Agenda and Papers

`
NHS LIVERPOOL CLINICAL COMMISSIONING GROUP
GOVERNING BODY
TUESDAY 12TH JANUARY 2016 AT 1PM
BOARDROOM, THE DEPARTMENT, LEWIS’S BUILDING
RENSHAW STREET L1 1JX
(lunch to be provided at 12.30pm)
Part 1:
Introductions and Apologies
1.1
Declarations of Interest
All
1.2
Minutes and action points from the meeting
on 8th December 2015
Attached
All
1.3
Matters Arising
All
Part 2:
2.1
Updates
Feedback from Committees:
Report no: GB 01-16
 Primary Care Commissioning Committee –
15th December 2015
 Audit Risk & Scrutiny Committee 17th December 2015
 Finance Procurement & Contracting Committee
- 22nd December 2015
 Healthy Liverpool Programme Board –
23rd December 2015
 Committees in Common 6th January 2016
Dave Antrobus
Prof. Maureen Williams
Dr Nadim Fazlani
Tom Jackson
Katherine Sheerin
2.2
Feedback from Liverpool City Region CCG Alliance Report no: GB 02-16
- 6th January 2016
Katherine Sheerin
2.3
Chief Officer’s Update
Verbal
Katherine Sheerin
2.4
NHS England Update
Verbal
Clare Duggan
1
Page 1 of 2
2.5
Public Health Update
Part 3:
Performance
Part 4:
Strategy and Commissioning
Verbal
Dr Sandra Davies
4.1
Delivering the Forward View – NHS
Planning Guidance 2016/17 – 2020/21
Report no: GB 03-16
& Presentation
Katherine Sheerin/
Tom Jackson
4.2
Healthy Liverpool Engagement and
Communications Plan
Report no: GB 04-16
Carole Hill
Part 5:
Governance
5.1
Corporate Risk Register
Report no: GB 05-16
Stephen Hendry
5.2
Liverpool CCG Standards of Business Conduct
(December 2015)
Report no: GB 06-16
Prof Maureen Williams
5.3
CCG Safeguarding Annual Report
Report no: GB 07-16
Jane Lunt
6.
Questions from the Public
7.
Date and time of next meetings:
Tuesday 9th February 2016 at 1pm Boardroom, The Department
For Noting:
 Primary Care Commissioning Committee – 17th November 2015
 Healthy Liverpool Programme Board – 25th November 2015
 Finance Procurement & Contracting Committee – 24th November 2015
 Audit Risk & Scrutiny Committee – 6th October 2015
Exclusion of Press and Public: that in view of the confidential nature of the business to be
transacted, members of the public, press and non voting members be excluded from the
meeting at this point.
2
Page 2 of 2
Report no: GB 01-16
NHS LIVERPOOL CLINICAL COMMISSIONING GROUP
GOVERNING BODY
TUESDAY 12TH JANUARY 2016
Title of Report
Feedback from Committees
Lead Governor
Senior Management
Team Lead
Report Author(s)
Summary
Recommendation
Impact on improving
health outcomes,
reducing inequalities
and promoting
financial
sustainability
Relevant Standards
or targets
25
Dr Nadim Fazlani, Dr Rosie Kaur, Dave Antrobus,
Prof, Maureen Williams
Cheryl Mould, Head of Primary Care Quality &
Improvement, Tom Jackson, Chief Finance Officer,
Jane Lunt, Head of Quality/Chief Nurse, Katherine
Sheerin, Chief Officer
Cheryl Mould, Head of Primary Care Quality &
Improvement
Tom Jackson, Chief Finance Officer
Jane Lunt, Head of Quality/Chief Nurse
The purpose of this paper is to present the key issues
discussed, risks identified and mitigating actions
agreed at the following committees:
 Primary Care Commissioning Committee – 15th
December 2015
 Audit Risk & Scrutiny Committee - 17th
December 2015
 Finance Procurement & Contracting Committee
22nd December 2015
 Healthy Liverpool Programme Board – 23rd
December 2015
 Committees in Common 6th January 2016
This will ensure that the Governing Body is fully
engaged with the work of committees, and reflects
sound governance and decision making arrangements
for the CCG.
That Liverpool CCG Governing Body:
 Considers the report and recommendations from the
committees
As per each Committee’s Terms of Reference
Page 1 of 14
NHS LIVERPOOL CLINICAL COMMISSIONING GROUP
PRIMARY CARE COMMISSIONING COMMITTEE
TUESDAY 15TH DECEMBER 2015 AT 10AM – 12PM
BOARDROOM THE DEPARTMENT
AGENDA
Part 1: Introductions and Apologies
1.1
Declarations of Interest
All
1.2
Minutes and actions from previous meeting on
17th November 2015
All
1.3
Matters Arising
1.3.1
Memorandum of Understanding
Tom Knight
Part 2: Updates
2.1
Primary Care Quality Sub-Committee Feedback
PCCC 23-15
Rosie Kaur
Part 3: Transition Issues
Part 4: Strategy & Commissioning
4.1
Primary Care Support Services
PCCC 25-15
Tom Knight
4.2
Local Estates Strategy
Presentation
Sam McCumiskey
4.3
Practice Merger Application
PCCC 26-15
Cheryl Mould
Part 5: Performance
5.1
CCG primary Care Commissioning Committee
Performance report
26
PCCC 27-15
Scott Aldridge
Page 2 of 14
Part 6: Governance
6.1
Risk Register
PCCC 28-15
Cheryl Mould
5.
Any Other Business
ALL
6.
Date and time of next meeting:
Tuesday 19th January 2016 Boardroom The Department
27
Page 3 of 14
LIVERPOOL CCG
CORPORATE GOVERNANCE TEMPLATE – COMMITTEE MINUTES
Committee: Primary Care Commissioning
Committee
Key issues:
1. Primary Care Support Services.
Meeting Date: 15th December 2015
Chair: Dave Antrobus
Vice Chair: Katherine Sheerin
Risks Identified:
Mitigating Actions:
• That sustainability of services post April
2016 is not maintained.
• Ensure issues/concerns are raised at
both national and local level.
• That local representation from member
practices are not part of the stakeholder
forum.
• Invite Healthwatch and Governing
Body Practice Manager Leads to
attend the local stakeholder forum.
.
2. Primary Care Performance Report.
• That the local CCG quality premium
targets are not achieved.
• Limited assurance provided to improve
performance.
• Identify practices in lower quartile.
• Co-ordinate bespoke team to visit
these practices to offer support.
• Formally strengthen the Primary Care
monitoring framework.
Recommendations to NHS Liverpool CCG Governing Body:
1. To note the issues, risks and mitigating actions.
28
Page 4 of 14
AUDIT, RISK AND SCRUTINY COMMITTEE (ARSC)
THURSDAY 17TH DECEMBER 2015 3:00PM – 5:00PM
BOARDROOM 3RD LEVEL, LEWIS’S BUILDING
AGENDA
Section 1 Standing Items for Noting (N)
1. Welcome and Introductions
ALL
2. Minutes from the previous ARSC meetings on
6 October 2015
ALL (N)
3. Actions from the previous ARSC meetings on
6 October 2015
ALL (d/N)
4. Declaration of Interests
ALL (N)
5. Register of Interest
Report no: ARSC56-15 (N)
Maureen Williams
6. Gifts and Hospitality Register
Report no: ARSC57-15 (N)
Maureen Williams
7. Official Use of Liverpool CCG Seal (to follow)
Report no: ARSC58-15 (N)
Tom Jackson
8. Liverpool CCG Loss & Special Payments Register Verbal update
Alison Ormrod
Section 2 Items for discussion(d) or Decision (D) or Noting (N)
9. Safeguarding Update (to follow)
Report no: ARSC59-15 (d/D)
Jane Lunt
10. Internal Audit Progress Report
Report no: ARSC60-15 (d/D)
Matt Roberts/Gary Baines
29
Page 5 of 14
11. MIAA Briefing Report
Report no: ARSC61-15 (d/D)
Matt Roberts/Gary Baines
12. MIAA Partnership Working
Verbal
Matt Roberts/Gar Baines
13. Grant Thornton Progress Report
Report no: ARSC62-15 (d/D)
Iain Miles/Robin Baker
14. Grant Thornton Follow up work
Report no: ARSC63-15 (d/D)
Iain Miles/Robin Baker
15. SBS Authorisation Form (to follow)
Report no: ARSC64-15 (d/D)
Bev Bird
16. Tender Waiver Requests (to follow)
Report no: ARSC65-15 (d/D)
Derek Rothwell
17. Market Testing on Business Services Update
Verbal update
Maureen Williams
Section3 Items for Information (i)
18. Financial Control Evaluation
Assessment Summary (For information)
19. Date of next meeting(s) for 2016
• Friday 19 February 2016
• Friday 22 April 2016
th
• Thursday 26 May 2016
Report no: ARSC66-15
Matt Roberts/Tom Jackson
All
3pm – 5pm
1pm -3pm
3pm – 5pm **
(**AR & Final Accounts - Audit Committee Members/attendees and Katherine Sheerin and
Nadim Fazlani)
•
•
•
30
Friday 29 July 2016
Friday 30 September 2016
Friday 16th December 2016
1pm - 3pm
1pm – 3:30pm (Private meeting 1:00-1:30pm)
1pm – 3pm
Page 6 of 14
LIVERPOOL CCG
CORPORATE GOVERNANCE TEMPLATE – COMMITTEE MINUTES
Committee: Audit, Risk and
Scrutiny Committee
Key issues:
1. Conflicts of Interest
2. Transition of Banking
arrangements
3. Safeguarding
Meeting Date: Thursday 17
December 2015
Risks Identified:
• Reputational harm to CCG.
Poor value for public
money/NHS
• Threat to Bank Accounts
• Harm to vulnerable children
and adults
• Reputational harm to CCG
Chair: Professor Maureen
Williams
Mitigating Actions:
• Robust application of policy.
• Regular Monitoring and update
of Registers
• Refusal to agree without
additional safeguards
• Robust monitoring adequate
staffing
• Regular reports to Board and
Audit, Risk and Scrutiny
Committee
Recommendations to NHS Liverpool CCG Governing Body:
1. To note the risks and mitigating actions.
31
Page 7 of 14
FINANCE, PROCUREMENT AND CONTRACTING COMMITTEE
TUESDAY 22nd DECEMBER 2015
10:00AM – 12:30PM
ROOM 2 – LEWIS’S BUILDING, THE DEPARTMENT, LIVERPOOL, L1 1JX
AGENDA
1.
Welcome and Introductions
All
2.
Declaration of Interests (form available)
All
3.
Minutes and action notes of previous meeting
held on 24 November 2015
Chair
4.
GP Specification
Report no:FPCC74-15
Cheryl Mould
5.
Talk Liverpool IAPT update
Report no:FPCC75-15
Derek Rothwell
6.
Contracts Month 08 Update
Report no:FPCC76-15
Derek Rothwell
7.
Finance and KPI update
Report no:FPCC77-15
Alison Ormrod
8.
Investment Proposals
a: Early Support Discharge Business Case
Report no:FPCC78-15
Andrea Astbury
9.
Grants Paper (To follow if agreed at HLP)
Report no:FPCC79-15
Kelly Jones
10. Mental Health Clustering update
Verbal Update
Derek Rothwell
11. Specialised Commissioning Update
Verbal update
Tom Jackson
12. Any Other Business
All
32
Page 8 of 14
Date of next meeting(s):
2015 monthly meetings:
4th Tuesday of the month
12:30pm
Tuesday 26 January 2016
10am-12.30pm
Tuesday 23 February 2016
10am-12.30pm
Tuesday 22 March 2016
10am-12.30pm
33
10am –
Room 2 – Lewis’s Building
Room 2 - Lewis’s Building
Room 2 - Lewis’s Building
Room 2 - Lewis’s Building
Page 9 of 14
LIVERPOOL CCG
CORPORATE GOVERNANCE TEMPLATE – COMMITTEE MINUTES
Committee: Finance, Procurement &
Contracting Committee
Meeting Date: Tuesday 22 December
2015
Chair: Dr Nadim Fazlani
Key issues:
Risks Identified:
Mitigating Actions:
1.Talk Liverpool service
• Performance targets not achieved
in two areas – Access and
Recovery
•
•
•
• Contract levers to be
implemented and financial
sanctions to be applied
•
•
•
2.
3.
4.
Recommendations to NHS Liverpool CCG Governing Body:
1. To note the above issues, risks and mitigating actions.
34
Page 10 of 14
Healthy Liverpool Programme Board
Wednesday 23 December 2015
3:00pm to 4:30pm
Room 1, 3rd Floor, The Department, Lewis’s
AGENDA
1.
Welcome and Introductions
T. Jackson
2.
Minutes of the last meeting
T. Jackson
3.
Programme Highlight reports (attached)
SRO’s
4.
Programme Plans & Outcomes
C Hill
5.
Estates Strategy
P Fitzpatrick
6.
Public Engagement 2015
C Hill
7.
Liverpool Women’s Hospital update
All
8.
Risk Register
C Hill
9.
Any Other Business
All
10.
Date and time of next meeting – Wednesday 27 January 2015
3pm to 4.30pm, Meeting Room 1, 3rd Floor, The Department
Apologies
Dr Janet Bliss
Dr Simon Bowers
Sue Lavell
Dr Maurice Smith
Samih Kalikeche
35
Page 11 of 14
LIVERPOOL CCG
CORPORATE GOVERNANCE TEMPLATE – COMMITTEE MINUTES
Committee:
Health Liverpool Programme Board
Key issues:
Meeting Date
Wednesday 23rd December 2015
Risks Identified:
Estates Strategy
Not taking a strategic approach to
future health and care estate
requirements could present a risk to
the long term achievement of Healthy
Liverpool objectives.
Outcomes Development
Lack of clarity around outcomes at a
project, programme and Healthy
Liverpool level will not provide
assurance that we will achieve our
ambitions for better health and health
services.
Healthy Liverpool delivery
Poor understanding of scope and
management of delivery to timescales
through to March 2018 could threaten the
achievement of Healthy Liverpool
objectives and outcomes.
Chair:
Tom Jackson
Mitigating Actions:
A first draft of the CCG Estates
Strategy has been produced and
submitted to NHS England. The focus
at this point is on our strategic
intentions around community estate.
There are opportunities to refresh the
strategy over time as a clear strategy
for hospital and public services estate
emerges.
The PMO is leading a piece of work to
review stated outcomes for existing
projects and to ensure that outcomes
for new investments are robust. An
overarching assessment will
demonstrate a clear ‘golden thread’
from projects through to high level
outcomes.
PIDs for all projects have been
produced to ensure there is a clear
scope for all parts of the programme.
Milestones and timescales for every
project have been mapped and this
information will form the basis of robust
performance management.
Recommendations to NHS Liverpool CCG Governing Body:
•
To note the above issues, risks and mitigating actions.
36
Page 12 of 14
HEALTHY LIVERPOOL PROGRAMME
RE-ALIGNING HOSPITAL BASED CARE
COMMITTEE(S) IN COMMON (CIC)
KNOWSLEY, LIVERPOOL AND SOUTH SEFTON CCGS
WEDNESDAY 6th JANUARY 2016
Boardroom, Nutgrove Villa
Westmorland Road, Huyton, L36 6GA
Time 4:00pm – 5:30pm
1.
Welcome, Introductions and apologies
All
2.
Declarations of Interest
All
3.
Notes / Actions from the previous meeting held on
4 November 2015 (to follow)
Links with Liverpool City Region Committee in Common and
Feedback
All
4.
5.
KS
Interdependencies across Sefton, Knowsley and Liverpool
•
•
Shaping Sefton
Knowsley Joint Health & Wellbeing Strategy
F Taylor
D Johnson
6.
Feedback from clinical discussions
F Lemmens
7.
Liverpool Women’s Hospital Update
KS
8.
Planning Guidance (attached)
All
9.
Strategic Estates Programme (attached)
TJ
10. Strategic Options Appraisal – report from RLUBHT & AUHFT
(copies will be provided on the day)
KS
11. Public Engagement / Consultation ( attached)
KS
12. Any other business
All
13. Date of Next Meeting –
Wednesday 3 February 2016 4:00pm - 5:30pm
(venue same as the CIC (formerly CCG Network) –
Nutgrove Villa)
37
Page 13 of 14
LIVERPOOL CCG
CORPORATE GOVERNANCE TEMPLATE – COMMITTEE MINUTES
Committee:
Meeting Date
Healthy Liverpool Realigning Hospital
Based Care Committees in Common (CIC)
5 January 2016
Chair:
Key issues:
Risks Identified:
Mitigating Actions:
1 Relationship between this Committee
and the LCR CCG Alliance
•
•
Healthy Liverpool Realigning Hospital
Based Care CIC to continue to meet,
focusing on engagement of partners
and recommending courses of action
regarding services delivered from the
Liverpool footprint.
•
Governance and reporting
arrangements to be reviewed.
Confusion/lack of clarity leading to
slower implementation of required
changes.
Dr Nadim Fazlani
Recommendations to NHS Liverpool CCG Governing Body:
•
To note the above issues, risks and mitigating actions.
38
Page 14 of 14
Report no: GB 02-16
NHS LIVERPOOL CLINICAL COMMISSIONING GROUP
GOVERNING BODY
Title of Report
TUESDAY 12TH JANUARY 2016
Feedback from Liverpool City Region CCG Alliance
Lead Governor
Dr Nadim Fazlani, Chair
Senior Management
Team Lead
Katherine Sheerin, Chief Officer
Report Author
Katherine Sheerin, Chief Officer
Summary
The purpose of this paper is to present the key issues
discussed, risks identified and mitigating actions
agreed at the Liverpool City Region CCG Alliance on
6th January 2016.
This will ensure that the Governing Body is fully
engaged with the work of the Liverpool City Region
CCG Alliance and reflects sound governance and
decision making arrangements for the CCG.
That Liverpool CCG Governing Body:
 Considers the reports and recommendations
from the Liverpool City Region CCG Alliance
Impact on improving
health outcomes,
reducing inequalities
and promoting
financial sustainability
Relevant Standards or
targets
39
By working collaboratively with CCGs across
Merseyside we will ensure that opportunities are
maximised for Liverpool patients and the
consequence of commissioning services understood
and managed.
Standards of Good Governance
Putting Patients First 2014 – 16
Everyone Counts: Planning for Patients 2014/15
CCG’s COMMITTEE IN COMMON
Wednesday 6th January 2016
Chief Officers Pre-Meet - 12.00 pm to 12.45
pm Lunch 12.45 pm
Meeting: 1.00 pm
Boardroom, Nutgrove
Villa
Westmorland Road, Huyton, L36 6GA
TIME
1pm
Welcome and Introductions
Chair
Apologies for Absence
Chair
Declarations of Interest
Chair
1:05pm
Minutes and Action Log from the CCG Network
meeting held on Wednesday 2nd December 2015
All
1:15pm
Dissolution of the CCG Network (5mins)
All
1
Terms of Reference of the Committee in Common (to
be reviewed throughout the meeting and finalised at
the end)
All
2
Delivering the 5 Year Forward View – footprint
discussion
All
3
Repository update/developing our work programme
4
CCG Alliance Slide Deck
JD
5
Provider Alliance
KS
6
Strategic Approach
• Marketing ourselves and our successes
All
Any Other Business
All
3:45pm
40
JD/All
DATE AND TIME OF NEXT MEETING:
Wednesday 3rd February 2016 1pm in the Boardroom,
Nutgrove Villa Westmorland Road, Huyton, L36 6GA
41
LIVERPOOL CCG
CORPORATE GOVERNANCE TEMPLATE – COMMITTEE MINUTES
Committee:
Meeting Date
CCG Network/
LCR NHS CCG Alliance
Chair:
5 January 2016
Dianne Johnson
Key issues:
Risks Identified:
Mitigating Actions:
1 Need for more formal collaborative
commissioning and strategic planning
across Liverpool City Region (LCR)
•
That opportunities for hospital service
reconfiguration are not realised,
resulting in poor services and
outcomes for patients.
•
Establishment of LCR NHS CCG
Alliance as a Committee in Common
across all 7 LCR CCGs.
•
That CCG statutory duties are not
delivered.
•
Draft Terms of Reference amended
and agreed - to be approved by each
CCG Governing Body in
January/February 2016.
•
Work Programme to be confirmed
including production of Sustainability
and Transformation Plan as set out in
Planning Guidance 16/17 – 20/21
Recommendations to NHS Liverpool CCG Governing Body:
•
To note that the Merseyside CCG Network has been formally disbanded.
42
Page 4 of 4
Report no: GB 03-16
NHS LIVERPOOL CLINICAL COMMISSIONING GROUP
GOVERNING BODY
TUESDAY, 12 JANUARY 2015
Title of Report
Lead Governor
Delivering the Forward View: NHS Planning
Guidance 2016/17 – 2020/21
Katherine Sheerin, Chief Officer
Senior Management
Team Lead
Tom Jackson. Chief Finance Officer
Report Author
Katherine Sheerin/Tom Jackson
Summary
The purpose of this paper is to present an overview
of the NHS Planning Guidance for 2016/17 –
2020/21
That Liverpool CCG Governing Body:
 Notes the content of the Planning Guidance
2016/17 – 2020/21
 Notes the synergy with the aims and direction
of Healthy Liverpool
 Notes the next steps in developing the CCG
response to producing the Operational Plan for
2016/17 and the Sustainability and
Transformation Plan for 2016/17 - 2020/21.
In line with Healthy Liverpool, this will enable the
CCG to understand that commissioning activities
improve health outcomes, reduce inequalities and
secure financial sustainability.
Recommendations
Impact on improving
health outcomes,
reducing inequalities
and promoting
financial
sustainability
Relevant Standards
or targets
43
 Delivery of the Five Year Forward View
 Delivery of NHS Constitution Targets
 Delivery of CCG Statutory Duties.
Page 1 of 1
44
Report no: GB 04-16
NHS LIVERPOOL CLINICAL COMMISSIONING GROUP
GOVERNING BODY
TUESDAY 12TH JANUARY 2016
Title of Report
Lead Governor
Senior Management
Team Lead
Report Author
Summary
Healthy Liverpool Engagement and
Communications Plan
Dr Nadim Fazlani, Chair
Carole Hill, Integrated Programme Director,
Healthy Liverpool Programme
Helen Shaw, Engagement Lead, Healthy
Liverpool Programme
The purpose of this paper is to update the
Governing Body on plans for engagement
and communications activity to support the
next phase of the Healthy Liverpool
communications and engagement
programme.
This is a refreshed version of the plan which
was approved by the Governing Body in
December 2014.
Recommendation
That Liverpool CCG Governing Body:
• Approves the updated stakeholder
engagement and communications plan.
Impact on
improving health
outcomes, reducing
inequalities and
promoting financial
sustainability
This plan supports the achievement of the
Healthy Liverpool Programme objectives to
improve health outcomes, reduce health
inequalities and to deliver clinical and
financial sustainability.
Relevant Standards
or targets
Delivery of statutory responsibilities for the
CCG.
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45
Healthy
Liverpool
Engagement
and
Communications
Plan
1. INTRODUCTION
The purpose of this paper is to update the Governing Body on plans for
engagement and communications activity to support the next phase of
the Healthy Liverpool programme.
2. RECOMMENDATIONS
That Liverpool CCG Governing Body:
• Approves the updated Healthy
communications plan.
Liverpool
engagement
and
3. BACKGROUND
In December 2014 NHS Liverpool CCG adopted a Healthy Liverpool
Engagement and Communications Plan which set out clear objectives to
embed best practice engagement within the programme. In addition, the
plan set out objectives to ensure that the case for change for Healthy
Liverpool transformation and the deliverables from all work-streams
were clearly communicated, understood and supported by key
stakeholders.
The report appended to this paper is an updated version of that plan,
taking into account the progress that has been made in the last year and
the deliverables proposed for the next phase of the continuous
communications and engagement process that we have committed to
over the life of the programme.
This covering paper highlights the key revisions to the 2014 plan,
and the specific plans for the next phase of public engagement and
the communications to support it.
4. PHASE 3 ENGAGEMENT UPDATE
The findings from the most recent phase of engagement on the Healthy
Liverpool vision, the case for change and high level proposals, which
took place from March to August 2015, were presented to the Governing
Body in November 2015.
In concluding the case for change phase of engagement we will ensure
that we communicate the findings; that we have listened and have used
this insight to inform our future plans.
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46
The engagement to date has provided some clear messages and issues
to be addressed both within programme delivery and the next phase of
communications and engagement. The key issues and our response are
summarised below:
Recommendations from
Case for Change
Engagement
HL
programme
boards
consider detailed feedback
and recommendations and
make adjustments to plans
Respondents stated they
would like to see detailed
plans for the next phase of
engagement.
All programmes to review
contribution
to
improved
mental health, social model,
education and awareness
Review outcomes
benefits
Actions
All boards have considered programme
specific feedback and the overall results
of the summer 2015 engagement.
Many
issues are already being
addressed - for example, general
practice access as part of the 7 day
primary care project in the community
programme; ‘online appointments within
the digital programme, and urgent care
centres within the urgent and emergency
care programme.
The engagement plan contains detailed
plans for most programmes.
For the hospital programme we will be
engaging on the principles around
‘single-service, city-wide delivery’ and
some initial services which will be redesigned following this approach.
For urgent care, we will be engaging on
the model set out in the national review
for urgent and emergency care,
incorporating proposals to expand selfcare and urgent care centres.
Clinical re-design process for all HLP
projects to consider how mental health
considerations impact on the model.
The
neighbourhood
collaborative
component of the Community Model has
been informed by the engagement
findings.
against A comprehensive review of Healthy
Liverpool outcomes is underway. This
will refresh project outcomes, address
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47
gaps
around
measuring
patient
experience, health inequalities and
provide a ‘golden thread’ to demonstrate
how the programme’s high level
outcomes will be achieved.
Articulate how the vision for Engagement will use examples that have
hospital services translates delivered single service city wide
into specific changes.
delivery.
This phase represents pre-consultation
engagement for specific service change
proposals that are being developed and
may be subject to formal public
consultation at a later stage.
Review
translation
and To be actioned through provider
interpretation
offered
by contracts.
providers
via
contract
meetings/other means
Greater training in all care To be included in a review of the EDS
providers
re
appropriate plan.
support for equalities groups
5. NEXT PHASE OF ENGAGEMENT
The next phase of engagement will introduce more detailed information,
plans and proposals for improvements that have been identified across
all Healthy Liverpool programmes, the main themes of which are
summarised below:
Living Well – There are complementary programmes of insight and
engagement on the Living Well physical activity programme which will
inform branding, future marketing and communication campaigns and
developing initiatives. The feedback from this engagement will also feed
into other clinical redesign workstreams, including mental health,
learning disability and cancer .
Digital – the digital programme underpins many areas of Healthy
Liverpool, including prevention and self-care. Engagement will focus on
data sharing and personal health records, which earlier engagement has
indicated require further engagement to reassure people about privacy,
security and to emphasise the significant benefits.
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48
Community Services – this phase of engagement will seek to articulate
the new model of care in an accessible way, with a focus on how the
new approach will improve person-centred care, access and outcomes.
There are specific community projects that we wish to engage on,
including:
• The neighbourhood collaborative – how we can best deliver a social
model for health and wellbeing, with engagement on proposals for
social prescribing, centres of wellbeing and health trainer and peer
support approaches.
• Plans to extend access to GP services 7days a week through locality
hubs.
• Plans to deliver more care closer to home, including the provision of
diagnostics and outpatient clinics.
• The proposed community mental health model.
• Plans to improve patient experience and outcomes for people with
learning disabilities.
Urgent Care – we will engage on aspects of the new model for urgent
care, including:
• 7 day primary care access and how this may influence behaviour
change and use of urgent care in other settings.
• Gaining feedback on support for the model for urgent care centres.
Hospitals Programme – engagement in this phase will focus on
articulating and understanding views on the principle of single-service
city-wide delivery around a central university hospital campus. In
addition, we will engage at an early stage on 7 days services, complex
gynaecology, cardiology, stroke and neonatal services; effectively as
pre-consultation for service change proposals that are currently being
considered.
A detailed list of public engagement themes for the next phase of
engagement are summarised below:
Healthy Liverpool
Programme level
Transformation Topics
topics
(underline = likely for formal
consultation)
Living Well Physical activity (starts 16th
Raise physical activity
January 2016)
for Cancer, LD, Mental
Health
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49
Digital
Person Held Record – offering
people access and control over
their health records
(starts February 2016)
Community Prevention, self-care, social
model, neighbourhood
collaborative, pro-active person
centred.
(starts Late January 2016)
LTCs Respiratory
service redesign
(February 2016)
Learning Disability –
access and patient
experience in primary
and secondary care,
specialist services.
(starts late January
2016)
Mental Health – new
model
(January 2016)
Urgent
Care
Hospital
services
care closer to home/specialist
clinical integration
(starts Late January 2016)
7 day GP services and GP
access
(starts Late January 2016)
understand what re behaviour –
why ,
Urgent Care Centres February
2016
Single service city wide model
Women’s and
maternity - neonates
only - February 2016
Cancer – pelvic - Late
January 2016
Haem-oncology –
February
6. NEXT PHASE OF COMMUNICATIONS
A public-facing summary of the Healthy Liverpool Blueprint will be
developed as the primary source to support city-wide engagement and
communications. This will be delivered door to door across Liverpool;
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50
widely distributed within health and social care organisations and to a
range of public venues, including GP surgeries, libraries, One-Stop
centres, hospitals and other health locations, Children’s centres, Care
Homes, pharmacies, dental surgeries etc.
To help articulate Healthy Liverpool in an accessible way, a short
animation is being developed explaining why we need to improve health
and health services across the 5 programmes.
A series of short films are also being produced to illustrate some of the
projects already being implemented and how they improve care and the
experience for patients. The first 3 films will be completed in January for
haem-oncology, exercise on prescription and ambulance hear and
treat/see and treat. Over the next few months we will continue to add
new films to demonstrate new models of care across all programmes
and settings.
A toolkit will be produced for use by health and social care organisations
to engage with their workforce. This will include the messages from the
public facing summary along with more specific messages for staff.
7. WORKFORCE ENGAGEMENT
Engaging the health and social care workforce will be critical to the
success of the programme. As a group they are in a unique situation to
influence patient and public opinion and to act as agents for change.
There will therefore be a strong focus on the workforce during this next
phase of engagement with the delivery of a workforce engagement plan,
involving all providers and the local authority. The core communications
materials will be supplemented by tailored communications and toolkits
that will be used to engage and communicate to the whole workforce,
across health and social care.
8. STAKEHOLDER ENGAGEMENT
Stakeholder engagement with organisations across the health economy
will also be strengthened in the next phase. There has already been
strong engagement with Trust Chairs and Chief Execs. Measures will be
put in place with each Trust to ensure that Boards, governors and senior
management teams are fully engaged with the programme.
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51
As part of the resourcing for this key area of work and to strengthen
partnership working, a senior communications and engagement lead has
been seconded from a partner organisation to lead this workstream.
9. CONCLUSION
This summary of the communications and engagement plan sets out
how we will achieve our objectives to engage meaningfully,
communicate clearly and continue to embed best practice
communications and engagement for the Healthy Liverpool Programme.
Page 8 of 8
52
Appendix 1
Healthy Liverpool Engagement and Communications
Plan
1 Introduction
In 2014 NHS Liverpool CCG adopted a Healthy Liverpool Engagement and
Communications Plan which set out the proposed delivery plan for Healthy
Liverpool engagement and communications; along with clear objectives to
embed best practice engagement both within this programme and in
everything we do as a commissioning organisation. In addition, the plan set
out objectives to ensure that the case for change for Healthy Liverpool
transformation and the deliverables from all work-streams were clearly
communicated, understood and supported by key stakeholders.
This document is an updated version of that plan, taking into account the
progress that has been made since then and the developments that have
taken place. It therefore replaces the 2014 plan.
Healthy Liverpool is an ambitious five year programme to transform
Liverpool’s health and social care system to one that is person-centred,
supports people to stay well and provides the very best in care.
To recap on progress to date, Healthy Liverpool engagement has been
conducted in three distinct phases:
PROGRESS TO DATE
Phase 1 - Launch (May to November 2013)
The first phase of the programme facilitated the alignment of health
economy wide views, to define the case for change, to confirm commitment
and to identify the ‘big ideas’ which would deliver the transformation
required. This phase led to system agreement for the Healthy Liverpool
vision and a commitment that partners would ‘Act as One’; to identify the key
components of the future model of care and to shape a tangible
implementation plan.
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1
Phase 2 – Planning (December 2013 to October 2014)
This phase focused upon planning and early implementation, which defined
the overarching model of care in outline, clear standards and benefits
informed by early stakeholder engagement. The product of this phase was
represented in the Healthy Liverpool Prospectus for Change which was
published in November 2014.
Phase 3 (commenced November 2014)
This phase commenced with a focus on engaging stakeholders about the
vision and the ambition of the proposals contained in the Prospectus for
Change. Key engagement outputs from this phase include:
• Publication of the Prospectus for Change, launched at a Mayoral Health
Summit on 3rd November 2014;
• A city-wide engagement programme on the vision and proposals set out in
the Prospectus for Change, to be conducted from March –August 2015,
intended to communicate the case for change and to engage people on the
vision, ambition and concepts underpinning the programme;
• Progress through the NHS England reconfiguration assurance process,
including evidence that Healthy Liverpool meets the requirements of the ‘4
Tests’ for service reconfiguration.
In December 2014 the Governing Body approved proposals for a city-wide
engagement programme on the vision and proposals set out in the
Prospectus for Change.
This phase began with a large scale public listening event at St Georges Hall
27th March 2015. The technique of deliberative enquiry was used, which
enabled participants to understand and discuss issues and provide informed
and considered feedback about the overarching programme and the 5
programmes of transformation. The insight gained from this event was
utilised to inform the further development of plans as well as guiding further
engagement over this period.
A new online engagement portal went live in June 2015; enabling two-way
dialogue with Liverpool residents regarding the plans for Healthy Liverpool,
through a range of online tools and multi-media communications. This
platform can be accessed from both the CCG and Healthy Liverpool website,
as well as having its own URL – www.talkliverpoolhealth.info
54
2
Activities ranging from one-to-one and small group discussions, to larger
events, creative engagement activities and more quantitative survey based
activity took place over the summer of 2015. The CCG also engaged with
Liverpool residents through a city-wide series roadshows from June-August.
A number of Healthy Liverpool engagements also took place from June to
September, to inform specific programme development including physical
activity, learning disabilities and shared decision-making. The results were
presented to the Governing body in November 2015.
2 Engagement Vision and Objectives
Over the five years of the Healthy Liverpool programme our aim is achieve a
step change in stakeholder and patient and public engagement, to support
the CCG’s objectives for individuals, families, carers and communities to feel
supported and empowered; to have more control over their health and
wellbeing; to work in partnership with health care professionals to improve
health services and to work together to create a social movement for a
Healthy Liverpool.
Our overarching engagement and communication objectives are to:
• Ensure service review, redesign and transformational change is based on
good quality patient experience and public engagement;
• Establish and maintain effective engagement infrastructure that ensures
continuous, meaningful two way dialogue with people and stakeholders
that enables them to inform and be active in commissioning;
• Ensure our engagement and communications approach is designed to
support adherence to the 4 tests for service reconfiguration;
• Establish and support engagement at neighbourhood level which
facilitates person-centred and preventive approaches to improving health
and wellbeing;
• Empower people to live well and support themselves and each other
when unwell;
• Develop effective communication channels to ensure that stakeholders
have information to enable them to access the right care at the right time;
• Ensure people have access to information and are aware of how they can
influence the commissioning process;
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3
• Effectively engage with member practices to deliver wide-scale
understanding, involvement and support, thereby creating a strong CCG
membership-base;
• Ensure the CCG has the required communications and engagement
capacity and capability to deliver an effective communications and
engagement service.
We will achieve this through meaningful, on-going participation, built upon
four important principles:
1. A culture of partnership with people and communities, facilitated by the
CCG and healthcare professionals; carers and families will be actively
involved in care decisions in all settings;
2. Effective partnerships with voluntary, community and social enterprise
organisations (VCSEs) to better understand the needs of vulnerable
groups, to improve dialogue and design and deliver more effective
services, particularly for those experiencing health inequalities;
3. Strong community capacity to create the conditions for more active health
participation;
4. Clear, open and sustained communication and engagement to enable
people to be aware of how their local health service operates and to
understand how their experiences are heard and used to shape better
services.
Robust engagement planning and stakeholder management is required to
support the Healthy Liverpool programme both strategically and for
individual programme and service changes. The Engagement Cycle below
shows how engagement needs to support the commissioning process at
every stage.
56
4
1
The IAP2 public participation spectrum model provides a similar and useful
staged process:•
Inform – to provide the public with information that assists them in
understanding a problem, alternatives, and/or solutions
•
Consult – to obtain public feedback on analysis, alternatives, or
decisions
•
Involve – to work directly with the public throughout a process,
ensuring concerns and aspirations are understood and considered
•
Collaborate – to partner with the public in each aspect of a decision,
including the development of alternatives and preferred solution
•
Empower – to place the final decision-making in the hands of the
public
Using these models, we will build on the engagement delivered to date to
develop richer participatory processes and deeper involvement of patients
and public in both design and delivery of improved health.
1
NHS England Guidance, Transforming Participation in Health and Care, September 2013
57
5
3 Healthy Liverpool Communications and Engagement Objectives
A number of specific objectives have been identified to support further
phases of the Healthy Liverpool programme to be delivered in 2015/16 and
2016/17:
1. Raise awareness of the aims, ambitions and deliverables of the Healthy
Liverpool programme;
2. Involve the people of Liverpool in shaping the plans for transformation
across all settings of care and programmes;
3. Involve clinicians working across all settings of care, ensuring they are
shaping proposals for service transformation and ensuring that
communication and engagement processes are clinically-led;
4. Build awareness, interest, involvement and support for the Healthy
Liverpool vision and proposals within the LCCG membership, both at
individual GP and practice level;
5. Ensure all key influencers, including regional and national NHS bodies,
politicians, local authorities and media are fully engaged and informed;
6. Build ownership and support for the aims of transformation among the
health economy workforce - within the NHS, in social care and amongst
others with a stake in health and social care provision;
7. Ensure that insight from patient experience informs all Healthy Liverpool
proposals;
8. Incorporate insight and good practice from other engagement
programmes and areas of best practice, both locally and nationally.
4 Stakeholder Management
Healthy Liverpool is a whole-system transformational programme which
brings complexity in the management of stakeholder interests and
involvement. In order to manage these risks and opportunities we need a
clear understanding of the diverse interests and influence of our
stakeholders and a strategy to address their issues and needs.
The Healthy Liverpool stakeholder analysis has been refreshed and is set
out at Appendix 1. This analysis has informed the development of a focused
communication plan which responds to stakeholder interests and their
potential impact on the programme.
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6
5 Branding and Key Messages
A set of carefully considered key messages guides all Healthy Liverpool
communications; translating the Healthy Liverpool vision into a story which
compellingly describes the aims and ambitions of the transformation we wish
to achieve. For all the public feedback received over the last year we will
ensure we ‘close the loop’ and communicate how this insight is informing
and influencing the delivery of the programme.
The Healthy Liverpool brand created in 2014 to support communications and
engagement has been embedded and is being used well and consistently in
all engagement and communications. We continue to be guided by the
following communications principles:
• Keep it Clear - Healthy Liverpool is for everyone. People want to
understand the message first time, in as few words as possible. We will
say what we mean and avoid jargon.
• Keep it Positive - Healthy Liverpool is built on a compelling vision: better
services, better outcomes and greater control over your own health. We
will keep the tone positive and uplifting.
• Keep it Real - the brand is for and about the people of Liverpool. People
need to trust in our messages and support the goals of the programme.
Clinicians will lead in delivering these messages using an open and
honest tone and we will not ignore or under-state the challenges . We will
emphasise the sense of one city coming together to decide on the future
of our health and care services and our own health.
The 2015 engagement has provided some clear messages and issues that
will be addressed both within programme delivery and the next phase of
communications and engagement. Key issues include:
• GP appointments - concerns and frustrations over waiting times and
challenge of making appointments.
• Out-of-hours appointments in GPs and hospital requested by many and
felt important to increase access and reduce pressure on A&E.
• Deprivation is a challenge for people in accessing physical activities and
making healthy choices.
• Mental health – perceived that this is a low priority and concerns about
accessing good mental health services.
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7
• Better education and awareness is needed to improve health, encourage
better lifestyle choices and increase understanding of how to use health
services appropriately.
• Better access to interpretation/translation facilities and need to ensure all
staff are trained to be sensitive to the needs of different communities.
• A clear message about the desire to see clear, tangible plans for the next
phase of engagement.
6 Healthy Liverpool Engagement January to March 2016
This phase of engagement will introduce more detailed information, plans
and proposals for improvements that have been identified across all
programmes.
For a small number of hospital projects this phase of engagement will
represent pre-consultation for detailed proposals that may be subject to
formal public consultation later in 2016.
The public engagement and consultation themes that will be engaged on
over the winter and early spring are summarised below:
Healthy Liverpool
Transformation Topics
(underline = likely for formal
consultation)
Living Well Physical activity (starts 16th
January 2016)
Person Held Record – offering
people access and control over
their health records
(starts February 2016)
Community Prevention, self-care, social
model, neighbourhood
collaborative, pro-active person
centred.
(starts Late January 2016)
Programme level
topics
Raise physical activity
for Cancer, LD, Mental
Health
Digital
LTCs Respiratory
service redesign
(February 2016)
Learning Disability –
access and patient
experience in primary
and secondary care,
specialist services.
(starts late January
60
8
2016)
Mental Health – new
model
(January 2016)
Urgent
Care
Hospital
services
care closer to home/specialist
clinical integration
(starts Late January 2016)
7 day GP services and GP
access
(starts Late January 2016)
understand what re behaviour –
why ,
Urgent Care Centres February
2016
Single service city wide model
Women’s and
maternity - neonates
only - February 2016
Cancer – pelvic - Late
January 2016
Haem-oncology –
February
6.1 Communications Delivery
A public-facing summary of the Blueprint will be developed as the primary
source to support city-wide engagement and communications. This will be
delivered door to door across Liverpool; widely distributed within health and
social care organisations and to a range of public venues, including GP
surgeries, libraries, One-Stop centres, hospitals and other health locations,
Children’s centres, Care Homes, pharmacies, dental surgeries etc.
To articulate the aims and objectives of Healthy Liverpool in an accessible
way, a short animation will be completed in January 2016 explaining the key
messages around the need for change and how we aim to improve health
and health services across the 5 programmes.
A series of short films are also being produced to illustrate some of the
projects already being implemented and how they improve care and the
experience for patients. The first 3 films will be completed in January for
haem-oncology, exercise on prescription and ambulance hear and treat/see
and treat. Over the next few months we will continue to add new films to
demonstrate new models of care across all programmes and settings.
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9
A toolkit will be produced for use by health and social care organisations to
engage with their workforce. This will include the messages from the public
facing summary along with more specific messages for staff.
Engaging the health and social care workforce will be critical to the success
of the programme. As a group they are in a unique situation to influence
patient and public opinion and to act as agents for change.
There will therefore be a strong focus on the workforce during this next
phase of engagement with the delivery of a workforce engagement plan,
involving all providers and the local authority. The core communications
materials will be supplemented by tailored communications and toolkits that
will be used to engage and communicate to the whole workforce, across
health and social care.
Stakeholder engagement with organisations across the health economy will
also be strengthened in the next phase. There has already been strong
engagement with Trust Chairs and Chief Execs. Measures will be put in
place with each Trust to ensure that Boards, governors and senior
management teams are fully engaged with the programme.
As part of the resourcing for this key area of work and to strengthen
partnership working, a senior communications and engagement lead has
been seconded from a partner organisation to lead this workstream.
Healthy Liverpool is a whole system transformation programme that requires
high levels of public awareness, understanding and support if it is to
succeed. The communications strategy will use a broad range of channels to
ensure that the reach of our communications activity extends to all
demographics within our population and workforce.
A range of other communications mechanisms and channels will support
meaningful two-way communications, including:
Media Partnerships – over the last year we have commissioned media
partnerships with local print and broadcast media outlets through which we
have reached thousands of Liverpool people to raise awareness and
signpost to engagement opportunities. This will continue over the next phase
of engagement.
Social Media - over the last year we have significantly improved our profile
on social media and developed a strong following, which will continue to be
a key focus in the year ahead.
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10
Public Relations - our PR strategy incorporates proactive and reactive
elements, to both maximise the benefits of positive editorial coverage about
the programme and to mitigate the risks of negative attention, across local,
regional and national media. This will include a protocol around media
management with our NHS providers, Liverpool City Council and other key
partners, to ensure alignment and consistency of message. We will take a
risk-based approach to media management; with training on key themes for
clinicians, to ensure we articulate our messages effectively.
Insight and Social Marketing - Some elements of the Healthy Liverpool
programme lend themselves to the use of insight and social marketing
approaches to encourage a call to action and subsequent behaviour change.
For example, the physical activity programme includes a large scale
behaviour change marketing campaign which is built upon insight which his
currently being delivered.
6.2
Engagement Delivery
The next phase of engagement early in 2016 will adopt a number of
approaches:
Public meetings – a series of public meetings are scheduled; focusing on
different settings of care and including a city wide PPG meeting. Each will be
clinically-led.
Staff workshops – these will be a combination of system-wide
engagements to enable staff to share ideas across organisations; along with
organisation- specific and programme/project specific workshops. This
combination will provide engagement opportunities on a number of levels
and for tailored information to be targeted to relevant groups. Healthy
Liverpool engagement activities will also be integrated with existing
organisational engagement plans wherever possible.
Roadshows & Outreach – we will go to public places to engage people
about Healthy Liverpool, to complement the qualitative engagements taking
place. Venues will include places with a large footfall, including
supermarkets, sporting venues and large scale events.
We will also conduct roadshows to reach NHS staff in our hospitals and
health centres.
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11
Online engagement – this has become a key tool for ensuring we can
reach groups that would not be interested in participating in more traditional
approaches. The Engagement HQ web platform has been integrated into the
Healthy Liverpool and the CCG websites, enabling people to participate in a
range of ways for all Healthy Liverpool and wider CCG engagement
processes.
Community and Voluntary organisations – the CCG’s community
engagement partners are now well established and are conducting a
significant proportion of our engagement process; enabling us to
successfully reach individuals and communities that have previously been
difficult to access.
Governance and implementation structures – the formal Healthy
Liverpool governance and advisory structures are being used wherever
possible as mechanisms for engagement.
Partner organisation structures and activities – work is underway to
enhance and improve professional networks and access to influencers in
partner organisations.
6.3 Systematic and Inclusive Engagement
Over the last year robust, effective engagement has been embedded into
every work-stream and programme in the following ways:
• A fully established structured approach to planning engagement and
ensuring engagement and equality duties are met through a risk-based
approach as part of CCG governance processes;
• A volunteer public/patient recruitment & participation programme has
been developed over the last year;
• Greater support for GP practice Patient Participation Groups;
• Involvement of people and groups in shaping programmes for the three
Healthy Liverpool settings of care – Living Well, Community Services and
Hospital Services, as well as the six priority programmes – Cancer, Long
Term Conditions, Healthy Ageing, Children and Young people and
Learning Disabilities. In 2016 the Healthy Liverpool PMO will be
supporting a process to embed co-production into service redesign;
• Involvement in other service redesign components of the commissioning
cycle, including service specifications and procurement processes and
ongoing monitoring of contracts and service delivery.
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12
7 Partnerships for Delivery
Healthy Liverpool, although led by Liverpool CCG, is a partnership
programme involving the whole health and care system in the city. In the
context of engagement, this means there is an opportunity for Liverpool City
Council, NHS providers, the voluntary and community sector and other
organisations such as Housing Associations to become partners in
delivering the engagement programme as well as being key stakeholders.
For example, it is clear that Healthy Liverpool engagement with the NHS
workforce can only be delivered effectively with the full participation of the
large NHS provider trusts that employ the majority of NHS staff in the city.
Liverpool CCG is developing an effective partnership approach to
engagement with Liverpool City Council and will jointly plan engagement
processes and/or share engagement resources where appropriate. The
principle of ‘do once’ will be adopted wherever possible, utilising existing
engagement infrastructure including LCC’s Making it Happen Groups and
various Provider Forums as well as VCSE and employer networks,
Healthwatch, and specific fora such as Mental Health Consortia, Dementia
Action Alliance and housing association resident networks.
8 Conclusion
This refreshed version of the Healthy Liverpool Engagement and
Communications Plan includes new detail about further phases of
communications and engagement to be delivered in 2016, along with
updates on planned delivery over the last year.
ENDS
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13
APPENDIX 1 - Healthy Liverpool Stakeholder Plan
Stakeholder
Category
Stakeholder
group
Stakeholder
sub/specific group
Goals, motivations, and
interests
Influence
Interest
Action/
Win/win strategies
strategy
Internal
CCG
membership
Neighbourhood leads
– GPs and managers
Services that deliver what
they need for their patients
Trust that the programme
will deliver transformation
High
Medium
Key Player
More opportunities for active
engagement and
communications, informed by
channels that work – more
face to face and tailored
briefings.
Link secondary care clinicians
into neighbourhood leads
meetings
Internal
CCG Governing
Body and staff
To achieve the ambitions of
the HLP programme
Clinical decision-making to
drive change
People/patients to see and
feel tangible change and
improvement
Collaboration in design and
real joined up service
delivery
Step change in improved
outcomes
High
High
Key Player
Proactive and tailored HLP
staff communications – regular
briefings, floor meetings and
‘focus on’ specific projects.
14
66
NHS Partners and
Providers
Community
services
leadership
LCH
Key Player
Closely involve in development
of proposals and incorporate
into HLP governance
infrastructure for decisionmaking.
Ensure provider leadership
regularly briefed to show
evidence of planning,
ambition, progress.
Key Player
Closely involve in development
of proposals and incorporate
into HLP governance
infrastructure for decisionmaking.
Ensure provider leadership.
Regularly briefed to show
evidence of planning,
ambition, progress.
COOs, Locality
Medical Directors,
Nursing Directors, GP
leads
Merseycare
Local Authority
rd
3 Voluntary Sector
Private Social Care
Provider
NHS –
Partners and
Providers
Secondary
provider
executive
leadership
CEOs, DoFs, Medical
Directors, Nursing
Directors, Senior
management teams,
senior clinical teams
Improvements in patient
experience and outcomes
Sustainable provider
landscape
Clinical quality and
improvement
Involvement in the design
and process
Strong commissioning
leadership
Clarity of intention
Longer term planning for
stability
High
High
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67
NHS –
Partners and
Providers
NHS
Secondary
provider nonexecutive
leadership
Liverpool NHS
and social care
workforce –
Chairs, NEDs
Sustainable provider
landscape
Key Player
Risk management
throughout change
processes
Hospitals:
Registered qualified
Non registered
qualified
Other front line
Support staff
General Practice:
Managers,
Nurses,HCA,admin
Community:
Nursing,AHP,GP
Pharmacists
Dentists
Ophthalmologists
Pathway groupings
Security over their future
and greater stability
Sense of control
Pride in the NHS
Advocate for patients
Feeling they make a
positive impact
Clarity over plans for
change and their impact on
themselves and their
organisation
Regularly briefed to show
evidence of planning,
ambition, progress.
Explain how the risks are
being/will be managed
Meet their
needs
Proactive, tailored, regular
communications to all
Liverpool-based NHS staff.
Build NHS comms leads
network as the conduit to
workforce.
High
Medium
NHS staff roadshows as part
of the phase 3 and 4
engagement/consultation
programme.
Develop staff engagement
model within sub group of the
NW Social Partnership Forum
Use workforce sample for
listening event
Build bespoke arrangements
for staff engagement with each
Trust/organisation
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68
NHS
Staffside –
across local NHS
organisations
Need to contribute in
processes of change
For the needs of the
workforce to be considered
Protection of terms and
conditions
Protection of the NHS as a
public institution
Governance
Health &
Wellbeing Board
Strategic alignment across
the health and care system
Medium
Medium
Show
Consideration
Agree staffside engagement
model with providers.
Regular briefings.
Ensure they are formally
engaged and consulted in the
process.
Use of the sub group of the
NW Social Partnership
Forum?
High
High
Key Player
Regular/Standing item on
H&WB agenda.
Informal briefings and
communications to members
of the board.
Governance
and Partner
NHS England
Adherence to the formal
assurance process
Alignment with Specialised
Commissioning
intentions/priorities
Degree of political
interest/challenge
Public perception of the
programme/specific plans
High
High
Key Player
HLP assurance is a standing
item at quarterly meetings.
Close involvement at lead
officer level, with an action
plan re. assurance process.
Proactive briefings regarding
issues, risks.
Close involvement of Spec
Comm in HLP governance
(CIC) for hospital proposals
and decision-making.
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69
Governance
Liverpool Health
Overview and
Scrutiny
Committee
(OSC) and Select
Committee
Assurance over the
decision-making and
engagement/consultation
process
Impact on local service
provision
High
High
Key Player
Regular presentations to Adult
Health Select Committee,
which refers to OSC.
Agree engagement and
consultation process with OSC
and report regularly through
phases 3 and 4.
Briefings and comms to
members of committees.
Governance
and delivery
Partners
Healthy Liverpool
Programme
Boards
All CCGs in the
city region
Achieve the objectives of
the programme
South Sefton and
Knowsley
Other CCGs
Impact of HLP plans on
commissioned services in
their area – particularly
hospital services
Need to control
communications and
engagement with their own
population and stakeholders
High
High
Key Player
Review structures for potential
engagement gaps and fill
where appropriate.
Key Player
CCG colleagues in South
Sefton and Knowsley CCGs
involved in relevant HLP
working groups.
Involvement in development of
proposals and decisionmaking for hospital services as
members of CIC.
Regular briefings and comms
to CCG leadership and
broader membership.
18
70
Political
Partners &
Providers
MPs : Liverpool &
Neighbouring
Voluntary &
Community
sector, inc.
HealthWatch
Community Groups
Faith leaders
Heightened interest in preelection period
Alignment with party
policies/manifesto in relation
to health and social care
Public perceptions, support
or opposition to plans by
their constituents
High
Impact on communities they
represent or have an
interest in
Opportunities for
involvement or delivery of
services
Scrutiny of proposals –
Health Watch
Medium
High
Key Player
Quarterly face to face
meetings scheduled with
Liverpool MPs.
Pro-active briefing regarding
risks and issues.
Ensure MPs from
neighbouring areas have
opportunities to be briefed and
receive regular
communications. Agree
engagement approach with
the relevant CCG.
High
Meet their
needs
Involve in opportunities to
support engagement process.
Regular briefings and
communications.
19
71
Public &
Partners
Partners
Residents
Liverpool City
Council
What does it mean for me or
my family now and in the
future?
Perceptions – apathy,
support or opposition to
proposals
Want to see
tangible/understandable
plans
Public resources – is there
enough for the NHS to be
effective locally?
Access to services
Quality of services as they
are experienced
Support to stay well or
remain independent
Majority experience only
primary care
High
Strengthened partnership
joining health and social
care to improve services
and to support the resource
challenge in social care and
PH
Scrutiny function –
democratic accountability
Strategic approach, taking
in wider determinants of
health
High
Medium
Key Player
2016 – provide detail and
tangible benefits.
Social movement and
behaviour change approach
for self-care, Living Well,
person-centred care.
Engage using a wide range of
channels to maximise
involvement, inc. conventional
approaches, outreach and
digital.
Clarity of messages, adopting
insight and branding.
High
Key Player
Deep involvement in HLP
development and decisionmaking in terms of partnership
role.
Regular briefings and comms
to key players in LCC.
Communicate partnership in
HLP comms.
Adopt integrated approach to
engagement.
20
72
Partners
Liverpool Health
Partners
Need to be involved in
strategic development
linked to its core role
Conduit to broader
partnerships with research,
academic institutions
Medium
High
Meet their
needs
Consider how this relationship
can be developed for mutual
benefit.
Collaboration in marketing
Liverpool as a health
powerhouse.
Regular briefings and comms.
Partners
Academic
Institutions –
AHSNs,
Universities
Building partnerships for
city to become a health
sciences powerhouse
Low
Medium
Show
Consideration
Regular comms and
appropriate engagement.
Promote role of research in
HLP.
Create career pathways
across education,
manufacturing, research and
healthcare.
Partners
Local enterprise
Partnerships
Need to be involved to
support workforce
development
Partners
Housing
Associations
Interest in collaboration for
mutual benefit, for tenants
and communities
Deliverables that focus on
reducing health inequalities
and targeted support in their
communities
Conduit for engaging at
neighbourhood level
Medium
Medium
Meet their
needs
Engage in the context of
workforce development and
economic impacts.
Meet their
needs
RSL summit to agree a
strategic approach to
partnership with this sector,
which could support inequality
related programmes.
Explore ways to access their
tenants and communities for
comms, engagement and
targeting for programmes –
self-care, Living Well, Mi etc.
21
73
Partners
Political
Other
agencies/orgs
that could
support HLP Eg.
Schools,
Colleges, Sport
England, Police,
Fire Service etc.
Councillors
Central
Government
Departments
Partners
Organisations in
receipt of
community
grants
Involvement in HLP projects
that meet mutual goals
Medium
Medium
Meet their
needs
Identify and map all potential
non-health partners to settings
and programmes.
Regular communications and
appropriate engagement
approaches.
Ward Councillors for
areas of structural
change
Interested in impact of HLP
projects on their
communities and the city
Alignment with party political
policies
Medium
Medium
Meet their
Needs
Poor opinion of Liverpool
Health Economy due to
fragmentation
Developing relationship with
CCG as a funder
Supporting delivery where
appropriate
Regular HLP comms and
involvement in engagement at
city-wide and neighbourhood
level, including use of locality
forums.
Lobbying to influence
perceptions and support
Low
High
Show
consideration
Collaboration to promote their
delivery of programmes and
contribution to HLP outcomes.
Communications to
demonstrate grass
roots/community involvement
in HLP programme.
Governance
Monitor
Provider alignment for any
changes to FT services
Sustainability of providers
High
Medium
Meet their
needs
Regular face to face updates.
Pro-active contact on issues
and risks
Regular briefings and
communications.
22
74
Governance
Clinical Senate
Clinical Networks
Media
Liverpool Echo
BBC
Radio City,
Juice FM
HSJ
Municipal Journal
Guardian?
Panorama?
Clinical alignment within the
local system
Link to national policy,
reviews and standards
Part of the formal assurance
process for reconfiguration
Medium
Medium
Meet their
needs
Plan for assurance
requirements for the Senate
Agree communication
channels and frequency.
Topline headlines – public
interest
Interest in scale of change
and ambition
Interest in hospital changes
or perceived
contentious/politically
charged areas
Need for tangible details,
facts and figures
High
Medium
Meet their
needs
Pro-active media
management.
Face to face briefings with key
players.
Seek to develop media
partnerships on social
movement elements of
programme.
HLP media protocol to ensure
whole system approach to
media relations.
Strategic approach to
managing key messages,
issues and risks.
Pro-active media plan for
positive stories around delivery
and engagement.
23
75
Professional
Bodies
LMC
Impact of proposals on
primary care and the wider
system
Representative of GP
practices and individual GPs
Need to influence proposals
Professional
Bodies
Royal Colleges
Alignment with their own
strategic position in their
area of interest
High
High
Key Player
LMC involved in HLP planning
and developments.
Close consultation with LMC
key players.
Temperature checks on LMC
position.
Pro-active briefing on key
issues and risks.
Regular updates, face to face
and briefings to LMC
membership.
Medium
Low
Meet their
needs
Inclusion in HLP briefings and
communication updates.
Engagement on specific
proposals that link with RC
reviews/priorities/policies.
Meet their needs
• engage & consult on interest area
• try to increase level of interest
• aim to move into right hand box
Key player
• key players focus efforts on this group
• involve in governance/decision making bodies
• engage & consult regularly
Show consideration
• make use of interest through involvement in low risk areas
• keep informed & consult on interest area
• potential supporter/ goodwill ambassador
Least important
• minimum effort
•
•
inform via general communications
aim to move into right hand box
24
76
25
77
78
Report no: GB 05-16
NHS LIVERPOOL CLINICAL COMMISSIONING GROUP
GOVERNING BODY
TUESDAY 12TH JANUARY 2016
Title of Report
Corporate Risk Register Update January 2016
Lead Governor
Maureen Williams
Senior Management
Team Lead
Stephen Hendry, Acting Head of Operations &
Corporate Performance
Report Author
Joanne Davies, Corporate Services Manager
(Governance)
Summary
The purpose of this paper is to update the
Governing Body on the changes to the Corporate
Risk Register for January 2016
Recommendation
That the Governing Body:
 Notes the risks (CO15 and CO41b)
recommended for removal from the
Corporate Risk Register;
 Notes the two new risks added to the
Corporate Risk Register (CO52 and
CO53);
 Satisfies itself that current control
measures and the progress of action plans
provide reasonable/significant internal
assurances of mitigation, and;
 Agrees that the risk scores accurately
reflect the level of risk that the CCG is
exposed to given current controls and
assurances.
Impact on improving
The Corporate Risk Register provides evidence
health outcomes,
of the progress being made across the
reducing inequalities
organisation in the management of operational
and promoting financial and strategic risks against achieving improved
sustainability
health outcomes, reducing health inequalities
and financial duties/sustainability.
Page 1 of 8
79
Relevant Standards or
targets
The Health and Social Care Act states that:
“The main function of the governing body will be
to ensure that CCGs have appropriate
arrangements in place to ensure they exercise
their functions effectively, efficiently and
economically and in accordance with any
generally accepted principles of good
governance that are relevant to it.”
Page 2 of 8
80
Corporate Risk Register Update (January 2016)
1.
PURPOSE
The purpose of this paper is to highlight updates and amendments to the
CCG’s Corporate Risk Register and the key organisational responsibilities
for the mitigation of risks to the delivery of strategic, quality, performance
and financial objectives for the financial year 2015/16 and risks carried over
from the financial year 2014/15.
2.
RECOMMENDATIONS
That the Governing Body:
 Notes the risks (CO15 and CO41b) recommended for removal from
the Corporate Risk Register;
 Notes the two new risks added to the Corporate Risk Register (CO52
and CO53);
 Satisfies itself that current control measures and the progress of action
plans provide reasonable/significant internal assurances of mitigation,
and;
 Agrees that the risk scores accurately reflect the level of risk that the
CCG is exposed to given current controls and assurances.
3.
BACKGROUND
NHS Liverpool CCG aims to achieve its overall objectives, ambitions and
maintain its reputation via effective and robust risk management
procedures. As a public body, the CCG has a statutory commitment to
manage any risks that affect the safety of its employees, patients and its
commissioned, financial and business services by adopting a proactive
approach to the management of risk.
The Corporate Risk Register is a structured framework underpinned by
concepts of effective governance and other systems of internal control that
enable the identification and management of acceptable and unacceptable
risks. Opportunities for improvement in controls and assurances are
translated into action plans under specific named lead/managerial control so
that monitoring, tracking and reporting can be supported, with clear target
dates and milestones identified where appropriate.
Page 3 of 8
81
4.
OVERVIEW OF THE CORPORATE RISK REGISTER: JANUARY
2016
As at 4th January 2016 a total of 28 risks are recorded on the CCG’s
Corporate Risk Register. The CCG’s risk profile (low – extreme) is
summarised below:
Risk
Category
Score Range
Total
Risks
Change
+/-
Extreme
High
Moderate
Low
15-25
8-12
4-6
1-3
5
19
3
1
0
-2
0
0
Analysis of the direction of travel for risks since the last Governing Body
update (November 2015) can be summarised as follows:
▲
▼
►
Risk increased
Risk reduced
No change (static)
New risks
Total
Total
2
6
20
2
28
As with previous reporting periods, no ‘Extreme’ risks carry an acceptable
rating.
4.1 Overview of ‘Extreme’ Risks as at 4th January 2016
A total of four risks currently carry residual score ranges of 15-25, placing
them in the ‘Extreme’ category of risk against achievement of CCG
objectives.
Page 4 of 8
82
CO24a – Safe and effective delivery of health services by Liverpool
Community Health (LCH) to meet commissioning requirements
Review Date: March
Residual Risk Score 15
Trajectory ►
2016
This risk has been present on the Corporate Risk Register since March
2014 following CQC inspections in 2013 and 2014 which raised significant
quality and safety issues and resulted in enforcement action being taken
against the Trust. There has been no change in the trajectory since the
November 2015 Governing Body update, although established CCG control
measures and governance structures continue to mitigate and act as the
‘first line of assurance’ of remedial action plans and triangulation of risk.
Although the risk rating remains unchanged, Liverpool Community Health is
making good progress with its remedial action plans; particularly in relation
to the emerging issue concerning the Paediatric Speech & Language
Therapy service (the Trust had ceased accepting ‘new’ referrals into the
service due to capacity and demand issues within the Paediatric SALT
Team). In this regard the CCG is exploring other options for delivery of the
service (i.e. mixed models); recognising the growing demand for
assessments and the substantial impact of LCH’s capacity issues on
access/waiting times across a number of clinical pathways. Whilst exploring
alternative options, Liverpool CCG and LCH continue to work on
capacity/demand modelling to ensure longer-term sustainability (in
concordance with the TDA Transaction Board).
CO24b – Uncertainty of future LCH service provision as a
consequence of withdrawal from FT pipeline
Review Date: March
Residual Risk Score 15
Trajectory ►
2016
This risk was a new addition to the Corporate Risk Register on 1st
November 2015 and linked to CO24a (the original risk was split into two
sub-categories; CO24a relating to service quality and CO24b concerning the
sustainability of community health services). The risk score has remained
static and in the ‘extreme’ category as at 4th January 2015, which is relative
to the high strategic nature of the controls and assurances.
Although the Transactional Board maintains lead responsibility for the
eventual transaction of LCH services, the CCG continues to work closely
with the TDA and all stakeholders to ensure that the future needs of the
population and the delivery of the Healthy Liverpool Programme Community
Model are taken into account. A more detailed update on the progress of
Page 5 of 8
83
this risk (should it remain in the ‘extreme’ category) will be provided at the
March 2016 Governing Body meeting.
CO39 – Alder Hey ‘Red’ rating against Safeguarding Standards during
2013/14
Review Date: March
Residual Risk Score 16
Trajectory ►
2016
This risk has been included in the CCG Corporate Risk Register since
December 2014 and has remained static due to the continued
‘underperformance’ of the Trust against key Safeguarding Standards.
The continued inclusion in the Corporate Risk Register of this risk is driven
by the Trust’s under-performance each quarter. As previously reported, the
review of Alder Hey’s Quarter 1 data for 2015/16 did not show any
improvement and Liverpool CCG subsequently issued a contract notice to
the Trust in October 2015 which remains in place. Quarter 2 performance
was, at the time of writing this report still being analysed although early
indications are that there are signs of improvement. The Trust CQC report
published on 23rd December 2015 and relating to the visit conducted on 1516 June 2015 found that the majority of staff had completed Level 1
Safeguarding training but just over 50% had completed Level 3 (which is a
requirement for clinical staff).
