Policy Approval Process Number: THCCGCG0020 Executive Summary Date of approval Document Author(s) Version: 1 This procedure outlines which CCG Committees (including the Governing Body) have delegated authority for the approval of Strategies, Policies and Procedures. It outlines which Management Leads and Executive leads (CCG Governing Body Members have responsibility for ensuring which particular documents are fit for purpose. It also sets out the minimum requirements for NHS Tower Hamlets CCG Strategies, Policies and Procedures must meet; these are inclusive of content style, format, quality and accessibility. June 2013 Paul Balson – Governance and Risk Manager been Archna Mathur – Deputy Director Quality and Performance Collette McQueen – Business Manger Senior Management Team – June 2013 Who has consulted? Was an Equality No Analysis required? With what standards NHSLA Risk Management Standards - Standard 1: Governance does this document 1.2 Policy on Procedural Documents demonstrate compliance? References and NHS Tower Hamlets CCG Constitution associated CCG documentation List of obtained approvals Audit Committee – 25 June 2013 Senior Management Team – June 2013 Recommended review Every 2 years or when required. period Key words contained in document approval, audit and monitoring, baf, board assurance framework, committee, communications, consultation, corporate governance, corporate template, delegated authority, executive leads, finance, fit for purpose, governing body, human resources, information governance, management leads, nhsla, policies, policy, policy approval process, policy on procedural documents, prime financial policies, procedure, procedures, protocol, quality improvement, ratification, reviewing , safeguarding, scheme of delegation, standards of business conduct and managing conflicts of interest, storage, strategies, strategy, style guide, sub-committees, whistleblowing policy, writing Is this document fit for the public domain? Y / Y N Date ratified: June 2013 If No, why? THCCGCG0020 Policy Approval Procedure N/a 1 1 2 Purpose and Scope ....................................................................................................... 3 1.1 Purpose .................................................................................................................. 3 1.2 Scope ..................................................................................................................... 3 Guidance ....................................................................................................................... 4 Summary ........................................................................................................................... 4 2.1 Note 1: Write the Strategy, Policy or Procedure using the CCG template ............... 5 2.2 Note 2: Assignment of a Management Lead, Executive Lead and Committee with authority for final approval ................................................................................................. 6 2.3 Note 3: Consultation with the Senior Management Team, CCG staff and members (where appropriate) ........................................................................................................... 7 2.4 Note 4: Committee Approval ................................................................................... 8 2.5 Note 5: Storage and application .............................................................................. 8 2.6 Note 6: Review, audit and monitoring...................................................................... 8 3 Responsibilities .............................................................................................................. 9 4 Review, audit and monitoring ....................................................................................... 10 Date ratified: June 2013 THCCGCG0020 Policy Approval Procedure 2 1 Purpose and Scope 1.1 Purpose The Policy Approval Procedure ensures that: 1. There is a clear signposting of which NHS Tower Hamlets CCG Committees (including the Governing Body) have authority to approve strategies, policies and procedures. 2. That all Strategies, Policies and Procedures meet a set of requirements inclusive of: content style, format, quality and accessibility. The development and on-going management of a Policy Approval Process is important within any healthcare organisation. A standard approach to the development of documents will support the management of risk at all levels of the organisation. 1.2 Scope This procedure applies to all employees of NHS TH CCG who are writing, reviewing or being consulted upon a Strategy, Policy or Procedure for application within NHS Tower Hamlets CCG. Date ratified: June 2013 THCCGCG0020 Policy Approval Procedure 3 2 Guidance Summary The Policy Approval Process is summarised in the diagram below. Additional guidance notes are available underneath. Additional guidance on any aspect of the process is available from: Paul.Balson@towerhamletsccg.nhs.uk or Collette.McQueen@towerhamletsccg.nhs.uk Date ratified: June 2013 THCCGCG0020 Policy Approval Procedure 4 2.1 Note 1: Write the Strategy, Policy or Procedure using the CCG template This is the main body of your document. There are mandatory titles that must be included. A smart use of the approved format will make your document more accessible. The mandatory titles are below: Minimum requirements ensure that your Strategy, Policy or Procedure is accessible and compliant with both best practice and NHSLA Risk Management Standards. The template is available from the Governance Team and has built in styles and formats that should be adhered to. Date ratified: June 2013 THCCGCG0020 Policy Approval Procedure 5 2.2 Note 2: Assignment of a Management Lead, Executive Lead and Committee with authority for final approval Every Strategy, Policy or Procedure created for use within the CCG will be allocated a category. This category will indicate which Committee, Management Lead and Executive Lead (Governing Body Member) have responsibility for approval. „Approval‟ for the purposes of this procedure can be defined as: documentation which has been ratified by the relevant body within the organisation as set out in this procedure. The details of where categorised Strategies, Policies or Procedures go where are detailed below: 2.2.1 Strategies, Policies and Procedures delegated to Committees of the Governing Body Management Lead Governing Lead Archna Mathur Mariette Davis Executive Team Ellie Hobart Catherine Boyle Finance, Performance and Quality Committee Henry Black Mariette Davis Finance IG Information Governance Executive Team Henry Black Dr Isabel Hodkinson HR Human Resources Executive Team Archna Mathur Jane Milligan Quality Improvement Finance, Performance and Quality Committee Archna Mathur QI Dr Everington Archna Mathur Dr Hannah Falvey Code Category Committee CG Corporate Governance Governing Body CO Communications FI Body Sam (Children) SG Safeguarding Safeguarding Committee Richard Fradgley Dr Judith Littlejohn (Adults) Date ratified: June 2013 THCCGCG0020 Policy Approval Procedure 6 2.2.1 Strategies, Policies and Procedures reserved for the Governing Body Document Management Lead Governing Body Lead Scheme of Delegation Henry Black Jane Milligan Prime Financial Policies Henry Black Mariette Davis Standards of Business Conduct and Managing Conflicts of Interest Archna Mathur Jane Milligan Whistleblowing Policy Archna Mathur Jane Milligan Board Assurance Framework Archna Mathur Jane Milligan It must be noted that these tables are to be used a guide and are not prescriptive as some Strategies, Policies or Procedures may fall outside of these categories. The Senior Management Team will advise on any other groups, Sub-Committees or Committees that may be useful to consult. Responsibility for „Approval‟ will be allocated to one Body in the majority of cases. A notable exception would be where a Strategy, Policy or Procedure being developed for more than one organisation. 2.3 Note 3: Consultation with the Senior Management Team, CCG staff and members (where appropriate) A penultimate draft of each document should be sent to individuals or groups who will be responsible implementing aspects of the Strategy, Policy or Procedure, or who will be significantly affected by it. Details of who has been consulted should be recorded on the front sheet. For example: HR policies reviewed by the CSU HR team 11 June 2013 As a minimum the Senior Management Team will be consulted. The Senior Management Team will advise on any other groups, Sub-Committees or Committees that may be useful to consult. . Date ratified: June 2013 THCCGCG0020 Policy Approval Procedure 7 2.4 Note 4: Committee Approval Once the individuals or groups who will have responsibility for implementing aspects of the document or who will be affected by it have been consulted; it is ready for approval. At this point the Management Lead and Executive Lead will present it to the Committee with delegated authority for final approval. Approval is essentially a test of fitness for purpose. Typical prompts to ask include: When an individual or group is asked to approve a Strategy, Policy or Procedure this needs to be made clear to them: Marked for “Approval” on the agenda of the meeting Marked for “Approval” on the coversheet (where required) The outcome clearly recorded in the minutes 2.5 Note 5: Storage and application Following approval, the governance team will arrange for documents to be uploaded onto the intranet and shared drive. Approved documents will be stored on the shared drive here: I:\NHSTHCCG\NEW I DRIVE STRUCTURE\Strategy and Planning\Governance and Risk\4 Document Management\Tower Hamlets CCG Policies\Ratified Whilst it is acknowledged that some staff will need to print hard copies from the intranet, the CCG will discourage the routine use of this access route, and staff are alerted to the fact that documents viewed outside the intranet may have been updated since printed. Staff will therefore need processes in place to ensure they are accessing up to date documents. The documents that are superseded as a result of reviews, change in policy or become out of date will be stored in a folder on the shared drive. There will be other documents, for example those relating to emergency or business continuity, which will need to be accessed in situations where the intranet is not accessible. 2.6 2.6.1 Note 6: Review, audit and monitoring Review Each Strategy, Policy or Procedure will be given a review date. When the date of review approaches the the author or author‟s department will be asked to begin the review process by the Governance team. Date ratified: June 2013 THCCGCG0020 Policy Approval Procedure 8 The review and approval process should follow the same process as if writing a new document. 2.6.2 Audit and monitoring To ensure that the Strategy, