b JMLack of nursing input into quality, safeguarding and SUI operational systems
i)Development of robust quality to identify gaps
Link with Chief Nurse from neighbouring CCG to ensure links re SUIs
Chief Nurse and Quality Assurance Manager now in post
Low
BAF Theme:Contracts/OP Systems
ii) Regular reporting to Quality Committee of safeguarding/SUI and all quality metrics
Advertisement for additional nursing/quality posts in process
Reduce risk to low
11BAF Theme: KW
Ability to manage the gap in knowledge transfer during the transition process from PCT to CCG
i) attendance at transition/closedown group
Maintain contacts with PCT, services and other agencies during and after transition
Issues relating to knowledge transfer have now been resolved and no new issues have been raised.
Low
Delivery/Contracts/Operational
Systems
ii) Handover meetings scheduled
Maintain broader overview of developments to avoid unexpected problems
Risk reduced to low
iii) Legacy document re. service/agency specific knowledge & contacts
12BAF Theme:Operational
Systems
KW Lack of CCG business continuity plan
i) Currently linked to PCT continuity and recovery plans 3 1 3
Develop CCG specific continuity and recovery plans in liaison with partners and stakeholders
CSU Business Continuity Plan now received and both plans circulated to all relevant parties
Low
13 JWManaging the demands of the Local Area Team (LAT) regarding the performance of CCG contracted services
i) Established links with LAT 2 2 4Develop open culture with LAT regarding performance issues
Continuing dialogue current relationship is very positive.
Low
BAF Theme:Contracts/Delivery/
Engagement
ii) Agreement with LAT regarding CCG Annual Plan
Ensure strong links with other CCGs is maintainedSeeking to improve data around quality of GP services
Status remains satisfactory
14 JWPossible breaks in continuity of contracted services during and post transition
i) Comprehensive database of contracts in place 3 1 3
On-going verification of data relating to all contracts during transition
All contracts now in place and any transition issues resolved
Low
BAF Theme:Contracts/
Delivery
ii) PCT support to ensure all contracts are handed over to plan
15BAF Theme:Contracts/
Delivery
JWInherited risk from PCT- Lack of governance in the Brief Therapy Support Services.
i) Issues being investigated by former CL PCT CCGs 3 1 3 CCG have fully
investigated the issues.
Any issues have been resolved and sound governance arrangements are in place
Low
16BAF Theme:Operational
Systems
KWPotential impact on delivery of corporate and legal responsibilities arising from pressures on capacity.
i) CCG fully established with clearly defined roles
Robust prioritization process to be developed in relation to key priorities
New risk added December 2013) Moderate
Links to No. 21 ii) Matrix working principles established
Time management and resilience training to be developed to embed effective working practices
Prioritisation for 2014/15 needs to be progressed.
(Risk closed as relates to 2013/14) iii) PDP process in place 1-1 process in place.
iv) Informal staff and senior team meetings
PDR process about to commence for 2014/15
4 2 8
4 1 4
3 1 3
17BAF Theme:
Contracts/Operational Systems
CH
Failure of the CSU and hosted services to provide robust arrangements for meeting statutory duties relating to
safeguarding.
i) Hosted Services in place
Hosted Services proposals considered via Lancs CCG Chairs network – no agreement yet reached
Chief Nurse is now leading in this area.
Low/Moderate
ii) CSU proposalsCSU proposals via CCG managers meeting – no agreement yet reached
Multi CCG task and finish group has been established. Chief Nurse attends.
Multi CCG task and finish group to be established
Draft Safeguarding Policy received and awaiting approval at next quality committee.
Processes now in place. Risk mitigated and closed.
18BAF Theme:Operational
Systems
MM
Reduced prescribing capacity due to Lancashire Area Team (LAT) having no process in place to authorise practice based non-medical prescribers (NMP) to have prescription pads
Letter sent to LAT requesting they establish standard operating
procedures for registering new NMP with the prescription pricing division and implementing the required checks prior to issuing
prescriptions.
2 3 6 To monitor LAT’s response to letter sent
New Risk added 23.1.14Awaiting LAT response as at 6.3.14
Low
19BAF Theme:Operational
Systems JM
Failure to maintain equipment asset register by Lancashire
Teaching Hospitals for equipment issued re complex packages of care
Inform Chorley and South Ribble CCG (host CCG) and request they discuss issue at contract meeting re incident reporting and informing the CSU immediately so investigation can be undertaken.
3 3 9
Network Director contacted to discuss
procedure. Issue to be raised with CSU. Ensure procedure reviewed with
regard to incidents where CSU needs to be
informed.
CSU seeking to procure new equipment asset and maintenance system. The CCG is progressing this
issue with the CSU – Jan 15.
Risk removed from register on
8.6.15
20 PJ Not achieving financial balance in 2014/15
i) Financial system to take corrective action as required
Financial plan in draft Risk added 13.3.14 Low
BAF Theme:Contracts/
Delivery
RISK IS DUPLICATE OF 26 SO CLOSED
21BAF Theme:Operational
Systems
PJ i) Current position on running costs known
Plan for 15/16 being prepared Low/
ii) Plan for 15/16 being prepared Moderate
1)Monthly review meetings with nurse specialist
Meeting 22.7.14
2)Bi monthly meetingTrust to provide paper of up to date activity and risk.
With senior team Low
3)Process map September
4)Review Spec in August
4 1 4
4 2 8
4 2 8
Potential impact of 10% Reduction in running cost allocation from
2015/16
Cost allocation plan being prepared for 2015/16 –
Risk removed as incorporated into Risk 25
To continue with controls23 CMC
The Oxygen Service provided by Southport and Ormskirk Hospital Trust has a waiting list of existing patients to be reviewed
2 3 6
24BAF Theme:Engagement
MMLack of Engagement with NHS England Primary Care Teams
Regular meetings between chief officer and deputy primary care lead at LAT
Primary care issues raised at CCG and LAT quarterly
assurance meetingChief officer has regular 1:1s with chief executive of LAT
4 2 8
Significant issues arising from 1:1s
between chief officers and LAT to be
reported to the governing body within
the Chief Officers Report as from July
2014
Issue compacted with merger of NHS England
Area Teams.Concerns continue in relation to capacity to
fulfil any co-commissioning
requirements. Decision being made by the
Membership Council early January 2015 over
the level of Co-commissioning the CCG wished to take on. Jan
15.
Moderate
26BAF Theme:
ContractsPJ
Failure to Achieve Financial Balance 2014/15
Robust financial controls (ledger) and budget setting.
Some budget holders assigned.
Budget allocation agreed by DoH for 2014/15
4 2 8
Continuous monitoring of
financial position. Successful
implementation of QIPP schemes
On-going review of financial position – Jan
15.
Risk removed from register
on 8.6.15.
Moderate
28BAF Theme:
DeliveryKT
Uncertainty of future of CCG affecting ability to plan long
term
5 year plan finalised & submitted.
Strategic Partnership in place.Governing Body development workshop on strategic position
held.
3 3 9
5 year plan submitted and feedback
received. Risk reduced from (4x3) 12 to (3x3)
due to potential political impact
Facing the future together (FtFT) transformation
programme in place. Outcome of Gateway 1 resulted in RAG Rating of Red / Amber. Letter and Gateway Report
sent to S&O Trust outlining the current
position. Second Gateway is scheduled
for March 2015. Update Jan 15.
Risk removed from register
on 8.6.15. Risk around delivery of FFT remains
on register.
Moderate
30BAF Theme: Operational
Systems
Lack of approval/ Risk added July 2014.
implementation of an IM&T Strategy
2 3 6
Strategy approved at November 2014 GB
ModeratePK
IM&T strategy agreed in principle by CCG.
Strategy has been circulated to partner organisations.
Each member practice has an agreed programme plan
To review all feedback from circulation of
Strategy with partner organisations prior to full implementation.
Strategy being presented to governing
body for formal adoption in November.
31BAF Theme:Operational
Systems
Receive information via the CSU on all incidents reported in nursing homes. Incident
dashboard being developed. Chief nurse attends RADAR meeting with local authority Regular
attendance at Safeguarding Adult Board meetings.
Risk added July 2014.
Chief nurse meets fortnightly with safeguarding team.
Risk can now be closed as process strengthened in relation to care homes.
37BAF Theme:
Delivery
Provider has duty of care to patient.
CSU and provider meetings taking place.
Risk added October 2014
Request made to the CSU IPA team in relation to this new incident. CSU have stated that they
have no concerns regarding the safety of
this patient but are working with the provider
to resolve.Identified Risk now Closed – Jan 15.
39BAF Theme:
DeliveryMM/JM
Inappropriate placement of individual learning disability patients following Learning
Disabilities – Enhanced Support Service (LD ESS) being
transferred to CCGs as a result of CCG not having the expertise
in this area.
Further discussion at CCB meeting
3 3 9
July 15 Update - No progress with this
issued – risk unchanged.
Lead manager in post with a focus on LD -
Risk Closed - Jan 2016Medium \High
22BAF Theme:Operational
Systems
PK
Implementation of the new IT system at S&O as it may affect the delivery & quality of health
services
Monitoring of performance and quality metrics for all
metrics so any changes can be identified.
Updates on implementation going to SPB.
Contract penalties for non- submission of data.
4 2 8
On-going monitoring of performance &
quality metrics. CCG IT lead obtaining a status
report.
Data checks have been done and the CCG is
now satisfied that the new system has
bedded in appropriately. Risk Closed - Jan 2016
Moderate
9
Medium /HighPJ
Provider has given formal notice to CSU (28 day standard NHS
Contract) re patient on Sec 3 MHA as unable to meet patient's needs.
Vulnerable patient, risk of absconding risk to self and others
as well as a risk of self-harm.
4 3 12
The CSU IPA team are responsible for placing patients on behalf of the CCG. CCG to ascertain from the CSU IPA team why there have been a delay and when will they source a more suitable placement for the patient.
CHLimited assurances on nursing
home issues, -potential Safeguarding issues not identified
Southport & Ormskirk Trust to amend Policy to
ensure staff report incident relating to
Nursing Home patients. Awaiting confirmation
that this has been done
Moderate3 3
West Lancs CCG - Risk Movement Chart - Sept 2016 2
West Lancashire CCG Risk Register - Historical Risk Movement - September2016Version: 2016/17 - V1.1
Historic Risk Score
Historic Risk Score
Historic Risk Score
2
Risk Movement
May-16 Jul-16 Sep-16
7 Failure to deliver service priorities to plan including QIPP targets 9 9 9
8Lack of engagement of providers in the quality agenda leading to a lack of understanding and consistency between partners regarding outcomes of
specific schemes.
16 16 16
23
Children being discharged from CAMHS too early at 16 when they should remain with service until 18. Leading to risk of no services being received when child needs it – safeguarding issue transition into adult service where staff are not trained to provide an age appropriate service, inappropriate placement of
children on adult mental health ward.
6 6 6
25 Running costs outstrip available resources 9 9 9
27 Lack of a Referral Management Centre Strategy 9 9 9
29IPA process - financial instability, increasing costs, and assurances on quality of
assessments12 12 12
32
Patients in receipt of NHS funded care potentially at risk of harm as their health and care needs may not be addressed due to gaps in the commissioning of the CHC service in respect of care planning and case management. Lack of capacity
in CHC team resulting in routine reviews behind scheduled.
12 12 8
33
Decisions taken on referrals into MASH not informed by relevant health information and potential therefore that harm and risks not fully recognised leading to poorer outcomes for children/families and vulnerable adults. No
agreement for the on-going funding of the Lancashire multi-agency safeguarding Hub (MASH). Insufficient health contribution will impact on
timeliness of information sharing and decision making and may result in poorer outcomes for children and adults at risk.
6 6 6
34
Statutory health assessments for children looked after are not undertaken within statutory timescales and may result in the child not achieving their full potential as individual health needs not identified and addressed in a timely
manner.
4 4 4
35Services users are potentially at risk of harm due to unlawful deprivation of
liberty within hospital care home and supported living following the Cheshire West Judgement in March 2014.
12 12 12
36 Lack of commissioning policies to drive individual patient funding decisions. 9 9 9
38Inability to deliver corporate objectives as a result of Lancashire County Council (LCC) budget cuts impacting on CCG in terms of LCC service provision and the reduction in capacity and knowledge and relationships with key stakeholders.
9 9 9
Risk
Num
ber
Risk Description
West Lancs CCG - Risk Movement Chart - Sept 2016 2
Historic Risk Score
Historic Risk Score
Historic Risk Score
2
Risk Movement
May-16 Jul-16 Sep-16Risk
Num
ber
Risk Description
40Patient safety issues in relation to the cardiology services at Southport and Ormskirk Trust having a significant backlog of follow up patients not being
offered appointments 12 12 12
41Increasing financial risk in relation to the CCG taking on specialist services co-
commissioning and the associated budget.12 12 12
42 Failure to Achieve Financial Balance 2016/17 12 12 12
43Reduced services provision leading to increase demand on NHS services as a
result of £4M cut in public health funding in Lancashire12 12 12
44Risk of main ICO provider failing to meet required levels of delivery and
performance due to a number of issues including service quality, financial outlook and senior staff changes.
16 16 16
45 Failure to deliver the adult community services procurement. 9 9 9
46Increasing financial risk in relation to the CCG receiving charges for hospital Anti-coagulation Service in 2016/17. This service has previously not been charged for
separately. 10 8 10
47
There are concerns around MCA and DoLs quality assurance arrangements & compliance in relation to those patients diagnosed with learning disabilities
currently detained in secure settings where arrangements are being made for discharge as directed by Transforming Lives agenda. The risk is around
unauthorised deprivation of liberty upon discharge when the application is required to go to the Court of protection where significant backlog of
applications are being experienced further to a resource being available to manage the volume of applications to the court.
12 12 8
48
There is no case management of individuals allocated a personal health budget (PHB) with a package of care resulting in potential safeguarding risks. There is no oversight of individuals in receipt of PHB’s where the local authority have
transferred care arrangements to the CCG for a CHC package resulting in potential safeguarding risks
6 6 6
49
Arrangements are currently in place with a Lancashire County Council respite facility for children with complex needs where the CCG funds Interserve,
predominantly a provider of domiciliary packages of care to deliver a higher health component of support, which this current facility is not able to provide. CSU have not been involved in any assessment of need and the care package is
funded without any oversight or quality assurance.
0 6 6
50
There are no clear case management arrangements for those individuals who may be subject to a domestic DoL There is no oversight of individuals resulting
in potential safeguarding risks and people being subject to an unauthorised DoL.
0 16 16
51
There are no quality assurance arrangements or contracts in place for individuals in receipt of a CHC funded domiciliary health package of care. The
risk is a commissioning gap resulting in a lack of governance arrangements impacting from a safeguarding perspective. There is an increased risk of harm
to individuals due to a lack of quality assurance.
0 16 16
52There is no specialist out of hours mental health support and advice for
Ormskirk paediatric patients and staff .0 12 12
Integrated Business Report West Lancashire Clinical Commissioning Group Governing Body meeting – 27 September 2016
Agenda item no: WLCCGB 09/16/8
WEST LANCASHIRE CLINICAL COMMISSIONING GROUP GOVERING BODY REPORT
DATE OF BOARD MEETING: 27 September 2016 TITLE OF REPORT: Integrated Business Report BRIEFING POINTS: This report provides summary information on the financial
and activity performance of West Lancashire Clinical Commissioning Group for July 2016 and a financial position for August 2016. Quality and performance analysis is also provided for community based targets and for the Southport and Ormskirk Hospitals.
Does this report / its recommendations have implications and impact with regard to the following:
A. Commissioning Board’s Aims and Objectives 1. Quality (including patient safety, clinical effectiveness and patient
experience) – please outline impact Yes
The report outlines quality and performance issues relevant to the CCG and describes key actions to address these.
2. Commissioning of hospital and community services – please outline impact
Yes
The report includes financial and activity information in relation to commissioned services and highlights areas of risk and actions.
3. Commissioning and performance management of GP Prescribing – please outline impact
No
4. Delivering Financial Balance – please outline impact Yes The report summarises the financial position of the CCG and highlights areas of financial risk.
5. Development of the commissioning group as a commissioning organisation – please outline impact
Yes
This report will support the CCG in developing clear and credible plans. B. Governance – please outline impact 1. Does this report:
• provide the Commissioning Board with assurance against any of the risks identified in the assurance framework
• have any legal implications • promote effective governance practice
Yes
Links to financial risks. 2. Additional resource implications
(either financial or staffing resources) No
3. Health Inequalities Yes Links to health outcomes framework (all five domains) 4. Human Rights, Equality and Diversity Requirements No 5. Clinical Engagement No 6. Patient and Public Engagement No REPORT PREPARED BY: Paul Kingan, Chief finance officer
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West Lancashire Clinical Commissioning Group Integrated Business Report
September 2016 (Reporting Period July 2016)
2 | P a g e
TABLE OF CONTENTS
1 Executive Summary 3
2 Financial Position 4
3 QIPP 7
4 Planned Care: Referrals 8
5 Planned Care: eReferrals Service 9
6 Planned Care: Acute Contract 10
7 Unplanned Care: Acute Contract 11
8 Prescribing 13
9 Lancashire Care Foundation Trust (LCFT) Activity 15
10 Quality and Performance
a WL CCG Performance Dashboard 18
b Southport & Ormskirk hospitals NHS Trust Integrated Performance Dashboard 22
c Areas of Under-Performance 24
d Patients Waiting by Weeks 26
f Friends & Family Test 28
g Safety Thermometer
29
11 Complaints
GP Comments, Concerns & Issues with Healthcare Providers 29
12 Serious and Untoward Incident Reporting
30
3 | P a g e
1. Executive Summary This report provides summary information on the activity performance of West Lancashire Clinical Commissioning Group for July 2016 and a financial position as at August 2016. Quality and performance analysis is also provided for community based targets and for Southport and Ormskirk Hospitals NHS Trust. CCG Position Highlights
OVERALL POSITION Footprint CCG delivery of financial duties CCG CCG forecast CCG DEMAND GP referrals CCG Other referrals CCG PLANNED CARE Total planned care PBR CCG UNPLANNED CARE Total unplanned care PBR CCG PRESCRIBING Prescribing Budget CCG
CCG Key Performance Indicators YTD
NHS Constitution indicators Footprint RTT 18 Weeks wait (admitted) CCG
A&E 4 hours CCG
Cancer Waits 62 days CCG
Ambulance Category A Calls CCG Other key targets Friends and Family CCG
MRSA attributable to CCG CCG
C. difficile CCG
Cancer 14 day urgent target –breast CCG
Key information from this report NHS West Lancashire CCG As at August 2016 the CCG is forecasting a surplus of £1.510m, in line with the 1% target (£1.510m) required by NHS England. Indicative performance to the end of July 2016 against the planned care element of all contracts is under plan by £105k. The performance over the same period against the planned care element of the Southport and Ormskirk contract only is under plan by £382k. Indicative performance to the end of for May 2016 against the unplanned care element of all contracts is over plan by £207k. Unplanned care performance for the same period against the Southport and Ormskirk Hospital contract is over plan by £90k. Performance issues The CCG has again under achieved on Ambulance - All Category A call out indicators. The 4 hour A & E target continues to be an issue with S & O, Wrightington, Wigan and Leigh and Lancashire Teaching Hospitals Trusts all failing the 95% target. The cancer 62 day and 2 week breast targets are underperforming as are 2 of the 31 day cancer targets.
4 | P a g e
2. Financial Position
The following table summarises the financial position for West Lancashire CCG at Month 5 2016/17.
As at Month 5 the CCG has a year to date underspend of £0.629m, which is forecast to increase to £1.510m by the end of the financial year. This is consistent with the delivery of a 1% surplus as required by NHS England.
BudgetExpenditur
eVariance Budget Forecast
Forecast Variance
£000 £000 £000 £000 £000 £000
Acute servicesAcute 32,969 33,148 179 79,127 79,556 429 Ambulance services 1,297 1,297 - 3,113 3,113 - Sub-total Acute Services 34,267 34,445 179 82,240 82,669 429
Mental Health Services Mental Health 4,689 4,701 13 11,253 11,283 30 Learning Difficulties 375 456 81 900 1,095 195 Sub-total Mental Health Services 5,064 5,158 94 12,154 12,379 225
Community Health ServicesCommunity 6,583 6,642 60 15,798 15,941 143 Sub-total Community Services 6,583 6,642 60 15,798 15,941 143
Continuing Care ServicesIndividual Packages 3,925 3,997 72 9,419 9,592 173 Funding Nursing Care 383 508 125 919 1,219 300 Sub-total Continuing Care Services 4,308 4,505 197 10,339 10,812 473
Primary Care ServicesPrimary - Local Enhanced Services 456 469 13 1,095 1,125 30 Urgent Care 597 594 (3) 1,432 1,425 (7)GP IT 244 244 - 585 585 - Prescribing 8,048 8,413 365 19,316 20,192 876 Sub-total Primary Care Services 9,345 9,719 375 22,428 23,327 899
Other Budgets/ReservesRunning Costs 1,005 1,005 - 2,413 2,413 - NHS Property Services 358 316 (42) 859 759 (100)Other Corporate Costs 398 398 - 955 955 - Other Programme Services 554 557 3 1,329 1,337 8 Seasonal Resilience - - - - - - Non Recurrent Schemes 613 - (613) 1,471 - (1,471)Contingency 314 - (314) 755 - (755)Reserves (527) (465) 62 (1,265) (1,116) 149 Sub-total Other Programme Services 2,715 1,812 (904) 6,517 4,348 (2,169)
Total - Commissioning services 62,281 62,281 0 149,475 149,475 0
Planned Surplus 629 - (629) 1,510 - (1,510)
Grand Total 62,910 62,281 (629) 150,985 149,475 (1,510)
Year to Date Full Year
NHS West Lancashire CCGFinancial Position as at Month 5 2016/17
5 | P a g e
Key points to note are: Acute Services – Month 4 activity monitoring information indicates forecast overperformance of £537k. This can be attributed to the Ramsay Healthcare contract where activity is significantly in excess of planned levels and on current trends will generate an overspend of £752k (19.5%) against the contract value. Pain management accounts for £397k of this cost pressure; Gynaecology £127k. Expenditure is also forecast to be above plan at Fairfield Hospital (£114k) and Wrightington, Wigan and Leigh NHS Trust (£113k). Underspends at several Trusts help to partially mitigate the above variances, including at Southport & Ormskirk Hospitals Trust (£282k) and Salford Royal NHS Trust (£124k), giving an overall net overspend across the sector of £429k. Learning Difficulties – The CCG has evaluated the likelihood of realising the QIPP savings detailed in its financial plan. The CCG believes that it is not the responsible commissioner for a high cost patient based in Calderstones Hospital and that another CCG should assume responsibility for payment. However there is a legal process to follow and as yet no definite date of conclusion. Given the ongoing uncertainty the CCG believes that it is prudent not to account in full for the released costs until it receives further information on the outcome of proceedings.
Prescribing – The performance of the Prescribing budget, and the delivery of planned QIPP savings of £835k, will be critical to the CCG delivering its financial targets in 2016/17. However year to date expenditure for Q1 is 6.3% higher than the equivalent period last year, the largest increase in Lancashire. The CCG calculates that this could result in a £911k overspend by the end of the financial year. Funded Nursing Care – The NHS contribution towards the cost of a place in a care home with nursing has been increased, following an independent review, by 40% to £156.25 per week. The increase has been backdated to 1 April 2016 for individuals who were in receipt of NHS-funded nursing care from that time. This has caused an unexpected cost pressure for the CCG in the magnitude of of £300k.
1% Non Recurrent Reserve - The CCG is required to set aside 1% of its programme allocation for this. In a departure from previous financial years, HM Treasury has stipulated that all commissioning organisations must ensure that this reserve is fully uncommitted at the start of the financial year. By commissioning organisations not committing their 1% monies, this creates approximately £800m of additional headroom to mitigate financial risk in the overall NHS position. Approval for spending of the 1% non-recurrent monies during the year will also be subject to approval by HM Treasury but this will be contingent on the outcome of a review of the in-year NHS financial position. The CCG has therefore assumed that there will be no expenditure against this reserve in 2016/17 (and NHS England do not utilise it for any other purpose). The resultant underspend has been factored into the financial position. Reserves – Included within this figure are negative budgets (and associated planned savings) relating to QIPP schemes that have not yet been applied to individual operational budget lines. Examples of such schemes are Outpatient attendance reductions and the redesign of MSK pathways. These budgets will be transferred out of Reserves when the CCG has greater certainty of the impact of the schemes on specific provider contracts. There is a serious risk that if the QIPP schemes do not progress the negative budgets cannot be moved resulting in a significant financial pressure on this line.
Contingency – The CCG is holding 0.5% of its allocation as a contingency (as per NHS England’s 2016/17 Business Rules). Given the financial pressures that have already arisen, the contingency has been deployed in full to deliver a balanced financial position at Month 5. The CCG is still reporting achievement of the business rules at month 5, however we expect this position to change at month 6, with the forecast surplus likely to fall below the 1% requirement. As part of the NHSE reporting process the CCG understands it needs to submit a recovery plan in September, before it can adjust its full year forecast.
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The CCG’s annual budget as at Month 3 is £150.985m. This is derived as follows:
In addition to its duty on delivering a 1% surplus the CCG has other financial responsibilities: Better Payment Practice Code (BPPC) The Better Payment Practice Code requires the CCG to aim to pay valid invoices by the due date or within 30 days of receipt of a valid invoice, whichever is later. The CCG’s target is for 95% of invoices (both by value and volume) to be paid within this criteria. Below is the 2016/17 cumulative performance against these requirements:
Cash Management The CCG must not utilise more cash than it has available, both on a monthly and annual basis. It has to manage its cash flow accordingly whilst ensuring there are sufficient funds available to pay suppliers and meet the BPPC targets listed above.
NHS England issued the CCG with a Maximum Cash Drawdown (MCD) for 2016/17 of £149.189m
£000Opening Programme Allocation 146,593 Opening Running Cost Allocation 2,370 Return of 2014/15 Surplus 1,464 Recurrent 2015/16 Adjustments (post Allocation Setting) 488 Eating Disorders 60 GP Development - Reception and Clerical 10 Total resources (as at Month 5) 150,985
TargetCumulative
Performance to date
On Target for Year
End
Value 95% 98.37Volume 95% 99.44
Value 95% 99.93Volume 95% 99.82
NHS
Non-NHS
£000Maximum Cash Drawdown 2016/17 149,189
YTD Cash Drawdown 52,350 CHC Risk Pool Contribution 94 YTD Oxygen and Prescribing 8,040
Cash Available for Remainder of Year 88,705
7 | P a g e
3. QIPP Each year the CCG is faced with balancing the rising demand for services with a finite amount of resources. Therefore the CCG seeks to negotiate the best value for money it can achieve from its contracts, whilst also seeking to achieve Quality, Innovation, Productivity and Performance (QIPP) gains. These savings maybe either cash or non-cash releasing but need to be recurrent if the CCG is to see a sustainable financial benefit. 15 QIPP schemes have been identified for 2016/2017 and a description, expected savings, confidence levels, current indicative savings and project status for each are shown in the table below.
The figures shown in the table above will continue to be reviewed, refined and updated as the schemes develop and further analysis of supporting data is carried out.
Lead Expected Savings
Likelihood of savings being
delivered
Likely Savings
£k % £k
1 PrescribingSavings from more efficient and effective prescribing of medicines Nicola Baxter 835 90% 752 Medicines waste campaign to be launched
2 Right Care Right ValueSavings identified from the Right Care opportunities analysis Paul Kingan 265 50% 133
Right Care data has been analsyed and potential opportunities are being considered
3 Outpatient attendance reductionsSavings from reduction in outpatients as a result of improving first to follow-up ratios Jackie Moran 165 50% 83
4 Estates reviewReduction in the costs of running estates and better util isation George Hurst 100 50% 50
CCG are l iaising with NHS Property Services to pursue efficencies on Ormskirk site
5 Contract coding challengesChallenge coding for outpatient Orthopaedic procedures Paul Kingan 375 90% 338
CFO meeting with S&O Director of Finance on 21st September - CCG to reiterate their
stance on this matter.
6 Packages of Care review Reduction in CHC placement costs Paul Jones 325 90% 293Obtain accurate monitoring data from M&L
CSU
7 Musculoskeletal Redesign ProjectSavings from referrals, inpatient and follow-ups avoided Amanda Gordon 449 80% 359
CCG to decide level of collaboration with Southport & Formby CCG and speed of
implementation
8LD Discharges to community placements Reduction in LD case costs
Tracey Callaghan-Hayes 375 25% 94
Ongoing process to establish responsible commissioner
9 COPD Savings in complex cases Sandra Bonner 340 80% 272Respiratory Nurse establishing new
Community Service
10 Primary Care (Care Homes) Reduce urgent care costsCharlotte
McAllister 125 75% 94
11 IT Strategy Schemes FLO Telehealth - reduction in patient admissions Chris Russ 60 50% 30
12 Other Non Elective Schemes Includes Acute Visiting ServiceCharlotte
McAllister 384 50% 192
13 Community Gynaecology Service Scheme in development Jackie Moran 50 50% 25
14 Community Dermatotogy Service Scheme in development Jackie Moran 50 50% 25
15 Revised IPA System Develop discharge to assess service model Mike Maguire 250 50% 125
4,148 69% 2,862
Update/Actions Pending
Total
ID Scheme Name Description
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4. Planned Care: Referrals
The following section provides an overview of Referrals to secondary care up to May 2016 compared to the Referrals trend across this Financial Year and last Financial Year.
Chart A (below) shows numbers of referrals for West Lancashire CCG across all Lancashire providers and Merseyside providers. Referrals to Fairfield are now included as the Trust has been submitting data for all of 2015/16 so like for like comparisons can be made. Overall there has been a decrease by 321 (1.6%) in all sources of referrals YTD from same period last year. GP referrals have reduced by 2.8%, a decrease of 353 when comparing same period 2015/16 to 2016/17. Hospital referrals have reduced by 5.4% (280 referrals) and other referrals have increased by 11.4% (312 referrals). The increase in other referrals is spread across many specialties but with particular increase in midwife episodes, general medicine and orthotics. However, some of these apparent increases in other may be due to a change in recording from other referral sources/specialty codes.
Overall, the main overperforming specialties are optometry (202), general surgery (133), audiological medicine (129) and orthotics (92).
Overall reductions in referrals have occurred in a number of specialties but particularly in physiotherapy (-235), trauma and orthopaedics (-170) and oral surgery (-142), obstetrics (-132) and clinical psychology (-121).
Further analysis is required to understand these shifts in more detail.
Chart A: Referrals 2016/17 Compared to 2015/16 (Including Mersey Trusts)
Our main provider Southport & Ormskirk Trust has seen referrals decrease by 2.8% in all sources (-358 referrals); GP referrals have decreased by 422 (-5.2%) compared to same period last year. The overall market share in total referrals for Southport & Ormskirk Trust has decreased by 0.78% compared to same period last year.
The specialties experiencing increases at S & O are Optometry 110.4% increase (202 refs), Cardiology 46.2% increase (129 refs), Audiological Medicine which has only been recorded since July 2015 and accounted for a total of 129 refs, General Surgery 19.2% increase (96 refs). The specialties experiencing decreases at S & O are Trauma & Orthopaedics 17.8% decrease (-272 refs), Physiotherapy 12.2% decrease (-239 refs), Oral Surgery 37.5% decrease (-169 refs) and Obstetrics 44.3% decrease (-129 refs).
Our Second main provider Wrightington, Wigan & Leigh NHS Foundation Trust (WWL) has seen a 7% decrease in GP referrals from 2015/16 to 2016/17. The most significant decreases in GP referrals have been in Rheumatology 53 refs (-74.7%), Breast Surgery 29 refs) (-16.4%) and Cardiology 27 refs (-43.6%). Significant increases in GP referrals have
0
1000
2000
3000
4000
5000
6000
Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar
Referrals By Source - Financial YTD Comparison Year on Year
GP 20-15-16 HOSPITAL 2015-16 OTHER 2015-16 Total 2015-16
GP 2016-17 HOSPITAL 2016-17 OTHER 2016-17 Total 2016-17
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occurred in Respiratory Medicine 20 refs (+87%), General Surgery 18 refs (+128.6%) and Trauma & Orthopaedics 17 referrals (+5%). Overall market share for WWL total referrals decreased by 0.13% compared to same period last year.
University Hospitals Aintree Trust has seen a decrease in GP Referrals of 152 (-25.2%) when comparing to same period last year. This is mostly attributed to Respiratory Medicine a decrease of 61 GP referrals (-71.1%), Breast Surgery with 45 fewer GP referrals (-25%), Cardiology with 21 fewer GP referrals (-52.3%) and ENT with 21 fewer GP referrals (-40%). Overall market share for University Hospitals Aintree total referrals decreased by 0.7% compared to same period last year.
St Helens & Knowsley has seen an increase of 40 GP Referrals (16.95%) when comparing to same period last year. This is mainly attributed to Dermatology (increase of 14, 46.7% in period) and General Surgery (increase of 12, 500% in period). Overall market share for St Helens & Knowsley total referrals increased by 0.19% compared to same period last year.
There’s an increase in GP referrals to Ramsay, particularly in Trauma & Orthopaedics 98 additional GP referrals (+21.8%), Gynaecology 70 additional GP referrals (+33.5%), Gastroenterology 40 additional GP referrals (+14.9%), Urology 38 additional GP referrals (+34.2%) and Pain Management 37 additional GP referrals (+43,5%) when comparing to same period last year. Overall market share of total referrals for Ramsey increased by 1.94% compared to same period last year.
5. Planned Care: eReferrals Service (previously Choose & Book) The E-Referral Service (e-RS) utilisation data for NHS West Lancashire CCG practices based on Secondary Use Service (SUS) data for June and July shows a decline to 92.1% in July. Business Intelligence are currently investigating this drop in performance which may be related tochanges in the eRefarals monitoring process.
The e-Referral quality premium has been designed to Increase the proportion of GP referrals made by e-referrals. The referral quality premium (QP) is worth £1 per head of patient population which is currently about £112,501. In order for NHS West Lancs CCG to achieve the new 2016/17 QP the CCG will need to either:
• Meet a level of 80% by March 2017 (March 2017 performance only) and demonstrate a year on year increase in the percentage of referrals made by e-referrals (or achieve 100% e-referrals), or;
• March 2017 performance to exceed March 2016 performance by 20 percentage points.
Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar2014/15 52.4% 50.0% 50.4% 48.5% 47.2% 54.4% 58.8%2015/16 63.0% 71.7% 71.2% 77.9% 80.8% 81.7% 83.7% 91.2% 83.5% 94.2% 97.8% 96.6%2016/17 99.5% 95.1% 90.6% 92.1%
0.4
0.5
0.6
0.7
0.8
0.9
1
eReferrals as a Percentage of Total GP Referrals
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Monthly Activity Return (MAR) data for March 2016 which will be used as the stands at 76%, requiring an increase in e-RS Utilisation of 4% for up to March 2017 to achieve 80% e-RS utilisation. Work to meet the overall aims of improving the efficiency of referral processes for practices and local providers has continued. Input from the Health and Social Care Information Centre (HSCIC) has commenced and they are in the process of compiling reports to identify problem areas that can be addressed to improve e-RS utilisation as reported using Monthly Activity Return (MAR) data which shows a lower utilisation than SUS data. Work to understand SUS and MAR data has been started with the CCG Business Intelligence staff so that reports future will be more meaningful. 6. Planned Care: Acute Contract
All Providers Performance at month 4 against the planned care element of the contract is shown below in table 2a. This shows the planned care element of the contracts is under plan by £105K. While the greatest variance is seen in OPPROC POD (-£128K), the greatest specialty level variance at a single provider is in EL POD 110: Trauma & Orthopaedics at Southport and Ormskirk Hospital NHS Trust (-£103K). Table 2a: Month 4 Planned Care – All Providers
Southport and Ormskirk Hospitals NHS Trust
Performance at month 4 against the planned care element of the contract is shown below in table 2b. This shows the planned care element of the contract is under plan by £382K.The most significant variance is in OPPROC POD. The most significant variances within the OPPROC POD is 110: Trauma and Orthopaedics (-£103K. Table 2b: Month 4 Planned Care at Southport and Ormskirk Hospitals
Plan Actual Variance Plan Actual VarianceDC 5,190 5,189 -1 £3,703,549 £3,769,707 £66,158EL 835 777 -58 £2,356,856 £2,281,044 -£75,812ELXBD 344 298 -46 £77,356 £67,616 -£9,740OPFA 9,091 9,200 109 £1,427,280 £1,433,639 £6,359OPFUP 20,934 21,399 465 £1,997,217 £2,001,780 £4,564OPPROC 8,598 8,022 -576 £1,537,917 £1,410,012 -£127,905DIAGNOSTIC IMAGING 4,042 4,210 167 £364,141 £395,353 £31,212Grand Total 49,036 49,096 60 £11,464,317 £11,359,152 -£105,165
Point of Delivery Activity 2016/17 Cost 2016/17
Plan Actual Variance Plan Actual VarianceDC 3,102 2,972 -130 £1,816,745 £1,756,922 -£59,822EL 389 356 -33 £959,219 £881,241 -£77,979ELXBD 128 77 -51 £28,288 £16,985 -£11,303OPFA 4,804 4,578 -226 £742,007 £693,225 -£48,782OPFUP 12,404 12,385 -19 £1,187,862 £1,155,138 -£32,724OPPROC 6,052 5,403 -649 £1,098,058 £944,624 -£153,434DIAGNOSTIC IMAGING 2,076 2,025 51- £167,966 £170,469 £2,503Grand Total 28,955 27,796 1,159- £6,000,145 £5,618,604 -£381,541
Point of Delivery Activity 2016/17 Cost 2016/17
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All Other Providers
Performance at month 4 against the planned care element of the contract is shown below in table 2c. This shows the planned care element of the contract is over plan by £276K. This over performance is primarily seen in DC POD (£126K). Table 2c: Month 4 Planned Care at All Other Providers
Plan Actual Variance Plan Actual VarianceWrightington, Wigan & Leigh 5,252 5,179 -73 £1,523,748 £1,512,465 -£11,283Ramsay Operations (UK) 3,865 4,869 1,004 £1,195,869 £1,435,343 £239,475Aintree University Hospitals 3,486 3,519 33 £754,670 £722,719 -£31,951Lancashire Teaching Hospitals 1,168 1,252 84 £250,502 £234,364 -£16,138St Helens and Knowsley Hospitals 1,396 1,449 53 £370,316 £388,512 £18,196Royal Liverpool and Broadgreen Hospitals 2,276 2,300 24 £517,252 £560,751 £43,499
Other Providers 2,638 2,732 94 £851,816 £886,394 £34,578Grand Total 20,080 21,300 1,220 £5,464,172 £5,740,548 £276,376
Provider Activity 2016/17 Cost 2016/17
Key Risks and Actions Underperformance has continued since the July 2016 IBR (May data), although the level of underperformance has reduced. In May, the underperformance was 1.6% of plan whilst it has now fallen to 1% of plan. The overall underperformance in planned care is mainly driven by significant underperformance at Southport and Ormskirk Hospitals particularly in T & O (outpatient procedures and elective inpatients and day cases). There is evidence that this underperformance, particularly in outpatient procedures is decreasing. T & O outpatient procedures was the subject of an audit and following conclusion of the discussions with the Trust, the plan and actual activity may be adjusted. There is significant overperformance at Ramsay in most specialties. In some specialties such as Pain Management this can be partially attributed to Ramsay having formerly recorded activity against a limited basket of specialties. The financial effect of this change is partially covered by a contract adjustment. Some of this growth may be accounted for by Ramsay providing additional clinics within the West Lancashire CCG footprint.
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7. Unplanned Care: Acute Contract
All Providers Performance at month 4 against the unplanned care element of the contract is shown below in table 3a. Overall the unplanned care element of the contract is over plan by £203K. This is caused by significant over performance in NEL POD which is £270K over plan. Please see below for variances for Southport and Ormskirk Hospitals Foundation Trust. Table 3a: Month 4 Unplanned Care at All Providers
Southport and Ormskirk Hospitals NHS Trust Performance at month 4 against the unplanned care element of the contract is shown below in table 3b. Overall the unplanned care element of the contract is over plan by £90K. This is largely due to an over performance in NEL 300: General Medicine which is £136K over plan. Table 3b: Month 4 Unplanned Care at Southport and Ormskirk Hospitals
All Other Providers Performance at month 4 against the unplanned care element of the contract is shown below in table 3c. Overall the unplanned care element of the contract is over plan by £113K. The most significant variance is general over-performance at Wrightington, Wigan & Leigh which is £164K over plan.
*Includes points-of-delivery as per Tables 3a and 3b
Plan Actual Variance Plan Actual VarianceAccident and Emergency 10,222 10,350 128 £1,208,613 £1,220,689 £12,076Non-Elective Short Stay 422 434 12 £317,388 £297,863 -£19,525Non-Elective 2,823 2,881 58 £5,157,224 £5,426,767 £269,543Non-Elective Excess Beddays 1,484 1,406 -78 £325,979 £302,611 -£23,368Non-Elective Non-Emergency 429 636 207 £839,446 £807,898 -£31,548Non-Elective Non-Emergency Excess Beddays 129 63 -66 £36,339 £21,763 -£14,576Non-Elective Same Day Emergency Care 235 239 4 £191,619 £206,622 £15,003Non-Elective Threshold Adjustment 0 0 0 -£3,022 -£7,259 -£4,237Grand Total 15,744 16,009 265 £8,073,587 £8,276,954 £203,367
Provider Activity 2016/17 Cost 2016/17
Plan Actual Variance Plan Actual VarianceAccident and Emergency 8,001 8,001 0 £949,399 £940,438 -£8,960Non-Elective Short Stay 285 291 6 £220,501 £205,134 -£15,367Non-Elective 2,251 2,249 -2 £3,938,815 £4,074,423 £135,607Non-Elective Excess Beddays 1,205 1,157 -48 £260,076 £247,410 -£12,666Non-Elective Non-Emergency 375 586 211 £699,121 £687,623 -£11,498Non-Elective Non-Emergency Excess Beddays 70 62 -8 £19,816 £21,387 £1,572Non-Elective Same Day Emergency Care 188 176 -12 £154,443 £155,774 £1,331Grand Total 12,374 12,522 148 £6,242,171 £6,332,190 £90,019
Provider Activity 2016/17 Cost 2016/17
Plan Actual Variance Plan Actual VarianceWrightington, Wigan & Leigh 1,333 1,692 359 £668,452 £832,776 £164,324Aintree University Hospitals 567 630 63 £340,876 £399,964 £59,088Lancashire Teaching Hospitals 441 262 179- £189,604 £156,176 -£33,428Royal Liverpool and Broadgreen Hospitals 271 267 4- £175,262 £154,778 -£20,484St Helen's & Knowsley Hospitals NHS Trust 229 169 60- £112,898 £88,648 -£24,250
Other Providers 529 467 62- £344,324 £312,421 -£31,903Grand Total 3,370 3,487 118 £1,831,416 £1,944,763 £113,348
Provider Activity 2016/17 Cost 2016/17
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Key Risks and Actions. Since the July 2016 IBR (activity to May 2016) the indicated level of overperformance for unplanned care has decreased from 8.6% to 2.5% of total value. Partially this can be explained by a higher volume of fully coded data being included and this reducing the influence of distorting features such as artificially high tariff figures being applied to uncoded activity in T&O and General Medicine at Southport and Ormskirk Hospitals. There are still issues from uncoded activity at Southport and Ormskirk Hospitals, a best estimate being that £55K of the overperformance is still caused by this issue. There appears to be significant overperformance at Southport and Ormskirk Hospitals in a number of high cost HRGs in General Medicine which are currently being investigated. Unplanned care is also significantly over at WWL. There appears to be a 25% increase in AandE activity with commensurate increases in Non Elective activity. These increases are under investigation.
8. Prescribing In order to address the West Lancashire CCG Medicines Management duties as defined by the National Prescribing Centre’s Medicines Management Competency Framework, West Lancashire CCG has set up a Medicines Management Committee (MMC). The MMC’s remit encompasses all systems, policies and procedures designed to ensure the safe, secure and cost-effective use of medicines. Below is a summary of prescribing costs. West Lancashire CCG is showing a cost growth of 1.76% in 2016/17. Practices in West Lancashire CCG have the 4th lowest spend per APU of all CCGs across Lancashire as shown in the table below. However, it is too early in the year to make any robust comparisons.
The prescribing position by practice is shown in the table overleaf. The medicines management team are in the process of having discussions with practices about their end of year position.
CCG
Total Spend for Previous Year (15/16)
Previous YTD Spend(15/16)
Current YTD Spend(16/17)
£ Growth(Forecast Outturn v
15/16 Spend)
% Growth(Forecast Outturn v
15/16 Spend)
% List Size Growth
(APU Jun15 v Jun16)
Current YTD Spend per APU
(16/17)
BLACKBURN WITH DARWEN £27,044,573 £6,496,595.75 £6,699,506.84 -£574,784.05 -2.13% 1.45% £12.17
BLACKPOOL £33,610,511 £8,424,718.58 £8,191,559.20 -£1,225,348.82 -3.65% 0.46% £12.55
CHORLEY & SOUTH RIBBLE £28,955,105 £6,998,915.79 £7,083,073.41 -£785,750.89 -2.71% 3.49% £10.61
EAST LANCASHIRE £63,206,170 £15,475,883.60 £15,719,149.92 -£737,497.52 -1.17% 1.04% £11.79
FYLDE & WYRE £29,085,978 £7,054,014.08 £7,087,568.49 -£913,990.94 -3.14% 0.96% £10.96
GREATER PRESTON £33,130,075 £7,949,701.83 £8,324,373.84 £24,104.22 0.07% 1.37% £11.47
LANCASHIRE NORTH £25,668,849 £6,608,687.62 £6,383,041.42 -£388,348.50 -1.51% 0.84% £10.90
WEST LANCASHIRE £18,688,306 £4,510,953.87 £4,796,580.88 £328,727.21 1.76% 1.19% £11.11
Grand Total £259,389,565 £63,519,471.12 £64,284,854.00 -£4,272,889.28 -1.65% 1.80%
Prescribing Budget CCG Comparison
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Medicines Management
To address the growth in items and cost west Lancashire CCG have identified using national and local evidence that wasted medicines cost the NHS a significant amount of money. West Lancashire CCG member practices have committed to reduce waste through reviewing and improving the current ways that prescriptions are ordered and issued to ensure that these systems are safe, convenient to the patients and cost effective. The project also includes a waste strategy to support practice staff to reduce waste and a communication strategy that will educate patients, this will be a rolling program. OptimiseRx is currently installed in 18 practices across west Lancashire, this is a prescribing support tool that advises the prescriber at the point of prescribing of safety issues, good practice, and cost effective alternatives. The system has been installed now for 2 months and has saved £20 000 (annualised savings)
Prescriber Code Practice
Annual Budget
Forecast Outturn (16/17)
£ Over/Under Spend
(Variance)
% Over/Under Spend
(Variance)
% Uplift (16/17
Budget v 15/16
Spend)
Forecast Outturn
/APU
% Growth(Forecast Outturn v
15/16 Spend)
% List Size Growth
(APU This month 2016
v Same month 2015)
P81201 Practice ASHURST PRIMARY CARE £646,087 £612,965 -£33,122 -5.13% 0.97% £38.70 -4.20% 2.62%
P81695 Practice AUGHTON SURGERY £925,119 £866,679 -£58,440 -6.32% 0.48% £36.55 -5.86% 1.81%
P81112 Practice BEACON PRIMARY CARE £2,045,309 £2,053,060 £7,751 0.38% 0.49% £52.79 0.87% -1.75%
P81138 Practice BURSCOUGH FAMILY PRACTICE £484,899 £450,437 -£34,462 -7.11% 0.94% £37.34 -6.24% 2.01%
P81727 Practice COUNTY ROAD SURGERY £427,487 £422,542 -£4,945 -1.16% 0.49% £52.77 -0.67% 0.18%
P81136 Practice DR A BISARYA £409,757 £410,412 £655 0.16% 0.99% £40.91 1.15% 0.27%
P81774 Practice DR A LITTLER £1 £360,015 £360,014 36001400.00% -100.00% £40.06 -7.09% 0.51%
P81764 Practice SKELMERSDALE FAMILY PRACTICE(CLOSED) £0 £42,549 £42,549 0.00% -100.00% £4.78 -83.85% 2.01%
P81121 Practice BIRLEYWOOD HEALTH CENTRE £303,677 £343,210 £39,533 13.02% 1.00% £58.95 14.15% 2.77%
P81208 Practice SKELMERSDALE PRACTICE £1,984,715 £1,689,263 -£295,452 -14.89% 51.00% £62.72 28.52% 2.40%
P81084 Practice HALL GREEN SURGERY £1,263,625 £1,276,199 £12,574 1.00% 0.48% £41.79 1.48% 1.50%
P81646 Practice LATHOM HOUSE SURGERY £851,396 £825,227 -£26,169 -3.07% 0.49% £46.34 -2.60% -1.37%
P81039 Practice MANOR PRIMARY CARE £672,575 £690,527 £17,952 2.67% 0.99% £43.67 3.69% -0.33%
P81758 Practice MATTHEW RYDER CLINIC £406,441 £379,584 -£26,857 -6.61% 0.49% £37.75 -6.15% 3.01%
P81772 Practice NORTH MEOLS MEDICAL CENTRE £630,057 £699,732 £69,675 11.06% 0.48% £51.82 11.59% 5.92%
P81014 Practice ORMSKIRK MEDICAL PRACTICE £1,723,298 £1,737,260 £13,962 0.81% 0.48% £46.23 1.29% 2.06%
P81096 Practice PARBOLD SURGERY £1,090,567 £1,096,319 £5,752 0.53% 0.49% £37.36 1.02% 1.46%
P81041 Practice PARKGATE SURGERY £1,063,265 £1,063,435 £170 0.02% 0.98% £37.67 0.99% 2.21%
P81674 Practice STANLEY COURT SURGERY £888,725 £846,175 -£42,550 -4.79% 0.49% £39.67 -4.32% 1.14%
P81710 Practice TARLETON GROUP PRACTICE £1,201,518 £1,284,763 £83,245 6.93% 0.49% £39.77 7.45% 2.39%
P81045 Practice THE ELMS PRACTICE £883,329 £899,799 £16,470 1.86% 0.96% £36.14 2.84% -0.04%
P81177 Practice VIRAN MEDICAL CENTRE £401,376 £383,743 -£17,633 -4.39% 0.97% £34.73 -3.46% -2.95%
Y04479 Practice BRIDGEWATER CH CN WEST LANCS £10,249 £6,063 -£4,186 -40.84% 0.00% £0.00 -40.85% 0.00%
Y02609 Practice CAMHS £50,921 £66,144 £15,223 29.90% 0.00% £0.00 29.89% 0.00%
Y00580 Practice COMMUNITY PAEDIATRICS £65,876 £55,974 -£9,902 -15.03% 0.00% £0.00 -15.03% 0.00%
02G999 Practice DEPUTISING SERVICES £0 £0 £0 0.00% 0.00% £0.00 0.00% 0.00%
Y04313 Practice LCFT NMPS £535 £592 £57 10.65% -0.14% £0.00 10.50% 0.00%
Y04593 Practice LCH WEST LANCS HEART FAILURE SERVICE £1,532 £940 -£592 -38.64% -0.03% £0.00 -38.66% 0.00%
Y00972 Practice OWLS GP OOH SERVICES £0 £100,263 £100,263 0.00% -100.00% £0.00 160.25% 0.00%
Y04045 Practice SOUTHPORT & ORMSKIRK ICO NMPS WL £339,007 £353,150 £14,143 4.17% 0.00% £0.00 4.17% 0.00%
02G998 Practice UNIDENTIFIED DOCTORS £0 £12 £12 0.00% 0.00% £0.00 0.00% 0.00%
02G00 WEST LANCASHIRE £18,771,343 £19,017,033 £245,690 1.31% 0.44% £44.06 1.76% 1.19%
1 COMBINED PRACTICES £2,288,392 £2,075,022 -£213,370.00 -9.32% 21.81% £49.82 10.46% 2.37%
West Lancashire CCG Prescribing Budget Report- June 16
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9. Lancashire Care Foundation Trust Contract Activity The contract value for Lancashire Care Foundation Trust (LCFT) mental health services is £9.7m. The LCFT contract is for a range of mental health services such as rehabilitation, community mental health teams, hospital liaison, memory assessment, CAMHS child psychology and prison in-reach. Below is activity for 2016-17 by Month and Quarter up to M04.
9a Care Programme Approach (CPA) follow- up within 7 days The proportion of eligible patients followed up within 7 days is one of the performance measures on which CCG is monitored by Local Area Team. The Tables below show current West Lancashire performance with a Target of 95%.
Quarter 2Metric Apr May Jun Total JulAdult Ward Occupied Bed Days 318 416 380 1,114 317 1,431Adult/PICU Ward Admissions 11 12 6 29 10 39Adult/PICU Ward Discharges 9 10 8 27 12 39CCTT Teams - Accepted Referrals 49 43 41 133 28 161CCTT Teams - Contacts 852 867 914 2,633 746 3,379CMHT Contacts 484 437 439 1,360 473 1,833CMHT Referrals 20 4 2 26 2 28Community Restart Teams - Accepted Referrals 0 1 0 1 0 1CRHT Face to Face Contacts - 18 to 65 222 247 279 748 245 993CRHT Face to Face Contacts - Below 18 3 1 6 10 1 11CRHT Face to Face Contacts - Over 65 0 0 1 1 1 2CRHT Teams - Referrals 30 46 31 107 35 142CRHT Telephone Contacts - 18 to 65 221 253 224 698 180 878CRHT Telephone Contacts - Below 18 3 2 9 14 1 15CRHT Telephone Contacts - Over 65 5 5 2 12 3 15Criminal Justice Liaison - Contacts 20 22 15 57 18 75Eating Disorder Service - Contacts 12 8 9 29 17 46Eating Disorder Service - Referrals 4 7 7 18 6 24EIS: New EIS Patients in Year - VSMR 5378 1 0 2 3 2 5Hospital Liaison Contacts 0 19 1 20 0 20Hospital Liaison Referrals 0 3 0 3 0 3MAS Teams - Referrals 53 27 34 114 46 160Older Adult (Dementia) Ward Occupied Bed Days 30 31 30 91 31 122Older Adult (Functional) Inpatient 90 Day ReAdmis 0 0 1 1 0 1Older Adult (Functional) Inpatient Ward Admission 3 1 1 5 3 8Older Adult (Functional) Inpatient Ward Discharge 2 0 2 4 0 4Older Adult (Functional) Ward Occupied Bed Days 86 101 111 298 122 420PICU Ward Occupied Bed Days 84 62 60 206 79 285PICU Wards - Transfers In 2 0 0 2 3 5RITT Contacts 12 9 13 34 15 49RITT Referrals 0 3 3 6 2 8
Quarter 1 Year to Date
% Successful Apr-16 May-16 Jun-16 Jul-16 Aug-16 Sep-16 Oct-16 Nov-16 Dec-16 Jan-16 Feb-16 Mar-16 Q1Q2 to Date Q3 Q4 16/17
NHS West Lancashire CCG 100.00% 100.00% 75.00% 100.00% 95.00% 100.00% 96.67%Total Figure - 8 CCGs 95.96% 94.92% 96.63% 97.83% 95.75% 97.83% 96.23%
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9b IAPT – Performance SUMMARY of KEY PERFORMANCE for July
Detailed information is available on request. Prevalence
West Lancs CCG underperformed its July 2016 IAPT Access target by 16 patients. This was combined with an overall underperformance of 11 patients in Q1. Prevalence is assessed based on an agreed 9% of standardised population data. The fact that other CCG’s over-performed their access targets reduces capacity available for West Lancs residents.
Recovery Following discussion at previous CCG Performance Meetings, the service has introduced measures to exclude data for patients with severe presentations as measured by PHQ 9 (20 and above) and GAD 7 (15 and above). This is consistent with approach taken in other IAPT services. Although West Lancs CCG failed its recovery target in May 2016 the overall performance for Q1 was within target, achieving 53%. The recovery target is 50%. Performance for July 2016 was 63.6%. The trend is for recovery to continue to improve. Exceptions are Preston, Chorley and South Ribble and Lancashire North. Focussed work is ongoing within these teams to increase access to Silvercloud and to offer multiple interventions (rather than episodic care) to support improved recovery and also reduced waits.
Target Entered Treatment
Prevalence Target Entered Treatment
Prevalence Target Entered Treatment
Prevalence
NHS BLACKBURN WITH DARWEN CCG 738 818 4.16% 246 256 1.30% 984 1074 16.37%NHS EAST LANCASHIRE CCG 1782 1639 3.45% 594 625 1.32% 2376 2264 14.29%NHS CHORLEY AND SOUTH RIBBLE CCG 774 979 4.74% 258 296 1.43% 1032 1275 18.53%NHS GREATER PRESTON CCG 954 1078 4.24% 318 299 1.18% 1272 1377 16.24%NHS WEST LANCASHIRE CCG 522 511 3.67% 174 158 1.14% 696 669 14.42%NHS FYLDE & WYRE CCG 648 552 3.19% 216 267 1.55% 864 819 14.22%NHS LANCASHIRE NORTH CCG 684 683 3.74% 228 220 1.21% 912 903 14.85%
Quarter 1 July 2016 Year to Date
Completed Treatment
Moved to recovery
Not at Caseness
Completed Treatment
Moved to recovery
Not at Caseness
Completed Treatment
Moved to recovery
Not at Caseness
NHS BLACKBURN WITH DARWEN CCG 281 133 14 49.8% 136 68 5 51.9% 417 201 19 50.5%NHS EAST LANCASHIRE CCG 814 380 68 50.9% 268 130 23 53.1% 1082 510 91 51.5%NHS CHORLEY AND SOUTH RIBBLE CCG 322 153 18 50.3% 137 49 15 40.2% 459 202 33 47.4%NHS GREATER PRESTON CCG 441 156 27 37.7% 93 45 4 50.6% 534 201 31 40.0%NHS WEST LANCASHIRE CCG 206 106 6 53.0% 71 42 5 63.6% 277 148 11 55.6%NHS FYLDE & WYRE CCG 196 95 15 52.5% 58 30 6 57.7% 254 125 21 53.6%NHS LANCASHIRE NORTH CCG 320 131 11 42.4% 100 46 7 49.5% 420 177 18 44.0%
Quarter 1 July 2016 Year to Date
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10. Quality and Performance 10a West Lancashire CCG Performance Dashboard
Apr May Jun Jul Aug Sep Oct Nov Dec Jan Mar
RAG G G R G
Actual 95.989% 95.833% 92.378% 96.633%
Target 93.00% 93.00% 93.00% 93.00% 93.00% 93.00% 93.00% 93.00% 93.00% 93.00% 93.00%
RAG R G R R
Actual 90.244% 96.154% 91.429% 92.00%
Target 93.00% 93.00% 93.00% 93.00% 93.00% 93.00% 93.00% 93.00% 93.00% 93.00% 93.00%
RAG G G G R
Actual 100.00% 98.182% 100.00% 95.00%
Target 96.00% 96.00% 96.00% 96.00% 96.00% 96.00% 96.00% 96.00% 96.00% 96.00% 96.00%
RAG R R G G
Actual 90.909% 80.00% 100.00% 100.00%
Target 94.00% 94.00% 94.00% 94.00% 94.00% 94.00% 94.00% 94.00% 94.00% 94.00% 94.00%
RAG R G G G
Actual 94.118% 100.00% 100.00% 100.00%
Target 98.00% 98.00% 98.00% 98.00% 98.00% 98.00% 98.00% 98.00% 98.00% 98.00% 98.00%
RAG G R G R
Actual 100.00% 87.50% 100.00% 80.00%
Target 94.00% 94.00% 94.00% 94.00% 94.00% 94.00% 94.00% 94.00% 94.00% 94.00% 94.00%
RAG G R G R
Actual 95.652% 72.727% 93.75% 80.00%
Target 85.00% 85.00% 85.00% 85.00% 85.00% 85.00% 85.00% 85.00% 85.00% 85.00% 85.00%
RAG G
Actual - - - 100.00%
Target 90.00% 90.00% 90.00% 90.00% 90.00% 90.00% 90.00% 90.00% 90.00% 90.00% 90.00%
RAG
Actual 100.00% 83.333% 75.00% 87.50%
Target
% of patients receiving treatment for cancer within 62 days upgrade their priority.
West Lancashire CCG 84.444%
% of patients receiving treatment for cancer within 62 days from an NHS Cancer Screening Service.
West Lancashire CCG
G
100.00%
90.00% 90.00%
% of patients receiving 1st definitive treatment for cancer within 2 months (62 days).
West Lancashire CCG
G
85.185%
85.00% 85.00%
% of patients receiving subsequent treatment for cancer within 31 days (Radiotherapy Treatments).
West Lancashire CCG
G
95.238%
94.00% 94.00%
% of patients receiving subsequent treatment for cancer within 31 days (Drug Treatments).
West Lancashire CCG
G
98.039%
98.00% 98.00%
% of patients receiving subsequent treatment for cancer within 31 days (Surgery).
West Lancashire CCG
R
93.103%
94.00% 94.00%
% of patients receiving definitive treatment within 1 month of a cancer diagnosis.
West Lancashire CCG
G
98.361%
96.00% 96.00%
% of patients seen within 2 weeks for an urgent referral for breast symptoms.
West Lancashire CCG
R
92.105%
93.00% 93.00%
Cancer Waiting Times
% Patients seen within two weeks for an urgent GP referral for suspected cancer.
West Lancashire CCG
G
95.202%
93.00% 93.00%
Preventing People from Dying Prematurely
MetricReporting
Level
2016-17Q1 Q2 Q3 Q4 YTD
Feb
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RAG R R R R
Actual 41.38% 70.00% 74.30% 40.00%
Target 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00%
RAG G R R R
Actual 76.47% 74.28% 73.06% 70.45%
Target 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00%
RAG R R R R
Actual 53.37% 57.60% 54.60% 53.40%
Target 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00%
RAG R R R R
Actual 67.46% 66.26% 66.20% 62.69%
Target 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00% 75.00%
RAG R R R R
Actual 86.49% 86.20% 88.10% 80.91%
Target 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00%
RAG R R R R
Actual 92.01% 91.47% 91.49% 89.81%
Target 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00%
91.172%
95.00% 95.00%
Category A calls responded to within 19 minutes.
West Lancashire CCG
R
85.462%
95.00% 95.00%
NORTH WEST AMBULANCE SERVICE NHS TRUST
R
65.601%
75.00% 75.00%
Category A (Red 2) 8 Minute Response Time.
West Lancashire CCG
R
54.732%
75.00% 75.00%
NORTH WEST AMBULANCE SERVICE NHS TRUST
R
73.564%
75.00% 75.00%
Category A Calls Response Time (Red1).
West Lancashire CCG
R
57.697%
75.00% 75.00%
NORTH WEST AMBULANCE SERVICE NHS TRUST
R
Ambulance
RAG
Actual 12.999% 9.422% 10.632%
Target
Emergency Re-admissions
Emergency Re-admissions within 30 days of discharge.
West Lancashire CCG 11.032%
Helping People to Recover from Episodes of Ill Health or Following Injury
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RAG R R G R
Actual 3 5 0 4
Target 0 0 0 0 0 0 0 0 0 0 0
RAG R R G G
Actual 0.88 1.47 - 0.00
Target 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
RAG G G G G
Actual 96.315% 95.934% 95.572% 95.31%
Target 92.00% 92.00% 92.00% 92.00% 92.00% 92.00% 92.00% 92.00% 92.00% 92.00% 92.00%
RAG R R R G
Actual 1 1 1 0
Target 0 0 0 0 0 0 0 0 0 0 0
RAG G G G G
Actual 0.824% 0.605% 0.879% 0.582%
Target 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00%
RAG G G R R
YTD 0 0 1 2
Target 0 0 0 0 0 0 0 0 0 0 0
RAG G G G G
YTD 3 6 8 11
Target 4 8 11 15 19 22 26 30 34 38 46
Number of C.Difficile infections.
West Lancashire CCG
G
11
42 15
HCAI
Number of MRSA Bacteraemias.
West Lancashire CCG
R
2
0 0
Treating and Caring for People in a Safe Environment and Protect them from Avoidable Harm
% of patients waiting 6 weeks or more for a diagnostic test.
West Lancashire CCG
G
0.72%
1.00% 1.00%
Referral to Treatment RTT - No of Incomplete Pathways Waiting >52 weeks.
West Lancashire CCG
R
3
0 0
Referral to Treatment RTT (Incomplete).
West Lancashire CCG
G
95.779%
92.00% 92.00%
Referral to Treatment (RTT) & Diagnostics
Mixed Sex Accommodation - MSA Breach Rate.
West Lancashire CCG
R
12.00
0.00 0.00
EMSA
Mixed sex accommodation breaches - All Providers.
West Lancashire CCG
R
12
0 0
Ensuring that People Have a Positive Experience of Care
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RAG R R R
Actual 92.97% 90.314% 93.867%
Target 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00%
RAG R R R
Actual 88.596% 89.772% 90.923%
Target 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00%
RAG R R R
Actual 87.683% 87.276% 91.685%
Target 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00% 95.00%
RAG
Actual 5,746 6,394 6,225
Target
RAG
Actual 8,962 8,147 7,573
Target
RAG
Actual 7,368 8,249 7,386
Target
RAG G G G
Actual 11,005 11,820 11,281
Target 9,604 9,561 9,512 10,233 9,515 9,406 9,961 9,472 9,905 9,170 10,225
RAG
Actual 7,368 8,249 7,386
Target
RAG R G G
Actual 10,035 11,459 10,764
Target 10,608 10,956 10,608 10,956 10,956 10,608 10,956 10,609 10,956 10,956 10,955
RAG G G G
Actual 0 0 0
Target 0 0 0 0 0 0 0 0 0 0 0
RAG G G G
Actual 0 0 0
Target 0 0 0 0 0 0 0 0 0 0 0
RAG R G G
Actual 1 0 0
Target 0 0 0 0 0 0 0 0 0 0 0
Accident & Emergency
4-Hour A&E Waiting Time Target (Monthly Aggregate for Total Provider). WRIGHTINGTON, WIGAN AND LEIGH NHS FOUNDATION TRUST
R
92.305%
95.00% 95.00%
SOUTHPORT AND ORMSKIRK HOSPITAL NHS TRUST
R
LANCASHIRE TEACHING HOSPITALS NHS FOUNDATION TRUST
R
88.874%
95.00% 95.00%
89.773%
95.00% 95.00%
A&E Attendances: Type 1SOUTHPORT AND ORMSKIRK HOSPITAL NHS TRUST
18,365
LANCASHIRE TEACHING HOSPITALS NHS FOUNDATION TRUST
WRIGHTINGTON, WIGAN AND LEIGH NHS FOUNDATION TRUST
23,003
24,682
A&E Attendances: All Types.SOUTHPORT AND ORMSKIRK HOSPITAL NHS TRUST
G
34,106
8,664 9,604
WRIGHTINGTON, WIGAN AND LEIGH NHS FOUNDATION TRUST
LANCASHIRE TEACHING HOSPITALS NHS FOUNDATION TRUST
G
32,258
9,898 10,608
23,003
0
0 0
12 Hour Trolley waits in A&E.WRIGHTINGTON, WIGAN AND LEIGH NHS FOUNDATION TRUST
G
0
0 0
LANCASHIRE TEACHING HOSPITALS NHS FOUNDATION TRUST
G
SOUTHPORT AND ORMSKIRK HOSPITAL NHS TRUST
R
1
0 0
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10b Southport & Ormskirk Hospitals NHS Trust Integrated Performance Dashboard
INDICATOR JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUN JUL Q3 Q4 Q1 Q2 YTD TARGET18 Weeks - Ongoing - % <18 Weeks - Trust 93.5% 93.4% 93.7% 94.8% 96.0% 95.9% 97.0% 96.7% 97.1% 96.3% 95.8% 95.4% 94.5% 95.9% 97.1% 95.4% 94.5% 94.5% 92.0%A&E - Left Dept Without Being Seen Rate - Trust 2.35% 1.95% 2.24% 2.29% 2.64% 3.07% 3.71% 3.24% 3.47% 2.31% 2.25% 1.71% 2.49% 5.00%A&E - Time to Initial Assessment - 95th %tile - Trust 10.0 10.0 9.0 9.0 12.0 12.0 10.0 11.0 13.0 10.0 11.0 11.0 11.0 15.0A&E - Time to Treatment - Median - Trust 50.0 48.0 56.0 58.0 56.0 54.0 60.0 66.0 71.0 51.0 47.0 45.0 49.0 60.0A&E - Total Time - 95th Percentile - Trust 239.0 270.0 373.0 387.0 350.0 422.0 516.0 446.0 459.0 416.0 393.0 346.0 399.0 240.0A&E - Total Time in A&E - 4 Hour % - Trust Overall 95.50% 95.83% 92.42% 91.55% 91.46% 87.53% 83.38% 85.35% 84.62% 88.60% 89.96% 90.94% 87.98% 90.18% 84.45% 89.83% 87.98% 88.91% 95.00%A&E - Total Time in A&E - 4 Hour % - RVY01 89.10% 90.90% 81.44% 79.03% 78.59% 71.62% 60.20% 55.85% 53.20% 66.69% 70.45% 74.45% 66.73% 76.41% 56.41% 70.53% 66.73% 68.63% 95.00%A&E - Unplanned Re-attendance Rate (within 7 days) - Trust
0.84% 0.40% 0.74% 1.48% 1.09% 1.20% 0.86% 0.79% 0.71% 0.75% 0.80% 0.86% 1.11% 5.00%
ALOS - Elective - Trust 0.37 0.31 0.30 0.36 0.31 0.42 0.28 0.32 0.30 0.29 0.34 0.32 0.36 0.36 0.30 0.32 0.36 0.33 0.37ALOS - Non-Elective - Trust 4.03 4.64 4.77 4.96 4.46 5.26 5.16 5.31 5.25 5.62 4.95 4.65 5.27 4.88 5.24 5.03 5.27 5.09 4.30ALOS - Overall - Trust 2.10 2.37 2.33 2.49 2.23 2.77 2.49 2.56 2.63 2.74 2.58 2.37 2.62 2.50 2.56 2.55 2.62 2.57 2.30Cancelled Operations - % of Total Electives in Month 0.32% 1.07% 1.17% 2.04% 0.70% 0.86% 0.50% 1.23% 1.57% 0.43% 0.52% 0.21% 0.62% 1.20% 1.09% 0.39% 0.62% 0.44% 0.60%
INDICATOR JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUN JUL Q3 Q4 Q1 Q2 YTD TARGETCancer 14 Day - Urgent GP Referral Suspected Cancer 95.0% 95.0% 94.8% 96.8% 93.9% 98.0% 94.9% 96.2% 97.5% 96.8% 95.3% 94.6% 96.2% 96.3% 95.6% 0 93.0%Cancer 31 Day - Decision to Treatment 100.0% 98.6% 95.8% 97.3% 100.0% 98.0% 98.6% 100.0% 100.0% 100.0% 97.5% 98.6% 97.9% 99.5% 98.6% 0 96.0%Cancer 31 Day - Subsequent Treatment - Drug Therapy NTR 100.0% 100.0% NTR 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% NTR 100.0% 100.0% 100.0% 0 98.0%Cancer 31 Day - Subsequent Treatment - Surgery 90.0% 88.9% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 83.3% 100.0% 100.0% 100.0% 95.2% 92.3% 0 94.0%Cancer 62 Day - GP Referral to Treatment 87.4% 87.5% 86.5% 89.0% 90.0% 85.7% 79.8% 89.9% 83.7% 93.9% 70.7% 86.2% 88.0% 84.8% 83.1% 0 85.0%Cancer 62 Day - Screening Referral to Treatment 100.0% 0.0% 66.7% 66.7% 100.0% NTR 100.0% NTR NTR 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 0 90.0%Diagnostics waiting time: % >= 6 weeks - All Tests 0.77% 0.56% 0.42% 0.49% 0.44% 0.54% 0.91% 0.75% 1.02% 0.36% 0.15% 0.48% 0.52% 1.00%DSSA Breaches - Trust 2 8 5 8 6 11 10 14 19 14 10 4 10 25 43 28 10 38 0
2016/172015/16 2016/17 2015/16
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INDICATOR JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUN JUL Q3 Q4 Q1 Q2 YTD TARGETHR - Agency Staff Costs 7.82% 8.48% 9.66% 8.41% 9.13% 9.59% 8.40% 9.83% 10.68% 10.20% 9.46% 10.34% 8.71% 4.00%HR - Sickness Absence Rate - Trust 5.12% 4.75% 5.31% 5.96% 5.98% 5.78% 6.14% 4.85% 5.71% 5.08% 4.97% 5.16% 4.00%IC - Clostridium Difficile - Trust 3 2 5 1 3 0 6 4 1 3 5 1 1 4 11 9 1 10 36IC - Number of MRSA - Trust 0 0 0 0 0 0 0 1 0 0 0 0 0 0 1 0 0 0 0IC - MRSA Screening - Emergency Admissions - Trust 82.6% 87.0% 76.8% 82.9% 82.0% 83.0% 85.1% 86.0% 80.0% 81.0% 80.0% 86.0% 85.0% 100.0%IC - MRSA Screening - Elective Admissions - Trust 98.3% 96.9% 98.4% 97.4% 97.2% 97.9% 97.3% 98.0% 99.0% 98.0% 98.0% 98.0% 97.0% 100.0%Mortality - HSMR 12 Month Rolling Total - Trust 103.0 103.4 101.9 102.1 100.0 90.0Mortality - HSMR Monthly - Trust 95.0 103.3 79.9 86.7 80.8 90.0
INDICATOR JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUN JUL Q3 Q4 Q1 Q2 YTD TARGETRM - Never Events - Trust 0 0 0 0 1 0 0 1 0 0 0 0 0 1 1 0 0 0 0RM - Patient Falls - by 1,000 bed days 4.9 4.1 4.0 4.0 5.2 4.9 4.3 4.1 3.4 4.7 5.4 4.8 4.7 3.9 5.0 5.0RM - Steis Reportable Incidents - Trust 4 6 6 5 6 2 6 5 2 9 5 0 5 13 13 14 5 19Stroke/TIA - Stroke 90% Stay on ASU 85.2% 64.3% 59.1% 79.5% 83.3% 42.9% 55.6% 61.8% 64.0% 43.5% 57.6% 55.6% 48.5% 55.2% 64.0% 52.4% 48.5% 51.3% 80.0%Stroke/TIA - TIA - High Risk Treated within 24Hrs 80.0% 40.0% 60.0% 60.0% 75.0% 60.0% 62.5% 70.0% 54.5% 28.6% 45.5% 16.7% 33.3% 66.7% 58.1% 33.3% 33.3% 33.3% 60.0%TV - Community Acquired Grade 2 Pressure Sores 30 30 19 17 24 28 33 19 38 23 42 20 30 69 90 85 30 115TV - Community Acquired Grade 3 Pressure Sores 4 2 2 3 1 2 3 3 6 4 5 5 7 6 12 14 7 21TV - Community Acquired Grade 4 Pressure Sores 0 0 0 1 0 0 0 1 1 3 3 2 4 1 2 8 4 12TV - Hospital Acquired Pressure Sores - Grade 2-4 - Trust 6 2 0 6 7 4 8 8 1 4 5 6 6 17 17 15 6 21 28TV - Community Acquired Pressure Sores - Grade 2-4 34 32 21 21 25 30 36 23 45 30 50 27 41 76 104 107 41 148TV - Hospital Acquired Grade 2 Pressure Sores 5 2 0 5 6 4 8 7 1 4 5 6 6 15 16 15 6 21 18TV - Hospital Acquired Grade 3 Pressure Sores 1 0 0 1 1 0 0 1 0 0 0 0 0 2 1 0 0 0 10TV - Hospital Acquired Grade 4 Pressure Sores 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0VTE Prophylaxis Assessment - Trust 97.4% 95.6% 97.1% 98.1% 97.6% 95.2% 95.2% 95.1% 96.5% 98.4% 98.7% 97.7% 95.9% 95.0%
2015/16 2016/17 2015/16 2016/17
2015/16 2016/17 2015/16 2016/17
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10c Areas of Under-Performance for West Lancashire CCG A number of areas of underperformance are reported to end of July 2016 YTD; the detail below is presented by indicator for each of these areas with actions identified as required and on-going, seeking to improve performance. ‘Direction of travel’ of performance against indicator from previous reporting period is provided to demonstrate if performance is deteriorating or improving. Please note that an upwards pointing direction of travel arrow indicates that although the measure is not currently being met, the situation is improving. Conversly a downward pointing arrow indicates that performance against this measure is deteriorating. Cancer Waiting Times
Indicator: % of patients seen within 2 weeks for an urgent referral for breast symptoms.
Target: 93%
Current Performance YTD
92.1% Direction of travel
Forecast
Current Issues: At month 02 (May) status was green. Months 03 and 04 have both marginally failed the target resulting in a YTD status of red. Improvement Plans: No actions are currently planned as it is expected that the target will be met in future months.
Indicator: % of patients receiving subsequent treatment for cancer within 31 days (Surgery).
Target: 94%
Current Performance YTD
93.1% Direction of travel
Forecast
Current Issues: Performance has improved significantly since Month 02 with 100% being achieved in months 03 and 04. If present performance is maintained the annual target of 94% will be achieved. Improvement Plans: RCAs are continuing to be carried out on breaches and learning applied. Processes are in place to receive RCA from all Providers to review and investigate breaches.
Ambulance
Indicator: Ambulance response times – CCG Target: 95% (All Cat A) 75% (Red 1) 75% (Red 2)
Current Performance YTD
85.5 % 57.7% 54.7%
Direction of travel
Forecast
Current Issues: All Categories A calls responded to within 19 mins performance has failed to meet the 95% target for West Lancashire CCG for the year to July 2016. NWAS performance is also under the 95% target at 91.2%. Category A Calls (Red 1) performance has failed to meet the 75% target for West Lancashire CCG for the year to July 2016. NWAS performance also failed to meet the 75% target at 73.6%. Category A Calls (Red 2) performance has failed to meet the 75% target for West Lancashire CCG for the year to July 2016. NWAS performance has also failed the 75% target at 65.6%. Improvement Plans: S&O Trust and NWAS have agreed a new process for Escalation when there are Ambulances queueing at A&E. All Cheshire and Mersey organisations have now signed a Turnover Concordat, aiming at an average of 30 minutes turnover times and zero tolerance for long waits (over 4 hours)
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EMSA
Indicator: Mixed sex accommodation breaches - All Providers.
Target: 0
Current Performance YTD
12 Direction of travel
Forecast
Current Issues: Although the target of zero was met in June there were 4 additional breaches in July. As the annual target is zero this measure will be failed. Improvement Plans: They all related to Critical Care and Spinal patients at Southport and Ormskirk Hospitals. The Trust are currently reviewing single sex Critical Care through utilising unused side rooms. A reduction in MSA breaches is therefore expected.
Indicator: Mixed Sex Accommodation - MSA Breach Rate.
Target: 0
Current Performance YTD
12 Direction of travel
Forecast
Current Issues: Although the target of zero met in June and July performa nce in April and May mean the annual target will not be achieved. Improvement Plans: Southport and Ormskirk Hospitals are currently reviewing single sex Critical Care through utilising unused side rooms. A reduction in MSA breaches is therefore expected.
Referral to Treatment (RTT) & Diagnostics
Indicator: Referral to Treatment RTT - No of Incomplete Pathways Waiting >52 weeks.
Target: 0
Current Performance YTD
3 Direction of travel
Forecast
Current Issues: Although the target of zero was met in July performance in April and May and June mean the annual target will not be achieved. Improvement Plans:
HCAI
Indicator: Number of MRSA Bacteraemias.
Target: 0
Current Performance YTD
2 Direction of travel
Forecast
Current Issues: One recorded case in June and one in July mean the annual target of zero will not be achieved.. Improvement Plans:
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Accident and Emergency
Indicator: 4hr A+E Waiting Time Target
Target: 95%
Current Performance YTD - Lancashire Teaching
Current Performance YTD – Southport & Ormskirk
Current Performance YTD – WWL
88.9% 89.8% 92.97%
Direction of travel
Forecast
Current Issues: The 95% target has been failed by all 3 Providers. Demand for A&E services has been significantly higher than normal during the monitored period. Improvement Plans: The S & O Trust Recovery Plan for A&E has been approved. The CCG has reached financial agreement with the Trust to enable delivery of the plan. The plan will also assist with meeting the ambulance targets.
Indicator:12 Hour Trolley waits in A&E.
Target: 0
Current Performance YTD
1
Direction of travel Forecast
Current Issues: A single trolley wait at Lancashire Teaching Hospitals in April means the annual target of zero will not be met.
Improvement Plans: Contact has been made with the host commissioner(s) Greater Preston CCG/Chorley and South Ribble CCG to ascertain the cause of this wait and any actions being taken to prevent future issues.
Indicator: Stroke/TIA – Stroke 90% Stay on ASU – Southport and Ormskirk Hospitals
Target: 80%
Current Performance YTD
51.3%
Direction of travel
Forecast
Current Issues: The Trust is currently significantly underperforming the 80% national target. Part of the issue is problems ensuring thet MSA targets are not breached within the ASU. Improvement Plans: Stroke is part of the Trust’s Accelerated Flow Programme. This programme includes a focus on rehabilitation/discharge through a stepdown facility.
Indicator: Stroke/TIA – TIA – High Risk Treated Within 24 Hours – Southport and Ormskirk Hospitals
Target: 60%
Current Performance YTD
33.3%
Direction of travel
Forecast
Current Issues: The Trust is currently significantly underperforming the 60% national target. Patient numbers have meant the target has been difficult to achieve. Improvement Plans:
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10d West Lancashire CCG Patients Waiting To understand how many patients were still waiting for procedures or outpatient appointments, the numbers of patients waiting for all in-completed pathways for all trusts has been included in the graph below. More detailed reports on RTT waiters are available via Aristotle spotlight reports.
For the Lancashire footprint, in July 2016, there are 6,823 patients in total with an Incomplete Pathway. Of these, 6,503 are Under 18 Weeks and 320 Over 18 Weeks. The table below shows the top 5 highest number of breaches by provider for July 2016 for West Lancashire CCG. 2 of the top 5 have achieved the 92% target. The best performer is Southport and Ormskirk Hospital NHS Trust with 95.63%.
Southport & Ormskirk Possesses 3 specialties failing 92% target; ENT (91.7%), General Medicine (85.7%) and Gastroenterology (82.7%). Wrightington, Wigan and Leigh Has 2 specialties under 92% compliance target; Urology (90.0%) and General Surgery (76.9%). Royal Liverpool & Broadgreen Has 4 specialties failing 92% target; Cardiology (76.9%), General Surgery (88.1%), Trauma & Orthopaedics (76.5%) and Ophthalmology (87.7%). Lancashire Teaching Hospitals Has 6 specialties under 92% compliance target; General Surgery (81.8%), Trauma & Orthopaedics (81.3%), Plastic Surgery (75.0%), General Medicine (75.0%), Ophthalmology (85.7%), Cardiology (77.8%), Neurology (91.3%), Other (85.7%). Aintree Has 3 specialties under 92% compliance target; Respiratory Medicine (76.4%), Ophthalmology (84.1%) and Gastroenterology (90.9%).
TrustUnder 18
WeeksOver 18
WeeksTotal
% IN 18 Weeks
RAG
SOUTHPORT AND ORMSKIRK HOSPITAL TRUST:{RVY} 3566 163 3729 95.63%WRIGHTINGTON, WIGAN AND LEIGH NHS FOUNDATION TRUST: (RRF) 538 27 565 95.22%ROYAL LIVERPOOL AND BROADGREEN UNIVERSITY HOSPITALS NHS TRUST: (RQ6) 219 29 248 88.31%LANCASHIRE TEACHING HOSPITALS NHS FOUNDATION TRUST: (RXN) 168 24 192 87.50%AINTREE UNIVERSITY HOSPITAL NHS FOUNDATION TRUST: (REM) 320 31 351 91.17%
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10e Friends & Family Test
Friends andFamily Test
This month there were2807 - Recommendedresponses to the Friends and Family Test includedin the results below. - Not recommendedThe following numbers show the proportion of responses that would recommend or not recommend theseservices to a friend or family member.
Q1 16/17Results
July 2016
Inpatient & Daycases
A&E, Walk-in-Centres and Minor Injuries Units
Outpatients
Ambulance
Maternity
Community Health
*All data shown relates to Southport & Ormskirk NHS Hospitals Trust only, except for Ambulance (NWAS only), Mental Health (LCFT only) and GP (West Lancashire GP's only) A separate report detailing all the response rates and results for the Friends & Family Test has been provided for the Quality & Safety Committee.
Mental Health
Staff
GP
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10f Safety Thermometer On one day each month hospital trusts are required to check to see how many of their patients suffered certain types of harm whilst in their care. This measure is known as the safety thermometer. The safety thermometer looks at four harms: pressure ulcers, falls, blood clots and urine infections for those patients who have a urinary catheter in place. This helps Trusts to understand where they need to make improvements.
The table below shows the percentage of patients who did not experience any of the four harms in the Trust(s) during the period July 2015 to July 2016.
GP Comments, Concerns & Issues with Healthcare Providers There were 10 complaints, comments and concerns copied to the CCG from GPs across West Lancashire in July 2016, 1 was related to Discharge letters and 9 were related to Information Governance.
The chart below summarise the trends/themes of comment and complaints over the last 12 month period.
Jul-15 Aug-15 Sep-15 Oct-15 Nov-15 Dec-15 Jan-16 Feb-16 Mar-16 Apr-16 May-16 Jun-16 Jul-16 Trajectory from previous month
96.4% 94.6% 94.5% 95.4% 95.0% 94.1% 93.5% 93.1% 95.2% 96.3% 95.3% 94.7% 93.4%
94.6% 94.6% 95.9% 97.2% 94.6% 95.5% 95.3% 94.2% 93.7% 93.9% 94.6% 95.6% 92.8%
94.6% 95.2% 94.8% 94.8% 94.6% 94.4% 93.9% 93.8% 91.0% 95.1% 95.3% 96.5% 94.0%
95.5% 94.4% 95.6% 96.1% 95.1% 94.6% 94.6% 95.8% 93.9% 92.8% 94.6% 94.3% 93.6%
94.6% 96.1% 95.5% 95.5% 95.9% 96.4% 95.7% 93.8% 95.4% 94.1% 96.2% 95.7% 95.1%
95.4% 96.2% 95.9% 97.1% 94.9% 95.0% 95.2% 95.9% 96.3% 96.0% 94.5% 93.0% 95.0%
- Score more than 5% lower than previous month - Score lower than previous month but within 5% - Score equal to or higher than previous month
Lancashire Teaching Hospitals NHS Foundation Trust
St Helens & Knowsley Hospitals NHS Trust
Safety Thermometer - July 2016
Trust
Southport & Ormskirk NHS Hospitals Trust
Wrightington, Wigan & Leigh NHS Foundation Trust
Aintree University Hospitals NHS Trust
Royal Liverpool & Broadgreen University Hospitals NHS Trust
29 | P a g e
Themes & trends will continue to be monitored & reported against on a monthly basis, and raised with the Trust through the contract and quality monitoring process as appropriate. Serious Untoward Incidents During July, 6 new StEIS incident were reported involving West Lancashire CCG registered patients, 4 outside the 48h reporting timescale (all from Southport and Ormskirk NHS Trust) and no StEIS incidents were closed. Two RCA reports were due in July from Southport and Ormskirk NHS Trust, and both reports have been received. Only one of these reports were received within the 60 day timescales. These reports will be reviewed at the Serious Incident Review Group in August. As at 31 July 2016, 67 StEIS incidents remain open involving WL CCG patients, the majority of these are from Southport & Ormskirk Hospitals Trust (55 in total) and the highest reported incidents remain pressure ulcers with 46 pressure ulcer incidents currently open across all providers.
The collaborative Individual Funding Request process for Lancashire Clinical Commissioning Groups West Lancashire Clinical Commissioning Group Governing Body Meeting – 27 September 2016
1
WLCCGB 09/16/9
WEST LANCASHIRE CLINICAL COMMISSIONING GROUP GOVERNING BODY REPORT
DATE OF BOARD MEETING: 27 September 2016
TITLE OF REPORT: The collaborative Individual Funding Request process for Lancashire Clinical Commissioning Groups
BRIEFING POINTS: The above document was approved at the Executive Committee held on the 5 July 2016 with the intention of gaining formal ratification at the Governing Body meeting on the 26 July 2016. However, the Lancashire Commissioning Policies Subgroup met on the 7 July and approved some minor changes. These are detailed in the attached paper and do not impact the content of the process.
Does this report / its recommendations have implications and impact with regard to the following: A. Commissioning Board’s Aims and Objectives 1. Quality (including patient safety, clinical effectiveness and patient
experience) – please outline impact
2. Commissioning of hospital and community services – please outlineimpact
3. Commissioning and performance management of GP Prescribing –please outline impact
4. Delivering Financial Balance – please outline impact5. Development of the commissioning group as a commissioning
organisation – please outline impact
B. Governance – please outline impact 1. Does this report:
• provide the Commissioning Board with assurance against anyof the risks identified in the assurance framework (identify risknumber)
• have any legal implications• promote effective governance practice
X
Promotes effective governance in terms of: • The Individual funding request (IFR) process is the means by which the
Clinical Commissioning Group (CCG) manages and administers applicationsfor funding for treatments for individuals in accordance with the General Policyfor Individual Funding Request Decision Making and the Policies for theCommissioning of Healthcare, Statement of Principles.
• Auditable record of formal approval and adoption of the process2. Additional resource implications
(either financial or staffing resources)3. Health Inequalities
The collaborative Individual Funding Request process for Lancashire Clinical Commissioning Groups West Lancashire Clinical Commissioning Group Governing Body Meeting – 27 September 2016
2
4. Human Rights, Equality and Diversity Requirements5. Clinical Engagement6. Patient and Public Engagement
PAPER PRESENTED BY: Claire Heneghan, chief nurse
Title The Collaborative Individual Funding Request process for Lancashire Clinical Commissioning Groups
Summary
The above document was approved at the Executive Committee held on the 5th July 2016 with the intention of gaining formal ratification at the Governing Body meeting on the 26th July 2016. However, the Lancashire Commissioning Policies Subgroup met on the 7th July and approved some minor changes that had been requested. These are listed below and do not impact the content of the process.
Request / Comment Amendment
Appendix 3 para. 1. The greater part of the paragraph states that the evidence to the Appeal Panel will be entirely written but also towards the conclusion states that there may be an oral presentation by the patient or their representative. Under the present arrangement oral presentations are often made. The current wording seems to me to be confusing.
Amendment made to remove the word ‘written’ from the sentence ‘The IFR Appeal Panel will consider only the following written documentation’.
Appendix 3 (2). CCGs no longer have non- executive directors as identified in the composition of the IFR Review panel and the corresponding role is that of Lay member
The word ‘lay’ has replaced the word ‘non-executive’
Para 1.7 there is reference to the NHS funding "operations" - should this not refer to "procedures"? In some cases the application will not be for surgery. Indeed in para. 1.2 the words "treatment" and "operation" appear. The document needs to be internally consistent. In the conclusion of the first sentence of this para. there is reference to the NHS "carrying out" the operation (sic). Should this refer to funding not to carrying out?
Wording amended to ensure consistency.
Actions Required by the Governing Body
Formal ratification of the paper
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 1 of 34
The collaborative Individual Funding Request process for Lancashire Clinical Commissioning Groups
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 2 of 34
Table of Contents 1. Introduction .......................................................................................................................................... 4
2. Submitting an Individual Funding Request (IFR) .................................................................................. 5
3. Pre-screening stage .............................................................................................................................. 6
4. Screening stage ..................................................................................................................................... 7
5. IFR Panel ............................................................................................................................................... 8
6. Implementation .................................................................................................................................. 10
7. Urgent applications ............................................................................................................................ 10
8. Appeals process .................................................................................................................................. 11
9. Patient and clinician feedback ............................................................................................................ 14
10. Monitoring .......................................................................................................................................... 14
11. Photographic evidence ....................................................................................................................... 14
12. Schematic of decision making ............................................................................................................ 15
Appendix 1: Terms of Reference for the Individual Funding Request Team ............................................. 17
Appendix 2: Terms of Reference for the IFR Panel .................................................................................... 19
Appendix 3: Terms of Reference of the IFR Appeal Panel ......................................................................... 21
Appendix 4: Individual Funding Request (IFR) Application Appeal Form .................................................. 23
Appendix 5: Agenda template for Individual Funding Request (IFR) Appeal Panel .................................. 26
Appendix 6: IFR Application Form .............................................................................................................. 27
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Information Reader Box
Organisation/Directorate
Clinical Commissioning Groups; MLCSU Clinical Services Directorate;
- IFR Team
- Medicines Management Team
Document Purpose Administration Policy and High Level Procedure
Document Name The process for managing Individual Funding Requests
A collaborative document for Lancashire CCGs
Author Lancashire CCGs, Commissioning Policy Subgroup supported by
Jonathan Horgan, Head of Medicines Management and IFR Services.
Publication Date July 2016
Target Audience CCGs, CSU
Superseded Document Legacy documents
Contact Details
(for further information)
Document Status Final
Versions 1 to 14 were developed through the Commissioning Policy Subgroup and CCGs via their representatives during 2015/16 Version 14
Ratified By Policy Subgroup
Date Ratified To be approved by each Clinical Commissioning Group
Date of Issue via Intranet To be published by each Clinical Commissioning Group
Date of Review 2 years and carried out by Lead Officer (MLCSU)
Lead Officer (MLCSU)
Jonathan Horgan, Head of IFR and Medicines Management Services, MLCSU
Lead Officer (CCG) As per each CCG
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1. Introduction
1.1 The NHS belongs to us all. It is there to improve our health and well-being, support us to keep mentally and physically well, to get better when we are ill and, when we cannot fully recover to stay as well as we can to the end of our lives.
1.2 To make sure that we can provide the best care for the maximum number of people it is vital
that we make every penny count. This means funding procedures and treatments that have been demonstrated to work and where there is a high likelihood of benefit and a low likelihood of harm. Carrying out procedures such as operations that are not of great health benefit uses up resources that could be spent on really making a difference elsewhere. As happens in other parts of the country, we may decide that a treatment or procedure should not be routinely funded because:
• There is only limited or no evidence of its effectiveness (whether it works or not) • It is considered a low priority for funding, (for example, cosmetic surgery) compared to
other treatments (for example, dementia or stroke care)
1.3 The Individual funding request (IFR) process is the means by which the Clinical Commissioning Group (CCG) manages and administers applications for funding for treatments for individuals in accordance with the General Policy for Individual Funding Request Decision Making and the Policies for the Commissioning of Healthcare, Statement of Principles.
1.4 Lancashire CCGs are each responsible for making the decisions to fulfil its legal obligations and
duties and responsibilities for its own patient population. Therefore, it is for the CCG to ultimately decide whether or not an IFR should be funded.
1.5 Lancashire CCGs may commission business support services to help with the administration and
process of IFR’s, they currently purchase these services from Midlands and Lancashire Commissioning Support Unit. The Terms of Reference for the Individual Funding Request Team is shown in Appendix 1
The Lancashire CCG’s supported by this process are:
NHS Blackburn with Darwen CCG NHS Chorley and South Ribble CCG NHS East Lancashire CCG NHS Fylde and Wyre CCG NHS Greater Preston CCG NHS Lancashire North CCG NHS West Lancashire CCG
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1.6 Lancashire’s clinical commissioning policies list those procedures that are not funded or where funding will only be made available if specific criteria are met. Work is also taking place across Lancashire to review the policies contained within this list, as well as to develop new policies. This work will help to ensure that people across the whole of Lancashire are able to access these treatments in a fair and equitable way.
1.7 It is important to remember that, while the NHS does not want to carry out procedures or
treatments which have little health benefit in general, there may be overwhelming health benefits for an individual patient. In these cases, a doctor, on behalf of a patient, will explain the exceptional circumstances and request that these are considered through the IFR Process, where it will be decided if the NHS will fund the procedure. The IFR process will make decisions on an individual case by case basis. The IFR Process for requesting funding on an individual patient basis is detailed in this Policy below. This process is applied consistently by all clinical commissioning groups in Lancashire.
1.8 The IFR process identifies whether the request is for a commissioned service in accordance with
a clinical commissioning policy, or whether the request is for a commissioned service as an exception to a clinical commissioning policy, or whether the request is a service development that is not currently commissioned, or whether the request should be assessed empirically as a rare case for which the CCG would not expect to commission a service for a cohort of patients
1.9 A Service Development can be defined as a change to the CCG's portfolio of service agreements
such that a particular new healthcare intervention shall be routinely commissioned for a defined group of patients. Service developments are likely to result from a prioritisation process. Some requests for healthcare may more appropriately be considered as service developments than as individual funding requests. This is particularly likely where it is identified that there may be a cohort of patients who would wish to access the healthcare intervention.
1.10 This document is part of the governance framework in relation to IFRs and should be read in
conjunction with the General Policy for Individual Funding Request Decision Making and Policies for the Commissioning of Healthcare, Statement of Principles.
2. Submitting an Individual Funding Request (IFR)
2.1 The clinician who intends to use the treatment on behalf of their patient must submit an IFR
application in accordance with the General Policy for Individual Funding Request Decision Making. The IFR Application Form (appendix 6) can be obtained either by contacting the IFR Team or from the CCG.
2.2 The clinician should complete the IFR application form in full, and submit by an approved
secure email (e.g. nhs.net) to the IFR Team. The email addresses are provided on the application form (Appendix 6).
2.3 Postal applications are not recommended to prevent loss of patient identifiable information
and minimise unnecessary delays for patients.
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2.4 For any queries the IFR Team can be contacted by email; [email protected] (for general enquiries) or by phone 01772 214054.
2.5 The clinician submitting the IFR application is responsible for informing the patient and/or
their carer of progress.
2.6 The clinician is responsible for ensuring that the patient has consented to the IFR application and to their medical details being shared with the commissioner and relevant stakeholders defined in this policy for the purposes of considering the IFR application.
2.7 A flow diagram for funding decision making is shown in section 11.
3. Pre-screening stage
3.1 On receipt of the funding request the IFR Team will review the IFR application form to ensure that it is fully complete. Any incomplete or partially completed IFR application forms will be returned to the referring clinician by email. The IFR Team will email the referring clinician advising that the completed application should be returned within four weeks of the date of the email. If the IFR application form is not returned within this timescale, the clinician will be advised that the case will be closed, and no further action will be taken by the IFR Team.
3.2 It is the clinician’s responsibility to ensure that an IFR application form is fully completed and
that it contains all the relevant clinical and financial information which will be required for the CCG to properly evaluate and assess the IFR in accordance with the relevant policies and reach an appropriate decision.
3.3 As part of the pre-screening process, the IFR Team will perform the necessary checks to
identify which CCG is the responsible commissioner.
3.4 All completed IFR application forms will be date stamped, and logged on the IFR database. A case reference number will be assigned to the application, and all personal identifiable information will be redacted from the application where these are shared with expert reviewers to ensure anonymity during the process of decision making.
3.5 Within five working days an acknowledgement will be sent by the IFR Team to the referring
clinician advising that the application will be progressed through to screening stage.
3.6 At any point during the stages, the IFR Team may request further information from the referring clinician.
3.7 All cases will be treated as routine unless otherwise specified by the referring clinician. It is
the aim of the CCG to review all applications and provide a decision within 8 weeks. However, this is largely dependent upon the complexity of the application, whether or not all of the relevant information is contained within the initial application and whether there is a requirement to seek additional or supplementary information.
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4. Screening stage
4.1 The Screening stage is administered by the IFR Team supported by expert reviewers to screen the application.
4.2 The following can be involved in this stage;
• IFR Team (CSU)
Expert reviewers; • IFR Nurse Adviser (CSU) • Medicines Management Lead (e.g. CSU/CCG) • Public Health Lead (e.g. Local Authority) • General Practitioner (e.g. CCG)
4.3 The following practice is applied to the Screening Stage;
• The application is reviewed by the IFR Team initially prior to forwarding to the expert reviewers for screening review.
• The most appropriate expert reviewer will be requested to review the case; for example medicines requests are shared with the Medicines Management Lead.
• All reviews are checked by at least one second reviewer from the IFR Team, or an expert reviewer.
• Expert reviewers record their reviews in a standardised format which is available for audit and scrutiny for any case. These records are made in the IFR database within a secure area for expert reviewers.
4.4 The function of the Screening stage is to ensure that the General Policy for Individual Funding Request Decision Making and the Policies for the Commissioning of Healthcare, Statement of Principles are applied.
4.5 The screening review identifies if the application can be funded by an existing commissioned
service or has grounds for exceptionality.
4.6 The screening review will determine whether or not there is sufficient information such as clinical, financial and other information to enable the IFR Panel to properly assess the case.
4.7 The outcome of the Screening stage will be;
• The application is for treatment that is in accordance with an existing clinical commissioning policy/contract and can therefore be approved by the CCG as standard commissioning policy/contract.
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• The application is for treatment excluded by an existing clinical commissioning policy/contract and there is no basis for clinical exceptionality, and therefore the application is not approved.
• The application is for a treatment that is excluded by an existing clinical commissioning
policy/contract but there is a basis for clinical exceptionality that a reasonable panel might accept in accordance with the exceptionality policy, and therefore the application will be submitted for consideration by the IFR Panel.
• The application is for a treatment where no policy /contract exists and the patient is
described as a rare case for which the CCG would not expect to commission a service for a cohort of patients. The application will be submitted for consideration by the IFR Panel.
• The application is for treatment commissioned by NHS England (or any other commissioner), and is not a matter for the CCG to determine. The applicant will be advised to contact the appropriate commissioner and complete their application process.
• The application is for a case that may be one of a group of patients in similar
circumstances. Such a case should be regarded as a potential service development and considered in accordance with whatever agreement exists at the time between the CSU and the CCG for the management of such cases. In the absence of a specific agreement the individual case will be submitted for consideration by the IFR panel and the CCG will be notified of the issue.
4.8 If there is uncertainty during the screening stage about the application of a clinical commissioning policy, or whether there is exceptionality, the case is progressed to the IFR Panel.
4.9 If the expert reviewer requests further information, then the IFR team will seek that
information from the applicant. If the further information is not supplied within a reasonable period of time for the particular case (which would usually be no longer than 4 weeks) then the expert reviewer and the IFR Panel will be informed, and the IFR Team with expert advice will consider the case for closure.
4.10 The IFR Team will write to the applicant to outline the outcome of the screening stage and
the rationale for the outcome. The patient/patient’s representative where applicable will receive a copy of this letter.
5. IFR Panel
5.1 The IFR Panel may be a standalone panel or carried out as part of a wider commissioning
committee, e.g. Commissioning Request Panel (CRP), depending on CCG organisational arrangements.
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The IFR Panel is a multi-disciplinary professional group responsible for assisting the CCG member to make decisions on IFRs.
5.2 Applications are forwarded to the IFR Panel following screening review. The IFR Team will schedule the application for discussion at the next available IFR Panel.
5.3 The IFR Panel will operate within the limits of delegated authority as determined by the
CCG’s detailed scheme of delegation. 5.4 The membership of the Panel is defined in the Terms of Reference, appendix 2.
5.5 The IFR Panel will be held when required in order to ensure that there is a timely response to
all individual funding requests. Meetings are usually held 4-6 weekly.
5.6 The IFR Panel will take account of the evidence submitted with the application form before making a decision on an individual IFR.
5.7 The outcome of each individual IFR will be communicated to the referring clinician within
two weeks of the decision. This timescale is required to ensure that the documentation from the Panel has been authorised by the membership.
5.8 The IFR Panel may consider, but not be limited to, the following factors:-
• Relevant CCG clinical commissioning policies. • All of the clinical information provided with the application. • The planned treatment/intervention, and the expected benefits and risks of the
treatment. • The clinical evidence base of the treatment/intervention. • The value for money to the NHS of the treatment/intervention. • Whether the treatment/intervention being requested is experimental for a rare
clinical circumstance. • Whether the treatment/intervention being requested constitutes a service
development for a cohort of patients. • The implications of its decision on other patients and on the health of the
population.
5.9 A letter will be sent to the referring clinician, copied to the patient, by the IFR Team on behalf of the Chair of the IFR Panel, or the decision maker for the CCG, advising on the outcomes of the IFR Panel.
5.10 Throughout the process described above, the IFR Team may, at any time, be asked to
request additional information from the referring clinician.
5.11 A funding request cannot be resubmitted to the IFR Panel once it has been considered unless there is new evidence or policy to support a new assessment of the case. Resubmissions are recorded as a new IFR application and the IFR Panel will only consider these where there is
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new information relevant to the case to be considered. Any requests to extend the funding period will be considered in line with section 6.1.
6. Implementation
6.1 If the CCG makes a decision to fund an individual patient request, this decision is valid for a
period of six months from the date that the decision was communicated to the applicant.
7. Urgent Applications
7.1 It is unusual for the CCG to be asked to consider an urgent request for funding. It is expected that clinicians take reasonable steps to minimise the need for urgent requests to be made through the IFR process.
7.2 In rare circumstances, CCG’s recognise that an urgent decision may have to be made before
an IFR Panel can be convened. This section defines how the CCG will administer these cases to an urgent timescale.
7.3 An urgent request is one which requires urgent consideration and a prompt decision because
the patient faces a substantial risk of significant harm if a decision is not made before the next IFR Panel. It will be for the requesting clinician to clearly demonstrate the likelihood of this event occurring and the severity of its impact.
A request will not be treated as urgent where the apparent urgency arises solely as a result of:-
i) A failure by the clinical team to apply for funding through the appropriate route in a
timely manner or, ii) the patient’s expectations being improperly raised by a commitment being given by the
clinician, or their GP to provide a specific treatment to the patient.
7.4 In cases where the urgent request is inappropriate, the CCG will request an investigation is carried out by the referring organisation to prevent similar cases. The IFR Team will provide advice or training to the referring organisation on appropriate IFR referrals where required.
7.5 Urgent requests should be sent to the IFR Team as per the process described in Section 2
above.
7.6 To ensure that a case is prioritised as urgent, the IFR Team must be contacted by phone to advise that the application is urgent. The clinician must outline the level of urgency defined by the nature and severity of the patient’s condition and the reasons why the request is defined as urgent. This information enables the IFR Team to ensure that the request is genuinely urgent, and provides clarity for the administration team on timescales and rationale for communication with the CCG in the process. Telephone is the preferred route of contact to ensure that the IFR application is identified as urgent as soon as possible in the process.
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7.7 Where an urgent decision needs to be made to authorise funding, the IFR Team will contact
an Authorised Officer designated by the CCG. The Authorised Officer should be trained or experienced in IFRs.
7.8 The Authorised Officer has authority to make decisions on behalf of the CCG, and will follow
the CCG’s policies and procedures when making a decision. The Authorised Officer will consider the nature and severity of the patient’s clinical condition, and the time period within which the decision needs to be taken. The Authorised Officer will be supported by advice from expert reviewers, e.g. medicines management, public health or an IFR nurse adviser.
7.9 The Authorised Officer shall be entitled to reach a view that the decision is not of sufficient
urgency that a decision needs to be taken outside of the usual process.
7.10 The Authorised Officer is also entitled to reach a decision that the request is for a service development and therefore, refer the request to the CCG.
7.11 The Authorised Officer will be unable to make a decision if the urgent application does not
have sufficient information and may request further information. This information will be requested by the IFR Team on behalf of the Authorised Officer. The clinician will share the information with the IFR Team to ensure that the case remains anonymised, and that the process is recorded fully.
7.12 The case, decision, evidence and rationale will be recorded and the record will be
maintained by the IFR Team on behalf of the CCG.
8. Appeals Process
8.1 There is no statutory requirement for the CCG to hold appeals. However, in line with best
practice, the CCG does allow an appeal to be made against the process that was followed to arrive at the decision.
8.2 All appeals must be made in writing using the designated form (appendix 4) and submitted
to the IFR Team within 12 weeks of the decision. An Appeal can be made by a clinician requesting the treatment, or a patient.
8.3 It must be noted that an Appeal Panel cannot overturn a decision which has been taken by
the IFR Panel. If new medical evidence has come to light which has not previously been considered by the IFR Panel, then this will be treated as a new application for funding and the case will need to be submitted for reconsideration with the new evidence. The Appeals Panel will not consider the appeal further.
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8.4 The person submitting the appeal must clearly evidence where and how due process was not followed or where a policy was incorrectly applied. The clinician making or supporting the Appeal, must confirm the basis for the appeal i.e:-
Illegality: The refusal of the application was not an option that could lawfully
have been taken by the IFR Panel. Procedural Impropriety: There were substantial and/or serious procedural errors in the way in
which the IFR process was conducted. Irrationality: The decision of the CCG to refuse funding for the requested
treatment/intervention was one which no reasonable IFR Panel with the same terms of reference, could have reached on the evidence available to the Panel.
8.5 If an IFR has been referred as a service development, there will be no right to an Appeal.
8.6 The membership of the Appeal Panel is defined in the Terms of Reference (appendix 3). No
member of the appeal panel shall have been involved in the case previously. The appeal panel will be supported by the IFR Team.
8.7 Appendices 3 and 5 define the terms of reference for the Appeal Panel and a template
agenda for the meeting.
8.8 No Appeal’s Panel member will have had involvement in the original IFR Panel’s decision or should know the patient. A member of the IFR Team will be in attendance to provide administrative support, including minute taking. The IFR Team as administrators may have been involved in any part of the process including IFR Panel or the Appeals Panel.
8.9 On receipt of a request for an Appeal, the IFR Team will identify whether any new clinical
information has been submitted which was not available to the IFR Panel at the time the decision was made. If new information has emerged, the case will be re-scheduled for IFR Panel discussion and appellant will be informed.
8.10 The IFR Team will submit all Appeals, in which no new information has emerged since the IFR
Panel’s decision, to the Chair of the Appeals Panel within two weeks of receipt of the request for Appeal. Prior to convening a formal Appeals Panel meeting, the Chair of the Appeals Panel will read and consider all of the documentation relating to the original IFR Panel decision along with the Appeals submission. The Chair of the Appeals Panel will then decide within 2 weeks whether or not there is a case to answer. If there is no case to answer, the Chair of the Appeals Panel will communicate this decision in writing to the appellant and the case will be closed. If the Chair of the Appeals Panel decides to convene an Appeals Panel, the IFR Team will inform the applicant in writing.
8.11 The IFR Team on behalf of the Chair of the Appeals Panel will convene the meeting, inviting
appropriate representation. The Chair will ensure that the Appeal Panel is quorate in accordance with the Terms of Reference and consider if additional attendance or advice is required to ensure that a robust consideration of the Appeal can be made.
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8.12 The clinician and the patient (or representative) will be given the opportunity to attend and
will be given a minimum of 7 days notice of the date and time of the Appeal. The patient can advise the Chair in advance if they wish to bring any additional people to the panel. The patient (or representative) can bring up to two additional people.
8.13 At the Appeal Panel meeting, the patient’s clinician, or the patient (or their representative)
will be given the opportunity to set out orally the basis for the appeal. If preferred, information can be submitted in writing to the Chair via the IFR Team to be considered at the Appeal Panel. The Appeal Panel will review this alongside the Appeal application (appendix 4).
8.14 A CCG member of the IFR Panel will also be asked to explain the process that was followed
and the rationale for the original decision. The CCG member can request any other expert member of the IFR Panel to join the Appeal Panel to support this part of the process.
8.15 The Appeals Panel will:
i. Consider whether the decision making process was followed in accordance with the
CCG’s IFR Policy. ii. Consider whether the right clinical commissioning policy was applied for the decision.
iii. Consider whether the IFR Panel took account of all of the relevant information provided at the time of its decision and consider whether or not the IFR Panel took account of any irrelevant information at the time of its decision that may have affected the outcome.
iv. Consider whether the IFR Panel came to a decision that fell within the range of decisions which a reasonable IFR Panel could have reached with the same evidence available to them.
8.16 If the Appeals Panel concludes that:-
• new information has emerged since IFR Panels decision or, • that the IFR Panel did not consider all the available information or, • that the IFR Panel had considered irrelevant information that could have affected the
outcome or, • the wrong clinical commissioning policy was considered when the decision was made,
or • the decision did not fall within a range of decisions which a reasonable CCG could have
reached based on the evidence before them • that there had been misinterpretation of evidence submitted or • that the IFR Panel had not followed due process or documented the decision making
clearly to explain the rationale for the decision making.
then, the Chair of the Appeals Panel will refer the case back to the IFR Panel for reconsideration. If there is new evidence or information to support the IFR, then the applicant clinician will be required to resubmit the application with the new information to support the case.
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 14 of 34
8.17 The application will be scheduled for discussion at the next available IFR Panel to reconsider all of the information previously received including any new information and the recommendations of the IFR Appeal Panel. The decision and rationale for the new decision of the IFR Panel will be sent to the Chair of the Appeals Panel. The Chair of the Appeals Panel is required to satisfy him/herself that the IFR Panel has addressed the recommendations, and documented this before a decision is shared with the patient by the IFR Panel. The Chair of the Appeal Panel can be invited to the IFR Panel if required. If the Chair cannot satisfy him/herself, then he/she will meet with the Appeal panel decision maker(s). If that fails to resolve the issue, the matter will be referred to the Chair of the CCG, whose decision is final.
8.18 If the Appeals Panel concludes that due process was followed when the original decision was
taken and it wishes to uphold the original decision taken by the IFR Panel to decline funding, then the Chair of the Appeals Panel will communicate this to the clinician and the patient (or their representative) if appropriate, within four weeks of the Appeals Panel meeting. The Chair of the Appeals Panel will also advise the Chair of the IFR Panel, in writing, of the Appeal Panel’s conclusions.
8.19 The Chair will not have meetings with the patient (and or representative) or the CCG Panel
representative prior to the Appeal Panel.
9. Patient and clinician feedback
9.1 The CSU on behalf of the CCGs will put in place mechanisms to gain feedback from patients and requesting clinicians as part of the process.
10. Monitoring
10.1 The IFR process will be monitored and reviewed to ensure that the decision making is fair
and consistent and to make sure that Screening stages and IFR Panels are following the processes appropriately and effectively.
10.2 Regular finance and activity reports will be sent to the CCG,
10.3 The Collaborative IFR Process for Lancashire CCGs is reviewed every two years by the CCG
supported by the CSU.
10.4 The CSU will submit an annual report on behalf of IFR Panel to the Boards of constituent CCGs.
11. Photographic evidence
11.0 The CCG advises that photographic evidence will not be accepted for consideration unless it
is impossible to make the case in any other way. The decision to submit photographic evidence remains with the patient and responsible clinician. The CCG is concerned that photographs could be misleading, embarrassing or discriminatory. Ultimately however it is
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 15 of 34
the responsibility of the applicant to decide whether photographs are necessary, and submitted photographs may be taken into account if all of the following apply:
• A statement of what the photographs show and why they are submitted is included in
the text of the application. • The photographs are professionally taken by a medical illustration department. • They are submitted with the patient's consent, including consent for the photographs to
be examined, stored and destroyed in accordance with information governance requirements
• The submission should be made by secure NHS email with the IFR application detailing the identity of the patient, the date of the photograph and clinical opinion that it represents a true likeness of the affected body part.
• As far as possible subject to the body part in question, the photographs will be of the clothed appearance with the patient not being identifiable. Applicants should note that in many cases Clinical Commissioning Policies take account of the social (i.e. clothed) appearance rather than the intimate (unclothed) appearance.
• The photographs will be submitted only to support or clarify a case made in writing. There should be no expectation that the photographs themselves will amount to a case for funding, or will lead to a decision that the case is stronger than is described in writing. After consideration has been given to the written case, there is doubt about whether the CCG should offer funding and that doubt can be resolved only by examination of the photographs
11.1 If photographs are accepted for consideration in accordance with the above criteria, they
will be examined by the members of the IFR Panel. In the course of the work for the case the applicant should be aware that other members of the IFR Panel, IFR Appeals Panel or IFR team who prepare the papers may need to handle or see the photographs during their work on the case.
12. Schematic of decision making
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 16 of 34
Ye
s
Is th
ere
is a
pol
icy?
No
CC
G ad
vise
d
Yes
Do
es th
e pa
tient
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the
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ncer
tain
Is it
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ent?
Yes
CCG
advi
sed
N
o
No
CC
G ad
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No
Is
ther
e a
case
for
exce
ptio
nalit
y?
Ye
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CC
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Yes
Ye
s
Wou
ld it
be
fund
ed if
ther
e w
as
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Prin
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Do
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ase
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ally
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CCG
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U
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Unc
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CC
G de
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on n
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Form
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Furt
her c
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Exit
poin
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UND
Exit
poin
t - D
O N
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poin
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o co
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new
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EL
At a
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tage
furt
her
info
rmat
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may
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ht
from
the
appl
ican
t bef
ore
proc
eedi
ng
Exce
ptio
nalit
y w
ill a
lso
be c
onsi
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the
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of p
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- if
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l dec
ides
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ay th
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ider
exc
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y.
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 17 of 34
Appendix 1: Terms of Reference for the Individual Funding Request Team
1. Purpose The role of the Individual Funding Request Team is to support the IFR process for the Clinical Commissioning Groups. The team will:
1. Provide oversight of the management and co-ordination of the IFR process. 2. Ensure that the IFRs are managed in line with the policies of the CCG. 3. Provide the administrative function for screening, IFR Panel and IFR Appeals Panels. 4. Provide administrative oversight and ratification on IFR functions with clinical expertise 5. Administer the paperwork, ensuring the efficient handling and documentation of submissions,
from first receipt through to archiving. 6. Provide a single point of contact for clinicians involved in the IFR and IFR Appeal processes. 7. Maintain an IFR database. 8. Maintain a register of Authorised Officers and liaise with them in urgent cases. 9. Advise on publications on CCG websites 10. Liaise with the CCG Boards, Committees and officers responsible for priority-setting and policy
development as required. 11. Raise issues of policy with CCGs. 12. Bring new service developments identified during the IFR process to the attention of the CCGs. 13. Contribute to the recruitment and training of IFR Panel and IFR Appeal Panel members. 14. Attend meetings in an advisory capacity. 15. Liaise with the legal team to support the CCG. 16. Support update of the IFR policies 17. Provide a source of expertise including advising clinicians wishing to submit a funding request. 18. Monitor the quality of the IFR process and decision making including overseeing regular audits of
the process. 19. Arrange training if required to do so and ensure that members of the IFR Panels, IFR Appeal
Panels and Authorised Officers undergo training on a regular basis. 20. Liaise with Local Authority and other teams in the CSU supporting the IFR process
2. Corporate Governance and Risk Management The IFR Team will adhere to all the corporate governance and risk management arrangements set out in the agreement between the Midlands and Lancashire Commissioning Support Unit and the CCGs. The IFR Team will provide regular reports to the CCGs informing them of the number of IFRs that have been screened and the number considered at the IFR Panel, as well as the outcome and the financial commitment. The IFR Team will provide an annual report to the CCG Board. The IFR Team will report any governance concerns or risks to the CCG when this comes to their attention.
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 18 of 34
All members of the IFR Team and IFR Panel members must undergo training to cover both the legal and ethical framework for IFR decision making, the CCG’s commissioning processes and structures, the technical aspects of interpretation of clinical evidence and research, and guidance in respect of the policies relevant to their advice. This training will be regularly refreshed to ensure that all IFR and IFR Appeal Panel members maintain the appropriate skills and expertise to function effectively.
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 19 of 34
Appendix 2: Terms of Reference for the IFR Panel
1. Purpose The IFR Panel is a forum for discussion of the case and analysis of the evidence to assist the Clinical Commissioning Group member/employee to reach a decision in any particular case. This panel may be delivered as part of a wider commissioning committee within a CCG depending on organisational approaches. For example a Commissioning Request Panel which includes cases for Continuing Health Care and IFRs. The role of the Individual Funding Request Panel (IFR Panel) is to:
• Review screened cases • Discuss and analyse each case put before the IFR Panel in which a decision will be reached by
the responsible commissioner CCG. The IFR Panel will consider all the written evidence which is provided to it, including the individual funding request form itself and any other documentary evidence. In doing so, it will take into account the policies and procedures of the CCG. The IFR Panel may at its discretion request the attendance of any clinician to provide clarification on any issue, or request independent expert clinical advice for consideration by the IFR Panel at a further date. Only the member/employee from the patient’s responsible Clinical Commissioning Group can take the final decision on funding.
2. Membership and Quoracy The membership of the IFR Panel will be:
• A Chair, who shall be a senior manager of the IFR team from the CSU • A General Practitioner • A senior authorising manager from the CCG • A medicines management representative from the CCG/CSU • An additional health professional member who may have a medical and/or dental
and/or nursing and/or public health (MFPH or equivalent) background. In attendance where required: an IFR team member to support administration and minute taking. Other members of the IFR team and CCG staff may be in attendance if they have been involved in preparing cases for the agenda, or are recording the discussion.
The role of the panel will be to provide formal collective advice to the CCG decision makers. To be quorate in giving advice as a panel at least any three of the following members must be present for quoracy;
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 20 of 34
• IFR Chair • Senior authorising manager from the CCG • Medical representative - General Practitioner from the CCG, or health professional member
The final decision will be taken by the decision makers (in or outside of the panel meeting). The decision maker(s) will decide whether or not to accept the advice of the panel.
Each member should declare any potential conflict of interest as soon as they become aware of it. A general practitioner should not be involved in Panel discussions about their own patient or make a decision concerning their own patient. In these instances, another CCG member/employee should attend the Panel.
3. Decision making The final decision for any given IFR will be taken by the responsible commissioner CCG member/employee. The role of the panel is therefore to advise the CCG’s decision maker. The panel shall to be quorate and shall achieve a panel decision about what advice to offer. The decision of a quorate panel will be recorded in the notes as the formal advice of the panel. The decision maker shall take account of the formal advice of the panel at his/her discretion, and shall reject it only in accordance with any governance processes agreed by that CCG for the purpose.
4. Corporate Governance and Risk Management For each case the factors taken into account, the deliberations, the decisions and the reasons for the decision will be documented.
Members of the IFR Panel must undergo IFR training to cover legal and ethical frameworks for IFR decision making, the CCG’s commissioning processes and structures, the technical aspects of interpretation of clinical evidence and research, and guidance in respect of the policies relevant to their advice. This training will be regularly refreshed to ensure that all IFR and IFR Appeal Panel members maintain the appropriate skills and expertise to function effectively.
5. Frequency of Meetings The IFR Panel will meet regularly to ensure cases can be heard. Panels will normally be scheduled to meet every 4-6 weeks, but meetings may be cancelled or additional meetings arranged depending on the nature and amount of requests. Virtual meetings by telephone or web conferencing may be held, as and when required. The decisions made outside the regular meetings must be relayed to the next formal IFR Panel meeting for ratification by the CCG member/employee and incorporated into the minutes of the next IFR Panel.
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 21 of 34
Appendix 3: Terms of Reference of the IFR Appeal Panel
1. Purpose The role of the Individual Funding Request Appeal Panel (IFR Appeal Panel) is to consider appeals against decisions taken by the Clinical Commissioning Group to ensure that decisions have been taken in accordance with the policies and processes of the CCG and the specific processes and jurisdiction that are contained within the policy. The IFR Appeal Panel will normally reach its decision on the basis of all the written evidence which is provided to it, although it may request the attendance of legal, clinical or public health expertise to clarify any points for consideration by the IFR Appeal Panel. The IFR Appeal Panel will consider only the following documentation:
(a) the original IFR application submitted to the CSU; (b) the records documenting the process by which the request has been considered; (c) the IFR Panel records, including the IFR Panel record and any additional supporting
information considered by the IFR Panel; (d) the IFR Appeal application form (which can be found in appendix 4) which sets out the
grounds of the appeal by the requesting clinician and/or the patient/guardian or carer in their request for review.
(e) Any supporting written evidence if an oral presentation at the Panel is not made by the patient (or their clinician or representative).
If there is substantive new evidence presented to the IFR Appeal Panel, the IFR Appeal Panel will request the applicant clinician to resubmit the application to an IFR Panel and for the CCG to review its original decision in light of the new evidence. The IFR Appeal Panel will arrive at one of two decisions. The IFR Appeal Panel will either:
(a) uphold the decision reached by the IFR Panel and approved by the Clinical Commissioning Group; or
(b) refer the case back to the IFR Panel for reconsideration (which may require a resubmission by the clinician where new evidence has been identified)
2. Membership and Quoracy The Appeal Panel will comprise one lay Governing Body member, who will chair the panel, one General Practitioner, and one CCG senior manager. No member of the appeal panel shall have been involved in the case previously. The appeal panel will be supported by the IFR Team. To ensure that the review is independent of the original decision, the Appeal Panel members will be different from the IFR Panel members who originally considered the case and the CCG member/employee who made the original decision.
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 22 of 34
All members must be in attendance for the meeting to be considered quorate. The Chair of the IFR Appeal Panel can request the attendance of other individuals in an advisory capacity. A member of the IFR Team will provide administrative support. This may include staff who have been involved in administering the case for the IFR Panel.
3. Corporate Governance and Risk Management For each case considered the factors taken into account, the weighting given to those factors, the decisions and the reasons for the decision will be documented. All members of the IFR Appeals Panel must undergo training.
4. Frequency of Meetings The IFR Appeal Panel will be convened within 5 weeks of an appeal being received.
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 23 of 34
Appendix 4: Individual Funding Request (IFR) Application Appeal Form
The remit of the Individual Funding Request Appeal Panel is to ascertain whether the decision taken by the CCG at the IFR Panel:
• was taken in accordance with the requirements of this policy; • properly took into account and evaluated all the relevant evidence; • did not take into account irrelevant factors; • was taken in good faith; and • was a decision that falls within the range of responses which the CCG was reasonably entitled to
reach on the application and evidence submitted.
(M&L CSU use only)
Case code:
Date Received:
Date assessed by IFR Team: Decision:
IFR Screening Date: Decision:
IFR Panel Date:
Decision:
IFR Appeal Panel Date:
Decision:
1. Patient Details Forename: NHS Number: Surname: Hospital Number: Date of Birth: Sex: M/F: Patient’s Address & Postcode:
Ethnic Origin:
(Please note that all necessary personal information will be removed from this form prior to being reviewed. This information is collected for monitoring and case correlation purposes only)
2. Appellant Name
Position/Title
Relationship to the patient
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 24 of 34
Signature
Date Completed
3. Details of the appeal (Please note that one of the sections below needs to be completed for an appeal to be
considered)
Please detail how the decision making process was not followed appropriately.
Please detail how the decision made by the Clinical Commissioning Group was unreasonable in light of the following factors:
• The evidence of exceptionality (which the IFR Panel deemed to not be demonstrated) • The clinical & cost effectiveness evidence • The patient’s individual circumstances • Other material factors
Please detail any other information that you consider to be relevant to the appeal
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 25 of 34
Please note that if new evidence regarding exceptionality or new clinical evidence is submitted then the case will need to be referred back to the Individual Funding Request Panel for reconsideration.
This should be completed by resubmitting the application with any new information.
On Completion Email: Blackburn with Darwen CCG: [email protected]
East Lancashire CCG: [email protected] Lancashire North CCG: [email protected] Greater Preston CCG: [email protected] Chorley and South Ribble CCG: [email protected] Fylde and Wyre CCG: [email protected] West Lancashire CCG: [email protected]
or Post (Marked Confidential) to:
IFR Team
Midlands and Lancashire CSU Lancashire Business Park Centurion Way Leyland PR26 6TR
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 26 of 34
Appendix 5: Agenda template for Individual Funding Request (IFR) Appeal Panel
AGENDA
<<Insert CCG name>>
APPEAL PANEL
<<Insert date, time and venue>>
Item Title Lead Enclosure number 1 Apologies, welcome and introductions
Chair
2 Purpose of this Panel meeting
Chair
3 Presentation of the appeal case
Appellant clinician and/or patient (or representative)
4 Outline of the IFR Panel decision, rational and response to the appeal case
Chair of the IFR Panel or CCG representative
5 Questions and answers; Questions to the Presenters on behalf of the appeal from any person in attendance.
6 Questions to the Presenters on behalf of the IFR Panel from any person in attendance.
7 Presenters to leave the room, (appellant &/representatives and Chair or CCG member of the IFR Panel) for panel discussion
Chair
8 All attendees are invited to reconvene for the Chair to provide the conclusion or the position following deliberation and recommendations
Chair
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 27 of 34
Appendix 6: IFR Application Form
NHS Blackburn with Darwen CCG NHS Chorley and South Ribble CCG
NHS East Lancashire CCG NHS Fylde and Wyre CCG NHS Greater Preston CCG
NHS Lancashire North CCG NHS West Lancashire CCG
Appendix 6: Individual Funding Request (IFR) Application Form
All sections of the form must be completed otherwise the case will not be considered
Important information This is form is an appendix to the collaborative Individual Funding Request process for Lancashire Clinical Commissioning Groups. The full document must be considered before making an application on behalf of a patient to ensure that it is appropriate. Before you begin to complete this form to make an application you MUST first consider the following question: Are there similar patients with similar clinical circumstances who could also benefit from the treatment you are requesting across the population of the CCGs? If the answer is YES then making an individual funding request is an inappropriate way to deal with funding for this patient. This is because the case represents a service development for a predictable population. You should discuss with your contract team (or commissioning leads at the CCG) to understand how you submit a business case for consideration through the usual business planning process. If the answer is NO then please proceed by completing the application, providing the information and relevant evidence for the appropriate category of IFR into which this patient’s case falls.
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 28 of 34
Mandatory field if proceeding with the IFR Are there likely to be similar patients in your service in the next year who will receive the same expected benefits from this treatment or intervention? Yes or no (please delete) If YES, please indicate likely number of patients there are likely benefit from this treatment per million population. If you do not have this type of information, please advise how many cases you would expect to refer to a CCG per year.
MLCSU use only Case code:
Date received:
Date assessed by IFR Team:
Decision:
IFR screening stage date: Decision: IFR Panel date:
Decision:
Mandatory field
1. Requesting clinician or specialist details
The application form should be completed by the clinician responsible for the service or delivery of the treatment who has the knowledge to understand if a patient is exceptional to commissioning policy or current contracts. This would usually be a specialist clinician. Name of organisation:
Name & designation of requesting clinician:
Address:
Telephone no:
Email Address:
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 29 of 34
Mandatory field 2. Patient details
*Forename: NHS number: *Surname: Hospital number: Date of birth: Gender: Patient’s personal
email: (This is required for the patient to receive a copy of email correspondence)
*Patient’s address & postcode:
Ethnicity:
Please note that the necessary personal identifiable information shown by * will be removed from this form prior to being forwarded to IFR Reviewers by the IFR Team and the date of birth will be changed to
an age before being forwarded.
Mandatory field
3. Patient consent Does the patient, or their authorised representative provide consent for all information regarding their case to be shared with the Individual Funding Request Panels?
YES / NO
If the patient has been assessed as not having mental capacity to give informed consent, then please confirm that you have complied with the Mental Capacity Act 2005 and the accompanying Code of Practice.
YES / NO
I confirm that the patient consents to the use of their personal email to be included in any correspondence from IFR Services. If this is not provided then correspondence will be posted to the patient’s address
YES / NO
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 30 of 34
Mandatory field 4. Registered GP details
Name of registered GP practice:
Registered GP practice address:
Registered GP:
Telephone no:
Email address:
Mandatory field
5. Clinical urgency
Clinicians are advised to read Section 7 to understand how urgent applications are defined and managed. If this request is urgent in accordance with Section 7 of the collaborative Individual Funding Request process for Lancashire Clinical Commissioning Groups, then an IFR Case Manager (or IFR Team member) must be phoned to advise why there is urgency, and how urgent it is to ensure this case is given the appropriate priority and this completed form must be submitted to commence the process. The phone number is at the end of this form.
Mandatory field
6. Treatment history Details of diagnosis & prognosis (for which the treatment is requested):
Relevant medical history: (include dosage and frequency of all medications and co-morbidities)
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 31 of 34
Previous treatments / interventions this patient has received for this condition:
Date/s Intervention (e.g. drug. surgery)
Reason for stopping / Response achieved
Mandatory field
7. Treatment Requested
Information can be appended with your submission to support your submission, e.g. published trials.
Details of intervention / treatment for which funding is requested:
Name of treatment/intervention:
Describe details of treatment/intervention, e.g. drug, dose frequency, duration total number of treatments:
Status of the treatment/intervention
Describe the status of the intervention e.g. a UK licensed medicine to be used within the product specification, or to be used outside the product specification, an innovative device or appliance, a product under research, a NICE interventional procedure.
Cost of treatment:
Cost of the treatment:
Detail of associated costs: (including VAT & Associated Inpatient / Outpatient Activity):
Anticipated total cost:
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Efficacy of the treatment/intervention:
Describe the intended benefit for this patient:
Describe the evidence that delivers the health benefit:
Patient safety: Describe the risks or safety profile for the treatment or intervention in this patient:
Mandatory field
8. Alternative treatments What standard treatment does this request replace?
Why is the standard treatment not appropriate?
What would be the cost of the standard treatment?
If this treatment request is not approved, what treatment will be given to the patient?
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 33 of 34
Mandatory field
9. Request to treat this patient as an exception to a clinical commissioning policy or equivalent
Where known, please state which clinical commissioning policy or policies this IFR relates to:
Please set out below the case for this patient being considered an exception with reference to:
• why the patient in question is different to the usual population of patients to whom the commissioning policy applies
• why that difference means the commissioning policy should not apply. • any other material factors which have bearing on the case;
Please attach evidence in support of the benefit of treatment in this patient. Please provide a list of your enclosures below:
IFR Process and Application Form, Lancashire CCGs, June 2016 Copyright © Midlands and Lancashire CSU & Lancashire CCGs. All rights reserved. Page 34 of 34
Mandatory field 10. Declaration
To the best of my knowledge I have given the most accurate and up to date information regarding this patient’s clinical condition. Name
Position/title
Signature
Provider trust support for the application Name
Position/title
Signature
Date completed
On completion Please email the completed form and enclosures to the appropriate Clinical Commissioning Group via the nhs.net to nhs.net secure email:
Blackburn with Darwen CCG: East Lancashire CCG: Lancashire North CCG: Greater Preston CCG: Chorley and South Ribble CCG: Fylde and Wyre CCG: West Lancashire CCG:
[email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected]
Telephone number for Midlands and Lancashire IFR Team (Lancashire region): 01772 214054
EPRR Self-Assessment Framework West Lancashire Clinical Commissioning Group Governing Body Meeting – 27 September 2016
1
WLCCGB 09/16/10
WEST LANCASHIRE CLINICAL COMMISSIONING GROUP GOVERNING BODY REPORT
DATE OF BOARD MEETING: 27 September 2016
TITLE OF REPORT: EPRR Self-Assessment Framework BRIEFING POINTS: The CCG has partially met the assessment criteria. An Amber or Red areas have actions to address these areas currently ongoing.
Does this report / its recommendations have implications and impact with regard to the following:
A. Commissioning Board’s Aims and Objectives 1. Quality (including patient safety, clinical effectiveness and patient
experience) – please outline impact
2. Commissioning of hospital and community services – please outline impact
3. Commissioning and performance management of GP Prescribing – please outline impact
4. Delivering Financial Balance – please outline impact 5. Development of the commissioning group as a commissioning
organisation – please outline impact x
B. Governance – please outline impact 1. Does this report:
• provide the Commissioning Board with assurance against any of the risks identified in the assurance framework (identify risk number)
• have any legal implications • promote effective governance practice
x
2. Additional resource implications
(either financial or staffing resources)
3. Health Inequalities 4. Human Rights, Equality and Diversity Requirements 5. Clinical Engagement 6. Patient and Public Engagement
PAPER PRESENTED BY: Mike Maguire, Chief Officer
Statement of Compliance Version 2 27/07/16
Emergency Preparedness, Resilience and Response (EPRR) Assurance 2016-17
STATEMENT OF COMPLIANCE
West Lancashire CCG has undertaken a self-assessment against the NHS England Core Standards for EPRR (v4.0). Following self-assessment, and in line with the definitions of compliance stated below, the organisation declares itself as demonstrating the following level of compliance against the 2016-17 standards: Substantial
Compliance Level Evaluation and Testing Conclusion
Full Arrangements are in place that appropriately addresses all the core standards that the organisation is expected to achieve. The Board has agreed with this position statement.
Substantial Arrangements are in place however they do not appropriately address one to five of the core standards that the organisation is expected to achieve. A work plan is in place that the Board has agreed.
Partial Arrangements are in place, however they do not appropriately address six to ten of the core standards that the organisation is expected to achieve. A work plan is in place that the Board has agreed.
Non-compliant Arrangements in place do not appropriately address 11 or more core standards that the organisation is expected to achieve. A work plan has been agreed by the Board and will be monitored on a quarterly basis in order to demonstrate future compliance.
The results of the self-assessment were as follows:
Number of applicable standards
Standards rated as Red
Standards rated as Amber
Standards rated as Green
West ~Lancashire CCG 0 4 36
Acute providers: 53** Specialist providers: 44** Community providers: 44** Mental health providers:44** CCGs: 35**
**Includes ‘deep dive’ standards relating to business/service continuity with an emphasis on fuel: Standards: CCGs 5 / Providers 6 Also includes HAZMAT/CBRN standards applicable to providers: Standards: Acutes 14 / Specialist, Community, Mental health 7 Where areas require further action, this is detailed in the attached EPRR Work Plan and will be reviewed in line with the organisation’s governance arrangements. I confirm that the above level of compliance with the EPRR Core Standards has been or will be confirmed to the organisation’s board / governing body.
______________________________________________________________
Signed by the organisation’s Accountable Emergency Officer
27/09/2016 19/09/2016 Date of board / governing body meeting Date signed
WLCCGB 09/16/11
WEST LANCASHIRE CLINICAL COMMISSIONING GROUP
GOVERNING BODY REPORT
DATE OF BOARD MEETING: 27 September 2016
TITLE OF REPORT: CONFLICT OF INTEREST POLICY
BRIEFING POINTS: To provide:
• The Governing Body, the revised West Lancashire CCG’s (WLCCG) Conflict ofInterest (CoI) Policy.This paper provides assurance that WLCCG’s CoI policy continues to complywith relevant legislation and statutory requirements and aligns with the newguidance of NHS England published in June 2016.
There is a strong recommendation for CCGs to have a minimum of three laymembers on the Governing Body, which WLCCG would need to consider.
To align with the new guidance, WLCCG has:
• introduced a new role - Conflicts of Interest Guardian who will assume an importantpoint of contact role for any conflicts of interest queries or issues
• included a robust process for managingany breaches within their Conflict of Interest policy and for anonymised detailsof the breach to be published on WLCCG’s website for thepurpose of learning and development
• Strengthened provisions around decision-makingwhen a member of the governing body or committee or sub-committee is conflicted
• Strengthened provisions around the management ofgifts and hospitality, including the need for prompt declarations and a publiclyaccessible register of gifts and hospitality
• All WLCCG employees, governing body members,members of committees and sub-committees and practice staff with involvement inWLCCG business, to complete mandatory online conflicts of interest training by31 January of each year. The online training application is scheduled to be rolledout by NHS England in the Autumn of 2016.
In addition, the following requirement will need to planned and considered:
• to include an annual audit of Conflicts ofInterest management within WLCCG’s internal audit plans and to include thefindings of this audit within WLCCG’s annual end-of-year governance statement
EQUALITY IMPACT ASSESSMENT:
THE BOARD IS INVITED TO:
Has an Equality Impact Assessment been carried out? YES
The document has been sent to the CSU Equality and Inclusion Team for their approval.
and is it attached? YES
Approve the proposals set out in this paper
Does this report / its recommendations have implications and impact with regard to the following: A. Commissioning Board’s Aims and Objectives 1. Quality (including patient safety, clinical effectiveness and patient
experience) – please outline impact
2. Commissioning of hospital and community services – please outlineimpact
As above 3. Commissioning and performance management of GP Prescribing –
please outline impact4. Delivering Financial Balance – please outline impact5. Development of the commissioning group as a commissioning
organisation – please outline impact
B. Governance – please outline impact 1. Does this report:
• provide the Commissioning Board with assurance against any ofthe risks identified in the assurance framework (identify risknumber)
• have any legal implications• promote effective governance practice
X
2. Additional resource implications(either financial or staffing resources)
X
Appointment of Conflict of Interest Guardian, Lay Member, etc. For additional information see briefing notes 3. Health Inequalities4. Human Rights, Equality and Diversity Requirements5. Clinical Engagement6. Patient and Public Engagement X
The Register(s) of Declaration of Interest and gifts and hospitality register will be published on WLCCG website
REPORT WRITTEN BY: Smita Shetty, Service Redesign Manager (Corporate) PRESENTED BY: Paul Kingan, Chief Finance Officer
Conflict of Interest Policy West Lancashire Clinical Commissioning Group Governing Body Meeting – 27 September 2016
PRESENTED BY: Paul Kingan, Chief finance officer
Conflict of Interest Policy
Reference number Conflict of Interest Policy September 2016 V4
Approving committee & date Governing Body 27 Sep 2016 Document replaces Conflict Policy Feb 2015 REVIEW DUE DATE September 2017
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West Lancashire CCG is committed to ensuring that, as far as it is reasonably practicable, the way we provide services to the public and the way we treat our staff reflects their individual needs and does not discriminate against individuals or groups on the basis of their age, disability, gender, race, religion/belief or sexual orientation.
Should a member of staff or any other person require access to this policy in another language or format (such as Braille or large print) they can do so by contacting the West Lancashire CCG who will do its utmost to support and develop equitable access to all policies.
Senior managers within the CCG have a responsibility for ensuring that a system is in place for their area of responsibility that keeps staff up to date with new policy changes.
It is the responsibility of all staff employed directly or indirectly by the CCG to make themselves aware of the policies and procedures of that CCG.
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Table of Contents
1. Introduction & Scope .......................................................................................... 5
2. Definition of interest ............................................................................................ 6
3. Principles ............................................................................................................. 9
4. Identification and management of conflicts of interest…………………….….12
5. Declaring interests………………………………………………………………...….14
6. Register(s) of interests………………………………………………………………16
Register(s) of interests……………………………………………………...………..….16 Gifts……………………………………………………...…………………………….…..17 Hospitality……………………………………………………………………….………...17 Commercial sponsorship…………………...………………………………………..….18 Declaration of offers and receipt of gifts and hospitality………………….………….18 Publication of registers…………………………………………………………….…….19
7. Appointments and roles and responsibilities in the CCG
Secondary employment………………………………………………………………....20 Appointing governing body or committee members and senior employees…….…20 Conflicts of Interest Guardian…………………………………………………….…….21
8. Managing conflicts of interest at meetings………………………………………22
Chairing arrangements and decision-making process………………………………22 Primary care commissioning committees and sub-committees……………………24 Membership of primary care commissioning committees (for joint and delegated arrangements)………………………………………………………………………...….25 Primary care commissioning committee decision-making processes and voting arrangements……………………………………………………………………………..26 Minute-taking...…………………………………………………………………………...26
9. Managing conflicts of interest throughout the commissioning cycle…...….27
Designing service requirements……………………………………………….….……27 Provider engagement…………………………………………………………………...27 Specifications………………………………………………………………………….....28 Procurement and awarding grants…………………………………………………......28 Register of procurement decisions…………………………………………………..…30
10. CCG Improvement and Assessment Framework…………………………….33
11. Raising concerns and breaches…………………………………………………35
Reporting breaches………………………………………………………………………35 Fraud or Bribery………………………………………………………………….………36
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12. Impact of non-compliance……………………….………………………………....37
Civil implications…………………………………………….…………………………..37 Criminal implications…………………………………………...……………………….37 Disciplinary implications………………………………………………………….…….38 Professional regulatory…………………………………………………………………38
13. Conflicts of interest training………………………………………………………..39
14. Glossary…………………………………………………….………………………….40
Annexes…………………………………………………………………………..……….41 Annex A: Template Declaration of interests for CCG members and employees....43 Types of interest………………………………………………………………………….44 Annex B: Template Register of interests……………………………………………....45 Annex C: Template Declarations of gifts and hospitality…………………………….46 Annex D: Template Register of gifts and hospitality………………………………….47 Annex E: Template declarations of interest checklist………………………………..48 Template for recording any interests during meetings……………………………….50 Template to record interests during the meeting……………………………………..51 Annex F: Template for recording minutes…………………………………………….52 Annex G: Procurement checklist………………………………………………………54 Annex H: Template Register of procurement decisions and contracts awarded ...57 Annex I: Template Declaration of conflict of interests for bidders/contractors……58 Annex J: Conflicts of interest policy checklist…………………………………………60
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1.0 Introduction & Scope This policy sets out how NHS West Lancashire Clinical Commissioning Group (WLCCG) will manage conflicts of interest and potential conflicts of interest.
1.1 This policy applies to:
• All WLCCG employees, including:
• All full and part time staff; • Any staff on sessional or short term contracts; • Any students and trainees (including apprentices); • Agency staff; and • Seconded staff
In addition, any self-employed consultants or other individuals working for the WLCCG under a contract for services should make a declaration of interest in accordance with this guidance, as if they were WLCCG employees.
• Members of the governing body: All members of WLCCG’s
committees, sub-committees/sub-groups, including:
• Co-opted members; • Appointed deputies; and • Any members of committees/groups from other organisations.
Where WLCCG is participating in a joint committee alongside other CCGs, any interests which are declared by the committee members should be recorded on the register(s) of interest of each participating CCG.
• All members of the WLCCG (i.e., each practice)
This includes each provider of primary medical services which is a member of the CCG under Section 14O (1) of the 2006 Act. Declarations should be made by the following groups:
• GP partners (or where the practice is a company, each director); • Any individual directly involved with the business or decision-making of
the CCG
1.2 The policy should be read in conjunction with Managing Conflicts of Interest:
Statutory Guidance for Clinical Commissioning Groups (Publication date 28 June 2016). In addition to complying with this guidance, W LCCG will also need to adhere to relevant guidance issued by professional bodies on conflicts of interest, including the British Medical Association (BMA)1 the
1 BMA guidance on conflicts of interest for GPs in their role as commissioners and providers http://www.bma.org.uk/support-at-work/commissioning/ensuring-transparency-and-probity
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Royal College of General Practitioners2 and the General Medical Council (GMC)3, and to procurement rules including The Public Contract Regulations 20154 and The National Health Service (procurement, patient choice and competition) (no.2) regulations 20135, as well as the Bribery Act 20106.
1.3 NHS England has published a series of 2-page summary https://www.england.nhs.uk/commissioning/pc-co-comms/coi/ guides for different professional groups. This includes GPs in commissioning roles, the Conflicts of Interest Guardian, CCG lay members, CCG governance lead, admin staff and Healthwatch members of the primary care commissioning committee. In addition, NHS England has published a series of case studies https://www.england.nhs.uk/commissioning/wp-content/uploads/sites/12/2016/06/coi-case-studies-jun16.pdf to highlight potential conflicts of interest scenarios that could arise in CCGs, with advice on how to mitigate the risks.
2.0 Definition of an interest
2.1 A conflict of interest occurs where an individual’s ability to exercise judgement, or
act in a role is, could be, or is seen to be impaired or otherwise influenced by his or her involvement in another role or relationship. In some circumstances, it could be reasonably considered that a conflict exists even when there is no actual conflict. In these cases, it is important to still manage these perceived conflicts in order to maintain public trust.
2.2 Conflicts of interest can arise in many situations, environments and forms of
commissioning, with an increased risk in primary care commissioning, out-of- hours commissioning and involvement with integrated care organisations, as clinical commissioners may here find themselves in a position of being at once commissioner and provider of services. Conflicts of interest can arise throughout the whole commissioning cycle from needs assessment, to procurement exercises, to contract monitoring.
2.3 Interests can be captured in four different categories:
i. Financial interests: This is where an individual may get direct financial benefits from the consequences of a commissioning decision. This could, for example, include being:
• A director, including a non-executive director, or senior employee
in a private company or public limited company or other 2 Managing conflicts of interest in clinical commissioning groups:
http://www.rcgp.org.uk/~/media/Files/CIRC/Managing_conflicts_of_interest.ashx 3 GMC | Good medical practice (2013) http://www.gmc-uk.org/guidance/good_medical_practice.asp and http://www.gmc-uk.org/guidance/ethical_guidance/21161.asp and http://www.gmc- uk.org/guidance/ethical_guidance/21161.asp 4 The Public Contract Regulations 2015 http://www.legislation.gov.uk/uksi/2015/102/regulation/57/made 5 The NHS (Procurement, Patient Choice and Competition) (No.2) Regulations 2013 http://www.legislation.gov.uk/uksi/2013/500/contents/made 6 The Bribery Act 2010 http://www.legislation.gov.uk/ukpga/2010/23/contents 7 NHS England (2016) Co-commissioning Conflicts of Interest Audit: Summary Findings
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organisation which is doing, or which is likely, or possibly seeking to do, business with health or social care organisations.
• A shareholder (or similar ownership interests), a partner or owner
of a private or not-for-profit company, business, partnership or consultancy which is doing, or which is likely, or possibly seeking to do, business with health or social care organisations.
• A management consultant for a provider.
This could also include an individual being:
• In secondary employment (see paragraph 7.2-7.3);
• In receipt of secondary income from a provider;
• In receipt of a grant from a provider;
• In receipt of any payments (for example honoraria, one-off payments, day allowances or travel or subsistence) from a provider;
• In receipt of research funding, including grants that may be
received by the individual or any organisation in which they have an interest or role; and
• Having a pension that is funded by a provider (where the value of
this might be affected by the success or failure of the provider).
ii. Non-financial professional interests: This is where an individual may obtain a non-financial professional benefit from the consequences of a commissioning decision, such as increasing their professional reputation or status or promoting their professional career. This may, for example, include situations where the individual is:
• An advocate for a particular group of patients;
• A GP with special interests e.g., in dermatology, acupuncture etc.
• A member of a particular specialist professional body (although
routine GP membership of the RCGP, British Medical Association (BMA) or a medical defense organisation would not usually by itself amount to an interest which needed to be declared);
• An advisor for the Care Quality Commission (CQC) or the National
Institute for Health and Care Excellence (NICE);
• A medical researcher.
GPs and practice managers, who are members of the governing body or committees of WLCCG, should declare details of their roles and responsibilities held within their GP practices.
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iii. Non-financial personal interests: This is where an individual may benefit personally in ways which are not directly linked to their professional career and do not give rise to a direct financial benefit. This could include, for example, where the individual is:
• A voluntary sector champion for a provider;
• A volunteer for a provider;
• A member of a voluntary sector board or has any other position of
authority in or connection with a voluntary sector organisation;
• Suffering from a particular condition requiring individually funded treatment;
• A member of a lobby or pressure group with an interest in health.
iv. Indirect interests: This is where an individual has a close association
with an individual who has a financial interest, a non-financial professional interest or a non-financial personal interest in a commissioning decision (as those categories are described above) for example, a:
• Spouse / partner
• Close relative e.g., parent, grandparent, child, grandchild or sibling;
• Close friend;
• Business partner A declaration of interest for a “business partner” in a GP partnership should include all relevant collective interests of the partnership, and all interests of their fellow GP partners (which could be done by cross referring to the separate declarations made by those GP partners, rather than by repeating the same information verbatim). Whether an interest held by another person gives rise to a conflict of interests will depend upon the nature of the relationship between that person and the individual, and the role of the individual within the CCG.
2.4 The above categories and examples are not exhaustive and WLCCG will exercise discretion on a case by case basis, having regard to the principles set out in the next section of this guidance, in deciding whether any other role, relationship or interest would impair or otherwise influence the individual’s judgement or actions in their role within WLCCG. If so, this should be declared and appropriately managed.
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3.0 Principles
3.1. This section sets out a series of principles for those who are serving as members of WLCCG governing body, WLCCG committees or take decisions where they are acting on behalf of the public or spending public money.
3.2 WLCCG will observe the principles of good governance in the way we do business. These include: The Nolan Principles7 (as set our below)
The Good Governance Standards for Public Services (2004), Office for Public Management (OPM) and Chartered Institute of Public Finance and Accountancy (CIPFA)8
The seven key principles of the NHS Constitution9
The Equality Act 201010
The UK Corporate Governance Code11
Standards for members of NHS boards and CCG governing bodies in England12
7 The 7 principles of public life https://www.gov.uk/government/publications/the-7-principles-of-public-life 8 The Good Governance Standards for Public Services , 2004, OPM and CIPFA http://www.opm.co.uk/wp- content/uploads/2014/01/Good-Governance-Standard-for-Public-Services.pdf 9 The seven key principles of the NHS Constitution http://www.nhs.uk/NHSEngland/thenhs/about/Pages/nhscoreprinciples.aspx 10 The Equality Act 2010 http://www.legislation.gov.uk/ukpga/2010/15/contents 11 UK Corporate Governance Code https://www.frc.org.uk/Our-Work/Codes-Standards/Corporate-governance/UK- Corporate-Governance-Code.aspx 12 Standards for members of NHS boards and CCG governing bodies in England http://www.professionalstandards.org.uk/publications/detail/standards-for-members-of-nhs-boards-and-clinical- commissioning-group-governing-bodies-in-england
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3.3 All those with a position in public life should adhere to the Nolan principles, which are:
• Selflessness – Holders of public office should act solely in terms of the public interest. They should not do so in order to gain financial or other benefits for themselves, their family or their friends;
• Integrity – Holders of public office should not place themselves under any
financial or other obligation to outside individuals or organisations that might seek to influence them in the performance of their official duties;
• Objectivity – In carrying out public business, including making public
appointments, awarding contracts, or recommending individuals for rewards and benefits, holders of public office should make choices on merit;
• Accountability – Holders of public office are accountable for their decisions and
actions to the public and must submit themselves to whatever scrutiny is appropriate to their office;
• Openness – Holders of public office should be as open as possible about all
the decisions and actions they take. They should give reasons for their decisions and restrict information only when the wider public interest clearly demands;
• Honesty – Holders of public office have a duty to declare any private
interests relating to their public duties and to take steps to resolve any conflicts arising in a way that protects the public interest;
• Leadership – Holders of public office should promote and support these
principles by leadership and example.
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3.4 In addition, to support the management of conflicts of interest, WLCCG will:
3.5 In addition to the above, WLCCG will bear in mind:
• Do business appropriately: Conflicts of interest become much easier to
identify, avoid and/or manage when the processes for needs assessments, consultation mechanisms, commissioning strategies and procurement procedures are right from the outset, because the rationale for all decision- making will be clear and transparent and should withstand scrutiny;
• Be proactive, not reactive: Commissioners should seek to identify and
minimise the risk of conflicts of interest at the earliest possible opportunity; • Be balanced and proportionate: Rules should be clear and robust but not
overly prescriptive or restrictive. They should ensure that decision-making is transparent and fair whilst not being overly constraining, complex or cumbersome.
• Be transparent: Document clearly the approach and decisions taken at
every stage in the commissioning cycle so that a clear audit trail is evident. • Create an environment and culture where individuals feel supported and
confident in declaring relevant information and raising any concerns.
• A perception of wrongdoing, impaired judgement or undue influence can be as detrimental as any of them actually occurring;
• If in doubt, it is better to assume the existence of a conflict of interest and
manage it appropriately rather than ignore it. • For a conflict of interest to exist, financial gain is not necessary.
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4.0 Identification and management of conflicts of interest 4.1 Conflicts of interest are a common and sometimes unavoidable part of the delivery of healthcare. As such, it may not be possible or desirable to completely eliminate the risk of conflicts. Instead, it may be preferable to recognise the associated risks and put measures in place to manage the conflicts appropriately when they do arise. 4.2 WLCCG believes it should have robust systems in place to identify and manage conflicts of interest. This will involve creating an environment in which CCG staff, governing body and committee members, and member practices feel able, encouraged and obliged to be open, honest and upfront about actual or potential conflicts. Transparency in this regard will lead to effective identification and management of conflicts. The effect should be to make everyone aware of what to do if they suspect a conflict and ensure decision- making is efficient, transparent and fair. 4.3 The Accountable Officer has overall accountability for the CCG’s management of conflicts of interest. WLCCG’s governance lead is the Deputy Chief Officer/Chief Finance Officer, who shall have the responsibility for ensuring the following:
4.4 WLCCG’s governance lead will provide clear guidance to staff, governing body and committee members, and GP member practices on what might constitute a conflict of interest, including examples of possible conflicts and situations in which a conflict may arise. This may be achieved through training and wide promotion of WLCCG’s policy on conflicts of interest management. 4.5 There will be occasions where an individual declares an interest in good faith but, upon closer consideration, it is clear that this does not constitute a genuine conflict of interest. The governance lead will provide advice on this and decide whether it is necessary for the interest to be declared. 4.6 There may be other occasions where the conflict of interest is profound and acute. In such scenarios (such as where an individual has a direct financial interest which gives rise to a conflict, e.g., secondary employment or involvement with an organisation which benefits financially from contracts for the supply of goods and services to WLCCG), WLCCG will consider whether, practically, such an interest is manageable at all. If it is not, the appropriate course of action will be to refuse to allow the circumstances which gave rise to the conflict to persist. This may require an individual to step down from a particular role and/or move to another
• The day-to day management of conflicts of interest matters and queries; • Maintaining the WLCCG’s register(s) of interest and the other registers
referred to in this Guidance; • Supporting the Conflicts of Interest Guardian to enable them to carry out the
role effectively (see paragraph 7.8 onwards); • Providing advice, support, and guidance on how conflicts of interest should
be managed; and • Ensuring that appropriate administrative processes are put in place.
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role within WLCCG. 4.7 The following sections set out the other steps that have been put in place to support the appropriate management of conflicts of interest.
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5.0 Declaring interests Statutory requirements CCGs must make arrangements to ensure individuals declare any conflict or potential conflict in relation to a decision to be made by the group as soon as they become aware of it, and in any event within 28 days. CCGs must record the interest in the registers as soon as they become aware of it.13
5.1 WLCCG will need to ensure that, as a matter of course, declarations of interest are made and regularly confirmed or updated. The declaration of interest form is ANNEX A. 5.2 All persons referred to in Scope (Section 1.1) must declare any interests. Declarations of interest should be made as soon as reasonably practicable and by law within 28 days after the interest arises (this could include an interest an individual is pursuing). Further opportunities to make declaration include:
13 National Health Service Act 2006 (as amended by the Health and Social Care Act 2012) section 140(3)
On appointment: Applicants for any appointment to WLCCG or its governing body or any committees will be asked to declare any relevant interests. When an appointment is made, a formal declaration of interests should again be made and recorded.
Six-monthly: WLCCG will have systems in place to satisfy itself on a six-monthly basis that their register(s) of interests are accurate and up-to-date. Declarations of interest should be obtained from all relevant individuals every six months and where there are no interests or changes to declare, a “nil return” should be recorded.
At meetings: All attendees are required to declare their interests as a standing agenda item for every governing body, committee, sub-committee or working group meeting, before the item is discussed. Even if an interest has been recorded in the register of interests, it should still be declared in meetings where matters relating to that interest are discussed. Declarations of interest will be recorded in minutes of meetings. On changing role, responsibility or circumstances: Whenever an individual’s role, responsibility or circumstances change in a way that affects the individual’s interests (e.g., where an individual takes on a new role outside WLCCG or enters into a new business or relationship), a further declaration should be made to reflect the change in circumstances as soon as possible, and in any event within 28 days. This could involve a conflict of interest ceasing to exist or a new one materialising. It will be made clear to all individuals who are required to make a declaration of interests that if their circumstances change, it is their responsibility to make a further declaration to the governance lead as soon as possible and in any event within 28 days, rather than waiting to be asked.
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5.3 Whenever interests are declared they should be promptly reported to the WLCCG’s governance lead, who will ensure that the register of interests is updated accordingly.
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6.0 Register(s) of interests
6.1 WLCCG will maintain one or more registers of interest and one register of gifts and hospitality. These register(s) will cover the individuals covered in the Scope of the policy as defined under Scope (Section 1.1). 6.2 An interest will should remain on the public register(s) for a minimum of 6 months after the interest has expired. In addition, WLCCG will retain a private record of historic interests for a minimum of 6 years after the date on which it expired. The WLCCG’s published register of interest’s will should state that historic interests are retained by WLCCG for the specified timeframe, with contact details to submit a request for this information. 6.3 WLCCG will maintain one or more register(s) detailing actual or potential conflicts of interest pertaining to the individuals listed under the Scope (1.1). A declaration of interest(s) form and register of interests is avai lable at ANNEX A & B, respect ively. These contain the following information:
Register(s) of Gifts and Hospitality 6.4 WLCCG will maintain a r e g i s t e r of gifts and hospitality for the individuals listed under Scope (1.1). WLCCG will ensure that robust processes are in place to ensure that such individuals do not accept gifts or hospitality or other benefits, which might reasonably be seen to compromise their professional judgement or integrity.
6.5 All the individuals listed under Scope (Section 1.1) need to consider the risks associated with accepting offers of gifts, hospitality and entertainment when undertaking activities for or on behalf of WLCCG or their GP practice. This is
Statutory requirements CCGs must maintain one or more registers of interest of: the members of the group, members of its governing body, members of its committees or sub-committees of its governing body, and its employees. CCGs must publish, and make arrangements to ensure that members of the public have access to, these registers on request.
• Name of the person declaring the interest; • Position within, or relationship with, the CCG (or NHS England in the event of
joint committees); • Type of interest e.g., financial interests, non-financial professional interests; • Description of interest, including for indirect interests; details of the relationship
with the person who has the interest; • The dates from which the interest relates; and • The actions to be taken to mitigate risk - these should be agreed with
W LCCG’s governance lead.
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especially important during procurement exercises, as the acceptance of gifts could give rise to real or perceived conflicts of interests, or accusations of unfair influence, collusion or canvassing. Gifts
6.6 A 'gift' is defined as any item of cash or goods, or any service, which is provided for personal benefit, free of charge or at less than its commercial value.
6.7 All gifts of any nature offered to WLCCG staff, governing body and committee members and individuals within GP member practices by suppliers or contractors linked (currently or prospectively) to the WLCCG’s business should be declined, whatever their value. The person to whom the gifts were offered should also declare the offer to the Chief Officer’s Executive Assistant, who has designated responsibility for maintaining the register of gifts and hospitality so the offer which has been declined can be recorded on the register.
6.8 Gifts offered from other sources should also be declined if accepting them might give rise to perceptions of bias or favouritism, and a common sense approach should be adopted as to whether or not this is the case. The only exceptions to the presumption to decline gifts relates to items of little financial value (i.e., less than £10) such as diaries, calendars, stationery and other gifts acquired from meetings, events or conferences, and items such as flowers and small tokens of appreciation from members of the public to staff for work well done. Gifts of this nature do not need to be declared to the team or individual who has designated responsibility for maintaining the register of gifts and hospitality, nor recorded on the register.
6.9 Any personal gift of cash or cash equivalents (e.g. vouchers, tokens, offers of remuneration to attend meetings whilst in a capacity working for or representing the CCG) must always be declined, whatever their value and whatever their source. The offer which has been declined must be declared to the Chief Officer’s Executive Assistant who has designated responsibility for maintaining the register of gifts and hospitality and recorded on the register.
Hospitality
6.10 A blanket ban on accepting or providing hospitality is neither practical nor desirable from a business point of view. However, individuals should be able to demonstrate that the acceptance or provision of hospitality would benefit WLCCG.
6.11 Modest hospitality provided in normal and reasonable circumstances may be acceptable, although it should be on a similar scale to that which WLCCG might offer in similar circumstances (e.g., tea, coffee, light refreshments at meetings). A common sense approach should be adopted as to whether hospitality offered is modest or not. Hospitality of this nature does not need to be declared to the Chief Officer’s Executive Assistant who has designated responsibility for maintaining the register of gifts and hospitality, nor recorded on the register, unless it is offered by suppliers or contractors linked (currently or prospectively) to WLCCG’s business in which case all such offers (whether or not accepted) should be declared and recorded.
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6.12 There is a presumption that offers of hospitality which go beyond modest or of a type that WLCCG itself might offer, should be politely refused. A non- exhaustive list of examples includes:
• Hospitality of a value of above £25; and • In particular, offers of foreign travel and accommodation.
There may be some limited and exceptional circumstances where accepting the types of hospitality referred to in this paragraph may be contemplated. Express prior approval should be sought from the governance lead before accepting such offers, and the reasons for acceptance should be recorded in the WLCCG’s register of gifts and hospitality. Hospitality of this nature should be declared to the Chief Officer’s Executive Assistant who has designated responsibility for maintaining the register of gifts and hospitality, and recorded on the register, whether accepted or not. In addition, particular caution should be exercised where hospitality is offered by suppliers or contractors linked (currently or prospectively) to the CCG’s business. Offers of this nature can be accepted if they are modest and reasonable but advice should always be sought from the CCG governance lead as there may be particular sensitivities, for example if a contract re-tender is imminent. All offers of hospitality from actual or prospective suppliers or contractors (whether or not accepted) should be declared and recorded. Commercial sponsorship
6.13 WLCCG staff, governing body and committee members, and GP member practices may be offered commercial sponsorship for courses, conferences, post/project funding, meetings and publications in connection with the activities which they carry out for or on behalf of WLCCG or their GP practices. All such offers (whether accepted or declined) must be declared so that they can be included on the WLCCG’s register of interests, and the governance lead should provide advice on whether or not it would be appropriate to accept any such offers. More detailed guidance is contained within the WLCCG’s ‘Commercial Sponsorship & Joint working policy’.
6.14 Notwithstanding the above, acceptance of commercial sponsorship should not in any way compromise commissioning decisions of WLCCG or be dependent on the purchase or supply of goods or services. Sponsors should not have any influence over the content of an event, meeting, seminar, publication or training event. WLCCG should not endorse individual companies or their products. It should be made clear that the fact of sponsorship does not mean that WLCCG endorses a company’s products or services. During dealings with sponsors there must be no breach of patient or individual confidentiality or data protection legislation. Furthermore, no information should be supplied to a company for their commercial gain unless there is a clear benefit to the NHS. As a general rule, information which is not in the public domain should not normally be supplied.
Declaration of offers and receipt of gifts and hospitality
6.15 A form for declaring gifts and hospitality is annexed at ANNEX C. All hospitality or gifts declared must be promptly transferred to the register of gifts and hospitality by
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the Chief Officer’s Executive Assistant. This should include any gifts and hospitality declared in meetings. A gifts and hospitality register for use by WLCCG is annexed at ANNEX D. 6.16 The following information is contained on the form/register:
• Recipient’s name; • Current position(s) held by the individual (within the CCG); • Date of offer and/or receipt; • Details of the gifts of hospitality • The estimated value of the gifts or hospitality • Details of the supplier/offeror (e.g. their name and the nature of their business); • Details of previous gifts and hospitality offered or accepted by this offeror/
supplier; • Details of the officer reviewing/approving the declaration made and date; • Whether the offer was accepted or not; and • Reasons for accepting or declining the offer.
Publication of registers
6.17 WLCCG will publish the register(s) of interest and register of gifts and Hospitality, referred to above, and the Register of procurement decisions described below, in a prominent place on the CCG’s website.
6.18 In exceptional circumstances, where the public disclosure of information could give rise to a real risk of harm or is prohibited by law, an individual’s name and/or other information may be redacted from the publicly available register(s). Where an individual believes that substantial damage or distress may be caused, to him/herself or somebody else by the publication of information about them, they are entitled to request that the information is not published. Such requests must be made in writing to the governance lead for consideration by the conflict of interest guardian. Decisions not to publish information must be made by the Conflicts of Interest Guardian for WLCCG, who will seek appropriate legal advice where required, and WLCCG will retain a confidential un-redacted version of the register(s).
6.19 The register(s) of interests (including the register of gifts and hospitality) will be published as part of the CCG’s Annual Report and Annual Governance Statement.
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7.0 Appointments and roles and responsibilities in the CCG
7.1 Everyone in WLCCG has responsibility to appropriately manage conflicts of interest. Secondary employment 7.2 WLCCG will take all reasonable steps to ensure that employees, committee members, contractors and others engaged under contract with them are aware of the requirement to in fo rm the WLCCG if they are employed or engaged in, or wish to be employed or engage in, any employment or consultancy work in addition to their work with W LCCG. The purpose of this is to ensure that the W L CCG is aware of any potential conflict of interest. Examples of work which might conflict with the business of WLCCG, including part-time, temporary and fixed term contract work, include:
o Employment with another NHS body;
o Employment with another organisation which might be in a position to supply goods/services to WLCCG;
o Directorship of a GP federation; and
o Self-employment, including private practice, in a capacity which might
conflict with the work of WLCCG or which might be in a position to supply goods/services to WLCCG.
7.3 WLCCG requires that employees obtain prior permission to engage in secondary employment, and reserves the right to refuse permission where it believes a conflict will arise which cannot be effectively managed. WLCCG will ensure that it has clear and robust organisational policies in place to manage issues arising from secondary employment. In particular, it is unacceptable for pharmacy advisers or other advisers, employees or consultants to the CCG on matters of procurement to themselves be in receipt of payments from the pharmaceutical or devices sector. Appointing governing body or committee members and senior employees 7.4 On appointing governing body, committee or sub-committee members and senior staff, WLCCG will need to consider whether conflicts of interest should exclude individuals from being appointed to the relevant role. This will need to be considered on a case-by-case basis. 7.5 WLCCG will assess the materiality of the interest, in particular whether the individual (or any person with whom they have a close association as listed in paragraphs 1.1 and 2.3) could benefit (whether financially or otherwise) from any decision the CCG might make. This will be particularly relevant for governing
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body, committee and sub-committee appointments, but should also be considered for all employees and especially those operating at senior level. 7.6 WLCCG will also determine the extent of the interest and the nature of the appointee’s proposed role within the o r ga n i s a t i o n . If the interest is related to an area of business significant enough that the individual would be unable to operate effectively and make a full and proper contribution in the proposed role, then that individual should not be appointed to the role. 7.7 Any individual who has a material interest in an organisation which provides, or is likely to provide, substantial services to WLCCG (whether as a provider of healthcare or commissioning support services, or otherwise) should recognise the inherent conflict of interest risk that may arise and should not be a member of the governing body or of a committee or sub-committee of the CCG, in particular if the nature and extent of their interest and the nature of their proposed role is such that they are likely to need to exclude themselves from decision-making on so regular a basis that it significantly limits their ability to effectively perform that role. Specific considerations in relation to delegated or joint commissioning of primary care are set out below. Conflicts of Interest Guardian 7.8 To further strengthen scrutiny and transparency of the decision-making processes, the WLCCG will have a Conflicts of Interest Guardian (akin to a Caldicott Guardian). This role will be undertaken by the W L CCG audit chair, provided they have no provider interests, as audit chairs already have a key role in conflicts of interest management. They will be supported by WLCCG’s governance lead, who will have responsibility for the day-to-day management of conflicts of interest matters and queries. The W L CCG governance lead should keep the Conflicts of Interest Guardian well briefed on conflicts of interest matters and issues arising. 7.9 The Conflicts of Interest Guardian should, in collaboration with WLCCG’s governance lead:
o Act as a conduit for GP practice staff, members of the public and healthcare professionals who have any concerns with regards to conflicts of interest;
o Be a safe point of contact for employees or workers of the CCG to raise
any concerns in relation to this policy;
o Support the rigorous application of conflict of interest principles and policies;
o Provide independent advice and judgment where there is any doubt
about how to apply conflicts of interest policies and principles in an individual situation;
o Provide advice on minimising the risks of conflicts of interest.
7.10 Whilst the Conflicts of Interest Guardian has an important role within the
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management of conflicts of interest, executive members of WLCCG’s governing body have an on-going responsibility for ensuring the robust management of conflicts of interest, and all CCG employees, governing body and committee members and member practices will continue to have individual responsibility in playing their part on an ongoing and daily basis.
8.0 Managing conflicts of interest at meetings
Chairing arrangements and decision-making processes 8.1 The chair of a meeting of WLCCG’s governing body or any of its committees, sub-committees or groups has ultimate responsibility for deciding whether there is a conflict of interest and for taking the appropriate course of action in order to manage the conflict of interest.
8.2 In the event that the chair of a meeting has a conflict of interest, the vice chair is responsible for deciding the appropriate course of action in order to manage the conflict of interest. If the vice chair is also conflicted, then the remaining non-conflicted voting members of the meeting should agree between themselves how to manage the conflict(s). 8.3 In making such decisions, the chair (or vice chair or remaining non-conflicted members as above) may wish to consult with the Conflicts of Interest Guardian (see 7.8) or another member of the governing body. 8.4 It is good practice for the chair, with support of WLCCG’s governance lead or equivalent and, if required, the Conflicts of Interest Guardian, to proactively consider ahead of meetings what conflicts are likely to arise and how they should be managed, including taking steps to ensure that supporting papers for particular agenda items of private sessions/meetings are not sent to conflicted individuals in advance of the meeting where relevant. 8.5 To support chairs in their role, they should have access to a declaration of interest checklist prior to meetings, which should include details of any declarations of conflicts which have already been made by members of the group. A template declaration of interest checklist has been annexed at Annex E. 8.6 The chair should ask at the beginning of each meeting if anyone has any conflicts of interest to declare in relation to the business to be transacted at the meeting. Each member of the group should declare any interests which are relevant to the business of the meeting whether or not those interests have previously been declared. Any new interests which are declared at a meeting must be included on the CCG’s
Statutory requirements CCGs must make arrangements for managing conflicts of interest, and potential conflicts of interest, in such a way as to ensure that they do not, and do not appear to, affect the integrity of the group’s decision-making.
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relevant register of interests to ensure it is up- to-date. 8.7 Similarly, any new offers of gifts or hospitality (whether accepted or not) which are declared at a meeting must be included on the CCG’s register of gifts and hospitality to ensure it is up-to-date. 8.8 It is the responsibility of each individual member of the meeting to declare any relevant interests which they may have. However, should the chair or any other member of the meeting be aware of facts or circumstances which may give rise to a conflict of interests but which have not been declared then they should bring this to the attention of the chair who will decide whether there is a conflict of interest and the appropriate course of action to take in order to manage the conflict of interest. 8.9 When a member of the meeting (including the chair or vice chair) has a conflict of interest in relation to one or more items of business to be transacted at the meeting, the chair (or vice chair or remaining non-conflicted members where relevant as described above) must decide how to manage the conflict. The appropriate course of action will depend on the particular circumstances, but could include one or more of the following:
o Where the chair has a conflict of interest, deciding that the vice chair (or another non-conflicted member of the meeting if the vice chair is also conflicted) should chair all or part of the meeting;
o Requiring the individual who has a conflict of interest (including the chair or
vice chair if necessary) not to attend the meeting;
o Ensuring that the individual concerned does not receive the supporting papers or minutes of the meeting which relate to the matter(s) which give rise to the conflict;
o Requiring the individual to leave the discussion when the relevant matter(s)
are being discussed and when any decisions are being taken in relation to those matter(s). In private meetings, this could include requiring the individual to leave the room and in public meetings to either leave the room or join the audience in the public gallery;
o Allowing the individual to participate in some or all of the discussion when
the relevant matter(s) are being discussed but requiring them to leave the meeting when any decisions are being taken in relation to those matter(s). This may be appropriate where, for example, the conflicted individual has important relevant knowledge and experience of the matter(s) under discussion, which it would be of benefit for the meeting to hear, but this will depend on the nature and extent of the interest which has been declared;
o Noting the interest and ensuring that all attendees are aware of the nature
and extent of the interest, but allowing the individual to remain and participate in both the discussion and in any decisions. This is only likely to be the appropriate course of action where it is decided that the interest which has been declared is either immaterial or not relevant to the matter(s) under discussion. The Department of Health publish conflicts of interest case studies https://www.england.nhs.uk/commissioning/wp-
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content/uploads/sites/12/2016/06/coi-case-studies-jun16.pdf that include examples of material and immaterial conflicts of interest.
Primary care commissioning committees and sub-committees 8.10 There are three general practice co-commissioning models:
o Greater involvement is simply an invitation to CCGs to collaborate more closely with their NHS England teams to ensure that decisions taken about healthcare services are strategically aligned across the local health economy.
o Joint commissioning enables one or more CCGs to assume responsibility
for jointly commissioning primary medical services with their local NHS England team via a joint committee. It is a requirement for each joint committee to have a register of interests, and for the interests of both CCG and NHS England representatives to be included on this register. These interests should also be recorded on the CCG’s main register(s) of interests.
o Delegated commissioning enables CCGs to assume responsibility for
commissioning general practice services. 8.11 Each CCG with joint or delegated primary care co-commissioning arrangements must establish a primary care commissioning committee for the discharge of their primary medical services functions. This committee should be separate from the CCG governing body. The interests of all primary care commissioning committee members must be recorded on the CCG’s register(s) of interests. 8.12 The primary care commissioning committee should:
For joint commissioning, take the form of a joint committee established between the CCG (or CCGs) and NHS England; and
In the case of delegated commissioning, be a committee established by the CCG.
8.13 As a general rule, meetings of the primary care commissioning committee, including the decision-making and deliberations leading up to the decision, should be held in public unless WLCCG has concluded it is appropriate to exclude the public where it would be prejudicial to the public interest to hold that part of the meeting in public. Examples of where it may be appropriate to exclude the public include:
Information about individual patients or other individuals which includes sensitive personal data is to be discussed;
Commercially confidential information is to be discussed, for
example the detailed contents of a provider’s tender submission;
Information in respect of which a claim to legal professional
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privilege could be maintained in legal proceedings is to be discussed;
To allow the meeting to proceed without interruption and disruption.
Membership of primary care commissioning committees (for joint and delegated arrangements) 8.14 CCGs (and NHS England with regards to joint arrangements) can agree the full membership of their primary care commissioning committees, within the following parameters:
• The primary care commissioning committee must be constituted to have a lay and executive majority, where lay refers to non-clinical. This ensures that the meeting will be quorate if all GPs had to withdraw from the decision- making process due to conflicts of interest.
• The primary care commissioning committee should have a lay chair and lay
vice chair. • GPs can, and should, be members of the primary care commissioning
committee to ensure sufficient clinical input, but must not be in the majority. CCGs may wish to consider appointing retired GPs or out-of-area GPs to the committee to ensure clinical input whilst minimising the risk of conflicts of interest.
• A standing invitation must be made to the CCG’s local HealthWatch
representative and a local authority representative from the local Health and Wellbeing Board to join the primary care commissioning committee as non-voting attendees, including, where appropriate, for items where the public is excluded for reasons of confidentiality.
• Other individuals could be invited to attend the primary care commissioning committee on an ad-hoc basis to provide expertise to support with the decision-making process.
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Primary care commissioning committee decision-making processes and voting arrangements
8.15 In the interest of minimising the risks of conflicts of interest, it is recommended that GPs do not have voting rights on the p r im a ry care commiss ion ing committee. The arrangements do not preclude GP participation in strategic discussions on primary care issues, subject to appropriate management of conflicts of interest. They apply to decision-making on procurement issues and the deliberations leading up to the decision. 8.16 Whilst sub-committees or sub-groups of the primary care commissioning committee can be established e.g., to develop business cases and options appraisals, ultimate decision-making responsibility for the primary medical services functions must rest with the primary care commissioning committee. For example, whilst a sub-group could develop an options appraisal, it should take the options to the primary care commissioning committee for their review and decision-making. CCGs should carefully consider the membership of sub- groups. They should also consider appointing a lay member as the chair of the group. 8.17 It is important that conflicts of interests are managed appropriately within sub-committees and sub-groups. As an additional safeguard, it is recommended that sub-groups submit their minutes to the primary care commissioning committee, detailing any conflicts and how they have been managed. The primary care commissioning committee should be satisfied that conflicts of interest have been managed appropriately in its sub-committees and take action where there are concerns. Minute-taking 8.18 WLCCG shall endeavor to ensure complete transparency in their decision-making processes through robust record-keeping. If any conflicts of interest are declared or otherwise arise in a meeting, the chair must ensure the following information is recorded in the minutes:
8.19 An example of good minute keeping is annexed at Annex F.
• who has the interest;
• the nature of the interest and why it gives rise to a conflict, including the magnitude of any interest;
• the items on the agenda to which the interest relates;
• how the conflict was agreed to be managed; and
• evidence that the conflict was managed as intended (for example
recording the points during the meeting when particular individuals left or returned to the meeting).
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9.0 Managing conflicts of interest throughout the commissioning cycle
9.1 Conflicts of interest need to be managed appropriately throughout the whole commissioning cycle. At the outset of a commissioning process, the relevant interests of all individuals involved should be identified and clear arrangements put in place to manage any conflicts of interest. This includes consideration as to which stages of the process a conflicted individual should not participate in, and, in some circumstances, whether that individual should be involved in the process at all. The Department of Health conflicts of interest case studies https://www.england.nhs.uk/commissioning/wp-content/uploads/sites/12/2016/06/coi-case-studies-jun16.pdf include examples of this. Designing service requirements 9.2 The way in which services are designed can either increase or decrease the extent of perceived or actual conflicts of interest. Particular attention should be given to public and patient involvement in service development. 9.3 Public involvement supports transparent and credible commissioning decisions. It should happen at every stage of the commissioning cycle from needs assessment, planning and prioritisation to service design, procurement and monitoring. CCGs have legal duties under the Act to properly involve patients and the public in their respective commissioning processes and decisions. Provider engagement 9.4 It is good practice to engage relevant providers, especially clinicians, in confirming that the design of service specifications will meet patient needs. This may include providers from the acute, primary, community, and mental health sectors, and may include NHS, third sector and private sector providers. Such engagement, done transparently and fairly, is entirely legal. However, conflicts of interest, as well as challenges to the fairness of the procurement process, can arise if a commissioner engages selectively with only certain providers (be they incumbent or potential new providers) in developing a service specification for a contract for which they may later bid. 9.5 Provider engagement should follow the three main principles of procurement law, namely equal treatment, non-discrimination and transparency. This includes ensuring that the same information is given to all at the same time and procedures are transparent. This mitigates the risk of potential legal challenge.
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9.6 As the service design develops, it is good practice to engage with a range of providers on an on-going basis to seek comments on the proposed design e.g., via the commissioner’s website and/or via workshops with interested parties (ensuring a record is kept of all interaction). NHS Improvement14 has issued guidance on the use of provider boards in service design.15 9.7 Engagement should help to shape the requirement to meet patient need, but it is important not to gear the requirement in favour of any particular provider(s). If appropriate, the advice of an independent clinical adviser on the design of the service should be secured. Specifications 9.8 Commissioners should seek, as far as possible, to specify the outcomes that they wish to see delivered through a new service, rather than the process by which these outcomes are to be achieved. As well as supporting innovation, this helps prevent bias towards particular providers in the specification of services. However, they also need to ensure careful consideration is given to the appropriate degree of financial risk transfer in any new contractual model. 9.9 Specifications should be clear and transparent, reflecting the depth of engagement, and set out the basis on which any contract will be awarded. Procurement and awarding grants 9.10 W LCCG will endeavor to recognise and manage any conflicts or potential conflicts of interest that may arise in relation to the procurement of any services or the administration of grants. “Procurement” relates to any purchase of goods, services or works and the term “procurement decision” should be understood in a wide sense to ensure transparency of decision making on spending public funds. The decision to use a single tender action, for instance, is a procurement decision and if it results in the commissioner entering into a new contract, extending an existing contract, or materially altering the terms of an existing contract, then it is a decision that should be recorded. 9.11 NHS England and CCGs must comply with two different regimes of procurement law and regulation when commissioning healthcare services: the NHS procurement regime, and the European procurement regime: 9.12 The NHS procurement regime – the NHS (Procurement, Patient Choice and Competition (No.2)) Regulations 2013: made under S75 of the 2012 Act; apply only to NHS England and CCGs; enforced by NHS Improvement; and 9.13 The European procurement regime – Public Contracts Regulations 2015 (PCR 2105): incorporate the European Public Contracts Directive into national law; apply to all public contracts over the threshold value (€750,000, currently £589,148); enforced through the Courts. The general principles arising under the Treaty on the
14 NHS Improvement is the organisation which brings together Monitor and the NHS Trust Development Authority, and is a combination of the continuing statutory functions and legal powers vested in those
15 Monitor, Case closure decision on Greater Manchester and Cheshire cancer surgery services, January 2014 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/284832/ManchesterCaseClosure.pdf)
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Functioning of the European Union of equal treatment, transparency, mutual recognition, non- discrimination and proportionality may apply even to public contracts for healthcare services falling below the threshold value if there is likely to be interest from providers in other member states. Whilst the two regimes overlap in terms of some of their requirements, they are not the same – so compliance with one regime does not automatically mean compliance with the other. 9.14 The National Health Service (Procurement, Patient Choice and Competition) (No.2) Regulations 201316 state:
Paragraph 24 of PCR 2015 states: “Contracting authorities shall take appropriate measures to effectively prevent, identify and remedy conflicts of interest arising in the conduct of procurement procedures so as to avoid any distortion of competition and to ensure equal treatment of all economic operators”. Conflicts of interest are described as “any situation where relevant staff members have, directly or indirectly, a financial, economic or other personal interest which might be perceived to compromise their impartiality and independence in the context of the procurement procedure”. 9.15 The Procurement, Patient Choice and Competition Regulations (PPCCR) place requirements on commissioners to ensure that they adhere to good practice in relation to procurement, run a fair, transparent process that does not discriminate against any provider, do not engage in anti-competitive behaviour that is against the interest of patients, and protect the right of patients to make choices about their healthcare. Furthermore, the PPCCR places requirements on commissioners to secure high quality, efficient NHS healthcare services that meet the needs of the people who use those services. The PCR 2015 are focused on ensuring a fair and open selection process for providers. 9.16 An obvious area in which conflicts could arise is where a CCG commissions (or continues to commission by contract extension) healthcare services, including GP services, in which a member of the CCG has a financial or other interest. This may most often arise in the context of co-commissioning of primary care, particularly with regard to delegated commissioning, where GPs are current or possible providers.
16 The National Health Service (Procurement, Patient Choice and Competition) (No. 2) Regulations 2013 http://www.legislation.gov.uk/uksi/2013/500/contents/made
CCGs must not award a contract for the provision of NHS health care services where conflicts, or potential conflicts, between the interests involved in commissioning such services and the interests involved in providing them affect, or appear to affect, the integrity of the award of that contract; and
CCGs must keep a record of how it managed any such conflict in relation to NHS commissioning contracts it has entered into. [As set out in paragraph 113 below, details of this should also be published by the CCG.]
The National Health Service (Procurement, Patient Choice and Competition)
(No.2) Regulations 2013
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9.17 A procurement checklist, provided in Annex G, sets out factors that WLCCG shall endeavor to address when drawing up their plans to commission general practice services. The checklist will assist WLCCG in providing evidence of their deliberations on conflicts of interest. 9.18 WLCCG will make the evidence of their management of conflicts publicly available, and the relevant information from the procurement checklist should be used to complete the register of procurement decisions. Complete transparency around procurement will provide:
o Evidence that WLCCG is seeking and encouraging scrutiny of its decision-making process;
o A record of the public involvement throughout the commissioning of
the service;
o A record of how the proposed service meets local needs and priorities for partners such as the Health and Wellbeing Boards, local Healthwatch and local communities;
o Evidence to the audit committee and internal and external auditors that a
robust process has been followed in deciding to commission the service, in selecting the appropriate procurement route, and in addressing potential conflicts.
9.19 External services such as Commissioning Support Services (CSSs) can play an important role in helping CCGs decide the most appropriate procurement route, undertake procurements and manage contracts in ways that manage conflicts of interest and preserve the integrity of decision-making. When using a CSS, WLCCG will endeavor have systems to assure themselves that a CSS’ business processes are robust and enable WLCCG to meet its duties in relation to procurement ( including those r e l a t i n g to t h e managemen t o f c on f l i c t s o f interest). This would require the CSS to declare any conflicts of interest it may have in relation to the work commissioned by WLCCG. A CCG cannot, however, lawfully delegate commissioning decisions to an external provider of commissioning support. Although CSSs are likely to play a key role in helping to develop specifications, preparing tender documentation, inviting expressions of interest and inviting tenders, the CCG itself will need to:
• Determine and sign off the specification and evaluation criteria;
• Decide and sign off decisions on which providers to invite to tender; and
• Make final decisions on the selection of the provider. Register of procurement decisions 9.20 WLCCG will maintain a register of procurement decisions taken, either for the procurement of a new service or any extension or material variation of a current contract. This must include:
• The details of the decision;
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• Who was involved in making the decision (including the name of the CCG
clinical lead, the CCG contract manager, the name of the decision making committee and the name of any other individuals with decision-making responsibility);
• A summary of any conflicts of interest in relation to the decision and how this
was managed by the CCG (see paragraph 117 in relation to retaining the anonymity of bidders); and
• The award decision taken.
9.21 The register of procurement decisions must be updated whenever a procurement decision is taken. This register template is included at Annex H. The Procurement, Patient Choice and Competition Regulations 9(1) place a requirement on commissioners to maintain and publish on their website a record of each contract it awards. The register of procurement decisions should be made publicly available and easily accessible to patients and the public by:
• Ensuring that the register is available in a prominent place on the CCG’s website; and
• Making the register available upon request for inspection at the CCG’s
headquarters
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Declarations of interests for bidders / contractors 9.22 As part of a procurement process, it is good practice to ask bidders to declare any conflicts of interest. This allows commissioners to ensure that they comply with the principles of equal treatment and transparency. When a bidder declares a conflict, the commissioners must decide how best to deal with it to ensure that no bidder is treated differently to any other. Please see Annex I for a declaration of interests for bidders/ contractors template. 9.23 It will not usually be appropriate to declare such a conflict on the register of procurement decisions, as it may compromise the anonymity of bidders during the procurement process. However, commissioners should retain an internal audit trail of how the conflict or perceived conflict was dealt with to allow them to provide information at a later date if required. Commissioners are required under regulation 84 of the Public Contract Regulations 2015 to make and retain records of contract award decisions and key decisions that are made during the procurement process (there is no obligation to publish them). Such records must include “communications with economic operators and internal deliberations” which should include decisions made in relation to actual or perceived conflicts of interest declared by bidders. These records must be retained for a period of at least three years from the date of award of the contract. Contract Monitoring 9.24 The management of conflicts of interest applies to all aspects of the commissioning cycle, including contract management. 9.25 Any contract monitoring meeting needs to consider conflicts of interest as part of the process i.e., the chair of a contract management meeting should invite declarations of interests; record any declared interests in the minutes of the meeting; and manage any conflicts appropriately and in line with this guidance. This equally applies where a contract is held jointly with another organisation such as the Local Authority or with other CCGs under lead commissioner arrangements. 9.26 The individuals involved in the monitoring of a contract should not have any direct or indirect financial, professional or personal interest in the incumbent provider or in any other provider that could prevent them, or be perceived to prevent them, from carrying out their role in an impartial, fair and transparent manner. 9.27 WLCCG will endeavor to be mindful of any potential conflicts of interest when they disseminate any contract or performance information/reports on providers, and manage the risks appropriately.
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10. CCG Improvement and Assessment Framework
10.1 NHS England is introducing a new Improvement and Assessment Framework for CCGs from 2016/17 onwards. The management of conflicts of interest is a key indicator of the new framework.
10.2 As part of the new framework, W L CCG will be required on an annual basis to confirm via self-certification:
10.3 In addition, WLCCG will be required to report on a quarterly basis via self- certification whether the CCG:
• That the CCG has a clear policy for the management of conflicts of interest in line with the statutory guidance and a robust process for the management of breaches;
• That the CCG has a minimum of three lay members; • That the CCG audit chair has taken on the role of the Conflicts of
Interest Guardian; • The level of compliance with the mandated conflicts of interest on-line
training, as of 31 January annually.
• Has processes in place to ensure individuals declare any interests which may give rise to a conflict or potential conflict as soon as they become aware of it, and in any event within 28 days, ensuring accurate up to date registers are complete for:
• conflicts of interest, • procurement decisions and • gifts and hospitality
• Has made these registers available on its website and, upon request, at the
CCG’s HQ. • Is aware of any breaches of its policies and procedures in relation to the
management of conflicts of interest and how many:
• To include details of how they were managed; • Confirmation that anonymised details of the breach have been
published on the CCG website; • Confirmation that they been communicated to NHS England.
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10.4 If WLCCG decides not to comply with one or more of the requirements of the statutory guidance – whether in relation to any of the matters referred to in paragraphs 123 and 124 above or otherwise – this must be discussed in advance with NHS England. WLCCG will include within their self-certification statements the reasons for deciding not to do so, on a “comply or explain” basis.
10.5 In addition, there is a requirement for each CCG to undertake an annual internal audit on the management of conflicts of interest to provide further assurance about the degree of compliance with the statutory guidance.
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11. Raising concerns and breaches
11.1 It is the duty of every WLCCG employee, governing body member, committee or sub-committee member and GP practice member to speak up about genuine concerns in relation to the administration of WLCCG’s policy on conflicts of interest management, and to report these concerns. These individuals should not ignore their suspicions or investigate themselves, but rather speak to the designated W L CCG point of contact i.e. the governance lead, unless the governance lead is implicated in which case the conflict of interest guardian should be the direct contact.
11.2 Although concerns should if possible be raised initially with the governance lead,
the conflict of interest guardian maybe contacted on a strictly confidential basis, if required.
Reporting breaches 11.3 WLCCG has a clear process for managing breaches of their conflicts of interest policy. The process is detailed in this policy (see below):
• If following an investigation, a breach in this policy is found, this will be recorded on the breach of conflict of interest register by the governance lead. This will be published on the WLCCG website.
• Unless the allegations concern the governance lead, the governance lead will be
responsible for ensuring all alleged breaches of the conflict of interest policy are properly investigated. If the governance lead is implicated, the conflict of interest guardian will be responsible. If felt appropriate the governance lead or the conflict of interest guardian may commission an external investigator e.g. another CCG’s governance lead or an internal auditor.
• If following an investigation, a breach of conflict of interest is found to have
occurred then:
I. If it concerns a governing body member or member of a committee then the chief officer, chairman and conflict of interest guardian will consider if any further action is required e.g. Referral to Local Anti-Fraud Specialist/professional body, removal from office/committee, etc.*
II. If it concerns an employee the governance lead will decide whether the disciplinary process should be pursued
III. In all the cases the chief officer, chairman and conflict of interest guardian will consider if further action is necessary
IV. In all cases where breach of WLCCG’s conflict of interest policy is found to have taken place, anonymized details of breach will be published on WLCCG’s website for the purpose of learning and development
V. The governance lead will ensure a report is be taken to WLCCG’s Audit Committee detailing any breaches of the conflict of interest policy
VI. Taking into account of any National guidance, WLCCG’s chief officer will consider whether it is appropriate to
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notify NHS England *If the chief officer, chairman or conflict of interest guardian are the subject of the investigation then clearly those affected cannot consider the case. In these circumstances, the panel that considers further action may consist of just two members.
11.4 Anyone who wishes to report a suspected or known breach of the policy, who is not an employee or worker of WLCCG, should also ensure that they comply with their own organisation’s whistleblowing policy, since most such policies should provide protection against detriment or dismissal. 11.5 All such notifications should be treated with appropriate confidentiality at all times in accordance with the CCG’s policies and applicable laws, and the person making such disclosures should expect an appropriate explanation of any decisions taken as a result of any investigation. 11.6 Furthermore, providers, patients and other third parties can make a complaint to NHS Improvement17 in relation to a commissioner’s conduct under the Procurement Patient Choice and Competition Regulations. The regulations are designed as an accessible and effective alternative to challenging decisions in the courts. Fraud or Bribery 11.7 Any suspicions or concerns of acts of fraud or bribery can be reported to the Local Anti-Fraud Specialist on 0151 285 4555/07721237350 or online via https://www.reportnhsfraud.nhs.uk/ 11.8 This provides an easily accessible and confidential route for the reporting of genuine suspicions of fraud within or affecting the NHS. All calls are dealt with by experienced trained staff and any caller who wishes to remain anonymous may do so.
17 https://www.gov.uk/government/uploads/system/uploads/attachmenmonitor _data/file/283505/SubstantiveGuidanceDec2013_0.pdf
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12.0 Impact of non-compliance
12.1 Failure to comply with the CCG’s policies on conflicts of interest management, pursuant to this statutory guidance, can have serious implications for the CCG and any individuals concerned. Civil implications 12.2 If conflicts of interest are not effectively managed, CCGs could face civil
challenges to decisions they make. For instance, if breaches occur during a service re-design or procurement exercise, the CCG risks a legal challenge from providers that could potentially overturn the award of a contract, lead to damages claims against the CCG, and necessitate a repeat of the procurement process. This could delay the development of better services and care for patients, waste public money and damage the CCG’s reputation. In extreme cases, staff and other individuals could face personal civil liability, for example a claim for misfeasance in public office.
Criminal implications
12.3 Failure to manage conflicts of interest could lead to criminal proceedings
including for offences such as fraud, bribery and corruption. This could have implications for CCGs and linked organisations, and the individuals who are engaged by them.
12.4 The Fraud Act 2006 created a criminal offence of fraud and defines three ways of committing it:
• Fraud by false representation;
• Fraud by failing to disclose information; and,
• Fraud by abuse of position. 12.5 An essential ingredient of the offences is that, the offender’s conduct must be dishonest and their intention must be to make a gain, or cause a loss (or the risk of a loss) to another. Fraud carries a maximum sentence of 10 years of imprisonment and /or a fine if convicted in the Crown Court or 6 months imprisonment and/or a fine in the Magistrates’ Court. The offences can be committed by a body corporate. 12.6 Bribery is generally defined as giving or offering someone a financial or other advantage to encourage that person to perform their functions or activities. The Bribery Act 2010 reformed the criminal law of bribery, making it easier to tackle this offence proactively in both the public and private sectors. It introduced a corporate offence which means that commercial organisations, including NHS bodies, will be exposed to criminal liability, punishable by an unlimited fine, for failing to prevent bribery. The offences of bribing another person, being bribed and bribery of foreign public officials can also be committed by a body corporate. The Act repealed the UK’s previous anti-corruption legislation (the Public Bodies Corrupt Practices Act 1889, the Prevention of Corruption Acts of 1906 and 1916 and the common law offence of bribery) and provides an updated and extended framework of offences to cover bribery both in the UK and abroad. The offences of bribing another person, being bribed or bribery
38
of foreign public officials in relation to an individual carries a maximum sentence of 10 years o f imprisonment and/or a fine if convicted in the Crown Court and 6 months imprisonment and/or a fine in the Magistrates’ Court. In relation to a body corporate the penalty for these offences is a fine. Disciplinary implications
12.7 CCGs should ensure that individuals who fail to disclose any relevant interests or
who otherwise breach the CCG’s rules and policies relating to the management of conflicts of interest are subject to investigation and, where appropriate, to disciplinary action. CCG staff, governing body and committee members in particular should be aware that the outcomes of such action may, if appropriate, result in the termination of their employment or position with the CCG.
Professional regulatory implications 12.8 Statutorily regulated healthcare professionals who work for, or are engaged by, CCGs are under professional duties imposed by their relevant regulator to act appropriately with regard to conflicts of interest. The CCG should report statutorily regulated healthcare professionals to their regulator if they believe that they have acted improperly, so that these concerns can be investigated. Statutorily regulated healthcare professionals should be aware that the consequences for inappropriate action could include fitness to practise proceedings being brought against them, and that they could, if appropriate, be struck off by their professional regulator as a result.
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13.0 Conflicts of interest training
13.1 WLCCG must ensure that training is offered to all employees, governing body members and members of CCG committees and sub-committees on the management of conflicts of interest. This is to ensure staff and others within the CCG understand what conflicts are and how to manage them effectively (the governance lead is responsible for this task). 13.2 All such individuals should have training on the following:
13.3 NHS England is developing an online training package for CCG staff, governing body and committee members. This will be rolled out in the autumn of 2016. This will need to be completed on a yearly basis to raise awareness of the risks of conflicts of interest and to support staff in managing conflicts of interest. The annual training will be mandatory and this must be completed by all staff by 31 January of each year. WLCCG will record their completion rates as part of their annual conflicts of interest audit.
• What is a conflict of interest; • Why is conflict of interest management important;
• What are the responsibilities of the organisation you work for in relation to
conflicts of interest; • What should you do if you have a conflict of interest relating to your role,
the work you do or the organisation you work for (who to tell, where it should be recorded, what actions you may need to take and what implications it may have for your role);
• How conflicts of interest can be managed;
• What to do if you have concerns that a conflict of interest is not being
declared or managed appropriately; • What are the potential implications of a breach of the CCG’s rules and
policies for managing conflicts of interest.
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Glossary
The Act: The National Health Service Act 2006 (as amended by the Health and Social Care Act 2012) BMA: British Medical Association
CASC: Clinical Advisory Sub-Committee
CCG: Clinical Commissioning Group
CIPFA: The Chartered Institute for Public Finance and Accounting CQC: Care Quality Commission CSS: Commissioning Support Service RCGP: Royal College of General Practitioners GP: General Practitioner NAO: National Audit Office NICE: National Institute for Clinical Excellence OPM: Office for Public Management PCCC: Primary Care Commissioning Committee PCR: Public Contract Regulations 2015 WLCCG: West Lancashire Clinical Commissioning Group
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Annexes
Annex A Template Declaration of interests for CCG members and employees For CCG members and employees to complete when declaring any interest(s). The information should be transferred onto the CCG’s register of interest(s) promptly.
Annex B Template Register of interests for CCGs
For CCGs to record all declared interests. Up-to-date registers should be maintained at all times. The register must be published on the CCG’s website and made available at the CCG’s headquarters.
Annex C Template Declarations of gifts and hospitality
For CCG members and employees to complete on the offer of a gift and/or hospitality, whether accepted or declined. The information should be promptly transferred onto the CCG’s register of gifts and hospitality. Individuals should complete the template following discussion with their line manager or a senior manager in the CCG.
Annex D Template Registers of gifts and hospitality
For CCGs to record all declared gifts and hospitality. Up-to-date registers should be maintained at all times. The register must be published on the CCG’s website and made available at the CCG’s head office.
Annex E Template Declarations of interest checklist
For the chair of a governing body, committee and sub-committee meeting. The checklist will assist both the meeting Chair and the secretariat to give due consideration to managing conflicts of interest whilst planning and conducting the meeting. The checklist incorporates templates:
13.2 for recording any new interests declared during the meeting
13.3 a summary report which should be reviewed by the chair
in advance of the meeting to ensure they are aware of all associated discussions which take place at sub-committee and working group levels.
Annex F Template for recording minutes
For CCGs to use to record the minutes of the meeting. The headings should prompt the meeting Chair and secretariat to include declarations of interest as a standard agenda item and record any information accordingly.
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Annex G Procurement checklist For CCGs to implement when procuring services from providers, to ensure full due consideration is given to the process of procurement. CCGs are advised to address the factors set out in the procurement template when drawing up their plans to commission general practice services. The procurement template includes a template to record procurement decisions and contracts awarded. The information should be promptly transferred onto the CCG’s register of procurement decisions and contracts awarded.
Annex H Template Register of procurement decisions and contracts
awarded For CCGs to complete and maintain up to date records of all procurement decisions and contracts. The register must be updated whenever a procurement decision is taken. The register of procurement decisions and contracts awarded should be published on the CCG’s website and made available at the CCG’s head office.
Annex I Template Declaration of interests for bidders/ contractors
For all bidders and/or contractors to declare any potential conflicts of interest that could arise if the Relevant Organisation was to take part in any procurement process and/or provide services under, or otherwise enter into any contract with, the CCG, or with NHS England.
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Annex A: Template Declaration of interests for CCG members and employees
Name:
Position within, or relationship with, the CCG (or NHS England in the event of joint committees):
Detail of interests held (complete all that are applicable):
Type of Interest* *See reverse of form for details
Description of Interest (including for indirect Interests, details of the relationship with the person who has the interest)
Date interest relates From & To
Actions to be taken to mitigate risk (to be agreed with line manager or a senior CCG manager)
The information submitted will be held by the CCG for personnel or other reasons specified on this form and to comply with the organisation’s policies. This information may be held in both manual and electronic form in accordance with the Data Protection Act 1998. Information may be disclosed to third parties in accordance with the Freedom of Information Act 2000 and published in registers that the CCG holds.
I confirm that the information provided above is complete and correct. I acknowledge that any changes in these declarations must be notified to the CCG as soon as practicable and no later than 28 days after the interest arises. I am aware that if I do not make full, accurate and timely declarations then civil, criminal, or internal disciplinary action may result.
I do / do not [delete as applicable] give my consent for this information to published on registers that the CCG holds. If consent is NOT given, please give reasons:
Signed: Date:
Signed: Position: Date: (Line Manager or Senior CCG Manager)
Please return to <insert name/contact details for team or individual in CCG nominated to provide advice, support, and guidance on how conflicts of interest should be managed, and administer associated administrative processes>
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Types of interest
Type of Interest
Description
Financial Interests
This is where an individual may get direct financial benefits from the consequences of a commissioning decision. This could, for example, include being: • A director, including a non-executive director, or senior employee in a private
company or public limited company or other organisation which is doing, or which is likely, or possibly seeking to do, business with health or social care organisations;
• A shareholder (or similar owner interests), a partner or owner of a private or not-for-profit company, business, partnership or consultancy which is doing, or which is likely, or possibly seeking to do, business with health or social care organisations.
• A management consultant for a provider; • In secondary employment (see paragraph 56 to 57); • In receipt of secondary income from a provider; • In receipt of a grant from a provider; • In receipt of any payments (for example honoraria, one off payments, day
allowances or travel or subsistence) from a provider • In receipt of research funding, including grants that may be received by the
individual or any organisation in which they have an interest or role; and • Having a pension that is funded by a provider (where the value of this might
be affected by the success or failure of the provider). Non- Financial Professional Interests
This is where an individual may obtain a non-financial professional benefit from the consequences of a commissioning decision, such as increasing their professional reputation or status or promoting their professional career. This may, for example, include situations where the individual is: • An advocate for a particular group of patients; • A GP with special interests e.g., in dermatology, acupuncture etc. • A member of a particular specialist professional body (although routine GP
membership of the RCGP, BMA or a medical defense organisation would not usually by itself amount to an interest which needed to be declared);
• An advisor for Care Quality Commission (CQC) or National Institute for Health and Care Excellence (NICE);
• A medical researcher. Non- Financial Personal Interests
This is where an individual may benefit personally in ways which are not directly linked to their professional career and do not give rise to a direct financial benefit. This could include, for example, where the individual is: • A voluntary sector champion for a provider; • A volunteer for a provider; • A member of a voluntary sector board or has any other position of authority
in or connection with a voluntary sector organisation; • Suffering from a particular condition requiring individually funded treatment; • A member of a lobby or pressure groups with an interest in health.
Indirect Interests
This is where an individual has a close association with an individual who has a financial interest, a non-financial professional interest or a non-financial personal interest in a commissioning decision (as those categories are described above). For example, this should include: • Spouse / partner; • Close relative e.g., parent, grandparent, child, grandchild or sibling; • Close friend; • Business partner.
- 45 -
Annex B: Template Register of interests
Name Current position (s) held in the CCG i.e.
Governing Body member;
Committee member; Member
practice; CCG employee or other
Declared Interest
(Name of the organisation and nature of
business)
Type of Interest Is the interest direct or indirect
?
Nature of Interest
Date of Interest Action taken to mitigate risk
From
To
Fina
ncia
l Int
eres
t N
on-F
inan
cial
Pr
ofes
sion
al
Inte
rest
N
on-F
inan
cial
Pe
rson
al In
tere
st
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Annex C: Template Declarations of gifts and hospitality
Recipient Name
Position Date of Offer
Date of Receipt (if applicable)
Details of Gift / Hospitality
Estimated Value
Supplier / Offeror Name and Nature of Business
Details of Previous Offers or Acceptance by this Offeror/ Supplier
Details of the officer reviewing and approving the declaration made and date
Declined or Accepted?
Reason for Accepting or Declining
Other Comments
The information submitted will be held by the CCG for personnel or other reasons specified on this form and to comply with the organisation’s policies. This information may be held in both manual and electronic form in accordance with the Data Protection Act 1998. Information may be disclosed to third parties in accordance with the Freedom of Information Act 2000 and published in registers that the CCG holds.
I confirm that the information provided above is complete and correct. I acknowledge that any changes in these declarations must be notified to the CCG as soon as practicable and no later than 28 days after the interest arises. I am aware that if I do not make full, accurate and timely declarations then civil, criminal, professional regulatory or internal disciplinary action may result.
I do / do not (delete as applicable) give my consent for this information to published on registers that the CCG holds. If consent is NOT given please give reasons:
Signed: Date: Signed: Position: Date: (Line Manager or a Senior CCG Manager) Please return to <insert name/contact details for team or individual in CCG nominated to provide advice, support, and guidance on how conflicts of interest should be managed, and administer associated administrative processes>
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Annex D: Template Register of gifts and hospitality
Name Position Date of Offer
Declined or Accepted?
Date of Receipt (if applicable)
Details of Gift /Hospitality Estimated Value
Supplier / Offeror Name and Nature of business
Reason for Accepting or Declining
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Annex E: WLCCG’s declarations of interest checklist Under the Health and Social Care Act 2012, there is a legal obligation to manage conflicts of interest appropriately. It is essential that declarations of interest and actions arising from the declarations are recorded formally and consistently across all CCG governing body, committee and sub-committee meetings. This checklist has been developed with the intention of providing support in conflicts of interest management to the Chair of the meeting- prior to, during and following the meeting. It does not cover the requirements for declaring interests outside of the committee process.
Timing Checklist for Chairs Responsibility
In advance of the meeting
1. The agenda to include a standing
item on declaration of interests to enable individuals to raise any issues and/or make a declaration at the meeting.
2. A definition of conflicts of interest
should also be accompanied with each agenda to provide clarity for all recipients.
3. Agenda to be circulated to enable
attendees (including visitors) to identify any interests relating specifically to the agenda items being considered.
4. Members should contact the
Chair as soon as an actual or potential conflict is identified.
5. Chair to review a summary report
from preceding meetings i.e., sub- committee, working group, etc., detailing any conflicts of interest declared and how this was managed.
A template for a summary report to present discussions at preceding meetings is detailed below.
6. A copy of the members’ declared
interests is checked to establish any actual or potential conflicts of interest that may occur during the meeting.
Meeting Chair and secretariat
Meeting Chair and secretariat
Meeting Chair and secretariat
Meeting members
Meeting Chair
Meeting Chair
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During the meeting
7. Check and declare the meeting is
quorate and ensure that this is noted in the minutes of the meeting.
8. Chair requests members to
declare any interests in agenda items- which have not already been declared, including the nature of the conflict.
9. Chair makes a decision as to how
to manage each interest which has been declared, including whether / to what extent the individual member should continue to participate in the meeting, on a case by case basis, and this decision is recorded.
10. As minimum requirement, the
following should be recorded in the minutes of the meeting:
• Individual declaring the interest; • At what point the interest was
declared; • The nature of the interest; • The Chair’s decision and resulting
action taken; • The point during the meeting at
which any individuals retired from and returned to the meeting - even if an interest has not been declared;
• Visitors in attendance who
participate in the meeting must also follow the meeting protocol and declare any interests in a timely manner.
A template for recording any interests during meetings is detailed below.
Meeting Chair
Meeting Chair
Meeting Chair and secretariat
Secretariat
Following the meeting
11. All new interests declared at the
meeting should be promptly updated onto the declaration of interest form;
12. All new completed declarations of
interest should be transferred onto the register of interests.
Individual(s) declaring interest(s)
Designated person responsible for registers of interest
50
T
emplate for recording any interests during meetings
Report from <insert details of sub-committee/ work group>
Title of paper <insert full title of the paper>
Meeting details <insert date, time and location of the meeting>
Report author and job title
<insert full name and job title/ position of the person who has written this report>
Executive summary
<include summary of discussions held, options developed, commissioning rationale, etc.>
Recommendations <include details of any recommendations made including full rationale> <include details of finance and resource implications>
Outcome of Impact Assessments completed (e.g. Quality IA or Equality IA)
<Provide details of the QIA/EIA. If this section is not relevant to the paper state ‘not applicable’>
Outline engagement – clinical, stakeholder and public/patient:
<Insert details of any patient, public or stakeholder engagement activity. If this section is not relevant to the paper state ‘not applicable’>
Management of Conflicts of Interest
<Include details of any conflicts of interest declared> <Where declarations are made, include details of conflicted individual(s) name, position; the conflict(s) details, and how these have been managed in the meeting>
<Confirm whether the interest is recorded on the register of interests- if not agreed course of action>
Assurance departments/ organisations who will be affected have been consulted:
<Insert details of the people you have worked with or consulted during the process : Finance (insert job title) Commissioning (insert job title) Contracting (insert job title) Medicines Optimisation (insert job title) Clinical leads (insert job title) Quality (insert job title) Safeguarding (insert job title) Other (insert job title)>
Report previously presented at:
<Insert details (including the date) of any other meeting where this paper has been presented; or state ‘not applicable’>
Risk Assessments <insert details of how this paper mitigates risks- including conflicts of interest>
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Template to record interests during the meeting
Meeting Date of Meeting
Chairperson (name)
Secretariat (name) Name of person declaring interest
Agenda Item
Details of interest declared
Action taken
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Annex F: Template for recording minutes
XXXX Clinical Commissioning Group Primary Care Commissioning Committee Meeting
Date: 15 February 2016 Time: 2pm to 4pm Location: Room B, XXXX CCG
Attendees: Name
Initials Role
Sarah Kent Andy Booth Julie Hollings Carl Hodd Mina Patel Dr Myra Nara Dr Maria Stewart Jon Rhodes
SK AB JH CH MP MN MS JR
XXX CCG Governing Body Lay Member (Chair) XXX CCG Audit Chair Lay Member XXX CCG PPI Lay Member Assistant Head of Finance Interim Head of Localities Secondary Care Doctor Chief Clinical Officer Chief Executive – Local Healthwatch
In attendance from 2.35pm
Neil Ford NF Primary Care Development Director
Item No Agenda Item Actions
1 Chairs welcome
2
Apologies for absence
<apologies to be noted>
3
Declarations of interest
SK reminded committee members of their obligation to declare any interest they may have on any issues arising at committee meetings which might conflict with the business of XXX clinical commissioning group.
Declarations declared by members of the Primary Care Commissioning Committee are listed in the CCG’s Register of Interests. The Register is available either via the secretary to the governing body or the CCG website at the following link: http://xxxccg.nhs.uk/about-xxx-ccg/who-we- are/our -governing-body/
Declarations of interest from sub committees. None declared
Declarations of interest from today’s meeting
53
The following update was received at the meeting:
• With reference to business to be discussed at this meeting, MS declared that he is a shareholder in XXX Care Ltd.
SK declared that the meeting is quorate and that MS would not be included in any discussions on agenda item X due to a direct conflict of interest which could potentially lead to financial gain for MS.
SK and MS discussed the conflict of interest, which is recorded on the register of interest, before the meeting and MS agreed to remove himself from the table and not be involved in the discussion around agenda item X.
4
Minutes of the last meeting <date to be inserted> and matters arising
5
Agenda Item <Note the agenda item>
MS left the meeting, excluding himself from the discussion regarding xx.
<conclude decision has been made>
<Note the agenda item xx>
MS was brought back into the meeting.
6
Any other business
7
Date and time of the next meeting
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Annex G: Procurement checklist for commissioning general practice services
Service:
Question Comment/ Evidence
1. How does the proposal deliver good or improved outcomes and value for money – what are the estimated costs and the estimated benefits? How does it reflect the CCG’s proposed commissioning priorities? How does it comply with the CCG’s commissioning obligations?
2. How have you involved the public in the decision to commission this service?
3. What range of health professionals have been involved in designing the proposed service?
4. What range of potential providers have been involved in considering the proposals?
5. How have you involved your Health and Wellbeing Board(s)? How does the proposal support the priorities in the relevant joint health and wellbeing strategy (or strategies)?
6. What are the proposals for monitoring the quality of the service?
7. What systems will there be to monitor and publish data on referral patterns?
8. Have all conflicts and potential conflicts of interests been appropriately declared and entered in registers?
9. In respect of every conflict or potential conflict, you must record how you have managed that conflict or potential conflict. Has the management of all conflicts been recorded with a brief explanation of how they have been managed?
10. Why have you chosen this procurement route e.g., single action tender?25
Taking into account all relevant regulations (e.g. the NHS (Procurement, patient choice and competition) (No 2) Regulations 2013 and guidance (e.g. that of Monitor).
55
11. What additional external involvement will there be in scrutinising the proposed decisions?
12. How will the CCG make its final commissioning decision in ways that preserve the integrity of the decision-making process and award of any contract?
Additional question when qualifying a provider on a list or framework or pre selection for tender (including but not limited to any qualified provider) or direct award (for services where national tariffs do not apply)
13. How have you determined a fair price for the service?
Additional questions when qualifying a provider on a list or framework or pre selection for tender (including but not limited to any qualified provider) where GP practices are likely to be qualified providers
14. How will you ensure that patients are aware of the full range of qualified providers from whom they can choose?
Additional questions for proposed direct awards to GP providers
15. What steps have been taken to demonstrate that the services to which the contract relates are capable of being provided by only one provider?
16. In what ways does the proposed service go above and beyond what GP practices should be expected to provide under the GP contract?
17. What assurances will there be that a GP practice is providing high-quality services under the GP contract before it has the opportunity to provide any new services?
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Template: NHS West Lancashire CCG Procurement decisions and contracts awarded
Ref No
Contract/ Service title
Procurement description
Existing contract or new procurement (if existing include details)
Procurement type – CCG procurement, collaborative procurement with partners
CCG clinical lead (Name)
CCG contract manger (Name)
Decision making process and name of decision making committee
Summary of conflicts of interest noted
Actions to mitigate conflicts of interest
Justification for actions to mitigate conflicts of interest
Contract awarded (supplier name & registered address)
Contract value (£) (Total) and value to CCG
Comments to note
To the best of my knowledge and belief, the above information is complete and correct. I undertake to update as necessary the information.
Signed:
On behalf of:
Date:
Please return to <insert name/contact details for team or individual in CCG nominated for procurement management and administrative processes>
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Annex H: Template Register of procurement decisions and contracts awarded
Ref No
Contract/ Service title
Procurement description
Existing contract or new procurement (if existing include details)
Procurement type – CCG procurement, collaborative procurement with partners
CCG clinical lead
CCG contract manger
Decision making process and name of decision making committee
Summary of conflicts of interest declared and how these were managed
Contract awarded (supplier name & registered address)
Contract value (£) (Total)
Contract value (£) to CCG
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Annex I: Template Declaration of conflict of interests for bidders/contractors
Name of Organisation:
Details of interests held:
Type of Interest
Details
Provision of services or other work for the CCG or NHS England
Provision of services or other work for any other potential bidder in respect of this project or procurement process
Any other connection with the CCG or NHS England, whether personal or professional, which the public could perceive may impair or otherwise influence the CCG’s or any of its members’ or employees’ judgements, decisions or actions
59
OFFICIAL
Name of Relevant Person
[complete for all Relevant Persons]
Details of interests held:
Type of Interest
Details
Personal interest or that of a family member, close friend or other acquaintance?
Provision of services or other work for the CCG or NHS England
Provision of services or other work for any other potential bidder in respect of this project or procurement process
Any other connection with the CCG or NHS England, whether personal or professional, which the public could perceive may impair or otherwise influence the CCG’s or any of its members’ or employees’ judgements, decisions or actions
To the best of my knowledge and belief, the above information is complete and correct. I undertake to update as necessary the information.
Signed:
On behalf of:
Date:
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OFFICIAL Annex J: Conflicts of interest policy checklist
In accordance with the Health and Social Care Act 2012, there is a legal requirement for Clinical Commissioning Groups (CCGs) to manage the process of conflicts of interest, both actual and perceived. The aim of the conflicts of interest policy checklist is to support CCGs to develop their conflict of interest policy. It is recommended that the CCG makes a commitment to reviewing their conflicts of interest policy (subject to changes) annually to ensure all material is up to date. CCGs should refer to Managing Conflicts of Interest: Revised Statutory Guidance for CCGs when developing the conflicts of interest policy.
Conflicts of interest policy- checklist
Key areas for consideration
Introduction to the policy
• Introduction; • Aims and objectives of the policy; • Consider the CCG’s constitution and specified
requirements in terms of conducting business appropriately;
• Consider the legal requirements in terms of managing conflicts of interest;
• Consider any other appropriate regulations; • Scope of the policy <whom the policy applies to> • Commitment to review <include frequency>
Definition of an interest
• Definition of an interest: • Types of an interest, including:
o Financial interests; o Non-financial professional interests o Non-financial personal interests; or o Indirect interests where an individual has a close
association with an individual who has a financial interest, a non-financial professional interest or a non- financial personal interest in a commissioning decision
Refer to paragraphs 13 to 17 of the CCG Guidance for further information
Principles
• Principles of good governance for consideration,
include those set out in the following: o The Seven Principles of Public Life (commonly
known as the Nolan Principles); o The Good Governance Standards of Public
Services; o The Seven Key Principles of the NHS Constitution; o The Equality Act 2010.
Declaring conflicts of interest
• Consideration should be given to the statutory
requirements; • Detail the types of interests to be declared - as outlined
in the definition of an interest section; • Details of when a conflict of interest should be
declared; • State the contact details of the nominated person to
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OFFICIAL
whom declarations of interest should be reported to; • Consider visual formats including a flowchart detailing
the process of declaring conflicts of interest in various settings i.e. meetings, the transfer of information onto registers of interest, etc.
A declaration on interests template should be appended to the policy
Register(s) of conflicts of interest
• Consideration should be given to the statutory
requirements;
• One or more registers of interest should be maintained for the following: o All CCG employees; o All members of the CCG; o Members of the governing body; o Members of the CCG’s committees and sub-
committees; o Any self-employed consultants or other individuals
working for the CCG under a contract for services.
• Stipulate the period of time within which registers of interest have to be updated- upon receiving a declaration of interest in line with the guidance;
• Stipulate publication arrangements for registers of interests in line with the guidance.
A register of interests template should be appended to the policy
Declaration of gifts and hospitality
• Consideration should be given to the statutory
requirements; • Consideration of risks when accepting gifts and hospitality; • Define acceptable types of gifts and hospitality; • Define the process for reporting gifts and hospitality; • State the contact details of the nominated person to whom
declarations of gifts and hospitality should be reported to. A declaration of gifts and hospitality form template should be appended to the policy.
Maintaining a register of
gifts and hospitality
• Consideration should be given to the statutory
requirements; • Consideration should be given to the time period for
updating the registers of gifts and hospitality upon receiving a declaration of gifts and hospitality in line with the guidance;
• Stipulate publication arrangements for registers of gifts and hospitality in line with the guidance.
A register of gifts and hospitality template should be appended to the policy
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Roles and responsibilities
• Key considerations when appointing governing body
or committee members including the following: o Whether conflicts of interest should exclude
individuals from appointment; o Assessing materiality of interest; o Determining the extent of the interest.
• The role of CCG lay members in managing
organisational conflicts of interest, including the following: o Conflicts of interest guardian; o Primary care commissioning committee Chair.
Governance arrangements and decision making
• Consider the CCG’s policy of secondary employment
and procedure for declaring details- how will this impact on appointing governing board members.
• Define the procedure to be followed in governing body,
committee and sub-committee meetings, including: o Declarations of interest checklist (a template should
be appended to the policy); o Register of interests declared to be available for
the Chair in advance of the meeting; o Process for declaring interests during the meeting; o Recording minutes of the meeting including
interests declared.
• Procedures to be followed for managing conflicts of interest which arise during a governing body, committee or sub-committee meeting, including, where appropriate: o Excluding the conflicted individual(s) from any
associated discussions and decisions; o Actions to be taken if the exclusion affects the
quorum of the meeting- including postponing the agenda item until a quorum can be achieved without conflict;
o Clearly recording the agenda item for which the interest has been declared.
See paragraphs 72 to 94 of the CCG Guidance (Managing conflicts of interest at meetings) for further details
• Consider openness and transparency in decision
making processes through: o Effective record keeping in the form of clear minutes of
the meeting. o All minutes should clearly record the context of
discussions, any decisions and how any conflicts of interest were raised and managed.
A template for recording minutes of the meeting should be appended to the policy.
Managing conflicts of interest throughout
• Key areas for consideration include the following:
• Service design, this can either increase or reduce the
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the commissioning cycle
level of perceived or actual conflicts of interest; o Consider public and patient involvement and
provider engagement in service design; o Consider how you involve PPI in needs assessment,
planning and prioritisation to service design, procurement and monitoring;
o Consider how you will engage relevant providers, especially clinicians, in confirming the design of service specifications- ensuring an audit train/ evidence base is maintained;
o Consider how you ensure provider engagement is in accordance with the three main principles of procurement law, namely equal treatment, non- discrimination and transparency
o Are specifications clear and transparent.
• Procurement, are there clear processes to recognise and manage any conflicts or potential conflicts of interest that may arise in relation to procurement o Consideration should be given to statutory
regulations and guidance when procuring and contracting clinical services;
o Consideration should be given to how you ensure transparency and scrutiny of decisions i.e. keeping records of any conflicts and how these were managed;
o Maintaining register of procurement decisions detailing decisions taken, either for the procurement of a new service or any extension or material variation of a current contract.
A procurement template and register of procurement decisions should be appended to the policy.
• Contract monitoring, consider conflicts of interest as part
of the process i.e., the Chair of a contract management meeting should invite declarations of interests; o Process for recording any declared interests in the
minutes of the meeting; and how these are managed; o Consider commercial sensitivity of information i.e.
which information should be disseminated. A template for recording minutes of the contract meeting should be appended to the policy.
Raising concerns
• Key areas for consideration:
o When should a concern regarding conflicts of interest be reported;
o What is the process for reporting concerns; o Who should concerns be raised with; o How will concerns be investigated; o Who is responsible for making the decision; o How do you ensure confidentiality; o Reporting requirements.
Breach of conflicts of
interest policy
• Consider and agree a clear, defined process for
managing breaches of the CCG’s conflicts of interest policy, including:
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o How the breach is recorded; o How it is investigated; o The governance arrangements and reporting
mechanisms; o Clear links to whistleblowing and HR policies; o Communications and management of any media
interest; o When and who to notify NHS England; o Process for publishing the breach on the CCG
website.
Quality and Safety Committee – 26 July 2016 Page 1 of 5
Minutes
Quality and Safety Committee
Venue: Boardroom, Hilldale, Ormskirk
Date & Time: Tuesday 26 July 2016 at 1.30 – 3.30pm
Attendees: Mr G Mitten – Chair Mrs J DeBacker – Practice manager Mrs J Mastin - Infection, Prevention, Control Nurse for the Central Locality, Public Health England Dr J Kinsey – GP lead for safeguarding Dr R Jaidka – GP lead
In attendance: Miss C Ashcroft – Executive assistant Mrs A Sathiyanathan – Quality assurance manager Mrs A Lumley – Primary care nurse development lead Mrs L Elliott – Lead nurse for safeguarding adults and mental capacity act Mrs Sheralee Turner-Birchall – Chief officer of Healthwatch Lancashire
Apologies: Mrs C Heneghan – Chief nurse Mrs J Moran – Head of quality, performance and contracting Mrs L Burton – Designated lead nurse for safeguarding children (in attendance)
Agenda
Item CCGQIC
Summary of Discussion Lead
07/16/1 Welcome and apologies for absence Greg Mitten welcomed the members of the quality and safety committee to the meeting. The apologies above were relayed.
07/16/2 Declaration of interest There were no declarations of interest raised which were pertinent to the agenda. Members will raise any relevant declarations of interest as each item is discussed.
07/16/3 Minutes from the previous meeting on 28 June 2016 The notes from the previous meeting were approved as a correct record of the meeting.
07/16/4 Matters arising – action sheet The action sheet was updated.
07/16/5 Patient Quality, Performance, Safety and Experience a. Primary Care Nurse update
Alison Lumley presented a verbal update for primary care nursing: • A clinical supervision model has been agreed and will hopefully be
implemented from September. • Work is ongoing with the nurses to development a frailty template
following the delivery of frailty training. • The following training has been delivered / planned:
o Contraception & sexual health update for registered nurses o Diabetes for healthcare assistants (care home staff also invited) o Mental health including dementia for registered nurses o Frailty and dementia for healthcare assistants (care home staff
also invited)
Quality and Safety Committee – 26 July 2016 Page 2 of 5
Agenda Item
CCGQIC
Summary of Discussion Lead
• Two new nurses are in post. Neither have primary care experience and practices are being supported to ensure an appropriate development programme and support is in place.
b. Serious incidents monthly report (SIs) One of the purposes of this report produced by the CSU is to ensure lessons are learnt from reported serious incidents, which are looked at by the Serious Incident Review Group and escalated with themes identified. It was reported that quality and timeliness of the incident reporting had been discussed at these SI meetings over the last few meetings. The number of SIs reported last year was compared with 2014-15 figures and showed an increase of 30 incidents. While the level of SIs has actually reduced in Lancashire overall. This increase is due to the 36 pressure ulcers reported in 2015-16 compared with eight in the previous year. These mainly occurred at Southport and Ormskirk Hospital NHS Trust and has led to a contract query. An action plan for SIs relating to pressure ulcers has recently been received and will be reviewed at the SI Review Group in August to progress the closure of these SIs. Many RSAs managed by Southport and Formby CCGs are overdue for completion. Last April national guidance directed providers to produce 72-hour reports. Southport and Ormskirk Hospital NHS Trust do not routinely produce these reports. These issues will be raised at the SI Review Group meeting. Feedback from this will be provided to a future Quality and Safety Committee. It was highlighted that the CSU SI staff have been very supportive in producing an annual report that has highlighted these issues.
c. Quarter 1 CSU Customer Care report This section of the meeting will be retitled as customer complaints in the future as it should include complaints reports received by providing as well as the CSU. The patient complaint raised at the previous meeting has now received a response from the Trust. It led to a question being raised with the Trust around timescales. The Trust’s monthly report will include this complaint response information from September.
d. GP issues
This item had already been discussed and recorded on the action sheet. Southport and Ormskirk Hospital NHS Trust will produce reports from September, stating the actions taken as a result of GP issues received. There is a need to ensure GPs receive feedback to encourage more GPs to raise issues with providers via this route.
e. HCAI – infection control
Jane Mastin reported that two cases of C. Difficile infection had occurred in June. One was attributable to the provider and the other to community. The numbers are still under trajectory.
f.i. C. Diff terms of reference – minor typos will be amended. Bi-monthly C. Difficile panels will take place at the CCG from October, where cases from August and September will be discussed. This will be publicised in the GP newsletter. Learning from the case discussion can be fedback to the practices concerned in terms of caution around prescribing. Also a list of trends can be collated to share with the wider GP forum.
AS
Quality and Safety Committee – 26 July 2016 Page 3 of 5
Agenda Item
CCGQIC
Summary of Discussion Lead
ii & iii MRSA action plans An MRSA review meeting took place to discuss a case of MRSA identified in May from a sample taken in March. Following arbitration the final assignment has returned to the CCG. Jane Mastin requested that the rationale for the decision be obtained. One outstanding learning outcome in the action plan was in the delay in picking up the unusual strain of MRSA. It had been queried whether the test used had been appropriate or a more accurate test would have prevented the delay. The two Trusts involved confirmed the test had been appropriate. This action plan (ID 484309) is now complete. Another MRSA case from a sample in June had been identified and following review was assigned to the CCG. The MRSA target for the CCG (zero) is now breached for the year. The review group had identified a delay in ambulance attendance for this code red call. The care home identified this as a frequent issue. Paul Kingan will be made aware of delays in ambulance attendance to care homes for his discussions with the main provider of NWAS at Blackpool CCG. This action plan (ID 489316) is now closed.
g. CQUIN / other incentive schemes In terms of national CQUINs, the health and wellbeing CQUIN has not been submitted by Southport and Ormskirk Hospitals NHS Trust to Southport and Formby CCG. The e-discharge local CQUIN has been dropped by the CCG as the national guidance recommends a joint approach with the two CCGs, but Southport and Formby CCG did not want to pursue this and discharges will be maintained through the contract. Reducing follow up referrals, consultant to consultant referrals, the number of zero length of stay patients will be developed as the third local CQUIN.
JMastin AS AS / PK
07/16/6 Governance and Performance a. Corporate risk register
The corporate risk register, which had been presented to the Governing Body earlier today, is current and reflects the safeguarding risk raised at the last meeting.
b. Quality impact assessment for the re-procurement
The quality impact assessment (QIA) is a new process for the CCG. Fylde and Wyre CCG has shared the guidance document and the first QIA was undertaken for the re-procurement of community services. The assessment form is a living document which will be populated as information comes to light. The governance process requires that the QIA is reviewed by the Quality and Safety Committee at specified intervals. Specifications are being reviewed in August and these will impact on the QIA. The assessment form will return to the committee at the specification stage.
c. MIAA report and action plan on quality of commissioned services The review on the quality of commissioned services was carried out in November 2015 and publicised in June 2016. MIAA were asked to include the serious incident process as the quality team raised concerns over current practice. The review received limited assurance. West Lancashire CCG is not the lead commissioner and therefore does not hold primary
Quality and Safety Committee – 26 July 2016 Page 4 of 5
Agenda Item
CCGQIC
Summary of Discussion Lead
responsibility for managing SIs and monitoring contracts. Allison Sathiyanathan was new to the role at the time and has worked hard to develop a more robust process with Southport and Formby CCG particularly around SIs. The updated action plan will be brought back in October.
AS
07/16/7 Minutes of meetings The minutes from the following meetings show the depth of the discussion on quality and were noted: Southport and Ormskirk Collaborative Commissioning Forum (CCF) – April and June 2016 – Allison Sathiyanathan reported that at the July meeting of the CCF, the delay in producing the overarching action plan was raised. Southport and Ormskirk Hospital NHS Trust were not present at the meeting. The interim chief executive has stated that she will take primary responsibility for producing the action plan. At the Trust, Kevin Pritchard, performance and contracting, has not been replaced and the CCGs have been redirected to Steve Shanahan, director of finance for any contacting issues. Allison Sathiyanathan will express the committee’s concerns in the delay in producing the overarching action plan at the CCF. Southport and Ormskirk and Clinical Quality Review – May and June 2016 The quality and safety committee: noted the minutes.
AS
07/16/8 Any other business Lorraine Elliot reported that two care homes are under QIP. One is making progress and the suspension should be lifted soon. Another home had received a number of safeguarding alerts and measures have been put in place with the first QIP meeting to take place on Thursday. Lessons learned must be embedded to ensure strong leadership and effective staff training. Sheralee Turner-Birchall informed the committee about testing work being undertaken by care homes in East Lancashire. Healthwatch Lancashire also revisit care homes six months after a QIP has ceased. Healthwatch are looking into visiting care homes to identify best practice and to produce an action plan in liaison with CCGs. The best practice would be shared with the public and other care homes. Alison Lumley reported the benefits of knowing which patients in care homes belong to which GP practises. Should a patient in a care home require additional visits from a GP, repetitive referrals or raise safeguarding issues, the patient will be assessed. Alison Lumley stated that the RADAR group and the safeguarding model in West Lancashire are robust. It was suggested that a membership council meeting be used to bring together GPs, nurses and HCAs to provide further information about safeguarding and the different degrees of action taken. Greg Mitten asked if there were any comments on or omissions from the current format of the integrated business report. Allison Sathiyanathan suggested the process be amended to ensure her input during the production of the report on C. Difficile, MRSA and serious incidents. This will be reported
Quality and Safety Committee – 26 July 2016 Page 5 of 5
Agenda Item
CCGQIC
Summary of Discussion Lead
to Paul Kingan. It was agreed that an out of hours report should be presented to the committee by exception when RAG rated as amber or red. Helen Garten from the CSU presented a new toolkit called CHAT (Continuing Healthcare Assurance Tool) which will provide assurance. It will need to link with Southport and Formby CCG and NHS England to enable completion. Once completed, an action plan will be produced and be presented at committee meetings.
Date and time of the next meeting – Tuesday 23 August at 1.30 pm, Boardroom, Hilldale
1
West Lancashire CCG Clinical Executive Committee Action and Notes – 12/07/16
Discussion and Decisions This week’s actions Due Date
Responsible officer
RAG
Attendees John Caine – Chair Mike Maguire – Chief Officer Doug Soper – Lay Member Debbie Dobson - Practice Manager Jo DeBacker – Practice Manager Vikul Mittal - GP Executive Lead Bapi Biswas – GP Executive Lead Peter Gregory – GP Executive Lead Claire Heneghan – Chief Nurse Amanda Gordon – Service Redesign Manager Nicola Baxter - Head of Medicines Optimisation Amanda Gordon – Service Redesign Manager
Apologies Rakesh Jaidka - GP Executive Lead Greg Mitten - Lay Member Jackie Moran – Head of Quality Performance & Contracting Adam Robinson - Secondary Care Consultant Paul Kingan – Chief Finance Officer
Declaration of Interest
Dr Caine, Dr Mittal, Dr Biswas, Dr Gregory, Debbie Dobson and Jo DeBacker declared an interest in Reducing Spend on Prescribing.
Notes from previous meeting
The notes were noted and approved.
2
Strategic and service redesign
Item 3 – MCAS Model Update Peter Gregory and Amanda Gordon provided an update on the progress regarding the current MCAS Model redesign. The service specification still remains unsigned.
Amanda to prepare update for membership Amanda will present a paper for consideration at the next Executive Committee. Peter Gregory and Amanda Gordon to meet with Southport and Formby CCG. Amanda to meet with S&F CCG and Trust .
15.07.16 19.07.16 19.07.16 20.07.16
Amanda Gordon Amanda Gordon Amanda Gordon Amanda Gordon
Item 4 – Reducing Spend on Prescribing The Chair was passed over to Mike Maguire as it was fundamental Dr Caine, Dr Mittal, Dr Biswas, Dr Gregory, Debbie Dobson and Jo DeBacker left the room for this agenda item, having declared an interest. Nicola Baxter submitted a paper to the Committee regarding minimising medicines waste. The Committee approved a working group to come together to focus on an action plan on how this may be achieved
Nicola Baxter to update on Working Group
26.07.16 ????
Nicola Baxter
Item 5 – Membership Agenda Membership agenda was reviewed and agreed.
No Action Required
Item 6 – Lancashire & South Cumbria Draft STP June Submission Mike Maguire updated the Committee on the draft STP
No Action Required
3
June submission which the Committee noted.
Item 7 – Health System Leaders Briefing Mike Maguire updated the Committee on the Health System Leaders Briefing, which is a part of the STP submission.
No Action Required
Item 8 – New Conflict of Interest Guide The New Conflict of Interest Guide was reviewed and required action will be implemented.
Required action will be implemented.
Ongoing Doug Soper
Item 9 – Notes from previous meeting The notes were noted and approved.
No Action Required
Wrap up
West Lancashire CCG Clinical Executive Committee Action and Notes – 02/08/2016
Discussion and Decisions This week’s actions Due Date
Responsible officer
RAG
Attendees John Caine - Chair Paul Kingan – Chief Finance Officer Bapi Biswas – GP Executive Lead Jack Kinsey – GP Executive Lead Jo DeBacker – Practice Manager Rakesh Jaidka - GP Executive Lead Vikul Mittal – GP Executive Lead Adam Robinson – Secondary Care Consultant Claire Heneghan – Chief Nurse Doug Soper – Lay Member
Apologies Mike Maguire – Chief Officer Greg Mitten - Lay Member Jackie Moran – Head of Quality Performance & Contracting Debbie Dobson – Practice Manager Peter Gregory – GP Executive Lead
Declaration of Interest
All GP members and practice manager declared an interest in item 4 – 7 Day Access Proposal
Strategic and service redesign
Item 3 – MCAS Model Update Amanda Gordon gave an update to the committee on how the MCAS model was received at Membership Council. It was noted that this was well received and were in agreement with this moving forward. Amanda also raised that Southport & Formby CCG have decided not to phase in the new model over the 3 month period we had agreed and plan to introduce the changes from the 1 October
Paper around risk to be delivered at next committee
Amanda Gordon
2016. After discussion it was felt that the West Lancashire CCG need to move along the same timeline as Southport & Formby CCG. The committee requested that Amanda write a paper to highlight potential risks/benefits from this decision and bring back to the committee next week. This would then be communicated further to the GP membership to keep them informed.
Item 4 – 7 Day Access Proposal John Caine declared an interest in this and passed the chair to Paul Kingan. The declaration of interest was declared as fundamental and John Caine, all GP members and practice managers were asked to leave the room. After discussion the meeting was not quorate to take a vote on the decision although members expressed support for the proof of concept as outlined and it was decided that the Item be brought to a single item governing body to agree the decision.
Single item governing body
Paul Kingan
Operational Item 5 – CCG Ratings Paul Kingan passed the chair back to John Caine Paul Kingan gave an overview of the recently published CCG ratings. West Lancashire CCG were rated as Good and received a rating of Good in each of the individual categories. Paul reiterated that to maintain ‘good’ rating diligent stewardship of all areas assessed against will have to be maintained especially in the area of finance in the coming year.
