SAFEGUARDING VULNERABLE ADULTS: A STRATEGIC
FRAMEWORK 2012-2014
Our vision is to ensure that safeguarding vulnerable adults is everybody’s business
To achieve this we will commission services to promote and protect the human rights of each
individual, their independence and their well-being. And we will secure assurance, from all
service providers that we commission from on behalf of the population of Oldham, that
any adult identified as being at risk is effectively safeguarded against abuse, neglect,
discrimination, embarrassment or poor treatment, and is treated with dignity and respect.
Tanya Roberts
Safeguarding adults strategic framework
CONTENTS
1.
Introduction .................................................................................................................................................................... 3
2.
Background ..................................................................................................................................................................... 3
3.
Safeguarding Vulnerable adults: a strategic Framework .............................................................................................. 4
4.
Governance ..................................................................................................................................................................... 6
5.
Work Plan 2012-2014 Delivering the strategy ............................................................................................................... 7
6.
References .................................................................................................................................................................... 13
Safeguarding adults strategic framework
1. INTRODUCTION
Oldham NHS CCG is committed to working together with all stakeholders to safeguard and promote
the welfare of vulnerable adults. This framework underpins the development of the safeguarding
vulnerable adults ‘plan on a page’ for the CCG, which scopes our accountability and our assurance
processes, specifies outcomes and identifies mechanisms for delivery.
Prevention and effective responses to neglect, harm and abuse is a basic requirement of modern
health care services. Safeguarding adults involves a range of additional measures taken to protect
patients in the most vulnerable circumstances, patients that are currently defined within No Secrets
(DH 2000) as ‘vulnerable adults’. This may be due to illness, impaired mental capacity, physical or
learning disability or frailty brought about by age or other circumstance.
Safeguarding adults includes:
 Prevention of harm and abuse through the provision of high quality care;
 Effective responses to allegations of harm and abuse in line with local guidance;
 Using learning to improve services to patients
2. BACKGROUND
People have fundamental rights contained within the Human Rights Act 1998. Commissioners as
public bodies have statutory obligations to uphold these rights and protect patients who are unable to
do this for themselves. Other legislation particularly relevant to safeguarding adults includes:
 Equality Act 2010
 Mental Capacity Act 2005
 Safeguarding Vulnerable Groups Act 2006
 Mental Health Act 1983.
 NHS Act 2006
The No Secrets (DH 2000) sets out the standards for the NHS for multi-agency working to safeguard
vulnerable adults and will remain as statutory guidance until at least 2013. Whilst it is the local
authority who is the lead agency, other agencies such as health, police and housing all have
responsibilities with regard to safeguarding vulnerable adults.
More recently, the Department of Health guidance Safeguarding Adults: The Role of
NHS Commissioners (March 2011) sets the expectation that NHS commissioners must work
proactively with all contractors and service providers to ensure safeguarding arrangements are in
place that maintain the safety and well being of those adults who are contractually under the care of
the NHS.
Safeguarding is also central to the quality of care and the NHS Outcomes Framework
(Dept. of Health, 2010), particularly:
 Domain 4: Ensuring people have a positive experience of care.
 Domain 5: Treating and caring for people in a safe environment and protecting them from
avoidable harm.
The Care Quality Commission’s ‘Essential Standards for Quality and Safety’ (2010) sets specific
outcomes for safeguarding and safety as a requirement for registration for all providers of NHS care.
Commissioners have responsibilities to address failures of care in addition to the responsibilities of
the CQC. Where the CQC take enforcement action, Oldham CCG recognises that we have a key role
in managing the impact this may have on the local health economy.
Safeguarding adults strategic framework
3. SAFEGUARDING VULNERABLE ADULTS: A STRATEGIC FRAMEWORK
The framework is illustrated overleaf.
Safeguarding adults strategic framework
Key Objectives
Governance
To demonstrate strong partnership working and collaborative working with
the Local Authority
To demonstrate that safeguarding adults is a fundamental part of the
commissioning strategy.
To provide assurance that all organsiations commissioned to provide
services for the population of Oldham are meeting mandated service
standards
To provide strong leadership (strategic and operational) across the health
economy and with established partnerships
To support and embed innovation and continuous quality improvement
across the health economy and within established partnerships
A lead CCG Governing Body member will have responsibility for
safeguarding vulnerable adults and the Mental Capactity Act
The CCG will discharge its statutory functions contributing effectively to
the LSAB, and any relevant sub groups and multi agency approaches
The CCG Governing body will receive a quarterly safeguarding vulnerable
adults report and will be alerted to areas of concern through the
exception reporting mechanism
The Designated Nurse will provide strategic and clinical leadership and
expertise to the Governing Body
Safeguarding vulnerable adults: our
strategic framework
Mechanisms
Ensuring that safeguarding vulnerable
adults is everybody's business
Refinement and development of monitoring systems for assurance in
relation to the quality of service provision including the development of
contractual levers
Refinement and development of monitoring systems for education and
training across all organisations and member practices
The support of innovation and continuous quality improvement in
providers through the use of CQUIN and other incentives
Development and education of Governing Body members
Regular self assessment and review of our performance
Safeguarding adults strategic framework
Outcomes
We will be able to demonstrate that we have discharged our statutory
duty and are compliant with nationally mandated standards and directives
Partner agencies will state that we have fully engaged with partnership
working and supported innovation across Oldham
We will able to demonstrate through an annual 'pen portrait' of
safeguarding vulnerable adults across all health providers that we have a
grip on and have a role in directly influencing the quality of provision and
that safeguarding is everybody's business
We will be able to demostrate that we have supported service user
engagement and member pratice engagement with safeguarding
vulnerable adults in Oldham
4. GOVERNANCE
The Governance and associated relationships (
are illustrated below:
Governing
Body
HWB
LSAB
) with regards to Safeguarding Vulnerable Adults
Quality Forum
Safeguarding
working group
ERFPQ
Contract
monitoring
infrastructure
Denotes governance structures with ACCOUNTABILITY
Denotes governance structures with LEADERSHIP
Denotes Governance structures with ASSURANCE
Safeguarding adults strategic framework
NCB LAT
CPAG
5. WORK PLAN 2012-2014 DELIVERING THE STRATEGY
The work plan has been developed both in light of the new clinically led commissioning arrangements
and the opportunities that these have brought specifically in influencing continuous quality
improvement and innovation, but also in terms of what we know already about safeguarding
vulnerable adults in Oldham and the outcome of a detailed self assessment undertaken in September
2012.
We intend to benchmark our performance and underpin our work plan using the following principles
as described in the the Department of Health guidance Safeguarding Adults: The Role of
NHS Commissioners (March 2011).
Empowerment: The presumption of person led decisions and consent
Partnerships: Local solutions through services working with their communities
Accountability: Accountability and transparency in delivering safeguarding
Leadership: The clinical leadership across the health economy and commissioned service
footprint
Proportionality: Proportionality and least intrusive response appropriate to the risk presented
Protection: Support and representation for those in greatest need
Prevention: Prevention of neglect harm and abuse is a primary objective.
Assurance: The implementation of the above principles across the health economy
Safeguarding adults strategic framework
Safeguarding adults strategic framework
Area
Issue
Action
Accountability To
be Evidence required
completed by
Accountability
Overall accountability
A lead member of the CCG Governing Body will have
overall accountability for safeguarding vulnerable
adults and the Mental Capacity Act
The CCG will write and agree an SLA for the services
of a Designated Doctor from a local provider Trust
The CCG will include the role of Designated Nurse for
Safeguarding Vulnerable Adults in its management
structure thus securing capability/ capacity to provide
specialist expertise for safeguarding adults (i.e.
Leading investigations, clinical leadership across the
local economy)
The CCG will formally define the governance
structures associated with safeguarding within its
quality framework
The CCG will ensure that members of the Governing
Body are educated about their statutory duties and
responsibilities to ensure they are capable to respond
The CCG will ensure that it has an agreed
mechanism for assuring itself that it has discharged
its statutory responsibilities in the form of an annual
report
The CCG will strengthen processes and systems to
ensure
effective
contribution
to
partnership
arrangements.
Governing Body
30 September
2012
Minutes of Governing
Body
Governing Body
31st
October
2012
30 September
2012
The SLA and service
reviews
The CCG structure
Governing Body
30th November
2012
The
CCG
strategy
Governing body
31st March 2013
Governing Body
31st March 2013
Safeguarding
working group
31st March 2013
Education programme
and
evaluation
of
members
Governing
Body
Forward plan
and
annual
report
completion
Evidence of integration
of governing body and
member practices in
LSCB priorities
The CCG will support the PCT close down
governance arrangements by supporting the
development of a knowledge repository/legacy
document for all safeguarding assurances in
preparation for ongoing Governing Body assurance,
Internal Audit and inspections from external bodies.