Monthly meetings are currently being held with Alder Hey and a remedial
action plan produced to address and increase acceptable compliance levels
for numbers of staff attending training for all levels of Safeguarding Training.
Through the monthly meetings it has become evident that there is senior
leadership at organisational level for safeguarding standards. Contract
performance will continue to be closely monitored along with trust remedial
action plans, and the Contract Performance Notice will remain in place until
there is evidential assurance of sustained improvement against
Safeguarding Key Performance Indicators (KPI). The risk will therefore be
reviewed in March 2016 following thorough analysis of Quarter 2 data and
robust monitoring of the remedial action plan.
Page 6 of 8
84
CO51 – Total bed capacity within independent nursing homes is < 2%
of total bed capacity in city
Review Date: March
Residual Risk Score 20
Trajectory ►
2016
This is a relatively new risk included on the Corporate Risk Register in
November 2015. The ‘extreme’ rating is reflective of the severe lack of bed
capacity within independent nursing homes in the Liverpool City region
which equates to less than 2% of overall capacity. This presents multiple
system resilience risks such as delayed discharges/transfers from Acute
Care, increased demand on (already stretched) community resources
supporting nursing homes and, equally important, the very limiting effects on
patient choice.
Although the trajectory of this risk since inclusion in November 2015 has
remained static, this is quite reasonable to expect given it is a fairly recent
addition and that a high percentage of mitigating actions are designed for
longer-term sustainability. In the short to medium term however, nursing
home bed availability continues to be updated, monitored and shared daily
across the local health economy whilst the development of intermediate
care pathways (to prevent admission to permanent/temporary care) gathers
pace. A more detailed position statement on this specific risk will be
presented to the March 2016 Governing Body meeting.
4.2 ‘Extreme’ Risks Downgraded (as at 4th January 2016)
CO14b – Resolution of current and new CCG commissioned (2015 –
2016) Continuing Healthcare review and appeal cases
Review Date: March
Residual Risk Score 12
Trajectory ▼
2016
This risk has been included on the CCG Corporate Risk Register since 16th
April 2015 and relates to the lack of capacity within the North West
Commissioning Support Unit to deliver the core CHC Service; presenting
risks to the CCG’s delivery of this key statutory function and a high potential
for complaints/claims and financial remedy instruction from the
Parliamentary & Health Service Ombudsman.
This risk has been downgraded from ‘extreme’ to ‘since high the November
2015 Governing Body update as the Midlands and Lancashire CSU has
been selected as the ‘new’ provider and this completes the procurement
process against the Lead Provider Framework. The residual ‘high’ risk is
reflective of the challenges ahead in terms of the transition of CHC from the
Page 7 of 8
85
NWCSU to Midlands and Lancashire CSU. The early indications of the new
provider’s ability to deliver the core CHC service have been quite
encouraging, with a number of ‘positive’ meetings and workshops taking
place in December 2015 as all parties work through transition plans. The
risk will be reviewed again once the process is fully completed (aim of 1st
March 2016), and a decision made as to whether it is appropriate to
recommended removal at the March 2016 Governing Body meeting.
4.3 Risks recommended for removal by the Governing Body
Four risks are recommended for removal by the Governing Body as at 31st
October 2015. These are:
• CO29b – The contract query with the Trust has now been lifted (as at
22/10/2015);
• CO32 – The event (over-performance at RLBUHT) has happened and
negotiations around the impact of the event are ongoing;
• CO47 – The transition work is now complete. Contract monitoring of
service by LCC will take account of any cross border issues arising
and the impact;
• CO49 – Monitor advised the CCG that they will not be opening a
formal investigation in to the pricing enforcement complaint regarding
the pricing of CHC care home services. The CCG can consider the
matter closed and no further action will be taken at this time.
5.
SUMMARY
The Corporate Risk Register continues to be monitored on a monthly basis.
Action plans put in place against each risk identified are reviewed monthly
by the appropriate sub-committee of the CCG Governing Body with first-line
assurance of controls and actions conducted by the Senior Management
Team on a bi-monthly basis. Strategic risks to corporate objectives are
monitored on a monthly basis by the Senior Management Team. Where
legal issues arise from individual risks the Corporate Risk Register will
include plans to mitigate them. There are no inherent legal implications
associated with the Corporate Risk Register in January 2016.
Joanne Davies
Corporate Services Manager (Governance)
4th January 2015.
Ends
Page 8 of 8
86
LIVERPOOL CCG: CORPORATE Risk Register January 2016 (Jan 16 GB)
Ref
C011G
B
Organisational
Values &
Objectives
To hold providers of
commissioned
services to account for
the quality of services
delivered
Date Entered Objective
11/06/2013 Delivery of
commissioned
services to
patients by
Aintree
University
Hospital NHS FT
meets
commissioning
requirements
(service and
quality) and
compliance with
Monitor
'operating
licence'
Version: v2.0
Description of Risks Current Controls Assurance in Controls
Some aspects of
patient care and
service delivery
falling below an
acceptable and safe
standard and
commissioner
expectations
/standards. Trust in
potential breach of
Monitor 'operating
licence'
Formal
collaborative
commissioning
arrangements in
place with South
Sefton and
Knowsley CCGs.
AED and mortality
monitored via
CPQG (holding
provider to account
for service
delivery).
Single Item Quality &
Safety Group actions
and reports from QSG
continue to be
NHS England
monitored by
continue to monitor
via 'STAR Chamber' Collaborative
on a monthly basis. Commissioning Forum
& reported to
Governing Body by
Mortality Action
Plan remains in
exception.
place monitored via
CQPG/
Collaborative
Commissioning
Forum (CCF).
87
Monthly reporting to
Governing Body;
regular reporting
through Regional
Quality Surveillance
arrangements;
CCF reviews action
plans at each meeting.
L
Current Current
Management Actions re gaps in controls
C
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
4
5
20
N
Monthly meetings now in place to address Star
Chamber Action Plan / Tripartite. DTOC and
medically optimised patients remain
problematic. Operational issues identified in
Clock View - Completion of Mental health
Assessmentsand delays in AED as a
consequence. System Resilience Group taking
this issue forward. The national CQUIN for AED
will also support mental health and acute
providers in understanding the challenges and
barriers when patients attend AED as the first
point of call.
L
Residual
Lead Completion Review
C
Risk
Officer Date
Date
(score)
3
3
9
KS
Monthly
review via
CPQG/ QSG
Mar-16
Progress
since last
update
▲
CCG has part funded the implentation of
Medworks system and this is currently in
progress.
Linked to Risk CO37
Phased roll out of Medworks across the Trust
from January 2016 to help support improved
intelligence regarding patient flow. The Trust
continues to fail the A&E 4hr target and work is
ongoing with the Trust, CCG and NHS England.
There have recently been a seroes of 12hr
trolley wait breaches and again the CCG and
NHS England are working with the Trust to fully
understand their internal escalation processes.
Increased scrutiny of performance is in place.
1
Ref
CO14
Organisational
Values &
Objectives
We will act with
honesty and
transparency in all our
actions. We are
committed to a
teamwork
environment, where
every member of the
CCG is valued,
encouraged to
contribute and
recognised for their
efforts.
88
Date Entered Objective
29/07/2013 Resolution of all
outstanding
Continuing
Health Care
restitution,
review and
appeals cases
Description of Risks Current Controls Assurance in Controls
L
C
Financial risk from
cases (financial
settlements and
interest);
reputational risk due
to significant delays
to resolution;
Formal Ombudsman
investigation into
delays.
'Remodelling' has
seen increase of
52% in likely 'panel'
cases and potential
increase in financial
liability from £2.4M
to £4M. (under
current rules CCG
liability is limited to
£2.8M, subject to
change
4
4
CSU
commissioned to
manage all
outstanding cases
and to clear the
backlog/legacy
cases - it is now
expected that all
claims will not be
cleared before
2016/17
Monthly progress
reports from CSU,
complaints monitoring
Risk reviewed bimonthly with
exception reporting to
Governing Body via
FPCC if risk increases/
decreases.
Monitored and assured
via monthly contract
The CCG
meetings with CSU;
continues to work oversight by CCG Chief
with the CSU to
Nurse)
ensure that the
current work plan
and performance
target for
processing claims
is met whilst a
long-term
solution is sought.
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
16
N
The new provider is Midlands and
Lancashire CSU and mobilisation has
commenced with service transition being
completed by 01/03/2016.
L
C
3
4
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
12
JL / ID
Mar-17
Mar-16
Progress
since last
update
►
A number of meetings and workshops have
taken place with the new provider where
the CCG has been assured plans are
underway to provide stability and
improvement to processes once the
newCSU is mobilised from 01/03/2016.
2
Ref
CO14b
Organisational
Values &
Objectives
We will act with
honesty and
transparency in all our
actions. We are
committed to a
teamwork
environment, where
every member of the
CCG is valued,
encouraged to
contribute and
recognised for their
efforts.
Date Entered Objective
16/04/2015 Resolution of
current/new
(2015/16) CCG
commissioned
Continuing
Health Care
review and
appeals cases
under core
service
Description of Risks Current Controls Assurance in Controls
L
C
CSU lacks capacity and
adequate resources to
deliver core CHC
service, with
significant reliance on
bank staff temporary
bank staff and lack of
leadership capacity.
High potential of
increasing backlog of
cases for financial
years 2014/15 and
2015/16 leading to
poor service delivery,
complaints and
criticism and/or
financial remedy
instruction from
Health Service
Ombudsman
3
4
Linked to Risks CO14,
CO40
89
Monthly Contract Risk reviewed biMeetings with
monthly with
CSU
exception reporting to
Governing Body via
Monthly progress FPCC if risk increases/
reports from CSU, decreases.
complaints
monitoring; CCG
has initiated an ongoing review of
Health Service
Ombudsman
findings
(nationally) to
identify areas for
learning and
improvement of
internal
processes.
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
12
N
The new provider is Midlands and
Lancashire CSU. Mobilisation has
commenced with transition being
completed by 01/03/2016.
L
C
3
4
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
12
JL
on-going
Mar-16
Progress
since last
update
▼
A number of meetings and workshops have
taken place with the new provider where
the CCG has been assured plans are
underway to provide stability and
improvement to processes once the
newCSU is mobilised from 01/03/2016.
The CCG is currently above the trajectory for
delivery of PUPOC (Previously Unassessed
Periods Of Care) cases and should finish
before the forecast of September 2016.
3
Ref
CO15
Organisational
Values &
Objectives
To hold providers of
commissioned
services to account for
the quality of services
delivered
Date Entered Objective
06/08/2013 CCG use and
reliance upon
quality and
timely
performance
data
Description of Risks Current Controls Assurance in Controls
Poor quality data
leading to
inaccurate
monitoring and
assessment of
providers,
operational and
financial risk
CSU is
commissioned to
provide business
intelligence support
including data
processing and
validation.
CSU held to account
for delivery of data
required standard
quality matters
raised at monthly
performance
meeting with CSU
leadership
Data issues with
individual providers
being taken up via
contract meetings.
'in house' analyst
capacity increased
to review data
accuracy and
mitigate risk
90
L
C
Monthly performance 4
meetings with CSU escalation to Finance &
Procurement
Committee by
exception with
oversight by Governing
Body
5
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
20
N
Specifications for the 'new' service have
been released and through the lead
provider framework a new provider is
currently being procured.
L
C
3
3
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
9
TJ/ID on-going
Dec-15
Progress
since last
update
▼
Data issues continue to be experienced
during this transition period and the CCG in
house team continues to take action to
mitigate this impact.
As part of the Lead Provider Framework
being undertaken by NHS England LCCG has
inhoused aspects of reporting to the BI
Team. This has now been completed and
the member of staff has TUPE across to the
CCG from 01/10/2015.
Linked to risk number CO40
It is recommended that this risk is
removed from the Corporate Risk
Register and the activities / performance
will be monitored as part of normal
business routine.
4
Ref
CO18
CO19
Organisational
Values &
Objectives
We accept
responsibility for
our actions. We
make and
support business
decisions
through
experience,
evidence and
good judgement,
and we will
deliver against
our promises
To maximise
value from our
financial
resources and
focus on
interventions
that will make a
major
difference
91
Date Entered Objective
01/10/2013 Deliver the
transformation
of health and
health & care
services across
the city through
the Healthy
Liverpool
Programme
01/12/2013 To agree with
Liverpool City
Council the
'Better Care
Fund' (formally
Integration
Transformation
Fund) for 201416, including
individual
schemes,
outcomes and
performance.
Description of Risks Current Controls Assurance in Controls
Failure to agree
model of care;
establishment of
programme leads
and infrastructure;
delivery of the
transformational
programme; failure
to communicate and
engage with
stakeholders and to
gain understanding
and support for the
programme;
reputational risk due
to high profile of
NHS change and
reconfiguration
programmes.
Programme
Advisory Board
established;
Governing Body
commitment to
HLP; officer-led
delivery group in
place; Additional
senior resource
sourced to manage
communication,
stakeholder
management and
engagement.
Clinically-led
settings and
programme groups
in place;
Failure to agree with
the City Council the
investment schedule
and associated
outcomes, including
the performance
element of the
Fund, threatening:
'retention' of the
BCF resources in the
City; service delivery
and continuity; and
relations with the
City Council
Section 75
agreement in
place with LCC
List of Programme
roles necessary to
mobilise produced
with prioritisation
of roles assessed to
mitigate risks to
delivery.
SDC completed and
approved by
Governing Body on
29/09/2015.
L
C
2
5
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
10
Y
NHS England service
change and
reconfiguration tracker
(formal assurance
process)
Progress
since last
update
C
2
5
10
NF, KS On-going
Mar-16
►
1
5
5
KS, TJ & On going
TW
Mar-16
►
HLP PMO fully established and resourced.
Governance infrastructure also established.
MiAA review of
governance
arrangements to
oversee the delivery of
the Healthy Liverpool
programme included in
CCG Audit Plan
2015/16
The CCG plan has been 2
externally assessed
and "Approved with
Support" by NHS E and
determined as putting
National guidance the CCG in a strong
position to meet the
published &
challenges in delivery
embedded in
with no high areas of
CCG.
risk.
Negotiations with
LCC led by the
Chief Finance
Officer, regular
updates to SMT
and, briefings to
Governing Body.
Enhanced arrangements in place effective
from 1st June 2015 that significantly
galvanise the support to HLP. Key
developments include the designation of
Clinical Leads and Senior Responsible
Officers (SRO) for each Transformational
Programme and creation of Programme
Management Office (PMO) model.
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
L
The Blueprint, published in November 2015,
sets out clear models of care and detailed
plans.
HLP Engagement and Comms Plan refreshed
in January 2015. Plan sets out detailed
actions for the year ahead.
5
10
Y
Risk continues to be monitored/managed as a
strategic risk in 2015/16 due to the continued
challenges and risks faced by CCG in reducing
Emergency Admissions.
Identified and recruited resource within the
finance team to perform a mapping exercise
across all elements of the Better Care Fund
and this will give assurance around
responsibilities and obligations for the CCG
and LA. This exercise is expected to be
completed by March 2016.
5
Ref
CO23
Organisational
Values &
Objectives
We accept
responsibility for
our actions. We
make and
support business
decisions
through
experience,
evidence and
good judgement,
and we will
deliver against
our promises
CO24a To hold providers
of commissioned
services to
account for the
quality of
services
delivered
92
Date Entered Objective
06/01/2014 To deliver
effective
information
governance
processes
01/11/2015 Delivery of
commissioned
services to
patients by
Liverpool
Community Health
meets
commissioning
requirements
(service and
quality)
Description of Risks Current Controls Assurance in Controls
L
C
Failure to comply
with requirements
of the Information
Governance Toolkit
leading to
restrictions placed
on the CCG on the
handling of weekly
psuedomynised
data, adversely
affecting key
business functions
MIAA is
supporting the
CCG in meeting
the level 2
requirements of
the Toolkit.
IG Steering Group in
1
place with formal &
approved Terms of
Reference - exception
reporting to Governing
Body via minutes.
4
Provider unable to
deliver safe and
effective services to
local residents
(concerns raised in
CQC Inspections in Oct
13 and May 14)
CCG Collaborative
Forum established
with other
commissioners of
services from LCH,
CPQG has new GP
chair and format of
agenda includes
'deep dives' into
areas of potential
concern and
oversight of the
remedial action
plan. Regular
assurance updates
to Merseyside QSG
(inc. pressure ulcer
reporting levels)
CPQG, reporting to
Governing Body and
Chief Officer; regular
reporting through
Regional Quality
Surveillance
arrangements
4
Trust remedial actions
monitored and
followed up through
the regular Clinical
Quality and
Performance meetings exception reporting to
QSOC & Governing
Body.
4
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
4
Y
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
L
C
IG Steering Group met in December 2015 1
assured that 'Level 2' is achievable and
there is a realistic ambition to achieve 'Level
3' for 2015/16.
4
4
TJ
5
20
JL
Mar-16
Progress
since last
update
Mar-16
►
Mar-16
►
Remains on CRR as a strategic risk until end
of financial year 2015/16 & submission of
IG Toolkit
16
N
CCG continues to gain assurance against the delivery of
the service improvement plans and resolution of specific
quality/safety issues through established control
mechanisms.
4
Monthly
review via
CPQG/ QSG
The recent cessation of referrals into the SALT service is a
matter of concern and officers are working with LCH to
assess the scale and scope of the problems in the service
and to explore urgent remedial action.
LCH are continuing to make steady progress with their
remedial actions in relation to Paediatric Speech and
Language Therapy, however, they are still not processing
new referrals. We are looking at other options including
private providers to supplement what the service can do
themselves. Alongside this, LCH are working on capacity
and demand modelling for future sustainability based on
demand, which continues to grow.
Full data cleanse exercise almost complete. Children
have been moved in to cohorts depending on their
needs. For cohorts currently not receiving treatment or
intervention a business case has been written to tackle
the backlog of cases over the next 12 months using a
mixed model of LCH staff and the private sector.
6
Ref
Organisational
Values &
Objectives
CO24b To hold providers
of commissioned
services to
account for the
quality of
services
delivered
CO26
QSOC
To hold providers of
commissioned
services to account for
the quality of services
delivered
93
Date Entered Objective
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
Description of Risks Current Controls Assurance in Controls
L
C
01/11/2015 Delivery of
Uncertainty of future
service provision as a
consequence of
withdrawal from the
FT pipeline and the
need to transact
services to a new
provider(s) by
01/04/2017
TDA have assumed
lead responsibility
for planning and
transacting the
transfer of services
to an alternative
provider(s). LCCG
has been a full
member of the
Sustainability Board
which reported to
the TDA Board in
Oct 2015. This has
now been replaced
by a Transactional
Board charged with
implementation of
the plan to transact
services to a new
provider(s)
CCG Chief Officer /
Chief Finance Officer
are full members of
the TDA led
Transactional Board
4
5
20
N
12/03/2014 Delivery of
commissioned
services to
patients by Alder
Hey NHS FT
meets
commissioning
requirements
(service and
quality) and
compliance with
Monitor
operating licence
Concerns raised as
to the safe and
effective delivery of
services to local
residents from
Whistleblowing
allegations
regarding theatre
staffing and sickness
levels and from
recent CQC
inspection.
Specialist
Commissioners
and CCGs working
together to
understand the
concerns raised
and determine
with the Trust a
sustainable
improvement
plan.
LCCG part of
Collaborative
Commissioning Forum
CCF) which oversees
workstreams to
address quality and
safety concerns
3
4
12
Y
commissioned
services to
patients by
Liverpool
Community Health
meets
commissioning
requirements
(service and
quality)
Specific issues re:
Theatre and
Whistleblowing have
now been addressed
and sustainability of
improvement continue
to be monitored
through CQPG
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
L
C
The CCG's Senior Management Team
continue to coordinate the necessary steps
and actions to define the future needs of
the CCG (taking in to account HLP
Community), with leads identified to work
alongside the TDA as the transactional
process progresses.
3
5
15
DR
Follow-up visit by CQC took place in June 2015 - report
published on 23rd December 2015.
2
4
8
JL
Trust received overall rating of 'Good' and ratings of
'Good' for Medical Care, Surgery, Critical Care and
Transitional Services. CQC determined that
Outpatients and Diagnostic Imaging 'Requires
Improvement'. Report found that the trust had
significantly improved the levels of nursing and that
medical support for the HDU had also significantly
improved, however there were several areas of poor
practice where the trust was required to make
improvements.
Monthly
review
Ongoing Monthly
review via
CPQG/ QSG
Progress
since last
update
Mar-16
►
Mar-16
►
Quality Summit has taken place and an action plan is
being formulated. The findings of the CQC inspection
and action plan will be monitored by CQPG.
Risk score will remain unchanged until report is
discussed by CCF & CPQG and appropriate remedial
action plan agreed.
7
Ref
CO29
Organisational
Values &
Objectives
To hold providers
of commissioned
services to
account for the
quality of
services
delivered
Date Entered Objective
01/06/2014 Delivery of the
commissioned 4
hour target in
AED to patients
by Royal
Liverpool &
Broadgreen
University
Hospitals NHS
Trust meeting
the
commissioning
requirements
(service and
quality) and
compliance with
TDA
requirements
Description of Risks Current Controls Assurance in Controls
Failure to meet the
95% 4 hour target in
AED 2014/15,
leading to patients
potentially receiving
delayed care and
treatment.
Remedial Action Plan in
place; previous 'contract
query' remains open and
subject to fortnightly
review.
Contract Query closed
November 2015 as
RLBUHT had completed
all actions albeit type 1
performance continued
to be challenged. The
CCG continues to work
closely with the Trust in
order to secure
sustainable delivery of
the 4hr Target (including
Type
CCG internal Trust
oversight group and
contract review meetings
continue in 2015/16 as
per established control
measures.
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
L
C
4
Current remedial
action plan monitored
through the formal
contract query process
and by the TDA.
4
16
N
3
12
N
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
L
C
Delivery of performance (all types) is still a
possibility for the financial year. However,
November 2015 data shows that RLBUHT is
underperforming at 92.1%.
2
4
8
ID
Trust was meeting RTT targets as at 30th
November 2015 with performance at 92.2%
and zero patients waiting in excess of 52
weeks.
3
3
9
JL/DR
Ongoing
Progress
since last
update
Feb-16
►
Mar-16
►
Agreement with NHS
England that RLBUHT
performance can take
into account Walk-in
Centre activity
Governing Body
Corporate
Performance Report
provides
updates/assurance on
CCG controls on a
monthly basis
RLBUHT Overview &
Scrutiny meetings
continue where
operational internal
issues / changes are
discussed.
CO34
To hold providers of
commissioned
services to account for
the quality of services
delivered
94
29/08/2014 Delivery of RTT
waiting times in
line with NHS
Constitution and
contractual
requirements at
Alder Hey NHS
Foundation Trust
Failure to agree and
implement elective
care operational
resilience and
capacity plan
Elective care
operational
resilience and
capacity plan
submitted to NHS
England by the
Trust as required.
4
Trust plan has been
subject to external
review by the NHS
IMAS Elective Intensive
Support Team
Governing Body
receipt of monthly
Corporate
Performance Report
provides oversight of
provider performance
and assurances of CCG
controls
Ongoing
There have been no patient safety incidents
reported as a result of the move.
8
Ref
CO35
CO36
Organisational
Values &
Objectives
To hold providers of
commissioned
services to account for
the quality of services
delivered
To hold providers of
commissioned
services to account for
the quality of services
delivered
95
Date Entered Objective
13/10/2014 Delivery of the
commissioned 4
hour target in AED
to patients by
Aintree University
Hospital NHS
Foundation Trust
meeting the
commissioning
requirements
(service and
quality) and
compliance with
Monitor
requirements
13/10/2014 Delivery of
commissioned
services is able
to meet likely
adverse weather
and 'winter'
demands
2015/16 (risk
from 2014/15
financial year
transferred to
current)
Description of Risks Current Controls Assurance in Controls
Failure to meet the
95% 4 hour target in
AED 2015/16,
leading to patients
potentially receiving
delayed care and
treatment.
Remedial Trust
plans in place;
Current remedial
action plan monitored
through the formal
Contract Query
contract query
remains in place as process, Collaborative
at Jul 15 and is
Commissioning Forum
subject to
(CCF) and by Monitor
fortnightly review.
Trust performance
reviewed by
Collaborative
Commissioning
Forum and System
Resilience Group
to gain assurance
for improved 4hr
performance for
2015/16
Failure to meet
patient demand
leading to a fall in
performance and a
potential adverse
impact upon service
responsiveness and
quality
Additional
national and local
resources
released to
enhance and
strengthen
service resilience
and capacity.
L
C
4
4
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
16
N
Trust performance against 4hr A&E standard
during Q1 of 2015/16 improved but this has not
been sustained. Current position as at 30th Nov
2015 shows AUHT is underperforming (inmonth) at 88.0% (Red).
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
L
C
3
4
12
ID
3
4
12
ID
Ongoing
Progress
since last
update
Feb-16
►
Feb-16
►
NHS England continue
to monitor via 'STAR
Chamber' on a
monthly basis.
Oversight of the plans
via the CCG Urgent
Care Team and the
North Mersey System
Resilience Group.
3
4
12
Y
The North Mersey SRG repeated its
assurance process post-October 2015 and
was still classified by NHSE as 'not assured'.
The prime areas of concern revolve around
Discharge and Patient Flow.
Ongoing
Mersey Internal Audit
Agency (MiAA)
commissioned by CCG
North Mersey SRG to strengthen
performance
has agreed the
management and
allocation of
monitoring of winter
baseline
schemes in-year. Risk
resources for
winter 2015/16. score remains
unchanged for
2015/16 financial year
9
Ref
C038
C039
Organisational
Values &
Objectives
To hold providers of
commissioned
services to account for
the quality of services
delivered
To hold providers of
commissioned
services to account for
the quality of services
delivered
96
Date Entered Objective
Description of Risks Current Controls Assurance in Controls
L
C
09/12/2014 Delivery of
commissioned
services to
patients by
Liverpool
Women's NHS
Trust meets the
required
standard in
terms of quality
& safety in
compliance with
safeguarding
standards
The Trust had an
overall Red RAG
rating on
Safeguarding
Standards during
the last 3 quarters of
2013/14 contractual
year.
On-going
reporting to
CQPG;
Reporting by CCG
Safeguarding
Service into
QSOC;
Trust required to
report against
safeguarding KPIs
on a quarterly
basis to the CCG
Safeguarding
Team with
remedial actions
agreed by group.
Exception reporting from 5
QSOC to Governing Body;
Chief Nurse Update
standing agenda item for
all Governing Body
Meetings ;
Safeguarding supervision
provided to the Head of
Safeguarding via the CCG
Safeguarding Service
Leads. Regular monthly
meetings with LWH
shows progress in
addressing the issues:
new head of
safeguarding in post with
support staff and
complete review of
systems, processes and
governance re
safeguarding
4
09/12/2014 Delivery of
commissioned
services to
patients by Alder
Hey Children's
Hospital NHS
Foundation Trust
meets the
required
standard in
terms of quality
& safety in
compliance with
safeguarding
standards
The Trust had an
overall Red RAG
rating on
Safeguarding
Standards during 3
quarters of 2013/14
contractual year.
On-going
reporting to
CQPG;
Reporting by CCG
Safeguarding
Service into
QSOC;
Trust required to
report against
safeguarding KPIs
on a quarterly
basis to the CCG
Safeguarding
Team with
remedial actions
agreed by group.
Exception reporting
from QSOC to
Governing Body;
Chief Nurse Update
standing agenda item
for all Governing Body
Meetings ;
Safeguarding
supervision provided
to the Head of
Safeguarding via the
CCG Safeguarding
Service Leads.
4
4
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
20
N
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
Progress
since last
update
L
C
3
4
12
JL
On-going
Mar-16
►
4
Quarter 1 data showed little or no
improvement. Contract performace notice
issued mid October and LCCG will work with
the Trust to support improvement.
4
16
JL
On-going
Feb-16
►
LCCG / safeguarding service continue to work
closely with the Trust to sustain improvement
trajectory.
Still awaiting formal evaluation of Q2 data, but
appears to show some improvement.
16
N
Monthly meetings are now being held with
the Trust and a remedial action plan is being
developed as a result with a trajectory of
the number of staff requring training for
each level of safeguarding.
Senior leadership regarding safeguarding at
an organisational level is now evident.
10
Ref
CO40
CO41a
Organisational
Values &
Objectives
To hold providers of
commissioned
services to account for
the quality of services
delivered
To hold providers of
commissioned
services to account for
the quality of services
delivered
97
Date Entered Objective
27/01/2015 Effective
provision of
commissioning
support services
to the CCG
27/01/2015 Effective
provision of
commissioning
support services
to the CCG and
primary care
contractors.
Description of Risks Current Controls Assurance in Controls
The NWCSU has
failed to secure a
place on the
national framework
agreement. This has
the potential effect
of their services
ceasing to be
available to the CCG
by the end of
2015/16 and the
CCG required to find
alternative means of
providing the
support services
commissioned from
the CSU.
Service Level
Agreement /
Contract in place
with the NWCSU
to provide support
services including
(Business
Intelligence,
continuing and
complex heath
care management,
EPRR, comms,
UCAT)
CCG has reviewed
commissioning
support service
requirements
going forward and
Transition Plan is
now in place.
Monthly performance
monitoring of current
service delivery,
including monthly
'scoring' of individual
service delivery
elements.
National
outsourcing of
primary care
support services
from 1st July 2015
will leave a gap in
provision which is
detrimental to the
CCG and local
primary care
contractors with
regard to delegated
commissioning of
primary care
medical services.
Standing agenda
item for Finance,
Procurement &
Contracting
Committee and
Primary Care
Commissioning
Committee
Limited assurance on
control measures due to
uncertainty in terms of
gaps.
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
L
C
5
2
10
3
3
9
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
L
C
Y
Transition meetings scheduled and attended 3
by LCCG. Multi CCG meeting with Midlands
and Lancashire CSU 11th December 2015.
CSU staff will commence TUPE transfer Dec
2015 to Feb 2016. Transition plan to be
agreed with Midlands and Lancashire CSU.
2
6
DR
N
Primary Care Team strengthened in anticipation of increased
workload.
3
4
12
AO/ CM
Ongoing
Progress
since last
update
Mar-16
►
Feb-16
▲
Mersey CCGs are
continuing to work
collaboratively to
ensure delivery in the
short term.
Ongoing
LMC and Head of Primary Care Quality and Improvement
attending local stakeholder forum monthly.
Minutes of committee
meetings & exception
reporting to Governing
Body
Head of Primary care Quality and Improvement was put
forward and has been accepted for the expert panel for PCS.
NHS England awarded
contract (22 Jun 2015) to
Capita to establish a
'single provider
framework' for primary
care administrative
support functions
Representatives of LCCG Finance and NHS England Finance
Teams meet regularly to discuss the provision of financial
data and address queries which the CCG may have.
Arranging stakeholder sessions with practices ear;y 2016 with
LMC.
Transformation timetable has been produced by Capita
demonstrating significant challenges to delivery of services
post April 2016. Additional representation to be sought from
healthwatch and member practices to attend local
stakeholder forum to ensure local issues are raised at a
national level.
11
Ref
Organisational
Values &
Objectives
Date Entered Objective
CO41b To hold providers 01/04/2015 Effective
of commissioned
provision of
services to
commissioning
account for the
support services
quality of
to the CCG and
services
primary care
delivered
contractors.
CO42
To maximise value
from our financial
resources and focus
on interventions that
will make a major
difference.
To hold providers of
commissioned
services to account for
the quality of services
delivered
98
27/01/2015 To accept from
NHS England
delegated
responsibility for
the
commissioning
of primary care
medical services
Description of Risks Current Controls Assurance in Controls
National
outsourcing of
primary care
support services due
to take effect from
1st July 2015; new
contract restrictions
took effect from 1st
April 2015. will
leave a gap in
provision which is
detrimental to the
CCG and local
primary care
contractors with
regard to payments
for local enhanced
services.
Standing agenda
item for Finance,
Procurement &
Contracting
Committee and
Primary Care
Commissioning
Committee
That the CCG
acceptance of
delegated authority
to commission
primary care
medical services
progresses without
a full and proper
due diligence
exercise to assess
the potential risks
including financial,
staffing and any preexisting liabilities to
the detriment of the
CCG.
Transition Group
in place with
approved Terms
of Reference and
meeting on
weekly basis.
L
C
5
Limited assurance on
control measures due
to uncertainty in terms
of gaps.
3
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
15
N
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
L
C
3
Primary Care Transition Group in place.
Action plan includes quantification of impact
of out of scope functions
3
12
4
12
AO/ CM
Jul-15
Progress
since last
update
Dec-15
►
Feb-16
►
LCCG is attending the Merseyside Primary
Care Finance Transition Group with other
CCGs and NHS England.
Minutes of committee
meetings & exception
reporting to Governing
Body
LCCG Finance Team have set up payment
methods for contingency purposes to make
payments locally as appropriate.
A 'workaround' for this has now been found.
Initially this was a manual process. Regular
payments are now going through. It is
recommended that this risk is now
removed.
Exception reporting to
the Governing Body
through Transition
Group and Primary
Care Commissioning
Committee
Primary Care Co- CCG has signed the
Commissioning
Scheme of Delegation
Manager in post with NHS England and
confirmation
assurances from the
Director of Finance,
NHS England Cheshire
& Merseyside SubRegional team that
there is sufficient
resource.