Item 6 – Leaders in the North Conference Paul Kingan attended the conference in Leeds and gave feedback to the committee on some of the speakers and the content.
Item 7 – Strengthening the QIPP Programme Paul Kingan highlighted the financial position and how the QIPP programme needs to be strengthened. Paul asked for any suggestions on schemes that could be introduced. After discussion it was decided that this should be a regular item agenda on the clinical executive committee to monitor the situation.
To become regular agenda item
E-meeting Item 8 – DSE Policy and Office Safety Procedures Papers approved.
Item 9 – Public Sector Operating Model Review of LCC Paul Kingan will be attending the Lancashire Board and will report back to the committee and working partnerships.
Item 10 – WLCCG Workforce Race Equality Standard Reporting Template Paper approved.
Item 11 – Notes from Previous Meeting Notes from 12.07.16 – Amend Item 8 – responsible officer should read Paul Kingan. Notes from 19.07.16 – Meeting was not quorate and these
minutes should not be published at the next governing body.
Item 12 – MIAA Presentation Roger Causer, Deputy Head of Fraud Services attended the meeting to provide a presentation on Fraud, Bribery and Corruption. This is in preparation for the upcoming inspection by NHS Protect which is due to take place on Wednesday and Thursday 10/11 August 2016.
Item 13 – Any other business Claire Heneghan gave an update on the position of Southport & Ormskirk Hospital NHS Trust and the recent Improvement Board meeting that was held following on from the Health Risk Summit. There was no one available from West Lancashire CCG to attend due to significant commitments, but Claire received feedback via telephone from Fiona Taylor, Chief Officer of Southport and Formby CCG. After feedback and discussion it was decided that a meeting with Southport & Formby CCG should take place before the next Improvement Board meeting. A telephone conference with Fiona, NHS England Cheshire and Mersey is also being arranged for early this week.
Wrap up
1
West Lancashire CCG Clinical Executive Committee Action and Notes – 09/08/16
Discussion and Decisions This week’s actions Due Date
Responsible officer
RAG
Attendees Mike Maguire – Chief Officer Doug Soper – Lay Member Jo DeBacker – Practice Manager Vikul Mittal - GP Executive Lead Bapi Biswas – GP Executive Lead Peter Gregory – GP Executive Lead Claire Heneghan – Chief Nurse Greg Mitten – Lay Member Jackie Moran – Head of Quality, Procurement and Contracting Chris Russ – IM&T Strategy Lead Anne-Marie Bridge – Admin Officer
Apologies John Caine – Chair Paul Kingan – Chief Finance Officer Debbie Dobson - Practice Manager Jack Kinsey – GP Executive Lead
Declaration of Interest
None noted.
Notes from previous meeting
Noted and approved.
Strategic and service redesign
Item 3 – LPRES Business Case Chris gave presentation to the committee with regards to the LPRES programme and how it is progressing. This programme will develop a shared care record. It is due to
2
be linked with EMIS and Southport and Ormskirk Hospital NHS Trust will also be linked enabling better communication links to the GPs and will be included in the mobilisation of the new community contract. Chris answered questions raised and assured the committee that many agencies are on board with moving this forward. The committee agreed to the progression of this programme.
Wrap up
West Lancashire CCG Clinical Executive Committee Action and Notes – 23/08/2016
Discussion and Decisions This week’s actions Due Date Responsible officer RAG
Attendees John Caine – Chair Mike Maguire – Chief Officer Bapi Biswas – GP Executive Lead Jo DeBacker – Practice Manager Debbie Dobson – Practice Manager Rakesh Jaidka - GP Executive Lead Vikul Mittal – GP Executive Lead Adam Robinson – Secondary Care Consultant Doug Soper – Lay Member
Attended the meeting for item 3 – QIPP Oversight – Medicines Waste
Nic Baxter – Head of Medicines Optimisation Matthew Greene – Finance Manager
Attended the meeting for item 6 – Media Issues
Meg Pugh – Head of Communication and Engagement Karen Tordoff – Lead Manager, Service Redesign
Apologies Paul Kingan – Chief Finance Officer Greg Mitten - Lay Member Jackie Moran – Head of Quality Performance & Contracting Peter Gregory – GP Executive Lead Jack Kinsey – GP Executive Lead Claire Heneghan – Chief Nurse
Declaration of Interest
None declared
Strategic and service redesign
Item 3 – QIPP Oversight – Medicines Waste
Matthew Greene led a discussion of the current prescribing forecast for 2016 / 2017.
An overview of the progress against prescribing QIPP targets was given as well as the support that is required from the Executive Committee.
Nic Baxter, , gave an overview of a new project aiming to support West Lancashire GP practices to ensure best practice for ordering and issuing of medication/ prescriptions. The project is also designed to identify and reduce waste across the current systems.
Group training sessions for practice staff / practice sessions will commence in September. These are being held in order to ensure that staff support patients to order their medication in the safest way, which encourages and ensures patient empowerment.
The Medicines Management Team at WLCCG has identified several areas that the groups might look at in training, including Pain Management. Chris Barker, Clinical Director and Specialist in Pain Medicine, is to be invited to the next Executive Committee to present what could be the influencing factors in Pain Management.
Medicines Management Team to commence a schedule of training sessions
Chris Barker to be invited to discuss Pain Management at the next Clinical Executive Meeting
During Sept. 2016
30th
August 2016
Medicines Management Team (via Nic Baxter)
Mike Maguire
The need for a GP Clinical Lead for Medicines Dr Vik Mittal and Dr 30th Dr Vik Mittal
Optimisation was identified and the Executive Committee Peter Gregory to meet August and Dr Peter voted in agreement for both Dr Vik Mittal and Dr Peter 2016 Gregory Gregory to work with the team on Medicines Waste.
Nic Baxter will present an update to Exec. on Medicines
Waste in a month’s time Present an update to 20th Sept Nic Baxter Exec. 2016
Item 4 – PDS Medical and Fairfield
PDS Medical contracts can be extended. More work is needed in respect of direct access MRI scanning
Papers to go to next Governing Body (Tuesday 27th September 2016)
Tues 27th
Sept. 216
Mike Maguire / Jackie Moran
Operational Item 5 – Intermediate Care Beds
This item had been dealt with outside of the meeting.
No action required at this time
Item 6 – Media Issues
Meg Pugh and Karen Tordoff discussed various current media issues with the Executive Committee.
No action required at this time
E-meeting Item 7 – DSE Policy and Office Safety Procedures DSE Policy - approved Office Safety Policy - approved Health and Safety Policy - approved Fire Safety Policy - approved
Papers approved.
Item 8 – Public Sector Operating Model Review of LCC
Paper for information only
No action required at this time
Item 9 – CQC CLAS Report Final Published
For information only
No action required at this time
Item 10 – Notes from Previous Meeting
Dr Rakesh Jaida advised that he did not attend the last Executive Committee meeting dated 9th August 2016, contrary to the notes
Wrap up
West Lancashire CCG Clinical Executive Committee Action and Notes – 30/08/2016
Discussion and Decisions This week’s actions Due Date
Responsible officer
RAG
Attendees John Caine – Chair Mike Maguire – Chief Officer Paul Kingan – Chief Finance Officer Peter Gregory – GP Executive Lead Rakesh Jaidka - GP Executive Lead Vik Mittal – GP Executive Lead Claire Heneghan – Chief Nurse Debbie Dobson – Practice Manager Jo DeBacker – Practice Manager Doug Soper – Lay Member Greg Mitten - Lay Member Amanda Gordon – Service Re-Design Manager – attended for Item 3 - QIPP oversight and discussion Leslie Jones – Public Health Registrar LCC, Lucinda McArthur and Kathryn Kavanagh attended for Item 4 – Outcome of Staff Wellbeing
Apologies Jackie Moran – Head of Quality Performance & Contracting Bapi Biswas – GP Executive Lead Adam Robinson – Secondary Care Consultant Jack Kinsey – GP Executive Lead
Declaration of Interest
None declared
Strategic and service redesign
Item 3 – QIPP oversight and discussion Discussion took place about the Pain Management Model and how it currently performs in preparation for the commissioning of cost-effective Chronic Pain Services to reduce costs and improve quality and outcomes. The current pathways with services and how they may best and cost-effectively be managed were then discussed. Data analysis and audit are planned in order to facilitate moving the Services forward. A future state mapping process to take place on 20th September
Update to be presented October 2016 Future state mapping process
Tbc 20.09.16
Amanda Gordon Amanda Gordon
Item 4 – Outcome of Staff Wellbeing Leslie Jones presented the outcomes and findings of an assessment carried out by Lancashire County Council Public Health looking at WLCCG’s activity re. the nationally rolled-out Workplace Wellbeing Charter (WWC). The findings delivered positive results and suggestions for the workplace environment and ‘Health at Work’. Future engagements and possible surveys are to be reviewed for future use; Leslie will speak to Smita Shetty to move this forward.
Leslie Jones to contact Smita Shetty
Sept. 2016
Smita Shetty to engage with Leslie Jones when he is in contact
Operational Item 5 – Stop the Clock
Paul Kingan provided an update on the ‘Stop the Clock’ project to take place at the end of September. It has been developed as a working tool to create and stimulate financial awareness for staff and wider WLCCG members on how, when and why the WLCCG spends money at any given ‘moment’ in time. Staff participation is widely encouraged.
E-meeting Item 6 – Policies for Comments
Cosmetics Policy Assisted fertility Spinal Cord Stimulation
Further detail, data and information has been requested in order to make fully-informed comments and decisions on key policies and procedures. Policies are in line with those Lancashire-wide
Paul Kingan to request the Business Analysts to collate data and information on WLCCG policies and procedures Paul Kingan to provide a summary of what information about primary care is currently available.
13th Sept 2016 13th Sept 2016
Paul Kingan Paul Kingan
Item 7 – WLCCG E&I Quarterly Report Noted and read
Item 8 – Notes from Previous Meeting Dr Rakesh Jaidka’ s name was spelt incorrectly in the previous meeting’s notes. Dr Jaidka advised that he did attend the meeting on 9th August, contrary to the minutes.
Hot Topic Item 9 – Patient Risk by Generic to Branded Switching This item will be deferred to the next Clinical Executive
Committee
Wrap up
West Lancashire CCG Clinical Executive Committee Action and Notes – 06/09/16
Discussion and Decisions This week’s actions Due Date
Responsible officer
RAG
Attendees In attendance for - Item 3 In attendance for – Items 5 and 8
John Caine – Chair Adam Robinson – Secondary Care Consultant Bapi Biswas – GP Executive Lead Claire Heneghan – Chief Nurse Debbie Dobson – Practice manager Doug Soper – Lay Member Jack Kinsey – GP Executive Lead Jackie Moran – Head of Quality Performance & Contracting Jo DeBacker – Practice Manager Joanne Kane – Admin Officer Mike Maguire – Chief Officer Paul Kingan – Chief Finance Officer Peter Gregory – GP Executive Lead Rakesh Jaidka - GP Executive Lead Vikul Mittal – GP Executive Lead Amanda Gordon – Service Redesign Manager Dawn Moody – Contracts manager Matt Greene – Finance manager Nicola Baxter – Head of Medicines Optimisation
Apologies Greg Mitten – Lay Member
Declaration of Interest
John Caine, Bapi Biswas and Rakesh Jaidka declared an interest in Item 4 Improving Patient Care in Anticoagulation
QIPP oversight and discussion
Item 3 – The big MSK debate Peter Gregory presented the slides which are to be shown at the next Membership meeting on September 14. The aim on the day will be to ensure that the Membership council is fully informed and able to give their recommendation on the future of the MSK redesign. In order to ensure that the membership is fully informed about the options on how to proceed with MSK redesign. This item will be discussed in debate form.
Discussion followed on the content of the slides, it was agreed that GPs need to understand what the proposed changes would mean for them on a day to day basis. The slides will now be amended to fully capture all the information that Membership will need to make their recommendation.
Strategic and service redesign
Item 4 – Improving Patient Care in Anticoagulation (IPCA) John Caine, Bapi Biswas, and Rakesh Jaidka declared an interest in this item. The chair was passed from John Caine to Mike Maguire for the duration of the item. The chair decided that the interest was significant but not fundamental and that John, Bapi and Rakesh could stay in the room and take part in the discussion but not vote. Adam Robinson declared a past involvement with Pfizer,
and made this known to the Executive Committee for transparency. As this is not within the past five years it was decided by the chair that this did not constitute a conflict of interest, therefore Adam was allowed to take part in the discussion. Amanda Gordon presented a paper regarding reducing AF related strokes. The Exec Committee was asked to approve submitting a letter of support in principle for a funding bid for this pilot in order to not miss the boat for the application. More work is needed before a final decision to support could be made. Discussion followed on whether this any benefit for patients in the area. It was considered that it would be beneficial and cost effective in the long term if patients received the right intervention at the right time. It was considered possible that NOAC prescribing would increase. Assurance was sought that any action is compliant with commercial sponsorship policy. A vote took place and it was agreed by all allowed to vote to supporting the initial application in principle.
Operational Item 5 - Reducing Spend on prescribing update The chair passed from Mike Maguire back to John Caine. Nicola Baxter gave the Committee an update on the Medicines waste programme. By the end of the week the Comms strategy will be signed off. The training for practice staff will also be signed off this afternoon. There will be a cost for postage that has been agreed, this
could be significant as there are a considerable number of the population on repeat prescriptions. Discussion took place on the barriers to success with the programme and Nicola Baxter assured the Exec Committee that the Medicines optimisation team are working hard to mitigate risks and overcome barrier. It was also acknowledged that all practices need to be onboard for the programme to be equitable and consistent. Both the Exec Committee and Membership will continue to be informed of progress.
Discussion with practices that have not committed to the programme will take place.
13.9.16
Debbie Dobson and Peter Gregory
E-meeting Item 6 - Membership agenda The draft agenda was discussed in detail and will be amended accordingly.
£5 per head to be standardised and a proposal drafted for the October Membership.
13.10.16
Jackie Moran and John Caine
Item 7 - Notes from Previous Meeting The notes were agreed as a correct record. It was requested that care is taken to capture full detail in our minutes.
Hot Topic Item 9 – Patient Risk by Generic to Branded Switching Bapi Biswas raised this topic for discussion, the concern voiced is that a lot of time can be spent switching medication. Also a lot of information is presented to consider and that perhaps the time spent on this out-weighs the saving made. Overall it was considered that even small savings are beneficial and add up to greater gain in longer term.
Nicola Baxter also suggested that patients have not made complaints regarding switches. It was agreed to ask OptimiseRx to provide a report on how messages are actioned and to continue to communicate the message of the benefits of this.
Wrap up
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WEST LANCASHIRE COMMUNITY SAFETY PARTNERSHIP HELD: 13th July 2016 Commenced: 6.00 pm Finished: 7.40 pm PRESENT: David Tilleray - WLBC (CSP Chairman) Andrew Hill - WLBC Cliff Owens - WLBC Gareth Dykes - Ormskirk Magistrates Bench / PACT Steve Mahon - WLBC June Chessell - Lancashire Constabulary Fay Sherrington - Edge Hill University Matt Hamer - Lancashire Fire and Rescue Alan Carr - Downholland Parish Council Jackie Hill - Liberty Centre Liz Jennings - Discover D&A Recovery Services Jill Halliwell - Lancashire Constabulary County Councillor Fillis - LCC Councillor Wright - WLBC County Councillor Gibson - LCC Councillor Furey - WLBC Michelle Dacre - Cumbria and Lancashire CRC 1. WELCOME AND INTRODUCTIONS
The Chairman welcomed colleagues to the meeting and introductions were made. 2. APOLOGIES
Apologies for absence were received from: Bill Hancox, Robert Ruston, Della Heaton, Eleanor Maddocks, Greg Mitten,
3. MINUTES OF LAST MEETING/MATTERS ARISING
The minutes of the last meeting were agreed as a true and accurate record. Andrew Hill confirmed that comments were put forward from the CSP and the Council in response to the Consultation on the Listing of Domestic Violence Cases in Cumbria and Lancashire which were previously discussed under AOB.
4. PERFORMANCE MONITORING
The Chairman, David Tilleray, invited partner agencies to provide a verbal overview of current performance.
Inspector June Chessell provided the Partnership with an overview of police performance. Inspector Chessell advised that from August 2016 West Lancashire will benefit from the deployment of 9 new PCSO’s. Inspector Chessell continued by advising that West Lancashire has a projected increase of 13.7% against the category ‘All Crime’ for 2016/17 but added performance remains strong in key areas
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including domestic, none domestic burglaries, robberies and vehicle crime which have all recorded decreases in comparison with the previous year. Inspector Chessell advised that we are recording increases in volume crime including ASB and criminal damage. Sexual offences are also recording increases and this includes the distribution of indecent images on social media platforms which have a high detection rate. Assault with less serious injury continues to record increases and it has been previously been identified that this is as a result of changes to recording procedures.
Councillor Furey raised a question with regards to the problem of motorcycle nuisance which is a continuing issue of concern for the community. Inspector Chessell advised that the Police had recorded a spike in reports of motorcycle nuisance and introduced a number of tactics to address the issue including Operation Spike which has a number of facets such as linking in with Trading Standards and delivering education talks in the local schools. The CSP have also provided funding for the installation of Section 59 signage in identified key areas to assist in prevention and enforcement.
Steve Mahon provided an overview of performance categories on behalf of the ASB Team. Steve advised that over the first quarter five tenants gave up their properties before court hearings began. Actions were taken against 3 tenants for drugs offences and two for serious ASB. Steve continued by providing an overview of each of the performance categories which were including in the meeting pack.
Matt Hamer provided the Partnership with an overview of performance on behalf of Lancashire Fire and Rescue Service. Matt referred the Partnership to the comprehensive report contained within the meeting pack and provided a brief summary of each of the key performance areas. Matt advised that overall incident numbers within the borough are down on the previous year’s total with the largest reductions recorded in accidental dwelling fires and anti-social behaviour fires. Matt advised that the team continue to be proactive in carrying out home fires safety checks and targeting vulnerable people and rural areas. Matt advised that although ASB fires are down there was a spike in Skelmersdale South due to one individual who was responsible for setting wheelie bin fires and an arrest was made. Councillor Wright outlined discussions within the Council to address logistical problems for storing wheelie bins where access to the back of properties is problematic. Councillor Furey highlighted some of the challenges residents come against particularly with regards to having no rear access to properties. Councillor Furey added that the wheelie bin stickers with safe storage and advice are good ideas but also emphasised the need for residents not to leave bins outside of the collection date. Liz Jennings provided the Partnership with an overview of performance on behalf of Discover Drug and Alcohol Services. Liz discussed the performance figures provided in the meeting pack and highlighted the slight increase in heroin presentations and misuse of prescribed drugs. Liz also advised that performance data is showing an early indication that cannabis users are also using spice which is a synthetic drug. Liz advised that service is monitoring the use of drugs that were previously described as ‘legal highs’ and Inspector Chessell also emphasised this an area of business the police are monitoring and are interested in ambulance and accident and emergency data in this regard.
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Liz provided the Partnership with a comprehensive update against the report which was contained in the meeting pack. Jackie Hill provided a comprehensive overview of the performance data on behalf of the Liberty Centre. Jackie also highlighted the current consultation event being run by LCC on the proposals to withdraw supporting people funding which will impact significantly on the Liberty Centre and Women’s refuge supporting people service which is currently funded by LCC.
County Councillor Julie Gibson advised that a committee has been set up at Lancashire County Councillor to consider the implications of the proposed savings and lobbying has been done and recommendations made to mitigate the impact of the proposed savings on refuge provision.
The Chairman thanked colleagues for providing an update against their performance indicators.
5. CSP FUNDING UPDATE
Andrew Hill provided the Partnership with an update against the CSP’s funding allocation for 2016 / 17. Andrew advised that the total allocation received for 2016 / 17 is £19,000. Andrew advised that a number of schemes have already been agreed and proceeded to provide a breakdown of the funding allocation which included: -
• PCC: £10,000 available for funding proposals against CSP and Police and Crime Plan Priorities. This is partially committed with schemes agreed including section 59 signage to deter motorcycle nuisance and funding bids submitted for consideration, including a CSE Education Package.
• PCC: £2,000 for delivery of a domestic abuse campaign aimed at friends and families of victims {committed}.
• WLBC EMT: £2,000 contribution towards the delivery of 12 Community Action and Engagement Events {committed}.
• WLBC: £3,000 specific allocation for the delivery of the Go4IT Event {committed}.
• WLBC: £2,000 specific allocation against Fresher’s Week. {committed}.
Andrew also invited CSP colleagues to submit suggestions for funded projects that will support CSP priorities. The current funding proposals for 2016 /17 were agreed by the Partnership.
6. COMMUNITY SAFETY PARTNERSHIP PLAN 2016-2019
Cliff advised that the Crime and Disorder Act requires Local Authorities and the police, and other key statutory agencies to work together at borough level to develop and implement strategies for reducing crime and disorder.
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As members of the West Lancashire CSP we are also required to develop a Partnership Plan. Our Partnership Plan has been designed as the delivery mechanism to reduce the threat and harm from identified local and national priorities. The Plan was supported by a full Lancashire Strategic Assessment process and individual Strategic Assessment District Profiles. Through this process carried out in 2015 the following six community safety priorities were agreed: -
• Violent Crime (in particular alcohol related) • Domestic Abuse • Sexual Offences (including child sexual exploitation) • Anti-Social Behaviour (nuisance) • Road Safety • Cross Border Crime / Organised Crime Groups
Cliff advised that the Partnership is responsible for overseeing the local delivery of the above priorities. The Partnership plan also provides an overview of the structure of the Partnership and highlights examples of successful schemes and demonstrates our commitment to partnership working. Cliff stated that the key focus of the plan is to continue to seek balanced solutions to our local issues and provide short, medium and long-term action plans secure sustainable solutions. The commitment to continue to deliver against the CSP’s priorities is evidenced in the Action Plan commencing on page 22. The CSP Plan 2016-2019 was endorsed by the Partnership.
7. SURVEILLANCE CAMERA CODE OF PRACTICE COMPLIANCE CERTIFICATE
Andrew advised the Partnership that the Council recently applied for and was successful in gaining full certification in relation to the Surveillance Camera Code of Practice. The scheme, launched in November 2015, enables organisations complying with the Surveillance Camera Code of Practice to be independently audited providing credibility and transparency to claims of compliance. On the 14th June the Council was audited in relation to compliance with the CoP and was awarded full certification.
Andrew stated that obtaining the full 5 year certification demonstrates the Council’s compliance with the Surveillance Code of Practice and evidences good practice. Certification also provides reassurance to the community that the Council’s public open space CCTV scheme is managed appropriately; the information gathered from the cameras is used in an appropriate manner and in accordance with the Surveillance Camera Code of Practice guidelines.
Andrew also advised the Partnership that the annual CCTV report 2015 / 16 has been completed. Andrew provided an overview of the key highlights which were as follows:-
• CCTV staff were involved in 5110 incidents. • CCTV staff were involved in 337 arrests by Lancashire Constabulary (363
the previous year). • CCTV staff were involved in 525 missing/vulnerable person “events” (499
the previous year).
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• They were also involved in monitoring 656 cash in transit “events” (345 the previous year).
• 1525 incidents were identified by the operators themselves, through their general monitoring (1096 the previous year).
Andrew added that as the number of cameras has increased and also as the operator’s familiarity with the system increases, so some of these figures have increased, from the previous years.
Councillor Wright stated that he was very pleased with the report which is vital for evidencing the outputs delivered by the Council’s CCTV scheme and added that although we can’t measure the prevent element of CCTV, it undoubtedly deters criminality.
8. CROSSING THE LINE
Cliff Owens provided an update on progress with regards to the development of a support package to support the delivery of ‘Crossing the Line’ into secondary schools in West Lancashire. The film was commissioned by the CSP with the overarching aim of developing a product that would assist in deterring young people from becoming involved in organised crime.
Cliff stated whilst the short film will highlight the dangers of organised crime and the consequences of making poor choices we also have a responsibility to ensure young people are more informed on this theme. The support package that will accompany ‘Crossing the Line’ will be delivered by the Constabulary’s Early Action Team. PC Rachel Jackson is currently leading on this element of the project and Rachael has begun the process of establishing contact with the local schools to promote the project with a view to commencing delivery from September 2016.
Councillor Wright stated the ‘Crossing the Line’ is an extremely powerful film and highlighted the excellent partnership working involved in the production of the film. Councillor Wright added that this a true reflection of the positive partnership work that takes place in Skelmersdale as opposed to the recent documentary shown on Grayson Perry programme. Councillor Fury added that it is was a very emotive film that moved many of the audience to tears.
9. ANY OTHER BUSINESS
Fay Sherrington provided a brief update on behalf of Edge Hill University. Fay stated that general complaints over the academic year have reduced and Fay attributed this to the on-going excellent partnership working. Fay added that for the academic year 2016 / 17 the University will have an extra 160 rooms on campus and EHU are also currently looking at the out of hours provision model. Fay advised that EHU has also recently won an award for the standard of accommodation. Michelle Dacre provided the Partnership with an overview of changes introduced by Lancashire and Cumbria CRC with regards to how the service operates in West Lancashire. Michelle confirmed that the service no longer operates out of the building in Skelmersdale High Street. Michelle stated that CRC staff now conduct a high volume of home visits and also when necessary use partner agency premises. Michelle advised that the service is hoping to establish a base at the Ecumenical Centre and discussions are currently being progressed by Sodexo’s legal
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department. Michelle advised that the CRC continue to work closely with NPS to try to iron out any problems since the transition and currently have a centralised hub premises in Preston. The CRC has a supply chain of partners and are looking at new ways of working, which also brings some challenges. Chief Inspector Jill Halliwell introduced herself to the Partnership and provided a brief overview of her role in West Lancashire which is still currently being developed. Jill advised that she is one of nine placed based Chief Inspectors in Lancashire and part of her role will be overseeing and managing Early Action. Matt Hamer provided a brief overview of the ‘Safe Drive Stay Alive’ campaign. Matt advised that ‘Safe Drive Stay Alive’ is a road safety initiative where audiences hear real life stories from the emergency services and families who have been affected by road traffic collisions. The campaign will reach new and pre-drivers in an emotive and hard-hitting way with the aim of influencing behaviour and attitude on the roads.
Matt added that RTA’s are on the rise and it would be good to bring the campaign down to West Lancashire. Fay Sherrington advised that EHU would be open to discussions for the campaign to be delivered directly to students.
10. DATE OF NEXT MEETING
The next meeting of the West Lancashire CSP will be held on Wednesday the 12th October 2016 at 6.00pm in the Council Chamber, at the Main Council Office, 52 Derby Street, Ormskirk, L39 2DF
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Lancashire Health and Wellbeing Board
Minutes of the Meeting held on Monday, 13th June, 2016 at 10.00 am in Cabinet Room 'C' - The Duke of Lancaster Room, County Hall, Preston
Present:
Chair
County Councillor Jennifer Mein, Leader of the County Council
Committee Members
County Councillor Azhar Ali, Cabinet Member for Health And Wellbeing (LCC)County Councillor Tony Martin, Cabinet Member for Adult and Community Services (LCC)County Councillor David Whipp, Lancashire County CouncilDr Sakthi Karunanithi, Director of Public Health, Public Health LancashireLouise Taylor, Corporate Director Operations and Delivery (LCC)Bob Stott, Director of Schools, Education and CareTony Pounder, Director of Adult ServicesCouncillor Bridget Hilton, Central Lancashire District CouncilsMichael Wedgeworth, Healthwatch Lancashire Interim ChairKaren Partington, Chief Executive of Lancashire Teaching Hospitals Foundation TrustSarah Swindley, Third Sector VCFS RepJane Booth, Independent Chair, Lancashire Safeguarding Children's BoardCouncillor Hasina Khan, Chorley Borough CouncilAndrew Bennett, Lancashire North CCGCllr Viv Willder, Fylde Borough CouncilJan Ledward, Chief Officer - Chorley & South Ribble and Greater Preston CCGJanet Thomas, Lancashire Care Foundation TrustSharon Martin, East Lancs Clinical Commissioning Group
Apologies
County Councillor Matthew Tomlinson
Cabinet Member for Children, Young People and Schools (LCC)
Dr Tony Naughton Fylde & Wyre CCGGraham Urwin NHS England, Lancashire and Greater ManchesterDavid Tilleray Chair West Lancs HWB Partnership
1. Appointment of Chair
Resolved: that in accordance with the Terms of Reference, County Councillor Jennifer Mein, as the Leader of the County Council, is appointed as the Chair for the remainder of the 2016/2017 municipal year.
2. Appointment of Deputy Chair
Resolved: that Dr Tony Naughton is appointed as the Deputy Chair of the Board for the remainder of the 2016/2017 municipal year.
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3. Membership and Terms of Reference of the Board
A report was presented in connection with the membership and Terms of Reference of the Board.
Resolved: that the Board accept the current Terms of Reference and Membership.
4. Welcome, introductions and apologies
Apologies for absence were noted as above.
Replacements were as follows:
Janet Thomas for Dee Roach (Lancashire NHS Foundation Trust)Sharon Martin for Mark Youlton – East Lancashire CCGJan Ledward for Dr Gora Banghi – Chorley and South Ribble CCG and Dr Dinesh Patel – Greater Preston CCG
5. Disclosure of Pecuniary and Non-Pecuniary Interests
There were no disclosures of interest in relation to items appearing on the agenda.
6. Minutes of the Last Meeting
The Chair informed the meeting that the Better Care Fund evaluation that was due to come to this meeting, be brought to the next meeting as Paul Robinson and Mark Youlton were unable to attend this meeting.
Resolved: i) that the minutes of the meeting held on 28 April 2016 are confirmed as an accurate record.
ii) that the BCF evaluation report is on the next agenda on 2 September 2016.
7. Director of Public Health Annual Report
Dr Sakthi Karunanithi gave a detailed account of the report Securing our Health and Wellbeing, highlighting key points.
The report is aimed at all partnerships and for them to raise awareness of it with the public.
The Board felt the report was excellent and it was clear that partnership working had to be effective in order to deliver the health outcomes needed. The report should also link in with the Sustainability Transformation Plan (STP).
It was noted that telecare/teleaccess to clinicians from the local hospital is available in parts of Lancashire.
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Sakthi agreed to update the Board regularly on progress on the report.
Resolved: that the Board noted the Director of Public Health's Annual Report and agreed to support the recommendations within it.
8. Sustainability and Transformation Plan
Sam Nicol, Healthier Lancashire was welcomed to the meeting.
The purpose of the report was to provide the HWBB with an update on the development of the Lancashire and South Cumbria STP. The original NHS England guidance regarding the STP which was published in December 2015, advised that STPs are approved by the HWBB prior to 30 June 2016 submission deadline. However, on Friday 20 May 2016, NHS England issued new guidance as follows:
“The plans that you submit on 30 June will form the basis for a face to face personal conversation with the national leadership in the NHS throughout July, and will be a key part of a subsequent managerial process to inform decisions about the geographical targeting of growth in the intervening years to 2020. Your submissions will therefore be work in progress, and as such we do not anticipate the requirement for formal approval from your boards and/or consultation at this early stage. We will, however, wish to be assured that your plans reflect a shared view from your leadership team where possible, based upon the needs of patients and taxpayers, and a robust plan to engage more formally with boards and partners following the July conversations.”
Sam also spoke about the meeting that had taken place recently with Councillors and County Councillors from Lancashire. One clear message that came from the session was that we cannot hold on to what we have – we have to have more joined up working and provide what works and what there is a demand for, within the resources available. The same message came from a session with Blackburn with Darwen also.
Local Delivery Plans (LDPs) have to be accountable to the delivery of local outcomes.
The public need to be aware of what is going on and it needs to be communicated in plain English.
The STP needs to focus on financial sustainability and get people's minds to look to the future and how it will work.
There needs to be a communication plan for the STP for County Councillors, Chief Executives and District HWB Partnerships so they can feed into other groups along with the LDPs.
It is now expected that the third, and final version of the STP will be required in October 2016. The Case for Change will be utilised at pace to agree a future system model and to mobilise the work required, with a strong focus on delivery of our ambitions set out in the STP, and the 10 priority areas.
Sounding Boards will be set up which will include politicians who will meet in September 2016.
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Resolved: that the Board:
i) noted the contents of the reportii) provided relevant comments on the Lancashire and South Cumbria
STP
Sam was thanked for her report.
9. Closure of Chorley A & E
Karen Partington tabled and gave a detailed description to the attached Briefing Paper to the HWBB and brought attention to the fact that this item had been discussed as set out in the agenda papers at Health Scrutiny also on a number of occasions.
The Board felt that the public needs to be clearly aware of the position around locums and how that affects the department, when quick decisions are needed.
Karen also expressed her personal thanks for support from various members of the Board around this issue.
10. Lancashire CYP Emotional Wellbeing and Mental Health Transformation
Julie Haywood, Midlands and Lancashire Commissioning Support Unit (MLCSU) and Peter Tinson, Fylde and Wyre Clinical Commissioning Group (CCG) were welcomed to the meeting.
They took the Board through the presentation attached to these minutes.
If anybody wished to receive any district specific information which can be shared with the Children's Partnership Boards then please contact Julie Haywood, email: Julie [email protected] or Peter Tinson, email: [email protected].
The workstream proposals for 2016/2017 are as follows:
Promoting Resilience Improving Access Care of the Most Vulnerable Accountability and Transparency Developing the Workforce
A digital concept called 'Thrive' is currently being scoped out for Lancashire which is a tool which provides:
i) a system overviewii) integrated performance reportingiii) enabling an interactive offer
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It was noted that monthly newsletters and an expanded quarterly newsletter will expand on what is and what is not working. A quarterly report will come back to the Board.
Following on from the CQC Inspection and the issues raised, the Board needs to feel confident that everything that is planned in the transformation covers the concerns expressed by the CQC.
Resolved: that the Board receive a quarterly update on the transformation.
11. Development of Pan Lancashire Health and Wellbeing Board
Sakthi gave a brief insight into the development of a Pan Lancashire HWBB working across three Authorities, Lancashire, Blackburn with Darwen and Blackpool.
A workshop will be held to discuss further development. To include the Third Sector and Local HWB Partnerships in these discussions.
12. Urgent Business
CQC Inspection
The Authority has recently undergone a CQC Inspection. A final report will be available mid-August and will bring it to a future Board meeting.
Resolved: that an item on the CQC Inspection is put on the agenda for a future meeting.
13. Date of Next Meeting
The next scheduled meeting of the Board will be held at 10.00am on Friday, 2 September 2016 in the Henry Bollingbroke Room (formerly Cabinet Room 'D' at County Hall, Preston, PR1 8RJ.
I YoungDirector of Governance, Finance and Public Services
County HallPreston