A GP Governing Body member will be delegated as
lead GP for safeguarding vulnerable adults and the
Mental Capacity Act
The CCG will ensure that learning associated with the
lessons and good practice from serious case reviews,
ERFPQ
31st March 2013
Submission of legacy
document and quality
handover documents
Governing Body
1st September
2012
Minutes of Governing
Body
Quality Forum
31st March 2014
Evidence of regular
communication
and
Designated Doctor
Designated Nurse
Governance structures
Statutory duty
Safeguarding
transition
Leadership
Leadership
in
General Practice
Safeguarding adults strategic framework
in
the
across
Governing Body
quality
Leadership across Oldham
Prevention
significant incident learning processes, local and
national enquiries are shared across member
practices
The CCG will promote governance arrangements
between organisations to include public, private,
community and voluntary organisations and promote
partnership working through membership/association
with the LSAB
The CCG will ensure that all health organisations with
whom the CCG has commissioning arrangements
have links with the LSAB and that there is appropriate
representation at an appropriate level of seniority; and
that health workers contribute to multi-agency
working.
Providers will be required to inform the CCG of any
gaps in provision of services which could place
vulnerable adults at risk within their organisation.
Providers have a contractual requirement to inform
the CCG of untoward incidences relating to
vulnerable adults.
The CCG will provide clinical leadership for
developmental forums across Health economy & in
partnership with Local Authority
The CCG will ensure representation within and
support for all initiatives related to prevention
prioritized by the LSAB.
The CCG will review the requirements of Prevent and
ensure that the infrastructure is in place to provide the
necessary assurance both in terms of itself and of its
providers
The CCG will ensure that commissioning decisions in
respect of adult care placements (e.g. in care homes,
nursing homes or independent hospitals) are based
on knowledge of standards of care and safeguarding
concerns
The CCG will implement standards for safeguarding
vulnerable adults within its member practices
Ensures that service
plans/specifications/contracts/invitations to tender etc.
include reference to the standards expected for
Safeguarding adults strategic framework
training with practices
Governing Body
31st March 2014
Evidence of effective
partnership
working
and involvement with
LSAB/HWB
Safeguarding
Working Group
31st March 2013
Evidence of effective
partnership
working
and involvement with
LSAB/HWB
Contract
Monitoring
infrastructure
31st March 2014
Quality Forum
31st March 2014
Safeguarding
working group
31st March 2014
Safeguarding
working group
31st March 2013
Evidence of exception
reporting from contract
monitoring processes
and
action
plan
monitoring to support
mitigation
Evidence of integration
into
LA
training,
support to LSAB and
sub committees
Evidence of clinical
support to LSAB and
sub committees
Review report
ERFPQ
31st March 2013
31st March 2014
Safeguarding
working
group/CPAG
Safeguarding
Working
Group/contract
30th September
2013
31st March 2014
Quarterly
exception
profile
of
provider
landscape/exception
reporting direct to
Governing Body
Profile of assurance
from general practices
Self assessment audit
described in annual
report
safeguarding vulnerable adults
Protection
Adult care placements
Proportionality
Mental Capacity Act
Empowerment
Patient
and
involvement
Carer
Partnership
Joint
Strategic
Assessment
Needs
Assurance
Contractual arrangements
will include clear service
standards for safeguarding
and promoting children’s
welfare
in
all
commissioning
arrangements. Section 11
Safeguarding adults strategic framework
The CCG will support the provision of training and
development for GPs and Practice Nurses on early
intervention
The CCG will take measures to demonstrate
compliance with the PREVENT agenda through
development of its member practices and also
through the assurance processes it uses with its
Providers
The CCG will work collaboratively with the local
authority in quality assuring the care in adult care
placements including the sharing of information where
there are multiple concerns that are indicative of early
warning signs.
The CCG will ensure that any system and processes
that include decision-making about an individual
patient (e.g. funding panels) takes account of the
requirements of the Mental Capacity Act 2005; this
includes ensuring that actions and decisions are
documented in a way that demonstrates compliance
with the Act.