4
4
16
N
3
The Primary Care Commissioning
Committee is fully established and has
formally convened twice in Q1. Process and
guidance in relation to delegated
commissioning responsibilities continues to
evolve. Risk will be re-assessed in Nov 2015.
KS / TJ Ongoing
Issues that remain include NHS England
resources, finance and confirmation of
accountability relating to counter fraud and
information governance.
Service Level Agreement to be developed
ready for April 2016 confirming
responsibility and assurance of the
remaining risks / issues.
12
Ref
Organisational
Values &
Objectives
Date Entered Objective
CO42b To hold providers 16/04/2015 To accept from
of commissioned
NHS England
services to
delegated
account for the
responsibility for
quality of
the
services
commissioning
delivered
of primary care
medical services
CO45
To maximise value from
our financial resources
and focus on
interventions that will
make a major difference
99
16/04/2015 Mental Health
Access Waits waiting time
standards
for people
entering a
course of
treatment in
adult IAPT
services.
Description of Risks Current Controls Assurance in Controls
L
C
Acceptance of
delegated authority
to commission
primary care
medical services
potentially does not
allow for necessary
timescales for reprocurement of 12
Liverpool APMS
practices (current
provider SSP) once
contract expires on
31st March 2016.
Risks are that
decision to either
extend or cease the
contract without full
and proper
consultation could
impact negatively
on service delivery
to patients
Standing agenda
item on Primary
Care
Commissioning
Committee
5
4
Transfer of service to
new provider on 1st
April 2015 revealed
inherited backlog of
an estimated 1,700
patients waiting for
IAPT treatment.
Patients waiting to be
seen at Step 2 and
Step 3 (the majority
are Step 3) and
although clinical risk is
relatively low, it is
unlikely that the CCG
will be able to deliver
against IAPT waiting
time contract
standards for this
cohort of patients,
which could result in
negative impact on
individual patients and
lead to public/media/
MP scrutiny. The
waiting list also needs
to be addressed
effectively to ensure
the CCG is compliant
with 2015/16 IAPT
waiting time
Contract
performance notice
issued on 28th
September 2015 in
respect of the Talk
Liverpool
performance.
4
Contract Review
Meetings with
exception reporting to
Governing Body on key
risks & progress with
actions to reduce waits
New'
patients/referrals
will be monitored
against IAPT
standards
separately from
those on inherited
waiting list to
ensure
proportionate
provider delivery
against standard
and monitor
progress of
recovery plan to
address backlog.
CCG working
collaboratively with
NHS England IAPT
Intensive Support
Team to ensure robust
recovery plan is
delivered
Interim Provider
Policy has been
developed
approved by the
Primary Care
Commissioning
Committee (June
2015).
5 practices being
extended until
April 2017. 7
practices require
interim provider
by April 2016 and
plans are in place
to ensure robust
provider in place
by that date.
Exception reporting
from PCCC to
Governing Body
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
20
N
Practice contracts
continue to be
monitored via normal
reporting processes
Funding secured from
CCG and NHSE.
Agreement has been
reached that the Trust
will be paid on a cost
per case basis for
waiting list activity
over and above its
contracted activity.
Interim provider policy successfully
implented for 2 practices which
demonstrates the document is fit for
purpose.
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
L
C
3
4
12
3
4
12
CM/DR on-going
Progress
since last
update
Mar-16
►
Mar-16
►
Expression of Interest received on 11th
December 2015. Review of EOI will
determine the CCG's course of action with
regards to working with GP colleagues for
submitting bids for those practices.
Deadline for bids is 20th January 2016.
4
16
N
Exception report re: IAPT waiting & access
times performance included in December
2015 Corporate Performance Report. Since
the transfer of the contract the waiting list
has reduced by 511 patients (as at 1st
December 2015).
JL
Mar-16
Mersey Care Trust have recruited additional
staff to deliver treatment at step 2 and 3.
Also subcontracted arrangement to clear
backlog of counselling (Listening Ear). This is
expected to reduce backlog.
The remedial action plan, its
implementation and impact continue to be
monitored via contract review meetings.
13
Ref
CO46
Organisational
Values &
Objectives
To build successful
partnerships which
promote system
working and
integrated service
delivery
Date Entered Objective
16/04/2015 Maintain safe &
effective
Vaccination &
immunisation
provision for
local patients
Description of Risks Current Controls Assurance in Controls
Transfer of
Vaccination &
Immunisation
provision to General
Practice could lead
to reduced uptake
across the city as
not all General
Practice staff are
adequately trained
or prepared to
access transfer.
There is also a risk
that "queues" of
patients build up as
a result of capacity
issues within the
practices post
transition.
CO48
We accept
responsibility for
our actions. We
make and
support business
decisions
through
experience,
evidence and
good judgement,
and we will
deliver against
our promises
100
06/07/2015 To secure a new
Headquarters
premises for the
CCG
That the building
works to fit out the
new HQ are delayed
beyond the deadline
at which the CCG
must vacate the
current Arthouse
Headquarters.
Audit underway of General
Practice preparedness to
take on transfer
Standing agenda item on
Primary Care Quality
Committee, oversight
conducted by PCCC
L
C
5
3
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
15
N
Exception reporting
from PCCC to
Governing Body
Delivery of childhood V&I to be included within
GP spec from 1st April 2016 to ensure city wide
delivery of routine vaccination programme and
support uptake rates to achieve national target
of 95%
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
C
3
3
9
CM/JL
on-going
though full
transition
should be
complete by
end of March
2016
Mar-16
►
1
2
2
ID
Nov-15
Feb-16
▼
Contingency model will be available to
support transition and ensure optimised
uptake rates for period Jan – June 16
Primary Care Quality Team
continuing to work with
Locality/N'hood teams to
quantify risk and establish
capacity gap.
Progress
since last
update
L
Fortnightly monitoring
meetings with PHE, CCG,
LCH, LCC and LMC to
discuss and oversee
progress
Fortnightly working group
since July 2015 to track
progress and identify
practices not
trained/without agreed go
live date
Training packages for
nursing/admin staff,
mentoring/shadowing
opportunities with HV
team, PNDT support to
practices without a nurse
all available to practices
Letter of
instruction sent ot
the developer to
commence
construction
works on the
29/05/15 which
would allow
sufficient time for
the works to be
completed;
funding for the
works lodged with
Hill Dickinson LLP
in an 'escrow'
account to be
released upon
phased
completion of the
works
Legal Advisers and
Liverpool Sefton Health
Partnership both acting
on behalf of the CCG to
expedite matters; NHS
Property Services as
current landlord
supporting the process.
Briefing provided to the
Finance, Contracting &
Procurement
Committee June 2015.
3
4
12
N
The CCG relocated into the new HQ on the
16th November 2015 as planned, with the
former HQ Arthouse Square returned to the
receiver on 30th November 2015. Snagging
work continues to complete outstanding
building works.
14
Ref
Organisational
Values &
Objectives
Date Entered Objective
Description of Risks Current Controls Assurance in Controls
L
C
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
CO50
We accept
responsibility for
our actions. We
make and support
business decisions
through
experience,
evidence and good
judgement, and we
will deliver against
our promises.
23/07/2015 Stability of
commissioning
support services
during
reprocurement
Timescale and
potential loss of
service up to
transition and
during mobilisation
Robust transition
plan from new
provider and exit
plan from
incumbent
Weekly transition
board meetings to
monitor progress and
highlight any risks.
Monthly steering
group meetings
3 4
12
N
Mobilisation of transition plans identified
for each service. Multi CCG meeting taking
place with Lancashire and Midlands CSU
11/12/2015
CO51
To hold providers
of commissioned
services to account
for the quality of
services delivered
03/11/2015 Effective
provision of
nursing home
beds to the
residents of
Liverpool
Total bed capacity within
independent nursing
homes is less than 2% at
1.1% of the total bed
capacity. (This is
equivalent to 6 out of
524 beds being
available). This is limiting
patient choice, delaying
discharge from Acute
Care, increasing the
demand on community
resources supporint
nursing home beds. The
average length of stay in
a nursing home bed is 3
years.
Current nursing
home bed
availability is
updated and
shaerd across the
system (Liverpool)
on a daily basis.
Limited assurance in
controls due to lack of
influence on market.
5 4
20
N
Development of intermediate care pathways to prevemt
admission to permanent / temporary care.
Professional revalidatio
required of nurses
including those working
in the care home sector.
101
Nursing Home
integrated dashboard
will create a single
point of access for
information and to
highlight early warning
signs and areas of
concern.
Further development
of the performance
dashboard to maximise
the intelligence and
information available
to commissioners,
providers and the
general public.
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
Progress
since last
update
L
C
3
3
9
DR
Ongoing
Feb-16
▼
5 4
20
JL
Ongoing
Mar-16
►
LCCG has purchased toolkit to assist nurses to revalidate
which will be marketed through the City Centre care home
forum.
More robust assessment porcesses being implemented.
Joint project group developing long term care home strategy
to shape the furture market to ensure sustainability of care
home market.
Developing new care home clinical model in order to prevent
closure due to poor quality and relccation of residents.
Continued adoptioni and refinement of the fair cost of care
methodology used by LCC
More accurate long term forecasting of supply and demand market position statement
Establish a more streamlined process for understanding real
time capacity and pressures
Work with the sctor to improve recruitment, retention and
training of care and nursing staff
Work with partners to improve exisiting estate and identify
opportunities for new developments to meet current gaps in
both the standard older people market and the specialist
residential and nursing market.
15
Ref
CO52
CO53
Organisational
Values &
Objectives
Date Entered Objective
We accept
responsibility for
our actions. We
make and
support business
decisions
through
experience,
evidence and
good judgement,
and we will
deliver against
our promises
04-Jan-16 Deliver the
transformation
of health and
health & care
services across
the city through
the Healthy
Liverpool
Programme
We accept
responsibility for
our actions. We
make and
support business
decisions
through
experience,
evidence and
good judgement,
and we will
deliver against
our promises
04-Jan-16 Deliver the
transformation
of health and
health & care
services across
the city through
the Healthy
Liverpool
Programme
Description of Risks Current Controls Assurance in Controls
The NHS
organisations
involved have
incompatible
organisational,
clinical and financial
interests
HLP Leadership
group, with
Provider CEO
membership.
Established
relationships with
regulators (
Monitor/ TDA)
and NHS England.
Programme Advisory
Board
L
4
C
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
4 16
Y
4
C
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
3 12
Progress
since last
update
KS/TJ
On-going
Mar-16
New Risk
KS
On-going
Mar-16
New Risk
HLP Leadership Group
Programme of provider engagement,
including summits, board presentations.
HLP Programme Board
Regular reporting to the Mayoral
Commission, which gave a clear mandate for
the system to collaborate effectively, led by
LCCG.
Provider
organisations
represented on
programme
groups.
Potential structural
changes in the
health economy
impacts on the
delivery, particularly
the hospitals
programme
Programme advisory board re-convened.
Meetings take place bi-monthly and the
next scheduled meeting is in January 2016.
L
Healthy Liverpool HLP Governance
engagement and
governance
enables a
CCG Network
collaborative
approach to
structural change
Work continues with the Trusts to
understand and support the outcome of the
collaboration/consolidation proposal for
RLBUHT, Aintree and LWH.
4
5
20
y
Establishment of a provider collaborative to
enable a system wide approach to
reconfiguration.
3
4
12
Development of CCG network into Strategic
City Region Commissioner Alliance.
NHS sustainability and transformation
funding from 17/18 to drive system wide
solutions.
The Planning Guidance issued in December
2015 requries system wide sustainability
and transformation plans.
Discussions underway in January 2016 to
determine the footprint for planning.
Consideration being given to Liverpool City
Region as the footprint.
102
16
Ref
Organisational
Values &
Objectives
Date Entered Objective
KEY:
103
Updates to
existing risks in
'blue'
Description of Risks Current Controls Assurance in Controls
L
C
Current Current
Management Actions re gaps in controls
Risk
risk
and assurance or unacceptable risk rating
(score) accepted
L
C
Residual
Lead Completion Review
Risk
Officer Date
Date
(score)
Progress
since last
update
new risk
Recommended for removal
►
Risk Unchanged
▲
▼
Risk increased
Risk decreased
17
104
Report no: GB 06-16
NHS LIVERPOOL CLINICAL COMMISSIONING GROUP
GOVERNING BODY
TUESDAY 12TH JANUARY 2016
Title of Report
Lead Governor
Liverpool CCG Standards of Business Conduct
(December 2015)
Maureen Williams (Deputy Chair)
Senior Management
Team Lead
Stephen Hendry, Acting Head of Operations &
Corporate Performance
Report Author
Stephen Hendry, Acting Head of Operations &
Corporate Performance
The purpose of this paper is to provide an
overview/summary to the Audit, Risk & Scrutiny
Committee of the revised Standards of Business
Conduct Policy (December 2015)
Summary
Recommendation
That the Governing Body:
 Notes the contents of the report and policy;
 Approves the Standards of Business Conduct
Policy (December 2015) as a Corporate
Policy for formal adoption by the CCG and
subsequent internal/external publication.
Impact on improving
health outcomes,
reducing inequalities
and promoting
financial
sustainability
The Standards of Business Conduct Policy aims to
describe the public service values which underpin
the NHS and to embed exemplary standards of
business conduct within NHS Liverpool CCG. The
policy reflects current guidance and best practice on
standards of corporate behaviour and responsibility
to which all individuals within NHS Liverpool CCG
must have regard in their work and duties.
Relevant Standards
or targets
• NHS Management Executive ‘Standards of
Business Conduct for NHS Staff (HSG (93) 5)
105
Page 1 of 4
• The Code of Conduct: Code of Accountability in
the NHS (revised 2004)
• Department of Health – Code of Conduct for
NHS Managers (October 2002)
• Health & Social Care Act (2012) Section 25
• The seven principles of public life set out by the
Committee on standards in public life (the Nolan
principles)
• NHS Commissioning Board: Standards of
Business Conduct (October 2012)
• NHS England: Conflicts of Interest: Statutory
Guidance for CCGs (December 2014)
NHS LIVERPOOL CCG STANDARDS OF BUSINESS CONDUCT
(DECEMBER 2015)
1.
PURPOSE
The purpose of this paper is to provide an overview/summary to the Governing
Body of the CCG’s revised Standards of Business Conduct Policy (December
2015).
2.
RECOMMENDATIONS
That the Governing Body:
 Notes the contents of the report and policy;
 Approves the Standards of Business Conduct Policy (December 2015) as
a Corporate Policy for formal adoption by the CCG and subsequent
internal/external publication.
3.
BACKGROUND
NHS Liverpool CCG aspires to achieve the highest standards of corporate
behaviour and responsibility. As a public body we have a duty to ensure the
appropriate safeguarding and stewardship of the public funds we are entrusted
with and that NHS Liverpool CCG is able to stand the test of the three public
service values which are central to everything we do, namely:
• Accountability;
• Probity, and;
106
Page 2 of 4
• Openness
Through the Standards of Business Conduct Policy (December 2015),
individuals will be made aware of their own responsibilities as well as the CCG’s
responsibilities as a public body.
The challenges faced by NHS Liverpool CCG in relation to this key area of
governance and accountability have become increasingly complex. This policy
has been developed as part of a ‘suite’ of policies and procedures aimed at
strengthening the CCG’s governance structure as the organisation evolves and
grows within the local health economy. Delegated commissioning arrangements
for primary medical care services has presented a unique set of challenges;
particularly in terms of managing conflicts of interest and it is essential that the
CCG is able to continually demonstrate that it is acting fairly, transparently and
in the best interests of the patients and population of the city of Liverpool.
The policy was presented to the Audit, Risk and Scrutiny Committee on 16th
December 2015 where it was recommended for Governing Body
ratification/approval.
4.
GUIDANCE AND LEGAL FRAMEWORK
The NHS Management Executive published guidance “Standards of Business
Conduct for NHS Staff” (HSG (93) 5) remains extant and provides specific
guidance on:
• The standards of conduct expected of all NHS staff where their private
interests may conflict with their public duties, and;
• The steps which NHS employers should take in order to safeguard
themselves and the NHS against conflicts of interest.
The Standards of Business Conduct Policy 2015 has utilised and fully
referenced the above guidance, in addition to the following legal frameworks,
principles and guidance documents:
• The Bribery Act 2010 (the underpinning legal framework);
• Section 25 of the Health & Social Care Act 2012
• NHS England: Managing Conflicts of Interest: Statutory Guidance for
CCGs (2014);
• The Code of Conduct: Code of Accountability in the NHS (Appointments
Commission/Department of Health 2004)
107
Page 3 of 4
It is essential that the CCG operates within this legal framework, whilst at the
same time maintaining a balanced approach which does not stifle innovation or
objective investment decisions.
5.
NEXT STEPS
If approved by the Governing Body, the 2015 Standards of Business Conduct
Policy will be considered as a ‘live’ policy document and placed on the CCG’s
intranet and public facing website. A plan for the dissemination, promotion and
‘socialising’ of the policy will then be designed to raise staff and stakeholder
awareness of the existence of the policy and the requirements contained within.
This specific area of work will be taken forward by the (current) Acting Head of
Operations and Corporate Performance under the stewardship and guidance of
the CCG’s Lay Member for Governance/Deputy Chair and the Chief Finance
Officer.
Stephen Hendry
Acting Head of Operations and Corporate Performance
4th January 2016
ENDS
108
Page 4 of 4
NHS LIVERPOOL CCG
STANDARDS OF BUSINESS CONDUCT
December 2015
Version 1.1
0
109
Version:
1.1
Ratified by:
Audit, Risk & Scrutiny Committee
Date ratified:
16th December 2015
Name of originator/author:
Date issued/published:
Stephen Hendry, Acting Head of
Operations & Corporate Performance
Stephen Hendry, Acting Head of
Operations & Corporate Performance
TBC
Review date:
December 2016
Target audience:
Organisation wide policy
Name of lead:
Any changes to this policy should be outlined and recorded in the version control
table below. In the event of any changes to relevant legislation or statutory
procedures or duty this policy will be automatically updated to ensure compliance
without approvals being necessary.
Version nos
Type of change
Date
Description of change
1.1
Reference to LCFS
06/10/2015
1.1
Revision
06/10/2015
All references to Local Counter Fraud
Specialist (LCFS) changed to ‘Anti-Fraud
Specialist’
Changes made to Section 7, Conflicts of
Interest to reference CCG Policy & provide
less prescriptive requirements for staff
completing declarations of interest &
exclusion from meetings.
1
110
Contents
Page
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
Introduction
Scope of Policy
Principles of this Policy
Prevention of Corruption
Anti-Fraud Measures
CCG Constitution, Standing Orders (SOs), Prime Financial Policies (PFPs) &
Scheme of Delegation (SD)
Conflicts of Interest
Gifts & Hospitality
Personal Conduct
Political Activities
Commercial Sponsorship
Third Party Contractors & Suppliers of Services
Initiatives
Confidentiality & Data Protection
Suspected or Known Breaches of this Policy
Publication & Dissemination
Management Arrangements & Monitoring Compliance
References & Further Information
Equality & Diversity
3
3
4
4
5
6
6
11
12
14
14
15
16
16
17
17
18
18
Appendices
Appendix 1 – The Seven Principles of Public Life (The Nolan Principles)
Appendix 2 – Declaration of Financial & Other Interests for
Members/Employees Form
Appendix 3 – Declaration of Financial Interests for Bidders/Contractors Form
Appendix 4 – Declaration of Offers & Receipt of Gifts/Hospitality
Appendix 5 – The Chartered Institute of Purchasing & Supply (CIPS) Code of
Ethics
2
111
19
20
23
26
28
1. INTRODUCTION
NHS Liverpool Clinical Commissioning Group (hereafter referred to as ‘the CCG’) is
committed to ensuring that exemplary standards of business conduct are adhered to
by Governing Body Members, committee and sub-committee members and all
employees of the CCG (including individuals contracted to work on behalf of the
CCG or otherwise providing services or facilities to the CCG for clinical programme
areas and/or commissioning support services).
This policy aims to describe and reinforce the public service values which underpin
the CCG’s Constitution (and the NHS as a whole); reflecting current guidance and
best practice to which all individuals within the CCG must have regard to in their
duties.
The Governing Body is determined to ensure that the CCG inspires public
confidence and achieves the highest possible standards of corporate behaviour. The
Code of Conduct and Code of Accountability in the NHS (2004) sets out three public
service values which are central to the on-going work and sustainability of the CCG:
•
Accountability – everything done by those who work in the NHS must be
able to stand the test of parliamentary scrutiny, public judgements on
propriety and professional codes of conduct;
•
Probity – there should be an absolute standard of honesty in dealing with the
assets of the NHS. Integrity should be the hallmark of all personal conduct in
decisions affecting patients, officers, members and suppliers and in the use of
information acquired during the course of their NHS duties, and;
•
Openness – there should be sufficient transparency about NHS activities to
promote confidence between each CCG, its’ staff, patients and public.
In addition to the above public service values, all individuals within the CCG must
abide by the Seven Principles of Public Life set out by the Nolan Committee, which
can be found in Appendix 1 of this policy.
2. SCOPE OF POLICY
This policy applies to all CCG employees regardless of whether they are directly
employed, in a seconded post or whether their remit is clinical or corporate. This
includes:
•
•
•
All employees of the CCG;
Governing Body Members of the CCG (including invited ‘non-voting’
members)
Committees and sub-committees of the CCG;
3
112
•
•
•
Third parties acting on behalf of the CCG (including Commissioning Support
and shared services);
Agency, locum and other temporary staff engaged by the CCG, and;
Students (including those on work experience), trainees and apprentices
Collectively, and for the purpose of this policy the above will simply be referred to as
‘CCG staff’ throughout the document. Additionally, all CCG staff are expected to:
•
Comply with the requirements of the CCG’s Constitution and be aware of the
responsibilities outlined within it. The Constitution can be accessed
electronically via the CCG’s intranet and internet
site http://www.liverpoolccg.nhs.uk/
•
Conduct themselves in accordance with HSG (93) 5 “Standards of Business
Conduct for NHS Staff”.
•
Adhere to the NHS Code of Conduct and Code of Accountability (2004),
maintaining strict ethical standards in the NHS.
Some staff may additionally be required to adhere to a code of conduct of their own
professional body. However, any non-compliance with this policy may lead to
disciplinary action which could ultimately result in dismissal for gross misconduct.
2.1 Member Practices
Under delegated commissioning arrangements from 1st April 2015, Member
Practices remain responsible for the development and management of standards of
business conduct within their own general medical practices in terms of the delivery
of day-to-day business, but can adopt this policy as an exemplar for local
implementation. However, in all other circumstances where Member Practices
(and/or individuals of Member Practices acting on their behalf) are engaged in CCG
business or exercising commissioning functions, they will be expected to fully comply
with the requirements contained within this document.
3. PRINCIPLES OF THIS POLICY
Holders of public office have a duty to act in the interests of the organisation of which
they serve and to act in accordance of the tasks of the body. Furthermore, holders of
public office must respect fellow members of the body and the role they play; treating
them with courtesy at all times. CCG staff are therefore expected at all times to:
•
Act in good faith and in the interests of the CCG; following the ‘Seven
Principles of Public Life’ as set out by the Committee on Standards in Public
Life (the Nolan Principles);
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•
Achieve value for money from the public funds with which they are entrusted
and to demonstrate high ethical values of personal conduct (i.e. honest,
supportive, caring, professional) at all times.
The CCG will take appropriate measures to ensure the requirements of this policy
and any supporting documents are brought to the attention of all staff and that robust
governance arrangements are in place for ensuring standards and guidelines are
effectively implemented. Awareness will be promoted by clauses in the terms and
conditions of employment and through publication/promotion on the CCG’s intranet
site for staff http://nww.liverpoolccg.nhs.uk/
4. PREVENTION OF BRIBERY & CORRUPTION
The CCG has a responsibility to ensure that all staff are made aware of their duties
and responsibilities under the Bribery Act (2010) and has a strict zero tolerance
approach to bribery and corruption. Under this Act there are four offences:
•
Bribing, or offering to bribe another person;
•
Requesting, agreeing to receive or accepting a bribe;
•
Bribing, or offering to bribe a foreign public official, and;
•
Failing to prevent bribery
In simple terms, “bribery” is an act where the offer of a gift or money is in exchange
for benefits. Whilst monetary bribery is often perceived as the most common, bribes
can often be less tangible and include things such as property, objects of value or
offering to provide a particular service in the future. There must be an offer and an
acceptance; based on the understanding that the individual accepting the offer is
expected to do something in return. This can often differentiate ‘bribes’ from gifts
offered in genuine goodwill; although the receipt of gifts and hospitality should never
be allowed to influence CCG staff’s judgement or conflict with the interests of the
CCG’s objectives. Further guidance for staff on the recording of gifts and hospitalities
can be found in Section 8 of this policy.
4.1 Raising concerns
All CCG staff members have a duty to report any genuine concerns in relation to
criminal activity, breach of legal obligation (including breach of
contract/administrative law and negligence), miscarriage of justice and the covering
up/obfuscation of such acts in the workplace. Codes of Conduct expected of CCG
staff also extend to reporting dangers to health and safety. The CCG is committed to
providing an open and learning environment in which individuals can raise concerns
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without fear of reprisal or victimisation. The procedure for reporting specific concerns
in relation to fraud are described in Section 5 below.
5 ANTI-FRAUD MEASURES
CCG staff members must not use their position to gain financial advantage. Where
individuals have concerns or reasonably held suspicions about actual/potential
fraudulent activity or practice, these should be reported immediately to the Chief
Finance Officer (CFO) and the nominated Anti-Fraud Specialist (AFS). Should the
CFO be implicated, individuals should instead report directly to the Chief Officer of
the CCG, who will then liaise with the AFS to determine an appropriate course of
action.
CCG staff can, at any point report NHS fraud by calling call NHS Protect on free
phone 0800 028 40 60 or via https://www.reportnhsfraud.nhs.uk. This provides an
easily accessible and confidential route for the reporting of genuine suspicions of
fraud in the NHS. All calls are dealt with by experienced and trained staff and any
caller wishing to remain anonymous may do so.
Anonymous letters and telephone calls can, on occasion, be received from
individuals who wish to raise matters of concern through more ‘unofficial’ channels.
Whilst suspicions and allegations may be erroneous or unsubstantiated, they could
also reflect a genuine concern and will therefore always be taken seriously by the
CCG. The Chief Finance Officer will make enquiries to establish whether or not there
is any foundation to the suspicions raised where this is possible.
It is important for CCG staff not to ignore their suspicions, but they should not under
any circumstances investigate matters themselves or discuss their suspicions with
colleagues or others as this could severely compromise any future formal
investigation by the CCG or AFS for criminal proceedings.
Further advice can be found in the CCG’s Anti-Fraud, Bribery and Corruption Policy:
http://nww.liverpoolccg.nhs.uk/Library/You/CCG_employees/policies/Liverpool%20C
CG%20Anti%20Fraud%20Bribery%20and%20Corruption%20Policy%202013.pdf
6 CCG CONSTITUTION, STANDING ORDERS (SOS), PRIME FINANCIAL
POLICIES (PFPS) AND SCHEME OF DELEGATION (SD)
All staff must carry out their duties in accordance with the CCG’s Standing Orders,
Prime Financial Policies and Scheme of Delegation as these set out the statutory
and governance framework in which the CCG operates (these can all be found in the
Appendix section of the CCG’s Constitution). There is considerable overlap with this
policy and the provisions set out in Liverpool CCG’s SOs, PFPs and SD so staff
must ensure that they refer to and act in accordance with them to follow the most
current CCG process. In the event of doubt as to compliance with these provisions,
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CCG staff should initially seek advice from their line manager. The provisions
detailed within the Constitution, SOs, PFPs and SD will always take primacy in the
event of any conflicts arising with the content of this policy.
7 CONFLICTS OF INTEREST
The CCG has clear principles and robust processes for minimising, managing and
registering real or perceived conflicts of interest which could be deemed or assumed
to affect the integrity of decisions made by CCG staff in awarding contracts,
procurement, policy development, employment and other commissioning decisions.
This section provides a summary description only of the CCG’s corporate policy and
responsibility in relation to the identification and management of conflicts of interest
for CCG staff. Liverpool CCG’s Conflicts of Interest Policy (2015) should be
referenced for detailed guidance, policy statements (including their procedural
implementation) and the requirements expected of CCG staff.
7.2 General overview
A conflict of interest occurs where an individual’s ability to exercise judgement or act
in one role is (or could be) impaired or otherwise influenced by their involvement in
another role or relationship. The individual does not need to exploit their position or
obtain an actual benefit; be it financial or otherwise. A potential for competing
interests and/or a perception of impaired judgement or undue influence can also be a
conflict of interest.
A conflict can arise from an indirect financial interest (e.g. a payment to a spouse) or
a non-financial interest such as kudos or reputation. Conflicts can also arise from
personal or professional relationships with others; particularly where the role or
interest of a family member, friend or acquaintance may influence an individual’s
judgement or actions or could be perceived to do so. CCG staff should not allow their
judgement or integrity to be compromised and should always be, and seen to be
honest and objective in the exercise of their duties in line with their terms of
employment, duties and responsibilities.
Conflicts may include (but not limited to):
•
Directorships, including non-executive directorships held in private companies
or public limited companies (with the exception of ‘dormant’ companies);
•
Ownership or part ownership of companies, businesses or consultancies
which may seek to conduct business with the CCG;
•
Financial interests such as shareholdings in organisations with which the
CCG may conduct business with;
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•
Membership of (or a position of trust) in a charity or voluntary organisation in
the field of health and social care;
•
Current contracts managed by the CCG in which the individual has a
beneficial interest;
•
A formal interest with a position of influence in a political party or organisation;
•
Interests in pooled funds that are under separate management. Any relevant
company included in this fund that has a potential relationship with the CCG
must be declared, and;
•
Any other employment, business involvement or relationship (or that of a
spouse or partner) that conflicts, or may potentially conflict with the interests
of the CCG.
All CCG staff should ensure that they are not placed in a position that risks (or
appears to risk) a conflict between their private interests and their CCG duties.
Where a situation falls outside of the above categories, for the avoidance of any
doubt as to whether it represents a conflict of interest or not, CCG staff should
always seek advice initially from their line manager, clinical lead or Head of Service.
7.2 Managing Conflicts of Interest
Although conflicts of interest are inevitable, in most circumstances it is possible to
manage them appropriately by adopting a balanced and proportionate approach
which does not constrain decision making. The CCG should be made aware of all
situations where an individual’s ability to exercise decision making may be conflicted
by interests outside of their role, or where that interest has the potential to result in a
conflict of interests between the individual’s private interests and their CCG duties.
A potential conflict of interest could include:
•
A direct financial interest - where an individual may financially benefit from
the consequence;
•
An indirect financial interest – where an individual is a member, partner or
shareholder in an organisation which will benefit financially from a
commissioning decision;
•
Non-financial interest – where an individual holds a not-for-profit/nonremunerative interest in an organisation that will benefit from a commissioning
decision (for example a Trustee of a charity that is bidding for a contract);
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•
Non-financial personal benefit. These occur where CCG staff receive no
financial benefit, but are influenced by other external factors which could
mean gaining status or wider recognition (for example, awarding contracts to
friends or personal business contacts), and;
•
Where an individual is closely related to, or in a relationship/friendship with an
individual in the above categories.
If in doubt, CCG staff should always assume that a conflict of interest exists and
declare it. Concerns may also relate to financial or personal commitments to friends,
colleagues and peers or from close family members interests and obligations by
association.
7.3 Declarations of Interests
The CCG will proactively manage conflicts of interest by:
•
Maintaining and reviewing a Declarations of Interest Register (held by the
Chief Finance Officer);
•
Managing membership of all formal committees and decision making bodies
supporting the CCG;
•
Working within the CCG Constitution, Standing Orders (SO) and Scheme of
Reservations and Delegations, and;
•
Ensuring robust mechanisms are in place for committee members to declare
interests and withdraw from decision making where appropriate.
The CCG’s Declaration of Interests pro-forma can be found in Appendix 2
Individuals contracted to work on behalf of the CCG (or otherwise providing services
of facilities to the CCG) will be made aware of their obligations under the CCG’s
Conflicts of Interest Policy (2015) to declare conflicts or potential conflicts of interest,
using the pro-forma in Appendix 3. This requirement will be written into all contracts
for services. The Declarations of Interest Register will be audited by the Chief
Finance Officer on a quarterly basis to ensure consistency and accuracy.
7.3
Committee Meetings & Decision Making
All CCG committee meetings will include a standing agenda item at the beginning of
each meeting for members to declare any interests relating specifically to business
being considered. In cases where an interest previously undeclared is identified
during the course of a meeting, the declaration will be noted in the minutes, which
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themselves will detail all declarations made and the context in which the conflict
occurs. The Chair of the meeting (unless himself/herself/ being conflicted) will rule on
how the declaration is managed during the meeting. Declarations may be treated as
relevant for decision making and any on-going contract monitoring arrangements. .
Any suspicion that a relevant personal interest may not have been declared should
be reported to the Chief Finance Officer immediately.
7.4
Outside Employment and Private Practice
The standard employment contract issued to CCG staff sets out the terms
concerning outside employment. Where staff have employment other than their
employment with the CCG, they must declare this in writing to their line
manager/Head of Service; detailing the hours and days worked, the duties carried
out and seeking written agreement that this work would not be detrimental to their
employment within the CCG. Any employee considering outside employment or
private practice should first discuss this with their line manager/Head of Service
before any undertaking or acceptance. The purpose of this is to ensure that the
CCG is aware and is able to manage any potential conflicts with the employment.
