APPROACH TO QUALITY IMPACT ASSESSING PROVIDER COST IMPROVEMENT PLANS (CIPs) Version: 0.2 Ratified by: Date Ratified: Name of originator/author Nikki Livermore, Quality and Patient Safety Manager Date Issued : Date Implemented : Next Review Date: Target Audience: CCG staff and Board members Policy Date: Review Date: Page 1 CONTENTS Contents 1. INTRODUCTION Page No. Page 3 2. PURPOSE Page 3 3. DEFINITIONS Page 3 4. ROLES AND RESPONSIBILITIES Page 3 5. POLICY PROCEDURAL REQUIREMENTS Page 4 6. MONITORING COMPLIANCE Page 7 7. ASSOCIATED DOCUMENTATION Page 8 8. REFERENCES Page 8 9. LIST OF STAKEHOLDERS CONSULTED Page 8 10. EQUALITY IMPACT ASSESSMENT (ANALYSIS OF THE EFFECTS ON EQUALITY) Page 8 11. VERSION CONTROL Page 9 Policy Date: Review Date: Page 2 1 INTRODUCTION The Francis Report (2012) identified how Mid Staffordshire Hospital focussed on finance and how little attention was paid to the potential impact of proposed savings on quality and safety. Following Mid Staffordshire, there has been an increased focus on the impact on quality of Cost Improvement Programmes. The Planning guidance ‘Everyone Counts: supporting Planning for Clinical Commissioning Groups 2013/14 also emphasises the need for commissioners to scrutinise provider cost improvement plans (CIPs) plans, to seek assurance and ensure the on going monitoring of risks. The National Quality Board (July 2012 to March 2013): HOW TO: Quality Impact Assess Provider Cost Improvement Plans guidance recommends a multidisciplinary approach to the assessment and sign off of provider CIPs through the development of a ‘Star Chamber’. Although the CCG have not adopted the ‘Star Chamber’ approach in its entirety, the guiding principles, promoting systematic exploration of quantitative and qualitative intelligence and encourages the orderly triangulation of information to help assess the quality impact of CIPs. 2 PURPOSE The following document will outlines the approach that NHS Basildon and Brentwood Clinical Commissioning Group (the CCG) will take to Quality Impact Assess the delivery of Cost Improvement Plans and QIPP plans of Provider organisations with whom the CCG directly commissions services. 3 DEFINITIONS The CCG The ‘CCG’ is defined as NHS Basildon and Brentwood Clinical Commissioning Group. The Provider The Provider is defined any providers from whom BBCCG directly commission services 4 ROLES AND RESPONSIBILITIES CCG Board It is the collective responsibility of the Board to ensure that quality impact assessing the CIP’s is not a one of application, but will require attention throughout the period of cost improvement once plans have been accepted. Any work generated by provider boards should be used to inform the external assurance process rather than taken at face value. The risk of false assurance is too great unless actual scrutiny by the CCG board or its committees takes place. Patient Safety and Quality Committee (PSQC) The PSQC will oversee the CIP process detailed in this document and will triangulate both soft and hard intelligence to evaluated the QIA process Policy Date: Review Date: Page 3 Chief Officer (CO) /Chief Nurse (CN) The Chief Officer will be required to endorse the approach outlined in section 5 and support the Chief Nurse to work collaboratively with other key colleagues such as board level clinicians and the Chief Finance Officer to complete the assurance process. Provider Responsibility It is recognised that the quality impact assessments of CIP’s is the primary responsibility of provider boards. Providers will manage their CIP process through implementing the four stages outlined by Monitor; 5 Identify potential CIPs Assess potential impact on quality and cost approve plans assess actual impact on quality POLICY PROCEDURAL REQUIREMENTS CCG Approach To assist the CCG in satisfying that providers have adequately designed and applied CIPs with due regard to quality, a ‘Star’ type ‘Chamber’ will be established using appropriately an attended existing CCG Committee, namely, the Patient Safety and Quality Committee (PSQC) The CCG will ensure that as part of the process for overseeing CIPs, it will: Operate within the standards set out in the NHS Early Warning Systems publication Be clinically led but not unduly dominated by clinicians – quality is everyone’s business Involve a broad range of contributors Ensure all contributions are valued and have currency Provide a solid basis for peer review and critique which supports open and constructive challenge Facilitate comparative analysis of information and trends to create an informed picture based on facts and appropriate judgement, including consideration of soft intelligence Enable exploration of the inter-relationship between variables and the resultant testing of hypotheses i.e. using data/intelligence to identify lines of enquiry, cues for action or prompts for intervention Offer a transparent and timely process for the validation of plans in the context of assumptions applied by providers Challenge the efficacy of CIPs in the context of any as possible unintended or adverse consequences for patient care Provide a reliable audit trail for future reference when reviewing CIPs, the CCG should consider whether the provider CIPs Policy Date: Review Date: Page 4 reflect the following: Track record of delivery of savings plans – specifically in terms of the proportion of the plans for previous years delivered The relative scale of the CIP in terms of cash value, CIP as a % of turnover (as an indicator of the challenge presented by the scale of the CIP required) and the level of unidentified CIP as an indicator of the level of planning already undertaken Triangulation of available data to ascertain whether the reported numbers align Whether activity, workforce and savings plans are aligned – do the assumptions correlate? Do CIP plans, as presented to the provider board, contain sufficient granularity? Has each CIP scheme been risk assessed and RAG rated? Has the risk assessment been reviewed for impact on staff, impact on quality of services, ability to deliver, ensuring that all 3 areas have been separately assessed? Evidence of comprehensive risk assessment process on the quality impact assessment completed for schemes with a potential impact on quality. This should include assessment of schemes in terms of patient experience, safety and clinical outcomes Have organisations used the Monitor Quality Assessment Framework to quality assure their CIPs? Evidence that unintended consequences have been assessed and mitigating actions clearly expressed for the risks identified Have the trust medical and nurse directors explicitly and formally signed off the CIP? Has the provider board formally approved the detail and risk assessment of the CIP? Is there sufficient level of transparency with regard to public, staff and patient engagement? Delivery of the CCG approach The CCG will follow a 3 stage approach; Stage one At the outset of the financial year, the CCG’s will create a baseline against which the CIP can be judged as plans unfold in the year. Stage Two a) For initial evaluation the Chief Nurse will, with the provider, review the CIP programme for the following financial year. At this point, a review of the associated QIAs will have been undertaken by the provider. This will include an understanding of which CIPs have been carried forward and those which have not due to failing the QIA. This exercise will be undertaken with access to the Deputy Director of Finance, Director of Nursing and Medical Director of Policy Date: Review Date: Page 5 the Trust should there be any concerns. b) The Provider will then be invited to present the CIP’s to the CCG. The CCG will use the following prompts (but not limited to) to review the CIPs presented; Has the provider chief executive agreed the governance arrangements and secured board endorsement? Are the medical and nurse directors engaged and leading the process? Is the board reporting regime clear and widely promoted i.e. is there transparency of process? Are the arrangements for providing assurance to the board, commissioners and Monitor in the case of NHS Foundation Trusts, both about the delivery of the CIP and the ongoing validity of the quality impact assessment clear and documented? Is the management team formally engaged and committed to matrix working / information exchange? Are quality impact assessment reports generated and circulated regularly to stakeholders? Are all stakeholders such as Healthwatch, overview and scrutiny committees, social partnership forums briefed and engaged? Are arrangements in place to ensure that quality is assessed as part of monthly performance reviews to ensure integration with finance, workforce and performance assessment? Is there a robust facility for front line staff to confidentially report concerns about CIP schemes and their potential negative impact on quality, patient experience or safety or indeed on staff? Any CIPs assessed by the CCG as high risk will undergo a ‘deep-dive’ to ensure no negative impact to quality of care. Stage Three The CCG will continue with the routine monitoring of performance against plan through the application of performance and patient safety/experience dashboards through the Patient Safety and Quality Committee The provider will share any internal reports about the impact of CIPs on Trust delivery of care. These reports will be taken through the internal governance of the CCG via the Patient Safety and Quality Committee The Chief Nurse will attend the Trust on a quarterly basis thereafter to review and assess any new CIPs and their associated QIAs. To gain assurances around the extent of any negative impact yielded from the implemented CIPs. The quarterly review will include; evidence of provider review of QIA for CIPs assessment of whether there been a drop in performance during the quarter, as measured by the CCG quality dashboard and other indicators (If there has been a drop in performance, is the reason for the change clear and unrelated to the CIP?) Policy Date: Review Date: Page 6 Assessment of whether any further review is required The provider will also present a quarterly report to PSQC. The initial and quarterly review along with any subsequent feedback will be documented to provide an audit trail of the process followed and track progress made towards their agreement and ultimately their sign-off and implementation. Time line Date April/May June/July July/ongoing August/November/ February 6 Action CN to attend Trust CIP/QIA discussion for following financial year Presentation of QIA/CIPs to CEG for review by CCG Follow up of any concerns regarding QIA/CIPs to enable CCG agreement Quarterly monitoring of provider review of CIPs owner Provider/CN CCG Provider/CCG CCG/Provider MONITORING COMPLIANCE This Policy will be monitored by the Patient Safety and Quality Committee. The CCG Executive Officer who has overall responsibility for monitoring the policy is the Chief Nurse. 7 ARRANGEMENTS FOR REVIEW If only minor changes are required the Governance Committee has authority to make these changes without referral to the CCG Board. If more significant or substantial changes are required, the policy will need to be ratified by the relevant committee before final approval by the CCG Board. If only minor revisions are made then version number for the policy will be updated by ‘.1’ e.g. from version 1.0 to 1.1. If significant amendments need to be made then the version number would increase to the next whole number e.g. from version 1.1 to 2. 7 ASSOCIATED DOCUMENTATION National Quality Board; HOW TO Quality Impact Assess Provider Cost Improvement Plans (July 2012 – March 2013) Policy Date: Review Date: Page 7 Monitor & Audit Commission; Delivering sustainable cost improvement programmes (January 2012) NHS Early Warning Systems www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPolicyAndGu idance/DH_113020 8 REFERENCES National Quality Board; HOW TO Quality Impact Assess Provider Cost Improvement Plans (July 2012 – March 2013) 9 LIST OF STAKEHOLDERS CONSULTED Date Policy circulated Name of individual Or Group Title Were Were comments comments incorporated received into the policy Yes/No Tom Able Dr. Anil Chopra Tracey Easton Lisa Allen Diane Sarkar Celia Skinner 10 If No – Why Not? Yes/No Chief Officer Chair Chief Finance Officer Chief Nurse BTUH Director of Nursing BTUH Medical Director EQUALITY IMPACT ASSESSMENT BB CCG is committed to carrying out a systematic review of all its existing and proposed policies to determine whether there are any equality implications. This policy has been assessed using the CCG’s Equality Impact Assessment framework which identified the following impact/s upon equality and diversity issues: Age Marital Status Disability Gender & Pregnancy Race Sexuality Religion Human Rights Total Points Impact 2 2 2 2 2 2 2 2 16 HIGH Points 3 – This area has a high relevance to equalities 2 – This area has a medium relevance to equalities 1 – This area has a low relevance to equalities 0 – This area has no relevance to equalities Policy Date: Review Date: Page 8 Scoring 13-18 points – high impact 7-12 points – medium impact 0-6 points – low or no impact Rationale: Ensuring sound processes around Provider services QIA’s and CIPS is likely to have a positive impact on all the protected characteristics. Using the framework, any impact to particular groups of people will be highlighted through the process which will, where appropriate, enable the CCG to ensure equitable delivery of services. 11 VERSION CONTROL Version 0.2 Author: Name & Title Nikki Livermore Date Policy Issued Date Policy Due to be Reviewed Policy Date: Review Date: Page 9
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