The CCG will ensure routine involvement of service
users and their carers in commissioning plans and
service reviews
The CCG will contribute to the Joint strategic needs
assessment ensuring that it, with Local Authority
partnership and stakeholder collaboration routinely
focuses on vulnerable communities and adults;
outputs are used to inform commissioning strategy
and joint health and wellbeing plan
The CCG will require Providers to provide evidence
that staff have training at the appropriate level and
are aware of the guidance in relation to information
sharing.
The CCG will develop monitoring systems of
safeguarding training and development for all
providers including member practices
monitoring
infrastructure
Safeguarding
working group
30th September
2013
Training programme
and evaluation
ERFPQ
30th September
2013
Training programme
and evaluation
Safeguarding
working group
31st March 2103
31st March 2014
Exception profiling of
providers
Governing Body
31st March 2013
31st March 2014
Governing
Body
papers/annual report
ERFPQ
31st March 2013
31st March 2014
Governing Body
31st March 2014
Implementation of the
carers strategy and
review. Annual PPE
report
Clinical
Programme reviews
JSNA/JSNA
reviews/HWBB papers
Contractual
monitoring
infrastructure
31st March 2013
Contract performance
report /audit
Safeguarding
working group
30th September
2013
Audit report
of the Children Act 2004
makes it clear that services
provided by or contracted
by the CCG abide by the
same regulations in respect
to safeguarding children.
Safeguarding adults strategic framework
Providers will be required to demonstrate that they
are compliant with the following standards and in
addition the North West Safeguarding assurance
framework (until 2013/14)
-CQC essential standards
-related legislation (including Mental Capacity Act,
Mental Health Act, Deprivation of Liberty Safeguards,
Safeguarding Vulnerable
Groups Act)
-Compliance with ‘Arrangements to Secure Children’s
and Adult Safeguarding in the future NHS - The new
accountability and assurance framework’ 2012
The CCG will ensure that each provider implements
the recommendations of Serious Case Reviews
(SCR).
The CCG will ensure that safe recruitment and vetting
procedures are followed within each Provider
organization and in member practices and itself along
with the procedures in relation to the management of
allegations against staff
The CCG will develop a systematic approach to
ensuring that provider assurance in relation to
safeguarding is evaluated through site visits,
walkarounds, clinical audit, observational work and
spot checks
The CCG will undertake a review of the safeguarding
elements of all its contracts
Contractual
monitoring
infrastructure
31st March 2013
31st March 2014
Contract performance
report /audit
Safeguarding
working group/
ERFPQ
Contractual
monitoring
infrastructure
31st March 2014
Evidence of monitored
and assured action
plans
Contract performance
report /audit
Safeguarding
working group
31st March 2013
31st March 2014
Safeguarding
working group
31st March 2013
31st March 2013
31st March 2014
Plan of walk arounds
Assurance profile with
actions and
recommendations
6. REFERENCES
Care Quality Commission (2010). Essential Standards of Quality and Safety. London: Care Quality
Commission.
Care Quality Commission. (2012). Review Of Learning Disability Services. Available:
Http://Www.Cqc.Org.Uk/Public/Reports-Surveys-And-Reviews/Themed-Inspections/Review-LearningDisability-Services. Last Accessed 27th June 2012.
Department Of Health (2012). The Functioning Of Clinical Commissioning Groups. London:
Department Of Health.
Department Of Health (2011). The NHS Outcomes Framework 2012/13. London: Department Of
Health.
Department Of Health (2011). The Operating Framework for the NHS in England 2012/13. London:
Department Of Health.
Department Of Health (2012). Using the Commissioning For Quality and Innovation (CQUIN)
Payment Framework: Guidance on New National Goals for 2012-13. London: Department Of Health.
HM Government (2010). Working Together To Safeguard Children: A Guide to Inter-Agency Working
To Safeguard and Promote the Welfare of Children. Nottingham: DCSF Publications.
Home Office (2011). Multi-Agency Statutory Guidance for the Conduct of Domestic Homicide
Reviews. London: The Stationery Office. .
Monitor (2010). Quality Governance Framework. London: Monitor.
National Quality Board (2012). Maintain Quality During The Transition: Preparing For Handover.
London: National Quality Board.
NHS Commissioning Board (2012). Clinical Commissioning Group Authorisation: Draft Guide for
Applicants. London: NHS Commissioning Board.
NHS Commissioning Board (2012). Clinical Commissioning Group Authorisation: Draft Guide For
Assessors Undertaking Desk Top Review. London: NHS Commissioning Board.
Safeguarding adults strategic framework