Examples of work which might conflict with the business of the CCG include:
•
Employment with another NHS body;
•
Employment with another organisation which might be in a position to supply
goods/services to the CCG, and/or;
•
Self-employment (including private practice and private advisory capacity) or
engagement with an organisation which may be in a position to supply
goods/services to the CCG which might conflict with the business of the CCG.
Where permission is granted, the individual should still complete a Declarations of
Interest form to safeguard themselves and the CCG. NHS Liverpool CCG reserves
the right to refuse permission where it is believed a conflict of interest may arise.
Employees are advised not to engage in outside employment during any periods of
sickness absence from the CCG. To do so may lead to a referral being made to the
Anti-Fraud Specialist (AFS) for investigation, which may ultimately lead to criminal
and/or disciplinary action in accordance with the CCG’s Anti-Fraud arrangements.
7.5 Payment for speaking at a meeting/conference
In circumstances where a member of staff acting on behalf of the CCG (including
Member Practice, Governing Body and/or Committee member) is asked to speak at
an event which is held in working hours, relates to CCG business and for which a
payment is offered, there are two options available; both of which must be agreed
first with their line manager/Head of Service:
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a) The payment should be credited to the CCG;
b) The member of staff takes annual or unpaid leave to speak at the event, and
accepts the payment as a private arrangement between the organisation
making the payment and the individual member of staff. The member of staff
remains responsible for any tax liability which arises and declaring any
conflicts of interest which may be of relevance to their role within the CCG.
8 GIFTS AND HOSPITALITY
For the purpose of this policy, a gift is defined as ‘any item of goods and/or cash or
any service which is provided for personal benefit at less than its commercial value’.
Hospitality or gifts with a value in excess of £25 will be recorded in the Gifts and
Hospitality Register. This includes accumulation of gifts from a single individual or
company that total £25 or more over a twelve month period. Modest hospitality,
which could be expected in reasonable circumstances during the course of visits,
may be acceptable although this should be considered and compared against what
the CCG might offer in similar circumstances where hospitality is provided at
meetings, events and seminars. All CCG staff should consider the following points in
relation to gifts and hospitality:
•
Any personal gift of cash or cash equivalents (i.e. gift cards, gift vouchers)
should be declined regardless of value. Trade or discount cards (by which
personal benefit is gained from the CCG’s purchase of goods or services at a
reduced price) are also classified as gifts and should also be politely declined.
Exceptions to this are where the CCG negotiates benefits on behalf of staff;
•
CCG staff should immediately report any offers of unreasonably generous
gifts or hospitality to the Chief Finance Officer;
•
CCG staff should politely decline or promptly return any gifts considered
unacceptable or inappropriate with a covering letter explaining the terms of
this policy and stating a polite refusal of acceptance;
•
During procurement processes, CCG staff should not accept any small items
of value or hospitality over that usually afforded in a normal meeting
environment from actual/potential bidders. This is purely so as to avoid any
accusations or claims of unfair influence, collusion or canvassing;
•
Providing hospitality at ‘non-business’ locations (for example hotels,
restaurants and domiciliary residences) should be avoided unless there is a
clear need to do so, and only if this is agreed in advance by a member of the
CCG’s Senior Management Team (SMT).
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The Code of Conduct: Code of Accountability in the NHS determines that the use of
NHS monies for hospitality and entertainment (including hospitality at conferences or
seminars) should always be given careful consideration. The CCG’s Conflicts of
Interest Policy (2015) also provides detailed guidance for CCG staff for the receipt of
both gifts and hospitality and the process for recording declarations on the CCG’s
Gifts and Hospitality Register.
9.
PERSONAL CONDUCT
The CCG places the utmost importance upon the honesty, integrity and moral
behaviour of its staff. It is the responsibility of all staff, irrespective of position or pay
band to ensure they are not placed in a position which risks, or appears to risk the
reputation of the CCG through actions which may considered as an abuse of official
position, or by placing personal interests ahead of those of the CCG during the
course of their duties. The following principles for personal conduct should be
applied consistently by CCG staff:
9.1
Lending and borrowing of money
CCG staff should always refrain from the lending or borrowing of money between
colleagues and peers; whether informally or as a business and particularly where the
amounts involve significant sums of money. It is a particularly serious breach of
discipline for any CCG staff to use their position to place pressure on colleagues,
business contacts or members of the public to loan them money. Where incidents of
this nature occur they should be reported to the Chief Finance Officer immediately or
NHS Protect on free phone 0800 028 40 60 / https://www.reportnhsfraud.nhs.uk .
9.2
Charitable collections
In general, charitable collections or fundraising conducted on site will be authorised
by the Chief Finance Officer or relevant Senior Management Team member. Staff
should be clear that under no circumstances should collection tins or boxes be
placed in CCG offices without prior authorisation. Charitable collections amongst
immediate colleagues and friends to support fundraising initiatives such as raffles,
appeals and sponsored events may be conducted. Permission will not be required
for informal collections amongst immediate colleagues for occasions such as
retirement, marriage, new job, new births or birthdays.
9.3
Bankruptcy and insolvency
CCG staff who are declared bankrupt or insolvent must inform the Chief Finance
Officer as soon as possible. Staff who are declared bankrupt or insolvent cannot be
employed in posts that may give opportunity for the misappropriation of public
monies, or involve the handling/processing of finances or money.
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9.4
Gambling
No member of staff may bet or gamble whilst on duty or on CCG premises. The only
exceptions to this are small lottery syndicates or sweepstakes relating to
national/world sporting events such as the Grand National or FIFA World Cup, which
are generally confined to immediate colleagues.
9.5
Trading on CCG premises
Trading on CCG premises is strictly prohibited, whether for personal gain or on
behalf of others. This also applies to canvassing within CCG offices by on behalf of
external bodies or companies (including non-CCG interests of staff or their relatives).
This provision excludes refreshment arrangements conducted solely by staff (e.g.
tea and coffee funds).
9.6
Arrest or conviction
A member of staff who is arrested and refused bail or convicted of any criminal
offence must inform their line management and Human Resources immediately. If
charged with any criminal offence (other than a motoring offence which does not
carry the penalty of disqualification) staff must immediately advise their line manager
of the charges and the outcome of the Police action; i.e. convicted, cautioned or
exonerated. In some instances criminal convictions, even though unconnected to
work, may lead to dismissal. This is also written into all staff contracts.
9.7
Social Media
CCG staff should ensure that their personal use of social media does not include
disclosure of confidential or commercially sensitive information, the display of
material or expression of views or opinions which could be linked with the CCG and
damage its reputation.
Employees should always be mindful of the risks that inappropriate behaviour
exposed by social media and/or inappropriate comments made on social media
could, in some cases be construed as misconduct. For example, whenever
employees post information about their work or their employer, it is highly likely that
the information will be circulated to a wider audience. In some cases, posts can be
(and have been) published by the local/national press. This is a particular risk where
an individual’s privacy settings are not limited to personal connections or ‘followers’
and are therefore not considered as protected under UK privacy, human rights or
data protection laws. CCG staff should not enter into any on-line social media
activity for personal or commercial gain without first seeking advice from the Chief
Finance Officer on whether it constitutes a direct or indirect conflict of interest.
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9.8 Private Transactions
CCG staff, Member Practices, Governing Body and Committee members or any
individual acting on behalf of the CCG must not seek or accept preferential rates or
benefits in kind for private transactions carried out with companies / organisations
with which they have had (or may have) official dealings on behalf of the CCG. This
does not apply to any concession agreements negotiated by the CCG, or by the
NHS as a whole in relation to recognised staff interests made on behalf of all staff
(for example NHS staff benefits schemes, long service awards).
10.
POLITICAL ACTIVITIES
Conferences or functions run by a party political organisation should not be attended
by CCG staff in an official capacity except where prior permission has been granted
by the Chief Officer. CCG staff should take care to ensure that any political activity
they undertake outside of their role does not identify them individually as an
employee of NHS Liverpool CCG.
11.
COMMERCIAL SPONSORSHIP
For the purpose of this policy, commercial sponsorship is defined as including:
(NHS funding) from an external source, including funding of all, or part of, the costs
of a member of staff, NHS research, staff training, pharmaceuticals, equipment,
meeting rooms, costs associated with meetings, meals, gifts, hospitality, hotel and
transport costs (including trips abroad), provision of free services (speakers),
buildings or premises.
CCG staff may accept commercial sponsorship for courses, conferences, project
funding and publications if they are reasonably justifiable and in accordance with the
principles set out in this policy. Where there is doubt as to what constitutes
‘reasonably justifiable’ advice should be sought from the Chief Finance Officer.
Written permission must first be obtained from the relevant Head of Service in
advance, which should also include details of the proposed sponsorship. A copy will
be retained centrally by the CCG for audit purposes.
Acceptance of commercial sponsorship should not in any way compromise nor
influence the commissioning decisions of the CCG and sponsors should not have
any influence over the content of an event, meeting seminar, training event or
publication. This includes financial support and hospitality for educational meetings,
training, attendance at conferences and publications. From the outset, it should be
made clear to the public or those attending an event that the fact of sponsorship (or
publicity material about the company or product) does not in any way act as an
endorsement by the CCG of the company’s products or services.
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When dealing with sponsors there must be no breach of patient or individual
confidentiality or data protection legislation. 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 will not normally be
supplied. Where meetings are sponsored by external sources however, this will be
disclosed in papers relevant to the meeting and in any published proceedings.
11.1 Collaborative Partnership Arrangements
It is recognised that NHS bodies work together and in collaboration with other
agencies to improve health services and health outcomes for the populations they
serve. Although collaborative partnership arrangements with the private sector can
yield a number of benefits for the local population, it is important to have a
transparent approach; both in terms of how the partnership would benefit the CCG
and for the CCG to fully consider the regulatory and ethical implications of the
arrangement before entering into it.
In the case of collaborative research and ‘evaluative exercises’ with manufacturers,
the CCG may be entitled to obtain fair reward for the input it provides. Where such
an exercise involves additional work for a CCG employee/employees that is paid for
by the CCG under the terms of their contract of employment or under sessional
arrangements, it will be determined how any benefits or rewards will be passed on to
the employee(s) or individuals concerned from the collaborating parties. Care will
always be taken to ensure that involvement in this type of arrangement with a
manufacturer does not influence the purchase of other supplies from that
manufacturer.
12.
THIRD PARTY CONTRACTORS AND SUPPLIERS OF SERVICES
CCG staff who are in contact with suppliers and contractors (including external
consultants) and particularly those who are authorised to sign purchase orders or
enter into contracts for goods and services are expected to adhere to professional
standards in line with those set out in the Codes of Ethics of the Chartered Institute
of Purchasing and Supply (Appendix 5)
CCG staff involved in the awarding of contracts and tender processes must take no
part in a selection process if a personal interest or conflict of interest is known. Such
an interest must be declared to the Chief Finance Officer using the pro-forma in
Appendix 2 as soon as it becomes apparent.
Where the potential provider of a service is a GP member, procurement may be
through competitive tender or Any Qualified Provider (AQP) approach or on a single
tender basis (where the GP is the only capable provider or where the service is of
minimal financial value). The CCG will ensure that services are procured in a manner
that is open, transparent, non-discriminatory and fair to all potential providers.
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Details of all contracts, including the value of the contract will be published on the
CCG’s public-facing website as soon as contracts are agreed. Where the CCG
decides to commission services via AQP, the type of service and agreed price for
each service commissioned will be published on the CCG’s
website www.liverpoolccg.nhs.uk and will also be included in the Annual Report.
13.
INITIATIVES
As a general principle any financial gain resulting from external work where the use
of the CCG’s time or title is involved (e.g. speaking at events/conferences, writing
articles) and/or which is connected with CCG business must be reported to the
CCG’s Chief Finance Officer.
Any patents or designs, trademarks or copyright resulting from the work of an
individual employee of Liverpool CCG carried out as part of their terms of
employment (for example research) shall remain the Intellectual Property of the
CCG.
Approval from the appropriate line manager/Head of Service should be sought
before entering into any obligation to undertake external work connected with the
business of the CCG (e.g. writing articles for publication, speaking at conferences or
events).
Where the undertaking of external work (including gaining patent, copyright or the
involvement of innovative work) benefits or enhances the CCG’s reputation or results
in a financial gain for the CCG, consideration will be given to rewarding employees
subject to any relevant guidance for the management of Intellectual Property in the
NHS issued by the Department of Health.
14.
CONFIDENTIALITY & DATA PROTECTION
During the course of their work for or with the CCG, individuals will be exposed to or
will handle information which is deemed personal, sensitive or confidential.
Information concerning Liverpool CCG which is not in the public domain must not, at
any time, be divulged to any unauthorised person. This particularly applies to patient
data or personal data concerning staff (in line with the Data Protection Act 1998).
Care should be taken at all times to ensure confidentiality is not breached
inadvertently by discussing confidential subjects in public places or social media or
by leaving portable IT/communications equipment containing confidential information
where it might easily be stolen. Confidential data should only be stored and
distributed with an appropriate level of security and encryption.
Information identified as sensitive (either commercially sensitive or relevant to ongoing business discussions and developments) must not be disclosed or otherwise
discussed where disclosure may inadvertently occur. CCG staff should not provide
information on the operations of the CCG which might provide a commercial
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advantage to any organisation (private or NHS) in a position to supply goods or
services to the CCG.
15. SUSPECTED OR KNOWN BREACHES OF THIS POLICY
Individuals who fail to disclose relevant interests, outside employment or receipts of
gifts, hospitality and sponsorship as required by this policy or the CCG’s Standing
Orders (SO) and financial policies may be subject to disciplinary action which could
ultimately result in the termination of their employment or position with the CCG.
Individuals who wish to report suspected or known breaches of this policy should
inform the Chief Finance Officer. Reporting of this nature will be treated in strictest
confidence and those reporting breaches can expect a full explanation of the
decisions taken as a result of any investigation. If there is evidence of fraud,
deception, bribery or corruption the matter will be referred to the Anti-Fraud
Specialist who will assess if legal action will be taken. The CCG may also refer
cases to other professional bodies (e.g. General Medical Council, Nursing &
Midwifery Council) with whom individuals are registered.
16. PUBLICATION & DISSEMINATION
All new staff will be made aware of this policy and associated documents on
appointment/induction to the CCG. An electronic copy of the Standards of Business
Conduct Policy will be made available on the CCG’s intranet and public-facing
website www.liverpoolccg.nhs.uk. The frequency of any specific awareness raising
or training in relation to this policy will be determined as part of the CCG’s
organisation development plan.
17. MANAGEMENT ARRANGEMENTS & MONITORING COMPLIANCE
The Chief Finance Officer will be responsible for maintaining the Register of
Interests, holding the Hospitality, Gifts and Sponsorship and reviewing the
implementation of this policy (including any awareness raising sessions or training).
Committee responsibility for the implementation, monitoring, effectiveness and
compliance of this policy and associated processes (including oversight of the
Register of Interests and Hospitality, Gifts and Sponsorship Register) has been
delegated to the Audit, Risk and Scrutiny Committee.
This policy will be reviewed on an annual basis by the Chief Operating Officer (or
earlier if there are changes in legislation, relevant case law decisions, significant
incidents and/or changes to the CCG’s organisational infrastructure).
CCG staff should be aware that a breach of this policy could render them liable to
prosecution as well as leading to the termination of their employment or position
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within the CCG. Hard copies of this policy will be made available on request by the
Chief Operating Officer.
18.
REFERENCES AND FURTHER INFORMATION
This policy should be read in conjunction with the CCG’s Constitution (latest version
March 2015) and the Standing Orders, Reservation and Scheme of Delegation,
Prime Financial Policies contained within. This policy should be read in conjunction
with the CCG’s Conflicts of Interest Policy (2015). Key national documents which
have formed the basis and influenced the development of this document are as
follows:
•
•
•
•
•
•
•
•
•
•
•
•
•
•
19.
NHS Liverpool CCG Anti-Fraud, Bribery & Corruption Policy (2015)
NHS Liverpool CCG Conflicts of Interest Policy (2015)
NHS Constitution
NHS Liverpool CCG Whistleblowing Policy (2015)
NHS Liverpool CCG Disciplinary Policy (2015)
The Health & Social Care Act 2012 (Section 25)
The Code of Conduct for NHS Managers
The Nolan Principles on Conduct in Public Life
NHS England – Standards of Business Conduct (2012)
The NHS Codes of Conduct & Accountability; (NHS Appointments
Commission & Department of Health – 2004)
The Code of Practice on Openness in the NHS
NHS England: Standards of Business Conduct (2012)
Bribery Act 2010
General Medical Council: Leadership and Management for all Doctors (March
2012)
EQUALITY & DIVERSITY
NHS Liverpool CCG is unreservedly opposed to any form of discrimination on the
grounds of age, disability, gender reassignment, marriage or civil partnership,
pregnancy and maternity, race, religion or belief, sex and sexual orientation (defined
as Protected Characteristics). The aim of this policy is to protect both the CCG and
the individuals involved from any appearance or accusations of impropriety. No gaps
or challenges have been identified in relation to Equality & Diversity in the impact
assessment of this policy.
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Appendix 1
The Seven Principles of Public Life (the Nolan Principles)
1. Selflessness Holders of public office should take decisions solely in terms of
the public interest. They should not do so in order to gain financial or other
material benefits for themselves, their family, or their friends.
2. Integrity Holders of public office should not place themselves under any
financial or other obligation to outside individuals or organisations that might
influence them in the performance of their official duties.
3. 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.
4. 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.
5. Openness Holders of public office should be as open as possible about all
the decisions and actions that they take. They should give reasons for their
decisions and restrict information only when the wider public interest clearly
demands.
6. 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.
7. Leadership Holders of public office should promote and support these
principles by leadership and example.
In addition to these principles and values, the CCG embraces and includes the
following standards of conduct expected in public service (as promoted by the
Scottish Executive and Good Governance Institute):
•
Public Service: Holders of public office have a duty to act in the interests of
the public body of which they are a Board member and to act in accordance of
the core tasks of the body, and;
•
Respect: Holders of public office must respect fellow members of the public
body and employees of the body and the role they play, treating them with
courtesy at all times.
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Appendix 2
NHS LIVERPOOL CLINICAL COMMISSIONING GROUP
Declaration of Financial and Other Interests for
Members/Employees April 2015 – March 2016
Please complete in block capitals and return (including nil returns) to:
Chief Finance Officer, Liverpool CCG, 3rd Level, The Department, Lewis’s
Building, Renshaw Street, Liverpool L1 1JX
Name (print)
Position or role within
Liverpool CCG
Member / Employee/ Governing Body Member / Committee or SubCommittee Member (including Committees and Sub-Committees of
the Governing Body) [delete as appropriate]
Date Appointed
This is a new declaration
This is a revised declaration
This form is required to be completed in accordance with the CCG’s Constitution and the
Code of Accountability
Before completing this form, please note:
•
Each CCG must make arrangements to ensure that the persons mentioned above
declare any interest which may lead to a conflict with the interests of the CCG and the
public for whom they commission services in relation to a decision to be made by the
CCG.
•
A declaration must be made of any interest likely to lead to a conflict or potential conflict
as soon as the individual becomes aware of it, and within 28 days.
•
If any assistance is required in order to complete this form, then the individual should
contact Lynne Hill, Liverpool CCG by telephoning 0151 296 7195 or via email at
[email protected]
•
The completed form should be sent by both email and signed hard copy to Chief
Finance Officer, Liverpool CCG, 3rd Level, The Department, Lewis’s Building,
Renshaw Street, Liverpool L1 1JX
•
Any changes to interests declared must also be registered within 28 days by completing
and submitting a new declaration form.
•
The register will be published as part of the CCG’s Governing Body meeting papers and
will be available for the public on the CCG website www.liverpoolccg.nhs.uk or by postal
application to the address given above.
•
Any individual – and in particular members and employees of the CCG - must provide
sufficient detail of the interest, and the potential for conflict with the interests of the CCG
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and the public for whom they commission services, to enable a lay person to understand
the implications and why the interest needs to be registered.
•
If there is any doubt as to whether or not a conflict of interests could arise, a declaration
of the interest must be made. Interests that must be declared (whether such interests are
those of the individual themselves or of a family member, close friend or other
acquaintance of the individual) include:
o
o
o
o
o
o
o
o
Roles and responsibilities held within member practices;
Directorships, including non-executive directorships, held in private
companies or PLCs;
Ownership or part-ownership of private companies, businesses or
consultancies likely or possibly seeking to do business with the CCG;
Shareholdings (more than 5%) of companies in the field of health and social
care;
A position of authority in an organisation (e.g. charity or voluntary
organisation) in the field of health and social care;
Any connection with a voluntary or other organisation contracting for NHS
services;
Research funding/grants that may be received by the individual or any
organisation in which they have an interest or role, and;
Any other role or relationship which the public could perceive would impair or
otherwise influence the individual’s judgement or actions in their role within
the CCG.
If there is any doubt as to whether or not an interest is relevant, a declaration of the
interest must be made. In the event of no interests to be declared, the form below
should be completed with ‘nil return’ recorded and duly signed/dated.
Declaration
In accordance with the Code of Accountability I wish to declare the following interests that
fall within the outlined within the Corporate Governance Framework to NHS Liverpool
Clinical Commissioning Group:
Type of Interest
Details
Is this a personal
interest or that of a
family member, close
friend or other
acquaintance?
Roles and responsibilities held within
member practices
Directorships - including non-executive
directorships, held in private companies
or PLCs
Ownership or part-ownership of private
companies, businesses or
consultancies likely or possibly seeking
to do business with the CCG
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Type of Interest
Details
Is this a personal
interest or that of a
family member, close
friend or other
acquaintance?
Shareholdings (more than 5%) of
companies in the field of health and
social care
Positions of authority in an organisation
(e.g. charity or voluntary organisation)
in the field of health and social care
Any connection with a voluntary or
other organisation contracting for NHS
services
Research funding/grants that may be
received by the individual or any
organisation in which they have an
interest or role
Any other specific interests?
Any other role or relationship which the
public could perceive would impair or
otherwise influence the individual’s
judgement or actions in their role within
the CCG
I understand that I have a responsibility at future meetings to declare my interest in any specific
items on the agenda or as part of any project at the point of commencement. This will include any
personal or immediate family interest which may impinge (or be perceived to impinge on my
impartiality in any matter relevant to my duties as a member of NHS Liverpool Clinical
Commissioning Group.
I have read and understood my obligations as outlined in the Conflicts of Interest Policy. I am
signing to confirm that the information provided on this form is true and correct to the best of my
knowledge. I consent to the disclosure of this information to the Local Counter Fraud Specialist
and/or NHS Protect for verification purposes and for the prevention or detection of crime. I confirm
that if any changes to the above declaration occur, it is my responsibility to inform the CCG at the
earliest opportunity. Further to this; I will not engage (directly or indirectly via a third party) in any
discussion or decision where my private or external interests may affect my ability to act in an
open and transparent way; as required by the Standards of Business Conduct (both National and
Local), Conflicts of Interest Policy and the CCG’s constitution.
Signature
Date
OR I have no interests to declare and I confirm a ‘nil’ declaration
Signature
Date
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Appendix 3
NHS LIVERPOOL CLINICAL COMMISSIONING GROUP
Declaration of Financial and Other Interests for
Bidders/Contractors April 2015 – March 2016
This form is required to be completed in accordance with the CCG’s Constitution and s140 of
the NHS Act 2006 (as amended by the Health & Social Care Act 2012) and the NHS
(Procurement, Patient Choice and Competition) (No2) Regulations 2013 and related
guidance.
Notes:
•
•
•
•
•
All potential bidders/contractors/service providers, including sub-contractors,
members of a consortium, advisers or other associated parties (Relevant
Organisation) are required to identify any potential conflicts of interest that could
arise if the Relevant Organisation were 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 in circumstances where the CCG is jointly commissioning the
service with, or acting under a delegation from, NHS England. If any assistance is
required in order to complete this form, then the Relevant Organisation should
contact Lynne Hill, Liverpool CCG by telephoning 0151 296 7195 or via email
at [email protected];
The completed form should be sent by both email (to the address above) and signed
hard copy to the Chief Finance Officer, Liverpool CCG, 3rd Level, The
Department, Lewis’s Building, Renshaw Street, Liverpool L1 1JX
Any changes to interests declared either during the procurement process or during
the term of any contract subsequently entered into by the Relevant Organisation and
the CCG must notified to the CCG by completing a new declaration form and
submitting it to [specify].
Relevant Organisations completing this declaration form must provide sufficient detail
of each interest so that the CCG, NHS England and also a member of the public
would be able to understand clearly the sort of financial or other interest the person
concerned has and the circumstances in which a conflict of interest with the business
or running of the CCG or NHS England (including the award of a contract) might
arise.
If in doubt as to whether a conflict of interests could arise, a declaration of the
interest should be made.
Interests that must be declared (whether such interests are those of the Relevant Person
themselves or of a family member, close friend or other acquaintance of the Relevant
Person), include the following:
•
•
the Relevant Organisation or any person employed or engaged by or otherwise
connected with a Relevant Organisation (Relevant Person) has provided or is
providing services or other work for the CCG or NHS England;
the Relevant Organisation or Relevant Person is providing services or other work for
any other potential bidder in respect of this project or procurement process;
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•
the Relevant Organisation or any Relevant Person has 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.
Declarations
Name of Relevant
Organisation
Interests
Type of Interest
Details
Provision of services or other
work for the CCG or NHS
England
Provision of services or any
other work for any potential
bidder in respect of this project
or procurement process
Any other connection with NHS
Liverpool 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
Name of relevant person
(complete for all relevant
persons)
Interests
Type of Interest
Details
Is this a 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 any
other work for any potential
bidder in respect of this project
Any other connection with NHS
Liverpool CCG or NHS
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Name of relevant person
(complete for all relevant
persons)
Interests
Type of Interest
Details
Is this a personal interest or that of
a family member, close friend or
other acquaintance?
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
Any other role or relationship
which the public could
perceive would impair or
otherwise influence the
individual’s judgement or
actions in their role within the
CCG
I am signing to confirm that the information provided on this form is true and correct to the
best of my knowledge. I consent to the disclosure of this information to the Local Counter
Fraud Specialist and/or NHS Protect for verification purposes and for the prevention or
detection of crime. I confirm that if any changes to the above declaration occur, it is my
responsibility to inform the CCG at the earliest opportunity. Further to this; I will not engage
(directly or indirectly via a third party) in any discussion or decision where my private or
external interests may affect my ability to act in an open and transparent way; as required by
the Standards of Business Conduct (both National and Local), Conflicts of Interest Policy
and the CCG’s constitution.
Signed:
On behalf of:
Date
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Appendix 4
Declaration of Offers and Receipt of Gifts/Hospitality
1: Personal details
Name
Title
Job Title/Role
Directorate/Service
Tel no
email
Base/location
2: Receipt/offer of Gift, Hospitality and/or Care
Nature of benefit offered
Value
Company or individual
from which offer was
made
Was the gift/hospitality
accepted?
YES
□
NO
□
Signed
Print Name
Date
3. Authorisation (for completion by line manager/Head of Service)
Title
Name
Job Title/Role
Directorate/Service
Tel no
email
Signed
Please return this form to Lynne Hill, Liverpool CCG, 3rd Level, The Department,
Lewis’s Building, Renshaw Street, Liverpool L1 1JX or via
email [email protected]
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Gifts and Hospitality Register Guidance
This Register is for the recording of any gift or hospitality offered to or by CCG staff
which may be associated with activities in their official capacity (as set out in the
Gifts and Hospitality section of the Conflicts of Interest Policy). Exceptions to this
may be considered where additional internal instructions have needed to be
provided.
The requirement to seek authorisation for gifts and hospitality arising from official
activity (and record on the register) applies equally where the beneficiary may be a
relative or associate. Examples are where a gift is made, employment offered to a
spouse, partner, relative or friend; or where a spouse/partner is included in an
invitation to a function.
Definition of terms
•
•
•
Gifts include tickets to events; vouchers, rewards and prizes and items loaned
or bought at market value;
Hospitality includes the provision of meals and invitations to functions, and
being accompanied to sporting, entertainment and other venues where the
‘other party’ pays some (or all) of the costs of the CCG attendees;
Excluded from scope are rewards and prizes internal to the CCG (e.g. within
the Long Service Award and Reward and Recognition schemes.
Gifts
Acceptable and Unacceptable Gifts and Hospitality - Examples
Acceptable
Isolated, trivial, inexpensive e.g.
Unacceptable
All other gifts, e.g.
•
•
•
•
•
•
•
Hospitality
•
•
•
Pocket diary
Calendar or other stationery
Calculators
Keyrings
Box of Chocolates
•
•
Catering service refreshments (tea/coffee) at
meetings with those coming from outside the
CCG
Catering service lunch/other meal for guests
to the CCG (only with suitable authorisation)
CCG funded drinks (or drinks reception) to
guests of the CCG (only with suitable
authorisation
Attendance at one off/annual dinner or
modest social function of an organisation,
association or body with which the CCG is in
regular contact (with suitable senior level
authorisation)
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•
•
•
•
•
•
Gift vouchers (other than issued via Reward
and Recognition schemes)
Membership/subscription to an organisation
such as sports or other clubs
Tickets to sporting, social and or leisure
events
Holidays (UK and abroad) or holiday travel
Goods and services at trade/discount prices
Catering service refreshments/luncheon
provided for closed internal CCG meetings
Payment to CCG staff by outside body of
hotel expenses or other subsistence
Payment to CCG staff of travelling expenses
by an outside body
Attendance at frequent or extravagant social
functions (particularly invitations from the
same source).
Appendix 5
The Chartered Institute of Purchasing and Supply (CIPS) Code of Ethics
Use of the code
Members of CIPS are required to uphold this code and to seek commitment to it by
all those with whom they engage in their professional practice. Members are
expected to encourage their organisation to adopt an ethical purchasing policy based
on the principles of this code and to raise any matter of concern relating to business
ethics at an appropriate level. The Institute’s Royal Charter sets out a disciplinary
procedure which enables the CIPS Board of Trustees to investigate complaints
against any of our members and, if it is found that they have breached the code to
take appropriate action. Advice on any aspect of the code is available from CIPS.
This code was approved by the CIPS Council on 11 March 2009.
As a member of The Chartered Institute of Purchasing & Supply, I will:
•
•
•
•
•
•
•
Maintain the highest standard of integrity in all my business relationships
Reject any business practice which might reasonably be deemed improper
Never use my authority or position for my own personal gain
Enhance the proficiency and stature of the profession by acquiring and applying
knowledge in the most appropriate way
Foster the highest standards of professional competence amongst those for
whom I am responsible
Optimise the use of resources which I have influence over for the benefit of my
organisation
Comply with both the letter and the intent of:
o The law of countries in which I practise
o Agreed contractual obligations
o CIPS guidance on professional practice
•
•
•
•
•
•
•
Declare any personal interest that might affect, or be seen by others to affect, my
impartiality or decision making
Ensure that the information I give in the course of my work is accurate
Respect the confidentiality of information I receive and never use it for personal
gain
Strive for genuine, fair and transparent competition
Not accept inducements or gifts, other than items of small value such as business
diaries or calendars
Always to declare the offer or acceptance of hospitality and never allow
hospitality to influence a business decision
Remain impartial in all business dealing and not be influenced by those with
vested interests
Advice on any aspect of the code of ethics is available from CIPS.
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138
Report no: GB 07-16
NHS LIVERPOOL CLINICAL COMMISSIONING GROUP
GOVERNING BODY
TUESDAY 12TH JANUARY 2016
Title of Report
CCG Safeguarding Annual Report
Lead Governor
Jane Lunt, Chief Nurse/Head of Quality
Senior Management
Team Lead
Jane Lunt, Chief Nurse/Head of Quality
Report Authors
Kerry Lloyd, Deputy Chief Nurse/Head of Quality
Helen Smith, Head of Safeguarding Adults
Ann Dunne, Head of Safeguarding Children
The purpose of this paper is to highlight the Safeguarding
Annual Report for 2014/2015 to the Governing Body
Summary
Recommendation
That Liverpool CCG Governing Body:
 Notes the report and the contents
Impact on improving
health outcomes,
reducing inequalities
and promoting
financial
sustainability
To ensure the CCG meets the standards and
responsibilities set out in ‘Safeguarding Vulnerable People
in the Reformed NHS: Accountability and Assurance
Framework’ NHS England March 2015
And Working Together 2015
Relevant Standards
or targets
Preventing people from dying prematurely
Ensuring that people have a positive experience of care
Treating and caring for people in a safe environment, with
dignity and protecting them from harm
139
Page 1 of 3
SAFEGUARDING ANNUAL REPORT 2014/15
1.
PURPOSE
The purpose of this paper is to highlight the Safeguarding Annual Report
for 2014/2015 to the Governing Body.
2.
RECOMMENDATIONS
That Liverpool CCG Governing Body

3.
Notes the report and the contents
BACKGROUND
Each CCG is required to produce an annual report with regard to
safeguarding which provides assurance that the CCG has safely
discharged its statutory responsibilities to safeguard the welfare of children
and adults at risk of abuse across the health services the CCG
commissions. Safeguarding accountabilities for CCGs are defined within
the Accountability and Assurance Framework: Safeguarding Vulnerable
People in the Reformed NHS (2015).
NHS Liverpool CCG, in conjunction with the other 5 Mersey CCGs, has
commissioned a Safeguarding Service, currently hosted by NHS Halton
CCG, which provides both adult and childrens’ safeguarding nurses who
provide a service to the CCG. In addition, the Designated Doctor role is
currently provided via Alder Hey NHS Trust and there are 2 Named
General Practitioners who work within the CCG to support Primary care to
meet its safeguarding responsibilities.
4.
OVERVIEW
This is the second annual report that the CCG has produced. It
demonstrates the progress made in establishing constructive relationships
across the health economy and within the Adult and Children
Safeguarding Boards and Citysafe (the Community Safety Partnership
within Liverpool). It is anticipated that the report will be published on the
CCG website.
Notable work undertaken in this year includes:
• Implementing the Prevent and Channel guidance
140
Page 2 of 3
•
•
•
Dealing with the increased number of Deprivation of Liberty
Safeguards (DoLS) following the Cheshire West and Chester ruling in
March 2013
Implementing Child Sexual Exploitation (CSE) guidance and ensuring
the health response is effective for those identified as at risk of CSE
Participating in the development of the Multi- Agency Safeguarding
Hub (MASH) for children
In terms of achieving the 8 Business Priorities for 2014/15, 4 have been
completed, 3 remain in progress and transferred into the Business Plan for
2015/16 to ensure completion. One remains outstanding; the model of
supervision for the Safeguarding Service, which despite exploration of a
number of options, and financial resource, has not been achieved. This is
a national issue, and NHS England is supporting the raising of this as a
national issue, and the securing of a solution.
Priorities for 15/16
• Female Genital Mutilation (FGM)- this is an area of national focus.
• Supervision for the Safeguarding Service
Jane Lunt
Chief Nurse/Head of Quality
06/01/16
ENDS
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Page 3 of 3
142
NHS Liverpool CCG
Safeguarding
Annual Report
Author: CCG Safeguarding Service
Date: October 2015
143
Foreword by the Chief Nurse for CCG
NHS Liverpool Clinical Commissioning group (CCG) demonstrates a strong commitment to
safeguarding children and adults within the local communities. There are strong governance
and accountability frameworks within the Organisation which clearly ensure that the
safeguarding of children and adults is core to the business priorities. The commitment to the
safeguarding agenda is demonstrated at Executive level and throughout all CCG employees.
One of the key focus areas for the CCG is to actively improve outcomes for children and
adults at risk and that this supports and informs decision making with regard to the
commissioning and redesign of health services within the City.
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144
Contents
1
2
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
2.9
2.10
2.11
2.12
2.13
3
3.1
3.2
3.3
3.4
3.5
3.6
3.7
3.8
3.9
4
Foreword
Executive summary
Purpose of the report
National Context
NHS Accountability framework
Intercollegiate Document: roles and competencies for health care
staff
Promoting Health and Wellbeing of Looked After Children
Looked after Children: Knowledge, Skills and competencies of
Health Care Staff
Safeguarding Inspection Framework
The Care Act
Mental Capacity Act and Deprivation of Liberty Safeguards
Prevent – Prevent Strategy
Channel
Prevent Delivery in Health and Home Office Priority and Non
Priority Areas
NHS Liverpool CCGs work with Prevent
Statutory guidance issued under section 29 of the CounterTerrorism and Security Act (2015)
HM Government Channel Duty Guidance – Protecting vulnerable
people from being drawn into terrorism
Local Context
CCG Governance arrangements
Effectiveness of Safeguarding Arrangements
Learning and Improvement
Child Death Overview Panel (CDOP)
Child Sexual Exploitation (CSE)
Multi-Agency Safeguarding Hubs (MASH)
Named GP
Business Continuity
Key Achievements
Conclusion
Emerging Priorities for 2015/16
3
145
Page No.
2
4
5
5
5
6
7
7
7
7
9
10
11
11
11
12
12
13
13
13
15
16
17
18
18
19
20
20
20
Executive Summary
This is the second annual safeguarding report to NHS Liverpool Clinical Commissioning
Group Governing Body. The purpose of the report is to assure the Governing Body and
members of the public that the Clinical Commissioning Group (CCG) is fulfilling its statutory
duties in relation to safeguarding children and adults in the city: it takes account of national
changes and influences and local developments and activity.
The report also highlights the local development, performance, governance arrangements
and activity and the challenges to business continuity.
A separate report around Looked After Children has been authored under the current
commissioning arrangements by the provider leads about how the health needs of this
cohort of children and young people have been met. The reporting arrangements will change
for 2015/16. It is anticipated that the Designated Nurse for Looked After Children will author
an overview report incorporating the CCG function and all relevant health provider data for
this group of children.
4
146
1
Purpose of the report
This is the second annual safeguarding report to NHS Liverpool Clinical Commissioning
Group Governing Body and reviews the work across and progress throughout the
2014/2015.
In Merseyside, to meet with national requirements, there is a Hosted Safeguarding Service,
which serves NHS Liverpool, South Sefton, Southport & Formby, Halton, St Helens and
Knowsley CCG’s. The hosting arrangements remain with NHS Halton CCG as originally
agreed in 2013.
This report is intended to provide assurance that the CCG has safely discharged its statutory
responsibilities to safeguard the welfare of children and adults at risk of abuse across the
health services it commissions.
The report will also provide information about national and local changes and influences,
local development, performance, governance arrangements and activity and the challenges
to business continuity.
Although the report does include information regarding Looked After Children, a separate
report has been authored under the current commissioning arrangements by the provider
Leads about how the health needs of this cohort of children and young people have been
met. These reporting arrangements will change for 2015/16 due to the new commissioning
arrangements.
2
National Context
2.1 The NHS Accountability and Assurance framework: Safeguarding Vulnerable
People in the Reformed NHS (2013)
Safeguarding accountabilities for CCG’s, NHS England, NHS Providers and other
Organisations within the health economy are defined within the Accountability and
Assurance framework: Safeguarding Vulnerable People in the Reformed NHS (2013).
NHS England has the responsibility for providing safeguarding clinical leadership
support to the designated professionals for safeguarding children, looked after children
and safeguarding adult’s leads.
The CCG safeguarding arrangements and work plan continues to take full account of
this. A revision to the 2013 framework was announced in early 2015 and a consultation
document released with the intent to publish the fully revised guidance in in May 2015.
The CCG responded and contributed to this consultation document.
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147
The current framework outlines and includes the need to:
• Promote partnership working to safeguard children, young people and adults at risk
of abuse, at both strategic and operational levels
• Clarify NHS roles and responsibilities for safeguarding, including in relation to
education and training
• Provide a shared understanding of how the new system will operate and, in
particular, how it will be held to account both locally and nationally
• Ensure professional leadership and expertise are retained in the NHS, including the
continuing key role of designated and named professionals for safeguarding children
• Outline a series of principles and ways of working that are equally applicable to the
safeguarding of children and young people and of adults in vulnerable situations,
recognising that safeguarding is everybody’s business. plans to train staff in
recognising and reporting safeguarding issues
• Provide a clear line of accountability for safeguarding, properly reflected in the CCG
governance arrangements
• Provide appropriate arrangements to co-operate with local authorities in the operation
of LSCBs, SABs and Health and Wellbeing Boards
• Ensure effective arrangements for information-sharing
• Have a safeguarding adults lead and a lead for the Mental Capacity Act, supported
by the relevant policies and training.
2.2 Intercollegiate document: safeguarding children and young people: roles and
competencies for health care staff (March 2014)
All health staff have a duty to promote the welfare of and safeguard children and young
people. Staff are required to have the competences to recognise when intervention is
required and be able to take effective action appropriate to their role. This third edition
document has been ratified by the Royal Colleges and professional bodies in order to
provide and support a consistent approach and framework for training and development
across the health economy.
The document takes account of the changing landscape of the NHS and included
requirements for the Executive Team and Board members.
The document indicates that all staff must clearly understand their responsibilities, and
should be supported by their employing organisation to fulfil their duties. The standards
within this document inform organisational training, training strategies and training
needs analysis for health care organisations, providing a framework for use within
annual staff appraisal to ensure knowledge and skills have been acquired.
2.3 Promoting the Health and Wellbeing of Looked After Children (March 2015):
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148
This document was published in March 2015 by the Department for Education and the
Department of Health. It outlines statutory roles and responsibilities for all agencies
including Local Authority partners and NHSE. This refreshed publication is explicit with
regard to the role of the CCG and will be crucial in supporting and informing the CCG
work plan in 2015/16.
2.4 Looked After Children: Knowledge, Skills and Competences of Health Care
Staff (March 2015):
This document was developed in partnership with the Royal College of Nursing and the
Royal College of GPs, and mirrors the Intercollegiate Document for Safeguarding
Children. The document outlines key levels of knowledge, skill and competencies for
health staff who work (indirectly or directly) with looked after children. It provides a
framework for healthcare staff to understand their role and responsibilities for meeting
the needs of looked after children.
This document will be key to informing the CCG’s safeguarding work plan and priorities
for Looked After Children going forward into 2015/16.
‘2.5 Working Together to Safeguard Children: A guide to inter-agency working to
safeguard and promote the welfare of children (March 2015)
Working Together to Safeguard Children was revised and published in March 2015.
The guidance outlines: the legislative requirements and expectations on individual
services to safeguard and promote the welfare of children and a clear framework for
Local Safeguarding Children’s Boards (LSCBs) to monitor effectiveness of local
services.
Although not a major review, the 2015 guidance includes changes around:
how to refer allegations of abuse against those who work with children;
clarification of requirements on local authorities to notify serious incidents; and
the definition of serious harm for the purposes of serious case reviews.
•
•
•
The CCG safeguarding arrangements and work plan takes full account of the 2013
framework and will incorporate the 2015 revisions and implications for practice going
forward into 2015 / 16.
2.6 Safeguarding Inspection Framework
The Care Quality Commission (CQC) single agency safeguarding inspection
programme continued throughout 2014 / 15 in the absence of a published multi-agency
inspection framework. Consultation on a joint inspection regime took place between July
2014 and September 2014 with a proposed pilot starting in autumn 2015. The current
CQC Safeguarding Inspection regime focuses on evaluating the quality and impact of
the local health arrangements. The hosted Safeguarding Service has continued
throughout the year to provide support across the health economy in readiness for an
inspection should the CQC notify.
During May and June 2014 Liverpool LSCB and Local Authority (LA) services for
children in need of help and protection, children in care and care leavers was subject to
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an Ofsted Inspection. The inspection took place over a four week period and was
supported by the CCG and commissioned health Providers within the City.
The final report was published in July 2014 the judgment being that both the LSCB and
the LA childrens services require improvement. Inspectors found no widespread or
serious failures that created or left children being harmed or at risk of harm and
concluded that the welfare of looked after children (children in care) is safeguarded and
promoted. The CCG, in conjunction with Partner agencies, continue to support and
progress actions against the recommendations made by Ofsted to improve outcomes for
children and young people in the City.
2.7 The Care Act 2014
The Care Act 2014 provides a coherent approach to adult social care in England. It
represents the most significant change to social care legislation in 60 years. The
changes aim to enable people to have more control over their own lives. Support should
be about prevention, with the ultimate goal of helping people stay independent. The
legislation sets out how people’s care and support needs should be met and introduces
the right to an assessment for anyone, including carers and self-funders, in need of
support. There is a requirement for partnership working and integration in relation to
care and finances. Transition assessments should be carried out for young people who
will be requiring adult services once aged 18, whether already receiving children’s
services or not - this will need to be integrated with health and education.
The safeguarding of adults is placed on a statutory footing from April 2015. The
safeguarding duties apply to an adult who:
•
•
•
has needs for care and support (whether or not the local authority is meeting any of
those needs) and;
is experiencing, or at risk of, abuse or neglect; and
as a result of those care and support needs is unable to protect themselves from
either the risk of, or the experience of abuse or neglect.
The Care Act places a duty on the Local Authority to make a Section 42 enquiry (or to
make sure that, as the lead agency, enquiries are carried out by the relevant
organisation) where there is a concern about the possible abuse or neglect of an adult
at risk. An enquiry must be proportionate and may take the form of a conversation with
the individual concerned (or with their representative or advocate). It may need the
involvement of another organisation or individual. Or it may require a more formal
process, perhaps leading to a formal multi-agency plan to ensure the wellbeing of the
adult concerned.
In many cases a professional who already knows the adult will be the best person to
undertake a Section 42 enquiry. The local authority retains the responsibility for
ensuring that the enquiry is referred to the right place and is acted upon. The local
authority, in its lead and coordinating role, should assure itself that the enquiry satisfies
its duty under section 42 to decide what action (if any) is necessary to help and protect
the adult and by whom and to ensure that such action is taken when necessary. In this
role if the local authority has asked someone else to make enquiries, it is able to
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challenge the body making the enquiry if it considers that the process and/or outcome is
unsatisfactory.
The Care Act requires that all statutory members of the Safeguarding Adults Board
(SAB) identify a Designated Adult Safeguarding Manager (DASM).This a similar role to
the Local Authority Designated Officer (LADO) role in children’s services, responsible for
the management and oversight of individual complex cases and coordination where
allegations are made or concerns raised about a person, whether an employee,
volunteer or student, paid or unpaid. Interim local arrangements are in place in
Merseyside and Cheshire.
The Care Act states that all Local Authorities must have a SAB and it places them on a
statutory footing from April 2015. Membership must include the local authority, the NHS
and the police, who should meet regularly to discuss and act upon local safeguarding
issues. The main objective of the SAB is to ensure itself that the local safeguarding
arrangements and partners act to protect adults in the area. A yearly plan and annual
report must be provided. There is a well-established Liverpool SAB is in place with
representation at the Board and subgroups by NHS Liverpool CCG and the hosted
Safeguarding Service. There is a legal requirement to arrange for Safeguarding Adults
Reviews (previously Adult Serious Case Reviews) to ensure lessons can be learned
from serious incidents.
The Care Act states that arrangements must be made where appropriate, for an
independent advocate to represent and support an adult who is the subject of a
safeguarding enquiry or Safeguarding Adult Review (SAR) where the adult has
‘substantial difficulty’ in being involved in the process and where there is no other
suitable person to represent and support them.
All commissioners, including CCG’s are expected to embed safe practice in all
commissioning activity in line with Care Act and local policy requirements. The quality
schedule contracts and safeguarding key performance indicators for NHS Liverpool
CCG health commissioned services for 2015/16 are compliant with the Care Act
requirements.
2.8 Mental Capacity Act and Deprivation of Liberty Safeguards
Supreme Court Ruling 2014
The Mental Capacity Act (MCA) 2005 has been fully implemented since October 2007.
The Deprivations of Liberty Safeguards (DoLS), which form part of the Act, were
introduced in April 2009 as part of the amendments to the Mental Health Act 1983. The
intention was to provide a legal framework around the deprivation for those people who
are assessed as lacking the capacity to make decisions about their care and treatment
or support. The intention was to avoid breaches under Article 5 of the European
Convention on Human Rights, which occurred in HL v United Kingdom (ECtHR; (20040
40 EHRR 761), and often referred to as the ‘Bournewood Gap’.
Originally there lacked a legal definition about what amounted to a Deprivation of
Liberty, however there were a number of factors which were required to be considered
(Page 17 DoLS Code of Practice). Cheshire West and Chester local authority have been
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challenged in the High Court on a DoLS authorisation that was granted on P resulting in
a Supreme Court ruling in March 2014. The Supreme Court Judgement passed, ruling
that the deprivation for P was unlawful. A subsequent judgment of P & Q v Surrey
County Council, also determined there was an unlawful deprivation. These land mark
cases have led to significant changes to whom and when a Deprivation of Liberty
authorisation must be made. There now exists a clear definition of the factors to
consider when deciding is a person is being deprived of their liberty. They introduced
the "acid test" term which need to be considered when deciding whether a person is
being deprived of their liberty;
1 - The person lacks capacity AND
2 - The person is not free to leave AND
3 - The person is subject to continuous supervision
The number of DoLS referrals has significantly increased as a result of the judgement.
This is a national concern and the implications are far reaching in; resources, workload
and financial costs. Several test cases continue to be taken through the Court of
Protection.
Deprivation of Liberty and the Coroner Act (2009)
There are specific implications where an individual who dies with a DoLS authorisation
is in place, which is deemed to be a death in custody under lawful detention.
Consequently all such deaths must be referred to the Coroner requiring an inquest.
Under these circumstances the responsible Medical Practitioner or General Practitioner
is legally not permitted to issue the medical certificate of cause of death. This process
has been described by Mr Sumner (HM Coroner) for Merseyside, in line with section
1(2)(c)) of the Coroners Act and Section 16 of the Chief Coroners Guidance. There is a
requirement for all GP’s employed with the Liverpool CCG area to be aware of their
legal responsibilities in line with the Coroners Act. The circular was completed and
submitted after April 2015 therefore, would this go into the action plan and then
evidence as completed as part of the annual report for 2015-16
https://www.judiciary.gov.uk/wp-content/uploads/2013/10/guidance-no16-dols.pdf
2.9 Prevent
The Prevent Strategy (2011)
The Prevent strategy is a key part of CONTEST, the Government’s counter terrorism
strategy. It aims to stop people becoming terrorists or supporting terrorism. The strategy
aims to respond to the ideological challenge of terrorism and those who promote it,
prevent people from being drawn into terrorism, and work with sectors and institutions
where there are risks of radicalisation.
Work includes disrupting extremist speakers, removing material online, intervening to
stop people being radicalised, and dissuading people from travelling to Syria and Iraq
and intervening when they return. The most significant terrorist threat is currently from Al
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Qai’da-associated groups and from terrorist organisations in Syria and Iraq, including
ISIL. Terrorists associated with the ‘extreme right’ also pose a threat.
2.10 Channel
‘Channel’ is a multi-agency safeguarding programme which operates throughout
England and Wales. It provides tailored support to people who have been identified as
at risk of being drawn into terrorism. The support offered can come from any of the
partners on the panel, which include the local authority, police, education, and health
providers. Support will often involve experts who understand extremist ideology.
Engagement with the programme is entirely voluntary at all stages
2.11 Prevent Delivery in Health and Home Office ‘Priority’ and ‘Non-Priority Areas’
Priority Areas are areas identified by the Home office as areas where there is a high risk
of radicalisation.
In January 2015, NHS England reduced the Prevent resource to priority areas within the
UK following the Home Office funding decision in April 2014. Regional Prevent
Coordinators (RPCs) within the priority areas identified by the Home Office, continued to
operate a business as usual policy providing support; and NHS commissioned providers
submitted quarterly Prevent returns monitoring progress against the Home Office
deliverables to RPCs.
In non-priority areas, each CCG Prevent Lead should have links with their provider
organisation’s Prevent Lead with RPCs being used as a point of contact for advice
about issues that could not be managed locally. In the North West region the RPC role
was only occupied for part of the reporting year and NHS Liverpool CCG health
commissioned services accessed the RPC lead from another priority area as required.
An RPC for the North West region will commence in post from August 2015.
CCGs were required to ensure that organisations within their regions were aware of the
changes and the necessity to comply with the prevent requirements set out in the
safeguarding clause of the NHS Standard Contract.
2.12 NHS Liverpool CCGs work with Prevent
Liverpool is identified as a priority area.
The CCG has an identified Prevent Lead and Prevent training for CCG staff is
anticipated to be a statutory requirement in line with the recommendations outlined in
the 2015 Prevent Duty Guidance: For England and Wales.
Prevent delivery for each provider organisation was included within the NHS Standard
Contract for 2014/15 for provider organisations.
The hosted Safeguarding Service for NHS Liverpool CCG has incorporated Prevent into
the safeguarding KPI’s for health commissioned services and all health commissioned
providers for NHS Liverpool CCG report on Prevent compliance as part of the Quality
Schedule
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2.13 Statutory guidance issued under section 29 of the Counter-Terrorism and
Security Act (2015)
Section 26 of the Counter-Terrorism and Security Act 2015 (the Act) places a duty on
certain bodies (“specified authorities” listed in Schedule 6 to the Act), in the exercise of
their functions, to have “due regard to the need to prevent people from being drawn into
terrorism”.
This guidance is issued under section 29 of the Act. The Act states that the authorities
subject to the provisions must have regard to this guidance when carrying out the duty.
The duty applies to specified authorities in England and Wales, and Scotland. Counter
terrorism is the responsibility of the UK Government.
In fulfilling the duty, the Act expects health bodies to demonstrate effective action in the
following areas:
•
•
•
•
Partnership
Risk Assessment
Staff Training
Monitoring and enforcement
2.14 HM Government Channel Duty Guidance – Protecting vulnerable people from
being drawn into terrorism
Channel is a programme which focuses on providing support at a pre criminal stage to
people who are identified as being vulnerable to being drawn into terrorism. The
programme uses a multi-agency approach to protect vulnerable people by:
•
•
•
identifying individuals at risk
assessing the nature and extent of that risk
developing the most appropriate support plan for the individuals concerned
Channel may be appropriate for anyone who is vulnerable to being drawn into any form
of terrorism. Channel is about ensuring that vulnerable children and adults of any faith,
ethnicity or background receive support before their vulnerabilities are exploited by
those that would want them to embrace terrorism, and before they become involved in
criminal terrorist activity. NHS Liverpool CCG and the hosted Safeguarding Service will
be statutory health members of a Channel Panel when required.
3
Local Context
3.1 CCG Governance arrangements
NHS Liverpool CCG Accountable Officer has the responsibility to ensure that the
contribution by health services to safeguarding and promoting the safety of children,
young people and adults at risk is appropriate and embedded across the health
economy. This is largely achieved by the local commissioning arrangements and
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membership of the Health and Wellbeing Board. Safeguarding is the responsibility of all
CCG employees and is clearly demonstrated within the CCG governance structure.
The Chief Nurse is the named representative for both the Local Safeguarding Children
and Adult Boards and has the responsibility to ensure that the monitoring of children,
young people and adults at risk takes place within these frameworks and should report
any risk within the system through to the Accountable Officer and Governing Body.
NHS Liverpool CCG jointly commissions a hosted service approach to the delivery of
their safeguarding function for both children and adults. The Safeguarding Service is
hosted by NHS Halton CCG and has a defined specification and Memorandum of
Understanding (MOU) in place. Further to a full review within this reporting year, the
Service has received increased resources and secured the expertise of: Designated
Nurses Safeguarding Children, Designated Nurse Looked After Children and
Designated Nurses Adults. Separate commissioning arrangements provide the expertise
of a Designated Doctor and Named GP. All of these professionals have acted as clinical
advisors to NHS Liverpool CCG on safeguarding matters and support the Chief Nurse to
ensure that the local health system is safely discharging safeguarding responsibilities.
3.2 Effectiveness of Safeguarding Arrangements
The CCG has a statutory requirement under Section 11 of the Children Act 2004 to
actively demonstrate that safeguarding duties are safely discharged ie the need to
safeguard and promote the welfare of children and young people. The current
arrangements require NHS Liverpool CCG to submit evidence of safeguarding
compliance to Liverpool LSCB for their scrutiny as per the agreed audit cycle. Any areas
for development and action are presented to and monitored by the Quality Committee in
accordance with the CCG governance arrangements. The hosted Safeguarding Service
responded to the request by Liverpool LSCB in 2014 / 15 to provide an update regarding
compliance against the Section 11 standards.
Evidence available to support these standards includes the revision and ratification of
the Safeguarding Children and Adults Policy, Managing Allegations against Health
Professionals policy, the Safeguarding Strategy and CCG declaration.
NHS Liverpool CCG commissioned a review of safeguarding arrangements, in
partnership with NHS Southport & Formby and South Sefton CCGs. The review was
conducted by Edge Hill University, the findings and recommendations of which were
reported in April 2014. Progress reports against the agreed action plan have been
submitted to the Quality Committee throughout the year.
The Review focused on the following themes:
•
•
•
•
•
Voice of the child and young person/ voice of the vulnerable adult/adult at risk
Vision, strategy, leadership and the capacity to improve
Governance, accountability and risk management
Quality improvement, learning and workforce development
Efficient/effective use of resources
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Within the current commissioning arrangements the CCG has a statutory duty to ensure
that that all health providers from whom we commissions services (both public and
independent sector), promote the welfare of children and protect adults from abuse or
the risk of abuse. This includes specific responsibilities for Looked After Children. This is
predominantly achieved but not limited to the use of the quality schedule within the NHS
contract. The hosted Safeguarding Service is responsible for the development of the
safeguarding quality schedule / performance framework and the key performance
indicators (KPI’s) for 2014 / 15 were informed by national indicators, guidance, LSCB
/SAB priorities and Inspection findings. Commissioned services are required to report
against this schedule as per the contractual agreement; evidence is submitted on a
quarterly basis to provide the CCG with assurance. The hosted Safeguarding Service is
responsible for the monitoring and validation of this evidence and reports on both
compliance and identified risk within the system, this is achieved through the Quality
Committee within the agreed reporting schedule and further discussed with our
commissioned health services within the Clinical Quality and Performance Group.
Throughout this reporting year the hosted Safeguarding Service has identified that a
number of commissioned health services were unable to provide an acceptable level of
assurance against the safeguarding quality schedule. They have been reported to the
quality committee as providing limited assurance and the detail of risk has been
outlined. NHS Liverpool CCG is working in collaboration with the coordinating
commissioners of these services and the Provider directly to support progress against
the schedule and to mitigate any risks within the system where possible.
The CCG and the hosted service are committed to supporting provider services and
work collaboratively with them to further develop systems that enable the health
economy to demonstrate outcomes for children, young people and adults at risk. This is
achieved throughout the year by attendance at internal provider safeguarding assurance
groups or by Chairing focus groups when developing work plans in accordance with
national and local guidance.
Supervision
The hosted Safeguarding Service has provided formal and informal children’s and adult
safeguarding supervision for health services commissioned by NHS Liverpool CCG.
3.3 Learning and Improvement
The hosted Safeguarding Service continues to promote the learning and development of
staff across the health economy. A review and revision of the safeguarding children
training modules for the NHS Liverpool CCG has been undertaken to ensure the quality
and content is in accordance with current guidance. Oversight of training within
commissioned health services is mainly achieved through the LSCB/SAB Joint training
Subgroup group which the Designated Nurse currently chairs.
Safeguarding training is part of the mandatory schedule for all CCG employees and
Level 1 competencies are achieved via an eLearning programme.
Safeguarding
Adults - Level 1
Safeguarding
Children - Level 1
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13.6%
47%
The compliance rates for Adult and Children’s Training fall below the targeted level of
95% and the CCG continue to invest resource to support progression to full compliance.
The hosted Safeguarding Service are fully engaged with the work of the LSCB/SAB and
continue to Lead across the health economy in relation to the Serious Case Reviews
(SCR) and Domestic Homicide Reviews (DHR): both of which are fully established on a
statutory basis and the threshold criteria, process and purpose defined in specific
guidance.
NHS Liverpool CCG Designated Nurse Professionals continues to work closely with the
LSCB furnishing the Critical Incident Group, DHR Panels and other review groups.
Liverpool City Safe Partnership commissioned three DHR’s within this reporting year
and one Single Agency Review which is being conducted by NHS England. The DHR
reviews are managed under the Home Office statutory guidance for conducting
homicide reviews.
The key purpose for undertaking DHRs is to enable lessons to be learned from
homicides where a person is killed as a result of domestic violence. The Designated
Nurse for Safeguarding Adults is a member of the DHR panels. Key learning points from
the reviews are monitored by the Violence Against Women and Girls (VAWG) sub group
which is attended by the Safeguarding Service.
During 2014 / 15 one new SCR has been commissioned by Liverpool SCB and there
has been support and contribution to an SCR commissioned by a neighbouring LSCB.
Four reviews were also completed within this time period; these comprised of three
Critical Incident Reviews (CIR) and one SCR. The key purpose for undertaking these
reviews is to enable lessons to be learned and to improve outcomes for children and
young people.
Findings and learning from the reviews, in relation to health, will be addressed and
monitored by the LSCB health sub group of which the CCG Chief Nurse, Designated
professionals and Named GP are active members and also Chair. This supports
learning across the whole of the health economy including primary care.
All reviews and findings are reported into the CCG via the agreed internal governance
arrangements.
Liverpool LSCB has further developed systems in relation to multi agency audit; the
Designated Nurse chairs this sub group.
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Liverpool Safeguarding Adults Board (SAB)
NHS Liverpool CCG is a core member of the Liverpool Safeguarding Adults Board
which gains statutory status from April 2015 following the implementation of the Care
Act 2014.
The Chief Nurse for Liverpool CCG co- chairs the Liverpool SAB. The Safeguarding
Service attends the SAB and subgroups and chairs the joint Sefton and Liverpool
Safeguarding Adult Boards.
NHS Liverpool CCG’s provide a financial contribution to support the work of the
Liverpool Safeguarding Adults Board
3.4 Child Death Overview Panel (CDOP)
Liverpool LSCB has a statutory responsibility to ensure that a review of all child deaths
(residents of the City). This is achieved by the Child Death Overview Panel (CDOP)
which Liverpool LSCB commission as a Merseyside arrangement .The CCG support this
arrangement through the financial contribution to the LSCB: the Designated
Professionals furnish this group and ensure that any learning is communicated back
through to the wider health economy.
During April 2014- March 2015 a total of 38 Liverpool child deaths were reported to the
Merseyside CDOP. 15 of the deaths were related to females and 23 to males. 29 of the
deaths were classed as being expected and 9 unexpected.
During April 2014 – March 2015 Merseyside CDOP met on 11 occasions and reviewed
a total of 92 deaths, 40 of the cases that were reviewed related to Liverpool children. Of
the 22 cases that were reviewed 5 were perinatal (24 weeks – 7days) 13 were neonatal
(birth – 28 days), 8 were infants (1 month- 1 year) and 14 were child deaths (1 year to
18 years).Of the 40 cases reviewed from Liverpool none were subject of a child
protection plan or child in need plan 2 were subject of a care order, 2 were looked after
children. 2 of the child deaths from Liverpool were reported to have resulted from risk
taking behaviour. 8 of the child deaths were considered to have had modifiable factors
these included smoking in the household, co-sleeping and risk taking behaviour.
The Merseyside CDOP has continued to focus work on promoting safe sleep. A set of
safe sleeping guidelines to be used by practitioners from the health economy has been
developed and there are plans to expand the guidelines to be used across the multiagency partnership. A number of safe sleeping awareness raising sessions were
conducted these were organised and funded by the Merseyside CDOP and facilitated by
the Lullaby Trust. There are plans to develop a safe sleeping campaign for 2015-16.
It has been highlighted that there continues to be an issue with missing data relating to
the child’s father, community midwifery records not being returned to the main maternity
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notes, lack of evidence that routine enquiry questions are being asked in relation to
domestic abuse
Reporting standards have been introduced to CDOP with an expectation that cases will
now be reviewed within four months of the child’s death. There have been modifications
made to the central recording database to ensure that alerts are sent to the relevant
providers when their CDOP report is required.
3.5 Child Sexual Exploitation (CSE)
The sexual exploitation of children and young people is a form of sexual abuse. It is not
new. What is new is the level of awareness of the extent and scale of the abuse and of
the increasingly different ways in which perpetrators sexually exploit children and young
people (Ofsted, 2014).
The Health Working Group Report on Child Sexual Exploitation (2014) highlights that ‘as
Clinical Commissioning Groups (CCGs) are responsible for commissioning children’s
healthcare treatment services for physical and mental health (CAMHS and other
therapeutic recovery services), they are in a key position not only to stop child sexual
abuse and exploitation in their day to day work, but also to significantly improve the local
multi-agency response’.
The CCG is fully engaged in this agenda and the hosted Safeguarding Service has
provided assurance to the Governing Body in January 2015 in respect of the actions
taken. The hosted Safeguarding Service is represented on National, Regional and Local
forums and has ensured that the CCG safeguarding quality schedule is fully developed
to obtain assurance about the commissioned health service response and support to the
agenda.
Current work within the City includes the mapping of children and young people
vulnerable to CSE and has identified that the predominant abuse is peer on peer
grooming with young people grooming each other: other models being boyfriend /
girlfriend and online CSE.
CSE will continue to be a priority into 2015/16 and features within the work plan for the
CCG hosted Safeguarding Service.
3.6 Multi Agency Safeguarding Hubs (MASH)
Multi-agency Safeguarding Hubs (MASH) co-locate safeguarding agencies and their
data into a secure assessment, research and decision making unit that is inclusive of all
notifications relating to safeguarding child and adult welfare in a Local Authority area. It
is well evidenced that the co-location of agencies builds trust and confidence and
speeds up the process of information sharing and decision making, but the added value
of MASH is that it provides for a fuller, more informative intelligence product with a risk
assessment supported by a clearly recorded rational for operational use at the earliest
stage. The objective is ‘early intervention’ to prevent the escalation of harm, risk and
crime.
Liverpool Partnerships continued to develop this model of working throughout 2014 / 15.
NHS Liverpool CCG has commissioned local health providers to support this model of
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working and have strategic oversight of development, management and impact of this
model of service delivery by attendance at the Strategic Group chaired by the Local
Authority (LA). The model of working will commence in the 2015/16 business year.
3.7 Named GP
The post of Named GP is non-statutory. Liverpool CCG has sought to retain the post
following the 2013 establishment of the new commissioning structures within the NHS.
The post was implemented through Liverpool Community Health until December 2014 at
which time it transferred to Liverpool CCG. This move has enabled the Named GP to
work within the correct governance structures for general practice. The main
responsibility of the Named GP is to support all member GP practices to establish
robust safeguarding systems and safeguarding practice in primary care.
The priority during 2014/15 has been to establish a baseline of safeguarding
understanding and activity within CCG member practices. A safeguarding standards
audit tool has been approved and uploaded on to an electronic platform provided by
Virtual College. The launch of the audit tool will be in January 2016.
The Accountability and Assurance framework uses a formula to calculate the number of
sessions a CCG would require of a Named GP to undertake to adequately deliver the
role and responsibilities. The formula states that 2 sessions are required for each
200,000 total population. The current Named GP is contracted for 4 sessions (16 hours)
per week which meets with the guidance. This provision has only been with respect to
safeguarding of children and young people. Within 2015/16 the requirements for the
provision of Named GP to comply with the requirements for safeguarding adults will be
reviewed with the intention of expanding the service.
The Named GP continues to provide support for statutory reviews and is an active
member of the LSCB.
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3.8 Business Continuity
Table 1 below identifies the business priority areas identified in last year’s annual report
and progress against:
Table 1
Business Priority 2014/15
The voice of the child and adult at
risk
Domestic Abuse, Harmful practices
Model of supervision for the hosted
Safeguarding Service
Designated LAC role and function
Develop a programme to deliver the
work that will be required under The
Care, Act 2015; identify a lead
person responsible for coordinating
and driving delivery of this and
model the likely costs and other
impacts of the Act
Contribute to the work of LSCBs and
LSABs Safeguarding Strategic
Plans. These should be reflected in
both the commissioned services
KPIs and safeguarding service work
plan
Ensure a consistent quality of
safeguarding training provision both
across the CCG and the health
economy as a whole
Processes in place to disseminate,
monitor and evaluate outcomes of all
Serious Case Reviews and
Domestic Homicide Reviews
recommendations and actions plan
within the CCG and with providers
Progress
Remains in progress within the CCG forums.
Included in quality schedule for commissioned
health services
Remains in progress and a core component of
the 2015/16 Business Plan
Remains outstanding whilst NHSE identify a
national supervision model for adult
safeguarding. Access to psychological support
has been commissioned whilst a national model
is awaited for all Designated Nurses (Adults
and Children)
Achieved - Post recruited to, will commence
May 2015. Refined data set in 2015/16 Quality
Schedule
In progress – policy and procedures are being
amended to reflect the emerging implications of
the Care Act. Hosted Service working in
partnership with the SAB to develop a
programme for the implementation of the Care
Act. Lead person identified
Achieved – both LSCB/SAB have had full
contribution to the business plans by the hosted
Safeguarding Service.
Safeguarding priorities are reflected in the work
plan and Safeguarding Quality Schedule
Achieved - core modules revised in accordance
with standards. Hosted Safeguarding Service
fully engaged with Joint LSCB / SAB sub group
(is current Chair)
Achieved – the 2014 / 15 safeguarding quality
schedule adapted to gain assurance across
commissioned health providers in relation to
progress against action and dissemination of
learning.
CCG Quality Committee receives report as
needed
Table 1 outlines achievements within 2014/15; it is evident that some aspects of the
work plan have not been achieved in full. There have been significant challenges faced
by the hosted safeguarding Service as it has been working for the whole reporting year
under capacity due to recruitment and retention of staff. This has impacted on the ability
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to deliver against the above work plan and other competing priorities that have emerged
throughout the year.
The findings of the 2014 / 15 Service Review reported that the service was under
resourced to safely discharge statutory safeguarding responsibilities and to deliver
against the increasing safeguarding agenda. NHS Liverpool CCG accepted these
findings and has supported this by a financial contribution into the service to enable
further recruitment. This, in effect, means that the hosted Service will be adequately
resourced for the 2015 /16.
3.9 Key Achievements
During the reporting period the NHS Liverpool CCG via the hosted Safeguarding
Service has:
• Successfully recruited to 2 Designated Nurse posts for children and a Designated
Nurse post for adults.
• Maintained a full engagement with the LSCBs and SABs ensuring full participation
with all Board activities including SCR’s/ MRs/DHRs.
• Chaired and maintained active membership of LSCB and SAB sub groups
• Established a robust system of monitoring and overseeing the key providers
safeguarding quality and activity.
• Provided assurance reports to inform the Governing Body in relation to areas of risk
within safeguarding.
• Re-defined the internal reporting systems in relation to safeguarding.
4
Conclusion
This annual report provides an insight into the local developments and initiatives pertaining
to safeguarding that have taken place during the last twelve months. In doing so it aims to
provide assurance to the Governing Body that NHS Liverpool CCG is fully committed to
ensuring they meet their statutory duties and responsibilities for safeguarding children and
adults at risk of harm.
For 2015/16 the CCG Accountable Officer and Chief Nurse have agreed the MOU and a
service specification. A set of performance indicators have been developed which will have a
significant impact on the service delivery and reporting.
The hosted Safeguarding Service has developed a comprehensive work plan to support the
national and local safeguarding agenda and also includes areas for further development.
This will be ratified by NHS Liverpool CCG in due course through the Safeguarding Clinical
Senate chaired by CCG Accountable Officer.
Emerging priorities for 2015/16 include:
Female genital mutilation (FGM) and Harmful Practices, CSE, LAC, DV, DoLS
Supervision (including health economy strategy) all of which are identified in the work plan
20
162
NHS Liverpool CCG
The Department
rd
3 Floor, Lewis’s Building
Renshaw Street
Liverpool
L1 1JX
Tel: 0151 296 7000
On request this report can be provided in different formats, such as large print, audio or Braille
versions and in other languages.
21
163
164
NHS LIVERPOOL CLINICAL COMMISSIONING GROUP
PRIMARY CARE COMMISSIONING COMMITTEE
Minutes of meeting held on Tuesday 17TH NOVEMBER 2015 at 10am
Rooms B&C Childwall Neighbourhood Health Centre
Present:
Voting Members:
Katherine Sheerin (KS)
Chief Officer (In the Chair)
Prof Maureen Williams (MW) Lay Member for Governance/Deputy Chair of
Governing Body
Tom Jackson (TJ)
Chief Finance Officer
Dr Rosie Kaur (RK)
GP Governing Body Member/Vice Chair
Nadim Fazlani (NF)
GP Governing Body Chair
Jane Lunt (JL)
Chief Nurse/Head of Quality
Paula Finnerty (PF)
GP – North Locality Chair
Non voting Members:
Moira Cain (MC)
Tina Atkins (TA)
Dr Adit Jain (AJ)
Rob Barnett (RB)
Cheryl Mould (CM)
In attendance:
Scott Aldridge (SA)
Colette Morris (CMo)
Alison Ormrod (AO)
Tom Knight (TK)
John Adams (JA)
Paula Jones
Practice Nurse Governing Body Member
Governing Body Practice Manager Co-Opted
Member
Out of Area GP Advisor
LMC Secretary
Head of Primary Care Quality and
Improvement
Neighbourhood Manager - North
Locality/Local Quality Improvement Schemes
and Veteran Health Lead
Liverpool Central Locality Development
Manager
Chief Accountant
Head of Primary Care - NHS England
NHS England
PA/Note Taker
Apologies:
Dave Antrobus (DA)
Sandra Davies (SD)
Simon Bowers (SB)
Dyane Aspinall (DAs)
Sarah Thwaites (ST)
Governing Body Lay Member – Patient
Engagement (Chair)
Interim Director of Public Health
GP/Governing Body Member
Assistant Director Adult Social Care & Health,
Liverpool City Council
Healthwatch
Page 1 of 15
165
Samih Kalakeche (SK)
Director of Adult Services and Health (Health
& Wellbeing Board Non-voting Member)
Public: 3
PART 1:
INTRODUCTIONS & APOLOGIES
The Chair welcomed everyone to the meeting and introductions were
made. It was highlighted that the public were in attendance but any
questions they wished to raise needed to be done via the public
Governing Body meeting in writing.
1.1
DECLARATIONS OF INTEREST
It was formally noted that the GPs/clinicians present had an
interest in the Liverpool Quality Improvement Scheme which was
on the agenda. However it was noted for the record that this was
proportionate to being a GP in Liverpool.
1.2
MINUTES AND ACTIONS FROM PREVIOUS MEETING ON 15TH
SEPTEMBER 2015
The minutes of the meetings on 15th September 2015 were
approved as an accurate record of the discussions subject to the
correction of the title of MW to include Deputy Chair of Governing
Body rather than Vice Chair.
The Primary Care Commissioning Committee:
 Noted the approval of the minutes.
1.3
MATTERS ARISING – Verbal
1.3.1
Amended Terms of Reference – these had been changed
to add:
•
Role of the Committee point 5 that the
committee would oversee all commissioning of
General Medical Services.
•
Point 5 addition to sub-section e) that the
committee would consider issues such as
workforce, training and development and
changes to models of care in order to deliver
the ambitions of the Healthy Liverpool
Programme and ensure continuous service
improvement.
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166
•
Point 9 membership – due to previous issues
around quoracy it had been agreed that the
Head of Primary Care Quality & Improvement
should become a voting member. The Interim
Director of Public Health was already a non
voting advisory member and was invited to
attend the meetings.
MW felt that in addition to what was added to point 7 subsection e) there should be mention of delivering the
ambitions of Healthy Liverpool and secure continuous
service improvement.
KS referred to the quorum requirement of 5 voting
members the majority of which must be lay/executive
members and to include 2 GPs. Point 16 outlined the
arrangements for dealing with conflict and the possibility
of using another CCG committee or inviting attendees on
a temporary basis from Governing Bodies of other CCGs.
Later on in the meeting a discussion would be taking
place around the Local Quality Improvement Scheme and
additional investment into practices which meant that the
GPs/clinicians presented were conflicted. It was not
practical to bring in additional attendees from other CCGs.
RB stressed the importance of the GPs not being seen to
be paying themselves for work undertaken.
For this reason KS and MW decided to take the matter of
additional investment into the Liverpool Quality
Improvement Scheme to the CCG Finance Procurement
& Contracting Committee (when the quorum does not
require practice members) to make a recommendation
around the investment and review in terms of value for
money. However, the clinical discussion needed to be in
the public domain so should be discussed at Primary Care
Commissioning Committee.
It was agreed to endorse the changes to the Terms of
Reference with immediate effect. The Committee agreed
that the quorum needed to be amended to 5 voting
members who must be non-conflicted in any decisions
taken.
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Terms of Reference to go to the Governing body for
approval.
1.3.2
Action Point One – it was noted that there was a paper on
the agenda about transition but this did not include
Primary Care Support Services – in the light of the
discussions at the November 2015 Governing Body
meeting this would be an item on the Agenda for the
December 2015 Primary Care Commissioning Committee.
1.3.3
Action Point Two – it was noted that GP Information
Technology had been approved at the Finance
Procurement & Contracting Committee and the Governing
Body for the funding and procurement route.
The Primary Care Commissioning Committee:
 Noted the issues raised under matters arising.
 Revised Terms of Reference to go to the Governing Body
for Approval.
PART 2:
2.1
UPDATES
PRIMARY CARE QUALITY SUB-COMMITTEE FEEDBACK –
REPORT NO: PCCC 19-15
RK updated the Primary Care Commissioning Committee on what
had been discussed at the Primary Care Quality Sub-Committee
on 29th September 2015:
.
• Musculoskeletal Redesign Model – some areas of clinical
model needed changing around referral and access.
• Liverpool Quality Improvement Scheme 2016/17 – each Key
Performance Indicator had been agreed approved and also
agreed with the Local Medical Committee.
The Primary Care Commissioning Committee:
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168
 Considered the report and recommendations from the
Primary Care Quality Sub-Committee
PART 3:
3.1
TRANSITION ISSUES
PRIMARY CARE COMMISSIONING TRANSITION PLAN
BETWEEN NHS ENGLAND AND LIVERPOOL CCG 6 MONTH
PROGRESS REPORT – REPORT NO: PCCC 20-15
CM presented a paper to the Primary Care Commissioning
Committee on the progress made in the delivery and
implementation of the transition plan between NHS England and
Liverpool CCG, setting out key risks and issues that were still to
be addressed. Appendix 1 contained the Transition Plan. In May
2015 22 functions had been red, 2 amber and 12 green, by
November 2015 there were 0 reds, 23 ambers and 14 greens.
Contract management, procurement, practice performance and
commissioning of Primary Care Medical Services had been
successfully delegated to the CCG. The functions which required
further work were management of delegated funds and premises.
Re the Financial position AO commented that as at the end of
October 2015 there was an underspend of £162k but the year-end
position was forecast to break even.
CM highlighted the issues of premises and that the CCG was
working closely with NHS England and a strategy paper on
premises would be brought to the December 2015 meeting.
TK continued to talk about the staffing model and the options
available which were:
• Assignment of NHS England staff.
• Secondment
• Direct Employment.
As yet there had been no formal confirmation on staffing models
from NHS England re a preference so CCGs were being advised
to look at all three. NHS England were looking to resolve this
issue.
CM refereed to the outstanding issue of Counter Fraud and
Information Governance and who was the responsible
organisation if issues were to arise.
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The Primary Care Commissioning
commented as follows:
Committee
members
• TA asked if any underspend would be lost. AO confirmed
that this was not a problem and that it would be included in
the baseline for the next year. It was noted that if there was
an underspend it was a minimal percentage of the overall
budget.
• CM noted that a co-commissioning network had been set up
to consider the allocation of staffing resources across all the
CCGs.
• TJ noted that the Estates Strategy could provide a useful
backdrop to the discussion in December on premises. With
regards to the proposed staffing model options he stressed
the need for a Service Level Agreement/Memorandum of
Understanding. Re Counter Fraud he stressed that the
CCG did not have a service level agreement with any
provider for counter fraud services therefore NHS England
would need to pick this up. TK agreed to provide an update
on the Memorandum of Understanding for the next meeting.
He stressed that no formal assignment had been
undertaken.
• The Primary Care Commissioning Committee members
were concerned about how long transition support would be
available from NHS England, given that more and more
CCGs were opting for delegated responsibility. TK noted
that this would be challenging for NHS England but the aim
was to support all CCGs.
The Primary Care Commissioning Committee:
 Noted the content of the report
 Noted the progress made in the delivery of the transition
Plan
 Noted the outstanding risks and issues
PART 4:
PERFORMANCE
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170
4.1
LIVERPOOL QUALITY IMPROVEMENT SCHEME
SPECIFICATION) 2014/15 – REPORT NO: PCCC 21-15
(GP
RK presented a report to the Primary Care Commissioning
Committee outlining the 2014/15 position on delivery of Key
Performance Indicators within the GP Specification and a
summary of the validation committee findings. The scheme had
been implemented in April 2011 to improve outcomes for patients
through setting clear standards of delivery for all practices to
adhere with additional investment which also equalized funding,
some of which is at risk if key performance indicators aren’t
achieved.
The key points to note are:
• Vaccinations/Immunisations and Health Check and
COPD/Heart Failure removed.
• New Key Performance Indicators: Diabetes 9 care process
and significant event analysis.
• A&E Attendances: the indicators definition was the rate per
1,000 HCHS weighted population of in-hours, self-referred,
unplanned, minor attendances where procedure code was
recorded as prescription, guidance and advice or nor and
excluding disposals to a clinic or other provider, for 2014/15
the indicator was amended to remove attendances to St
Paul’s Eye Unit and AED attendance for Trauma. There had
been an increase between 13/14 and 14/15 of 5.4%.
• Emergency admissions for ACS conditions: the indicator
definition was the rate per 1,000 hospital weighted
population for admissions for a selection of ACS conditions
where these conditions were coded in the primary diagnosis
– for 2014/15 the indicator baseline position was
recalculated to reflect the Liverpool average for 2012/13.
ACS emergency admissions had increased from 6,590 in
13/14 to 7,328 in 14/15 for all conditions with significant
increases for respiratory, Asthma and COPD.
• For the areas of A&E attendance and ACS conditions where
there were increases between 2013/14 and 2014/15 it was
noted that the percentage increase was less for practices
involved in the winter enhanced access than those not
involved as previously reported.
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171
• GP referred outpatients: the definition of the indicators was
the rate per 1,000 HCHS weighted population for GP
referred first outpatient attendance to Dermatology, ENT,
Gastroenterology, Gynaecology, Rheumatology, Trauma
and Orthopaedic, Urology and Vascular Surgery. There had
been a 9% reduction between 13/14 and 14/15 driven by
gynaecology and Trauma and Orthopaedics.
• Prevalence: substantial increases had been made to the
numbers of patients on disease registers but there was still
more which could be done.
• Exception reporting: the Key Performance Indicator was in
the GP Specification.
• Alcohol Brief Interventions: the percentage of patients
drinking over the recommended levels being offered brief
interventions had increased by 2.02% between March 2014
and March 2015. However alcohol intake recording had
dropped off.
• Diabetes 9 Care Processes: Band A had a 70% threshold,
the baseline position for the city was 58.33% at the end of
March 2014. which had increased to 65.14% by the end of
March 2015.
• Choose & Book referrals had risen steadily from 75% to
81.5%.
• Medicines Management: the CCG had achieved a
substantial reduction in prescribing costs in 2014-15 with an
overall 5.4% reduction.
• CM presented the findings from the Validation Committee:
this was the 4th year in operation. Practices failing to
achieve Band A had the opportunity to challenge and submit
additional evidence for the Validation Committee to consider
over a three day period in July. For 2014/15 73 practices
were required to submit evidence for validation. The
Validation Committee found that five did not meet the
standards, of which two decided not to appeal. The
committee found that seven practices would benefit from a
further visits from Dr Ogden-Forde regarding the 9 Care
Processes for Diabetes.
 Lessons Learnt:
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172
 Some St Paul’s data was still appearing in the
A& E data sets.
 Practice Appeals: two practices did not appeal the
Validation Committee decision and monies were to be
recovered. The other three practices received
practice visits and the findings were submitted to the
Primary Care Quality Sub-Committee and the Primary
Care Commissioning Committee was asked to support
the recommendations as set out in the paper:
 Practice A (antibiotics) – investment to be
recovered
 Practice B (Diabetes 9 Care Processes) –
investment to be recovered
 Practice C (antibiotic prescribing) – practice to
retain the investment,
 Practice D (in hour AED attendances) – the
practice to retain the investment
 Practice E (9 Care Processes for Diabetes) the
practice to retain the investment.
KS thanked RK for a comprehensive report. NF noted that many
other CCGs had copied elements of the Scheme but had not
adopted it in its entirety. The fact that Liverpool had the scheme
had meant that General Practice in Liverpool had fared better than
the rest of the country in dealing with the pressures facing it. RB
added that one of the issues facing practices was renewal of
workforce, Liverpool had weathered the storm longer than other
places due to the Scheme. RK pointed out that the Scheme
performance indicators were devised around evidence of what
was possible for practices to control and influence.
TJ praised the paper but commented that the impact on health
inequalities had not come out strongly and how to ensure
resources are used in the most cost effective way.
The Primary Care Commissioning Committee:
 Noted the end of year position for 2014/15
 Approved the recommendations from the Primary Care
Quality Sub-Committee in relation to recovery of
investment
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PART 5:
5.1
STRATEGY & COMMISSIONING
LIVERPOOL QUALITY IMPROVEMENT SCHEME 2016-17 (GP
SPECIFICATION) – REPORT NO: PCCC 22-15
KS noted that the paper needed to be considered by the Finance
Procurement & Contracting Committee to discuss the business
case, procurement route and value for money for onward
recommendation to the Governing Body for approval re the
recurrent investment. However the overall service model needed
to be debated at the Primary Care Commissioning Committee.
RK highlighted the key achievements since the implementation of
the GP Specification:
• Prevalence – 15% increase (19656 extra patients) since March
2012
• A&E - 6% decrease on GP specification defined attendances
for adults and children combined since 2011 compared to
benchmark trusts
• Prescribing - narrowed gap between Liverpool and national cost
despite pressures from high levels of deprivation and a large
number of specialist centres within the city using high cost
drugs whilst maintaining a focus on improving quality and
outcomes
• ACS – moved from reporting the highest ACS admission rates
in 2009/10, ranked 68 out of 68 CCGs within North of England
Region to being ranked 31 out of 68 in 2014/15
• Childhood Vaccinations – consistently achieved higher uptake
rates compared to England benchmarks 2011 – 2014; since this
was removed from the GP specification in April 2014 a slight
dip in performance has been reported
The specification provided for a range of services to be delivered
by every practice with a key element of this being the level of
access practices are required to offer. Prior to 2011, the funding
provided for 50 GP appointments per weighted 1000 population.
This was uplifted from April 2011 to 70 GP/Nurse
Practitioner/telephone appointments and to ensure patients were
treated out of hospital and as near to home as practically possible.
Changes had been made to the Local Quality Improvement
Scheme by a sub group of the Primary Care Quality SubCommittee for 2016-17 and consultation held with stakeholders.
Page 10 of 15
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The latest version had been peer reviewed by a panel of GPs
from outside Liverpool. The proposed changes were:
Access
Current standard 15/16
70 GP/Nurse
Practitioner/Telephone
appointments per 1000
weighted population
New standard 16/17
80 GP/Nurse
Practitioner/Telephone
appointments per 1000
weighted population
Childhood Vaccinations and Immunisations
Current standard 15/16
Not
included
in
specification
New standard 16/17
GP Practices are required to
undertake to immunise children
under
5
with
relevant
immunisations, including any
catch up campaigns identified
and to achieve the higher target
of 95%
Physical Activity
Current standard 15/16
Not included in GP Specification
New standard 16/17
Practices are required to
record physical activity
levels for patients aged 16
years and over and for
those who do not meet the
recommended 150 minutes
of physical activity per
week to receive brief
advice and be offered
specialist support where
indicated/appropriate.
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175
• A&E attendance – target had been stretched which means the
aim is for fewer patients to attend A&E in hours with a primary
care condition
• ACS admissions – amended from 7 conditions down to 4
conditions (COPD, Flu/pneumonia, Angina and Asthma) which
account for over 60% of total ACS admissions and their
associated costs. This will enable a greater focus on these
conditions.
• Alcohol consumption recorded – amended from 10% uplift on
practice baseline position to a bandings approach in line with
the rest of the specification. Also time period amended from 12
months to 3 years
• Outpatient attendances – activity relating to Trauma and
Orthopaedics removed from definition due to changes in referral
pathway in year and limited opportunity for general practice to
influence outcomes (all referrals triaged through MCAS before
onward referral to secondary care if appropriate).
The targets had also been amended:
Current Targets 2015/16
Area/Band
A
B
C
A&E attendance 7.91
11.40
12.79
rate per 1000
patients
ACS
9.97
12.19
12.97
admissions rate
per
1000
patients
Alcohol
%
10% uplift on practice
patients
aged
baseline position up to
Liverpool average 34%
18+ with alcohol
consumption
recorded
Alcohol
brief 93.8% >93.8 to >86.9 to
intervention
<= 86.9% 75.7%
Outpatient
attendance rate
per
1000
patients
82.42
87.22
102.57
New Targets 2016/17
A
B
C
6.29
7.35
10.36
TBC
TBC
TBC
7.30
8.01
9.79
38.6%
TBC
32.8%
TBC
27.4%
TBC
93.8%
TBC
63.48
>93.8 to >86.9 to
<=86.9% 75.7%
TBC
TBC
66.57
74.83
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Changes to weightings: there had been revised weightings for
2016/17 on ACS admissions, outpatient attendances and
antibiotic use.
Discontinued Key Performance Indicators: Choose & Book (as
target had been met), Heart Failure, Kidney Disease/statins
prescribing and hospital discharge.
Investment Proposal: in order to support the additional activity of
the Specification/Scheme it was proposed that an additional £10
per weighted patient should be provided. Practices will be
required to provide additional clinical sessions to increase access,
as well as implementing new systems and processes to support
the delivery of childhood vaccinations and immunisations and the
recording of physical activity levels. All of this will impact on the
level of clinical and non-clinical resource required. The changes
proposed to the Key Performance Indicators detailed in section 5
of the paper would also require additional effort and a much more
targeted approach by practices to achieve the more stringent
targets set.
Finally, with this additional investment, it was proposed that the
maximum resource ‘at risk’ to each practice is increased from £15
per weighted patient to £20 per weighted patient.
The Primary
Care
commented as follows:
Commissioning
Committee
members
• MW was concerned about double counting re care homes
and the continuing struggles around access. RK noted the
difficulty in measuring access as it was not always a matter
of seeing a GP but about having equitable access to other
services in addition to A&E. CM noted that over the coming
12 months there would be a review of the system to
understand how practices could improve access, this was
ongoing and reports would come to the committee in due
course.
• NF raised the issue of sexual health and HIV testing This
was not a key performance and therefore was not being
paid for and clarity was required as to where the
responsibility lay, with Public Health or General Practice.
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177
• RB referred to the childhood vaccination & immunisations
and the increase of the target from 90% to 95% and how
challenging this target would be for practices to reach.
• TJ noted that it was good that the proposals had been peer
reviewed – he was supportive of the general direction, he
noted the issue of access from recent public engagement
and that it would be useful to explore the strategic alignment
with other agendas (i.e. 7 day working), value and payments
and assurance from the validation process.
• TK noted digital technology and that national work was
being carried out already to look at capacity in general
practice and how technology could assist.
• KS referred to the amount of £20 per patient re funding at
risk and noted that this should be clarified to per weighted
patient.
• MW requested that the Business Case should include
findings from the Peer Review .
• MW also requested that the findings from the access review
are reported to the Primary Care Quality sub-Committee.
The Primary Care Commissioning Committee:
 Noted and approved the changes proposed to the
Liverpool Quality Improvement Scheme 2016/17
 Noted and approved the changes proposed to the Key
Performance Indicators from April 2016
 Noted a paper will go to Finance, Procurement and
Commissioning
Committee
for
confirmation
of
procurement route and for assessment of value for money
provided for the investment proposed.
PART 6:
GOVERNANCE
There were no items for discussion.
Page 14 of 15
178
7.
ANY OTHER BUSINESS
None
8.
DATE AND TIME OF NEXT MEETING
Tuesday 15th December 2015 – 10am to12pm Boardroom The
Department
Page 15 of 15
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180
Minutes of the Healthy Liverpool Programme Board
Room 2, 4th Floor, Arthouse Square
Wednesday 25 November 2015 1:00pm – 3:00pm
Present:
Members
Tom Jackson (Chair)
Kathrine Sheerin
Dr Nadim Fazlani
Carole Hill
Ian Davies
Jane Lunt
Sandra Davies
Samih Kalakeche
Helen Murphy
Julie Byrne
Chief Finance Officer / Integrated Programme SRO
Chief Officer
GP / Governing Body Chair
Integrated Programme Director
Programme Director, Hospitals and Urgent Care
Chief Nurse / Head of Quality / Governing Body Member
Director of Public Health / Programme Director, Living Well
Director of Adult Health & Social Care, Liverpool City Council
Project Manager, Hospitals
PA / Minutes
Apologies:
Dr Janet Bliss
Tony Woods
Sue Lavell
Dave Antrobus
Dr Simon Bowers
Dr Maurice Smith
Fiona Lemmens
181
GP/ Governing Body Member / Clinical Director, Community
Programme Director, Community and Digital
Programme Management, Office Manager
Lay Member / Patient Engagement / Vice Chair
GP / Governing Body Member /Clinical Lead, Digital
GP / Governing Body Member /Clinical Lead, Living Well
GP / Governing Body Member /Clinical Lead, Hospitals and
Urgent Care
1.0 Welcome, Introductions and apologies
1.1 Chair welcomed all, introductions were made around the table and apologies were
noted as above.
1.2 There were no declarations of interest.
2.0 Minutes of the last meeting (21st October 2015)
2.1 Chair addressed the actions from the previous minutes:
3.8 - Liverpool Test bed bid. Down to the last stage of the process. Progressing to
the next stage.
3.17 – H Shaw to lead on the Non-executive Directors event. Ongoing.
5.3 – Bain Decision Process. 73 PIDs to be submitted to PMO next week. An update
will be presented at the December’s Healthy Liverpool Programme Board.
2.2 The minutes were agreed as an accurate record of the 21st October’s 2015 meeting.
3.0 Risk Register Review
3.1 The Board reviewed each risk from the risk register and highlighted the exceptions.
HLP06 – risk changed to 16 – residual risk red
HLP07 – risk changed to 12
HLP11 – risk score 6
HLP12 - Additional risk, More structural changes – risk score 20 residual risk red
3.2 It agreed that risks HLP06 & HLP12 would be escalated to the CCG corporate
register. ACTION: C Hill to inform Stephen Hendry who is responsible for
monitoring the risk register.
4.0 Programme Highlight Reports
4.1 It was agreed to highlight the exceptions only from each report.
4.2 Living Well – PAS posts are out for advert.
4.3 There were baseline data errors with the Sports England Active People survey.
4.4 The first stage of the Insight commissioned has been presented.
4.5 Liverpool City Council Executive Group has requested Liverpool CCG’s policy around
corporate sponsorship.
182
4.6 Digital – S Kalakeche asked about potential links with prevention. It was suggested
S Kalakeche contact Dave Horsfield to explain.
4.7 Community – C Hill informed the Board that the Community Summit is taking place
on Friday 27th November.
4.8 The mental health community model was presented at the Health Summit for the
Mayor; feedback has been very positive.
4.9 The next community board will review the Healthy Liverpool Programme, which will
inform decisions about phasing, resourcing and dependencies.
4.10 Hospitals – I Davies informed the Board that the Maternity and Neonates workshop is
scheduled for the 11th December.
4.11 There is an upper GI planning meeting on the 4th December to map out business
process and roles.
4.12 Cardiac work continues to progress well.
4.13 The Cancer workshop scheduled for the 4th December has been re-scheduled for
early January due to a number of clinical colleague’s unavailability.
4.14 It was noted that the cardiology project links with the Community and Hospital
Programmes. It was decided to discuss the broader scope of the hospitals element at
the next Committees in Common meeting.
4.15 Urgent Care – I Davies informed the Board that the two confirmed posts have now
been filled and the new staff has started in their roles.
4.16 An urgent Care workshop has been arranged for the 10th December. It is expected
that between 30-40 people will attend to discuss and engage on the proposals in the
SDC.
6.17 NHS England has issued a draft mandate defining what Urgent Care centres must
contain. N Fazlani added that nationally they are not connected to vanguards or 7
day working and it needs to be clear that this model would work locally. A 7 day
working primary care workshop has been organised for the 3rd December, it was
noted that F Lemmens and I Davies should be invited to this.
6.18 Communications & Engagement – The Communications and Engagement team are
in preparations for the next phase of communications and engagement activity due to
launch in January.
6.19 Workforce – the first draft of the workforce strategy is in development. It was agreed
that this would be on the agenda of the next HLP Programme agenda in December.
ACTION: (draft) Workforce strategy to be on the December’s agenda of HLP.
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5.0 Healthy Liverpool PMO Update Paper
5.1 C Hill presented the Healthy Liverpool PMO paper, the paper has been shared with all
programme leads. Board endorsed the model and action plan, which set out a
preferred model for the PMO and action plan to achieve this.
6.0 Clinical Assembly Update
6.1 This item is on the agenda for information only.
7.0 Blueprint Document
7.1 The Blueprint document has been circulated to the relevant contacts. The Board
discussed the next steps. S Kalakeche said following a discussion with Mayor
Anderson, he would like to host an informal event and to invite key stakeholders to
support engagement. Date to be confirmed.
8.0 Senior Programme Leadership Structure
8.1 K Sheerin updated the Board on the proposed Healthy Liverpool Senior Leadership
Structure. The six month interim arrangements were due to end in December. The
new arrangements would proceed until March / April 2018.
9.0 Any Other Business
9.1 I Davies informed the Board that links have been made with Southport and Formby
CCG. ACTION: F Lemmens and I Davies to meet with Sefton CCG.
10.0 Date and Time of Next Meeting
10.1 Date and time of the next meeting – Wednesday 23rd December 3pm – 4.30pm,
Room 1, 4th Floor, Arthouse Square.
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FINANCE, PROCUREMENT AND CONTRACTING COMMITTEE
TUESDAY 24 NOVEMBER 2015
10:00am – 12:30pm
ROOM 2, THE DEPARTMENT, LEWIS’S BUILDING, L1 1JX
FINAL MINUTES
Members
Nadim Fazlani(NF)
Chair
Katherine Sheerin(KS)
Chief Officer
Maureen Williams(MW)
GB Member - Lay Member
Dave Antrobus(DA)
GB Member – Lay Member
Maurice Smith(MS)
GB Member - GP
In Attendance
Alison Ormrod(AO)
Phil Saha(PS)
Ian Davies (ID)
Scott Aldridge(SA)*
Teresa Clark (TCl)*
Interim Deputy Chief Finance Officer
Head of Programme Finance
Programme Director–Hospitals & Urgent
Care
Senior Contracts Manager
Intelligence Manager (on behalf of Tim
Caine)
Primary Care Co-Commissioning Manager
Contracts Manager / Mental Health
Lynne Hill ((LH)
PA / Minute Taker
Apologies
Tom Jackson (TJ)
Derek Rothwell (DR)
Tina Atkins (TA)
Tim Caines (TC)
Chief Finance Officer
Head of Contracts, Procurement and BI
Practice Manager
Principal Analyst
Alison Picton(AP)
Chris Buckels (CB)
1
Welcome and Introductions
Introductions were made and members welcomed to the meeting.
2
Declarations of Interest
No declarations were made.
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3
Minutes and action notes of previous meeting held on 27th
October 2015.
3a Accuracy of Minutes from 27th October 2015
The Committee suggested a few changes to the minutes as follows:
• Page 6: Patient Opinion - amend last line to read …which
identified that a suitable alternative provider was not available.
• Page 8: Merseycare – amend sentence to read Mersey Care
Trust are keen to move to a new mental health payment system as
per the national guidance and have put forward proposals for a
rebased activity plan and local price for each cluster which
requires analysis by CCG.
• Page 10: Change IR Rules to Identifications Rules
• Page 11: Living wage: Living wage to say …. The Living Wage
Foundation minimum rate is £7.85 per hour (as from November
2015 it has now increased to £8.25)
• Page 11: Update re Interim Provider – Change Dr Gerg to Dr
Dharmana.
 The Committee approved the minutes with the above
changes.
3b
Actions from the previous meeting held on 27th October 2015
3b1 Mental Health Clustering
An update on Mental Health Clustering will be presented in December
2015.
3b4 Specialised Commissioning
AO reported that TJ is working with the local CCG Finance network to
pilot a collaborative commissioning forum across the local health
economy. Exploratory work is to commence in April 2016 in shadow
form.
3b5 Interim Provider Update
Scott Aldridge (SA) fed back to Dr Murugesh surgery with regard to their
application and the significant over use of words. SA confirmed that
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embedded documents were not allowed and there is a need to make this
clear to the practices.
SA stated that there have been various information problems coming in
from the practices regarding their accounts and that they are having
difficulty submitting their accounts in the time scale required for the
procurement process.
We need to be clear that the accounts
information needs to be submitted at the beginning. TCl stated that
some of the practices said that they are waiting for the accountants to
come back to them and some have missed the original email requesting
the information.
TCl confirmed that Liverpool CCG have asked SBS to pull the
information together to inform a development day for the issues that are
causing problems. LCCG are also looking at comparing good and not
so good responses to be used as examples. LCCG need to stress the
importance of the timing of submissions to ensure equity. KS queried
how long do we give practices to complete. TCl confirmed that the
recent opportunities have unavoidably had tight turnaround times of
about 4 weeks, and we need to try and avoid this for future.
MW queried the SBS training day and how does this fit in with the one
we discussed at the Primary Care Clinical Commissioning Committee
meeting discussed between MW and Cheryl Mould (CM). TCl believes it
is two separate things with a local development day for CCG member
practices and a wider bidder day when the opportunity goes live. MW to
check with CM the details for the development day she has discussed at
the PCCC. DA added that this is critical for fairness and ensures we
are not open to challenge. AO stated that she is happy to provide
support from the finance department.
NF stated that the timelines are tight, however, when the timelines are
published we need to stick to them and this should be stressed to the
practices.
 Action: TCl/SA to follow up and clarify the Development Day
Session and clarification of process to practices. (December
2015)
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3b6 Haemto-oncology Update
KS confirmed that the paperwork for the Governing Body has been
completed.
3b7 IAPT Update
A paper is required for Governing Body and the Finance, Procurement
and Contracting Committee in December 2015.
 Action TCl/DR to write the IAPT paper for December 2015.
4
Mental Health 3rd Sector Payments
(FPCC64-15)
TCI presented the paper and request to extend various provider
commissioning arrangements as an interim until the work with the Local
Authority is completed. TCI reported that the request to extend the
funding detailed on page 7 is all existing funding and does result in a
slight saving.
ID highlighted the table on page 21 and that the information appears
incomplete and that there are still no SLA’s in place for a number of
organisations who have continued to receive funding over several years.
ID was concerned that we are being asked to further extend payments to
organisations for work that is unclear.
MW stated that when the paper was originally approved it was clearly
stated that the review would take place before it was resubmitted to the
FPCC and that the suggestion of a further extension undermines the
process. DA asked if the organisations were aware of this issue and
whether there had been discussions with Liverpool City Council, as there
are vulnerable organisations that may fall by the wayside.
MW commented that they should have been monitored and has a
number of issues with the process. Firstly, why was the procedure not
followed, what was the reason and how are we going to pull this back.
Secondly, what organisations are vulnerable and what short term
decision can we make to protect them as the process has not been
followed properly or at all.
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NF stated that there are certain services that we don’t want to allow to
fall by the wayside by default and the process needs to be fair. We had
this discussion 2 years ago and it does not look as if the previously
agreed actions have been followed through to a conclusion. NF
highlighted two potential issues, the extent to which internal capacity
constraints may have been a problem, and reference to a mental health
model, which appears that the organisations are not aware of.
MS and KS referred to needing to be clear who is responsible for this
and that it should be within someone’s work plan. KS stated that JL is
currently caretaking the Mental Health programme, however TCI stated
that as this is within her new role this will be on her work plan and she
will ensure that adequate monitoring is taking place for all schemes.
Additionally we urgently need to put SLAs in place where they are
absent, with outcomes measured and reported and she will work with
Andy Kerr over the next few months to ensure that this work is
completed.
MW commented that her understanding is that the money is allocated
until March 2016. Therefore, we do not need to make a decision on
funding at this time, we need it to come back to the FPCC and provide
an indication to us on the organisations that need an extension, their
performance to date and how it fits with the community model and to
make sure we do not go through this process again in the future.
ID highlighted his concern that that the timing of a request for a full
report is needed and that 90 days’ notice may be required to be given to
the organisation and a middle ground needs to be established.
MW commented that in her experience in the 3rd sector there is no
assumption that you are guaranteed an extension or additional monies.
Those organisation need to discuss at their Boards the potential of
issuing 90 days’ notice.
KS queried as to whether there are other (non-mental health) schemes
which should be at the end. AP stated that there are other potential
schemes in a similar position and this needs to be scoped out urgently.
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NF commented that some programmes of less than £100K have not
come to this FPCC (in accordance with the scheme of delegation) and
have gone to SMT.
MS queried if we have a master list available and should it be revisited.
ID confirmed that we have a master list of grants/SLAs that we inherited.
Some we have since stopped funding. A letter was sent out earlier in
the year to those organisations explaining funding would end by March
206 unless they were re-commissioned, and the programme leads
previously went through the list to identify actions.
MW commented that the political fallout is important and suggested
sending a letter stating that the current grant is due to expire and that we
would be ‘delighted’ to offer a further 3 months from 31 March 2016 – 30
June 2016.
The following actions were agreed:
 Action: The full master list of all 3rd sector payments to be
reviewed and refreshed with clear indications of when funding
ends.
 Action: Write to all those that expire in March 2016 with the 3
month extension. Need to be very clear that there is no
guarantee of funding after 3 months
 Action: SLAs with clear outputs and monitoring process for
all payments. All providers to be made aware of this.
 Action: Need assurance on the process we as a CCG are
following.
 Action: Forward plan to come to the FPCC on those
SLA/Contracts that are coming to an end.
5 Children and Young People’s Mental Health Transformation Plan
(NHS England Funded) (FPCC65-15)
The Committee requested the paper be withdrawn as the
responsible representative needed to be present to deliver the
paper.
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 Action: Jane Lunt or responsible representative to present the
paper at the December 2015/January 2015 FPCC.
MW highlighted that some of the MH providers are included in the 3rd
Sector paper presented today and there may be a knock on effect.
6
Urgent Care Underperformance Analysis (FPCC66-15)
Chris Buckels (CB) presented the paper. The Committee acknowledged
that the paper fully explains the performance position.
Royal Liverpool Broadgreen University Hospital (RLBUH)
CB reported that spending is the same like for like at the RLBUH as we
did last year. CB stated that the reason we are underspending is based
on the way the plan was set at the beginning of the year (i.e. at the
higher level) this should be addressed when we set the plan for next
year (i.e. 9 months data and 12 months data).
Aintree University Hospital (AUH)
CB reported that non-elective spend went up due to changes in the
clinical decision unit ie the way in which patients and admissions are
managed into the Trust. The plan for Aintree for 2014/15 was set on the
higher levels of admissions. Aintree opened their ‘new’ Urgent Care
unit in June 2015 and this has subsequently reduced the admissions,
however still need to review data for a few months to see if this is a true
trend. LCCG are in discussions with Aintree (via South Sefton CCG).
When LCCG come to plan setting for next year it should be nearer to the
correct level.
ID commented that the paper demonstrates an excellent analysis, with
AED attendances clearly not having gone up, but acknowledging a
potential increase in acuity as initiatives such as ‘hear & treat’ and ‘see &
treat’ maintain patients in the community and avoid ambulance
conveyance to hospital. The model is beginning to demonstrate what
we are wanting, still have got a long way to go, however green shoots of
the new model of urgent care is demonstrating the way in which we want
to go. ID confirmed his will be working through some of this with the
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Urgent & Emergency Care Programme within HLP in the next few
months.
KS queried if the activity data includes the Walk In Centre (WIC)
numbers. CB confirmed that are not included and are based on like for
like usage from last year. KS highlighted the Medical Assessment Unit
figures for Quarter 3 as this shows a real drop and queried what caused
this. ID stated that this could be the introduction of the Frailty Unit and
Ward 2a. Some patient pathways may have been changed due to
redesign.
 Action CB agreed the data explore further (January 2016).
DA queried the WIC and the value of excess of £3m (page 38). ID
explained that there was a difference in the calculations of numbers.
We therefore introduced a Contract Variation and the WIC numbers
could be then counted in the analysis.
MS queried based on the data and analysis what are the CCGs
intentions on commissioning. ID explained that we are working with the
two providers and Monitor to explore how urgent care might be
commissioned and resourced going forward, this would potentially
include a new funding mechanism that could for example recognise
perhaps 80% fixed funding, 10% variance and 10% towards quality
initiatives or outcomes.
KS stated that it was excellent report and showing that we are going in
the right direction.
MW asked if there something that we should present at the Governing
Body in the public. KS stated that we are presenting a paper showing
the additional funding in the GP Spec. ID suggested that we could work
on this paper and add some of it as an appendix to the main report. (i.e.
including the facts plus out of hours and 111).
KS agreed that this could be included in the January 2016 GB as part of
the performance report
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 Action ID/Chris Buckels to work together to provide the
performance report for the January 2016 Governing Body.
7
Interim Provider – Dr D
(FPCC67-15)
The Committee recommend that the paper presented should be emailed
following the FPCC and would be considered via email. The following
email was circulated by Scott Aldridge:
The review panel for Interim Provider Procurement for Dr Dharmana’s Surgery has
completed their evaluation. It was agreed at October’s FPCC that the outcome
could be agreed virtually, in order to urgently allow mobilisation to begin prior to
the current provider closing on the 31st December.
The attached paper is asking that the committee agree the recommendation to
award the contract to Vauxhall Primary Health Centre for a period of 15 months from
1st January 2016 to 31st March 2017 at an annual contract value of £225,795 for 6
months before the contract reverts back to a GMS list based value.
 The Committee members agreed the outcome via email.
8
Patient Transport Service Procurement
(FPCC68-15)
ID presented the PTS paper and reported that we had previously had a
3 year contract; the latter had been reviewed with a revised specification
which subsequently went out to advert. The specification included
increased hours of service and additional quality markers detailed in the
Executive summary (Page 52) Following the full procurement exercise
the bidders received were assessed by a Merseywide panel, with the
following outcomes.
• Bidder 1 – withdrew bid following advice
• Bidder 2 and 3 were assessed. Bidder 2 failed to deliver the
minimum requirement of 50% for service quality/deliverability and
therefore did not progress to interview.
• Bidder 3 met the evaluation threshold and proceeded to interview.
The Committee are asked to endorse the process and the
recommendation that Bidder 3 be the preferred bid for the new
Merseyside contract from July 2016. ID stressed that the bidder names
are not provided to ensure that the confidentiality of all bidders are
maintained.
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Approved:
 The Committee endorsed Bidder 3.
9
HLP – Urgent Care GP Scheme/Alder Hey Children’s Hospital
GP in A&E and Acute Procurement Waiver Proposals (FPCC69-15)
• AHH GP in A&E Scheme
• GP Acute Visiting Scheme (AVS)
ID talked through the paper and highlighted the key aspects of the
provisions and the dynamics of those presenting at Accident and
Emergency Departments and the role and operation of the two schemes
Alder Hey GP in A&E
ID explained the operation of the scheme and the contribution it made in
providing a suitable alternative to patients being managed via the A&E
staffing where the presenting need was primarily one that could be
managed effectively by a GP. The operational hours may be subject to
some amendment to better reflect demand.
GP Acute Visiting Scheme (AVS)
ID explained that UC24 provide a 24 hour GP and driver that are able to
respond to patients who have dialled 999 and the responding Paramedic
has determined that the patient’s need can be better addressed and a
hospital conveyance avoided by a rapid intervention or response by GP.
They also provide where required and appropriate a telephone contact
and face-to-face contact. The data shows that for most patients once
they have been seen by the 24 hour dedicated GP then they do not go
onto AED.
Reprocurement Options:
ID stated that there are four possible procurement options available,
however, we would want to look at the whole of the Out of Hours
service, 111 and ambulance commissioning as one system and then
look at the whole provision. Consequently we cannot justify the costs of
reprocurement (i.e. option 2) at this stage and would wish to see the
service considered as part of the wider re-procurement of the UC24
services in 2018.
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MS queried the GP Acute Visiting Scheme (AVS) and where are the
patients from and are there higher users in a specific area, also are
there any patterns i.e. where there are no WIC locally.
ID stated that
monitoring and detailed information is available, and would review the
data to see if any patterns emerging.
 Action: ID to review the data and see if any patterns emerging
and a report to be produced for the Primary Care Clinical
Commissioning Committee (PCCC) early in 2016 (Jan –
March).
MW stated that generally she was uncomfortable with a second waiver
for a provider. If these expire on 31 December 2015 we cannot have a
useful discussion and feels that there is a problem if the waiver is being
extended.
KS queried if the AHH GP in AED figures are included in the tariff. ID
responded that a separate tariff was negotiated for the front end triage.
KS acknowledged the comments with regard to the process and
suggested that we should not set up waivers for 12 months as this is too
short term, it should be 18 months or 2 years. However this performer
case fits in with the new model of care and should fit in the new model of
Urgent Care, 111 and this should all be worked together.
DA queried if there is any feedback from the 1200 patients and if any are
unhappy with the service. ID confirmed all the patients are feeding back
positively on the provision. High satisfaction from patients was noted and
comments reflected the responsiveness of the service and the outcome
that avoided a hospital attendance. DA asked for a report to come back
showing this information.
 Action: ID to produce report for January 2016 FPCC on
patient feedback.
NF supported KS on the length of the waiver contracts of being set for
no less than 2 years. NF stated that we need to be clearer on when the
variation is to happen and when it comes back to the FPCC. In the next
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2 years we will have the Primary Care Hub set up and Community care
set up in 2018.
MW queried when we would expect to go out to full re-procurement. ID
confirmed that this would be in September 2017 for the whole of the
service. However, a business case would be produced in June/July
2017.
MW asked if we will we get value for money for this current procurement.
ID stated that he is working with Alder Hey Hospital (AHH) now to
increase the uptake of available GP appointment slots, looking at the
operational hours (i.e. opening times). MW queried will the GP at AHH
be part of the reprocurement of the full service.
KS queried the AHH GP at AED provision extension. ID suggested that
we provide a waiver until 30 September 2018 with a built in 6 months’
notice period so that we could cut short the contract if required.
 The Committee agreed both waivers.
10 Information Governance (IG) Update (FPCC70-15)
AO talked through the Information Governance (IG) Update Report and
that this is a position statement. AO highlighted the following:
• The Senior Information Risk Officer (SIRO) role is to be taken over
by Tom Jackson (support provided by the Financial Accountant.)
• Quarterly IG Meetings arranged including Simon Bowers as
Caldicott Guardian and Individual Asset Owners.
• IG Tool Kit expecting to level 3 compliance by March 2017.
• Training to be undertaken by the SIRO and a data quality lead.
MIAA to provide support as well as the finance team.
• Potential for additional resource requirement and will be looked at
Quarter 3 or 4).
MW commented that the briefing is very helpful. The policy states all
employees; however this should also include Governing Body members.
ID stated that Sallyanne Hunter has some experience in IG and should
be included in meetings/advice.
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 Action: Governing Body members to be included in IG
toolkit/training
 Action: Sallyanne Hunter to be included in the IG Steering
Group work (Kate Warriner also invited following the FPCC)
 The Committee noted the report.
11 Finance and KPI Update (FPCC71-15)
AO reported that the position is positive although the delivery against
Better Payment Practice Code may be affected by delays as a result of
the move to the new premises.
AO advised that work to evaluate
investment plans and forecast out turn will be undertaken with Heads of
Service. Regarding 2016/17 investments the Finance and Contracts &
Procurement teams will work to produce one document containing
investments and commissioning intentions for review and comments
from Heads of Service.
DA queried the performance against CHC in the context of future cuts in
social care funding.
AO reported that an element of reserve is set
aside in respect of CHC activity. CHC Finance services will be
transferred in-house early 2016. Systems and processes will be fully
reviewed as part of this process and the level of challenges on invoicing
will increase. KS stated that the assessment process for CHC funding is
rigorous.
MS highlighted the prescribing variances and the risks. NF stated that
the prescribing information is submitted to the Quality Committee in
relation to quality and monitoring and to the Primary Care
Commissioning Committee in terms of spending.
 Action: AO agreed to bring a report back to give assurance to
the Committee. – January 2016.
12 Contract Approach and Financial Envelope 2016-17 (FPCC7215)
AP and PS talked through the report and highlighted the coding
accounting changes. AP reported that the Royal Liverpool Broadgreen
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University Hospital (RLBUH) have been asked to go back and relook at
the Allied Health Professionals details. As long as the PbR guidance
stays the same there will be no impact on 2016-17 but may be 2017-18.
It was noted that if the Royal charge for this then there may be other
providers that make similar charges and therefore a number of risks.
(Key risks 4.2).
PS talked through the Financial Envelope of £525m and stated they may
be looking at a reduced tariff deflator for 2016/17.
PS stated that
HRG4+ could be deemed as a risk. Identification Rules(IR) have been
refreshed and this is also a possible risk, could be a favourable impact
or not.
There was a consultation on Mental Health with a
recommendation with regard to the quality of data, with the possibility of
a local contract variation to remain with the same payment process.
KS agreed that there is a need to have very clear contract processes in
place and commended this.
KS highlighted the Healthy Liverpool Investments appear to be low (i.e.
£1.118m). AP stated that this is the known information on the schemes
and does not take in to consideration the unknown or the “non-contract
ready” schemes. AP has met with the programme leads, Programme
Finance and BI and has developed a scheme list for those that are
“contract ready”. AP will feed back to the programmes with any further
development and the position.
NF stated that it was very useful to have the principles in the contracts.
NF suggested sharing the report and principles with the contract leads to
maintain a consistent approach
 Action: Alison Picton (AP) to share the report and principles
of contracts.
13
Financial Control Evaluation Assessment Summary (FCEA)
(FPCC73-15)
AO reported on the FCEA which was provided for information. MIAA
have asked for the CCG to be named in a benchmarking piece of work
relating to the evaluation. This was agreed.
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Scoring was:
• 12 Excellent
• 5 Good
• 1 improvement needed
AO stated that she would find out what the difference between good and
excellent is.
 Action: Report to be shared with LCCG staff (AO)
 Action: Difference between “good and excellent” to be
explored (AO)
 The Committee noted the content and were satisfied with
being involved in the MIAA work and this should also be
shared with the staff.
15 Specialised Commissioning Update
As per item 3b4 above.
16 Any Other Business
Nothing further was discussed.
Next meeting
Tuesday 22 December 2015 10am – 12:30pm.
Meeting will be quorate to consider the GP Specification. Apologies
received from Dr Maurice Smith.
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NHS LIVERPOOL CCG
AUDIT, RISK AND SCRUTINY COMMITTEE (ARSC)
06 OCTOBER 2015 12:30pm -3:00pm
Boardroom – Arthouse Square
FINAL MINUTES
Members - Present
Maureen Williams (MW)
Dave Antrobus (DA)
Donal O’Donoghue (DOD)
In Attendance
Tom Jackson (TJ)
Alison Ormrod (AO)
Kerry Jenkinson (KJ)
Ian Davies (ID)
Stephen Hendry(SH)
Chair of Audit/Lay Member - Governance
Lay Member – Public Engagement
Secondary Care Doctor
Chief Finance Officer
Interim Deputy Chief Finance Officer
Interim Chief Accountant
Programme Director Hospitals & Urgent
Care
Acting Head of Operations and Corporate
Performance
Gary Baines (GB)
Elisabeth Harris (EH)
Michelle Moss (MM)
Audit Manager - MIAA
Principal Auditor – MIAA
Anti-Fraud Specialist -MIAA
Robin Baker (RB)
Iain Miles (IM)
Director – Audit – Grant Thornton
Audit Manager – Grant Thornton
Lynne Hill (LH)
PA/Minute Taker
Apologies
Simon Bowers (SB)
Jane Lunt (JL)
GP – Governing Body Member
Chief Nurse/Head of Quality
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1a Private Meeting
MW stated that the private meeting took place between the Committee
members and internal and external auditors. This meeting is required
annually and in the absence of CCG officers. No issues of concern were
raised and it was agreed that useful discussions had taken place at the
meeting.
1b Welcome and Introductions
Introductions were made and it was noted that Iain Miles, Audit
Manager, Grant Thornton and Elisabeth Harris, Principal Auditor, MIAA
are two new Committee attendees. All were welcomed to the meeting.
2
Minutes of the Committee held on 24 July 2015
 The minutes were agreed as a correct record.
3a Matters arising not in the actions
Nothing further discussed.
3b Actions of the committee held on 24 July 2015
3b1 Hospitality Register
Michelle Moss (MM) highlighted that there has been a recommended
Register of Interest for sharing. However, the Register is not any
different than the one already presented. This will be discussed further
with Stephen Hendry (SH).
 Action: MM and SH to meet to discuss further.
3b2 Patient Experience
Gary Baines(GB) circulated a Quality Focus on Patient Experience
report. DA stated that some Governing Bodies have a patient story on
their agenda for each meeting.
 Action: GB to explore how this is managed elsewhere and
share outside of the meeting.
3b3 Liverpool CCG Benchmarking Report
RB has made a request for updating the Conflicts of Interest policy and
this will be presented to the December meeting
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 Action: Robin Baker Conflicts of Interest Benchmarking
agenda item for December 2015.
3b5 Legacy Issues
Kim McNaught wrote to Phil Wadeson, NHS England, before she left the
CCG and AO has since followed up, however nothing further has been
received from NHS England. MW asked if the auditors can write to Phil
Wadeson requesting the information.
 Action: Robin Baker agreed to write to Phil Wadeson at
NHS England
3b9 Tender Waiver Requests
 Action: A report will be presented to the December 2015
Committee (AO/DR).
3b10 Risk Management Strategy
 Action: A second session to be arranged for the
Governing Body (SH).
3b12 Management Response and Update on Internal Audit
 Action: Report to be presented in February 2016(BB).
3b13 Internal Audit Progress Report – Partnership Working
Matt Roberts (MR) has explored this and Gary Baines(GB) will follow up
for the December 2015 meeting. It was agreed SH/TJ will be the
appropriate people to present back to the Committee.
 Action: Partnership working agenda item for December 2015.
3b14 Anti-Fraud Report Duplicate Matches
Roger Causer informed MM that there are no findings to report, however
the work is scheduled to be completed for the February 2015 committee.
 Action: MM to provide feedback to the February 2016 meeting.
3b15 Financial Control Environment Assessment
AO confirmed the report was submitted on time and as expected.
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3b16 Safeguarding Update – Implementation of the 2 reviews
Jane Lunt will be attending the December 2015 Committee to present an
update paper.
 Action: LH to remind Jane Lunt of requirement.
4
Declarations of interest
Nothing declared.
5 / 6 Register of Interest and Hospitality and Gifts Register
(ARSC43-15 and ASRC44-15)
MW suggested that in future the registers will be scrutinised by the
Committee and that TJ could provide an official declaration for the
minutes at each meeting, confirming that he has scrutinised the registers
and there are no matters requiring attention.
Discussion ensued with regard to policing and scrutinising the registers
and it was agreed scrutinising is the way forward. Once a month TJ and
SH will review a random sample of the registers. The findings will be fed
back to the Audit, Risk and Scrutiny Committee.
 Action: SH/TJ to undertake random audit of registers.
TJ outlined the complaint that was submitted to Sunderland CCG with
regard to the Register of Interest and the potential for conflicts around
commissioning. John Bewick had reviewed their Register of Interest and
reported on the learning from this.
 Action: John Bewick Report to be circulated following the
meeting (LH).
RB welcomed the changes made and the way forward. RB will also
seek good practice identified by Grant Thornton and forward anything
significant found to TJ.
 The Committee noted the Register of Interest and the Gifts
and Hospitality Register.
7
Official Use of Liverpool CCG Seal
(ARSC45-15)
TJ report that the seal has been used for Project MI Health.
 The Committee noted the use of the Seal.
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8
Losses and Special Payments
AO reported that there had been no losses and special payments in the
last quarter.
SECTION 2
9
Internal Audit Progress Report (ARSC46-15)
GB reported that there have been 2 audits completed reports plus
Informatics Merseyside (IM).
a)
Complaints Management Review
Limited Assurance given and areas highlighted:
• Response time of complaints
• Reporting arrangements
• Structure of complaints process
• Complaints Policy review
• Ensuring provides have similar processes place
• Lessons learnt and key areas agreed for action by September
2015.
• Actions in place going forward and these are being managed by
SH
b)
Payroll Feeder Systems Review
Significant Assurance given and some medium risk actions but did not
affect the assurance process. Key minor areas agreed for action to be
completed by December 2015.
c)
Informatics Merseyside (IM) Technical Penetration Test
As part of the Trust’s internal audit plan, and part funded by Liverpool
Community Health NHS Trust and Informatics Merseyside, MIAA have
undertaken penetration testing against the IT infrastructure.
GB will ensure that the weakness are tightened up and will follow up with
AO to ensure gaps are closed.
d)
Work In Progress
• Conflicts of Interest (fieldwork completed)
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• Committee Structures (fieldwork completed)
• Contract Management (fieldwork in progress)
• Grant Scheme Payments /Social Value Policy (fieldwork in
progress)
• Follow –up (fieldwork progress)
• Co-Commissioning Baseline Review (Draft Terms of Reference
Issued)
A full plan is highlighted in Appendix B. Appendix C: highlights the
critical/high risk recommendations. There are 3 limited assurances so
far in the year, however nothing substantial to report.
MW commented that the management response on the 3 limited
assurances and each recommendation will be looked at and assessed if
they have been implemented. Internal Audit will only sign off once the
evidence has been viewed.
DA highlighted the likely increase in complaints from GPs or about GPs
due to the role of commissioning of primary care and that the handover
of legacy of complaints from GPs has not been confirmed.
TJ stated that when handing over of legacy issues and complaints it is
not always straight forward and holds its own risks. ID updated the
Committee on the transfer of GP complaints to the CCGs post 1 April
2016.
SH confirmed that the complaints policy has been agreed and
implemented in LCCG, a new member of staff has been recruited and a
database has been installed to assist with management and audit of
complaints.
 The Committee noted the Internal Audit Update.
10 MIAA Insight Briefing Report
(ARSC47-15)
Report shows all the briefings/courses that are held by MIAA, Grant
Thornton and other organisations and the Committee were asked if they
would prefer to receive them via a report or via email.
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It was agreed that the Briefing Report be circulated via email and also be
added to the Agenda for future Audit Risk and Scrutiny Committee
meetings.
 Action: Briefing Report to be added to Audit Risk and
Scrutiny Committee agenda as a standard item.
 The Committee noted the Briefing Report.
11 MIAA Insight Critical Applications Briefing Note (ARSC48-15)
Critical Applications are those systems that are critical to the
organisation. Within the NHS organisation these include both clinical
and non-clinical systems. These critical systems are at the heart of
effective service delivery whether that is supporting patient care or
emergency response or providing business intelligence ti support
informed decision-making. The top 8 critical application issues were
listed in the briefing note.
 The Committee noted the Briefing Note.
12 Anti-Fraud Progress Report
(ARSC49-15)
Michelle Moss (MM) updated the Committee with the following;
• Risk session presented to Governing Body on 22 September 2015
• Briefing on Chargeable Patients issued.
• Briefing note on fraud i.e. NHS Protect report (FIRST) has been
used to analyse data nationally.
• Fact sheets emailed to Communications Team showing types of
fraud.
• Plan is on track for the year and detailed in Appendix A and B.
• No ongoing active investigations.
TJ reported that the session with the Governing Body went well. No live
investigations, however we are not aware of what is going on in Primary
Care. TJ highlighted that Liverpool CCG do not commission MIAA for
anti-fraud for primary care. MM has previously shared a document with
TJ and this describes some of the cases/investigations that have taken
place.
TJ stressed LCCG do not commission the service from MIAA and we
have not formally been given that responsibility from NHS England for
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primary care or independent contractors in the private sector. TJ
commented that this issue has been reported to NHS England and is on
the agenda for the regular DOF/CFO meetings held by NHS England.
MM stated that 66 other CCGs are in the same position.
TJ stated when we review the annual plan next year then this is an area
that we will need to look at so that we are clear. It is stressed that CCGs
currently do not have the responsibly delegated re anti-fraud.
 Action: Primary Care Anti-Fraud to be brought back to
February 2016 Committee for the Annual Plan discussion.
(TJ/MM)
13 External Audit Progress Report Update 2015 (ARSC50-15)
RB introduced Iain Miles(IM) to the Committee as the new audit
manager. IM has a national responsibility for audit requirements and
also covers External Audit responsibility for Liverpool City Council. It was
agreed there was no conflict of interest between Iain Miles covering both
LCC and LCCG Audits. It is envisaged that External Audit will look at
Healthy Liverpool across the city during the next few months. Planning
work will take place and an Audit Plan for the February 2016 meeting will
be drawn up.
Confirmation of the accounts timetable is agreed as:
• Submit draft accounts 22 April 2016
• Final Report and Audit Accounts on 27 May 2016 (midday)
RB reported that this the final year of the contract with Grant Thornton is
2016/17. This will be the final year of this type of arrangement as CCGs
will be responsible for appointing their own auditors. Some detailed
information available and will be circulated following the meeting. As
part of the process Appointment Panels will be required. Lay Members
of the Audit Risk and Scrutiny Committee can be on the Appointments
Panel. The process will need to be completed by 31 December 2016.
RB stated that Grant Thornton are happy to support LCCG in the
process if required.
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 Action: Agenda item Draft External Audit Plan for February
2016 (IM/RB)
 Action: Agenda item for Annual Report and Final Accounts
timetable process February 2016 (SH/IJ/AO).
 Action: The CCG will work to the required deadlines for the
production of draft and final accounts as required.
 Action: Governing Body members can step down from
attending the meeting in May 2016 for the adoption of the final
accounts for 2015/16 as the constitution will have been
changed. However, attendance is required by Katherine
Sheerin, Nadim Fazlani, Maureen Williams, Dave Antrobus,
Donal O’Donaghue, Simon Bowers and Tom Jackson. (LH)
The Committee formally welcomed Iain Mines to the LCCG ARSC and it
was recognised that he is overseeing audits for both Liverpool City
Council and Liverpool Clinical Commissioning Group.
14
Liverpool CCG Standards of Business Conduct Policy
(October 2015)
(ARSC51-15)
SH presented the policy and updated the Committee on the work
undertaken with MIAA. The policy applies to member practices
undertaking work on behalf of the CCG and should encourage member
practices to adopt the policy. The policy incorporates the following;
• Nolan Principles
• Conflicts of Interest
• Outside Employment and Private Practice
• Moral behaviours
• Social Media Policy
SH stated that the next step is to embed the policy within the
organisation. SH will take to the Staff Listening Group and champion the
application of the policy, and raise awareness via internal and external
communications and websites.
MW commented that it was a good policy document and was robust and
sensible and raised the following three queries:
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• Page 9 - Review Register of Interest should be every 12 months
not every 6 months.
• Page 112 - Employees are advised not to engage in outside
employment during any periods of sickness/absence…….. This is
too absolute and should be more proportionate. SH agreed to
change/review. DOD referred SH to NICE guidance for SH to
review.
• Page 11 – Cash equivalent should be expressed as gift
voucher/token.
TJ commented on the diversity of roles and staff seniority across the
CCG. The responsibilities incumbent on staff required to complete be
refined within the policy to clarify what needs to be disclosed.
This was agreed and staffing will be redefined in the Conflicts of Interest
and Register of Interest (i.e. proportionality and context). In addition, it
was agreed that once the policy is reviewed this will be recirculated to
the Audit, Risk and Scrutiny Committee members for review and virtual
approval if all in agreement.
 Action: SH to make the amendments as discussed and
recirculate to the Audit Committee for agreement.
RB outlined an e-learning package as a way to ensure that staff may
access the register and declarations are appropriate.
15 Third Party Assurance
(ARSC52-15)
SH provided an update to the Committee and confirmed the progress
has been slow and suggested that the best route is through the contract
monitoring meetings via an agenda item. Any appropriate issues will be
escalated through the Finance Procurement and Contracting Committee
(FPCC). Any risks identified and highlighted would then be progressed
up to the Audit, Risk and Scrutiny Committee (ARSC).
TJ queried the requirement for using the contract monitoring process
and stated that he would like further clarification as inclusion of this on a
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contract monitoring meeting agenda will not necessarily ensure that the
information is received.
MW stated that we should continue to pursue 3rd party assurance via an
appropriate channel. TJ suggested that this could be included in
commissioning intentions which would create and expectation and
means of monitor in the future.
 Action: SH to discuss 3rd Party Assurance process with TJ
and the Head of Business Intelligence, Contracts and
Procurement.
SECTION 3
16
Standards for Commissioners for Anti-Fraud (ARSC53-15)
 The Committee noted the briefing.
17
Anti-Fraud Intelligence update Taxonomy Report (ARSC54-15)
 The Committee noted the report.
18
NHS England Year end 2014-15 Letter (ARSC55-15)
 The Committee noted the letter.
19
Revised suggested committee dates for 2016
 The Committee agreed the revised dates and these will be
confirmed to e-diaries.
Date of Next Meeting
Thursday 17th December 2015
3:00pm – 5:00pm – Boardroom,
The Department, Level 3, Lewis’s Building, Renshaw Street,
Liverpool.
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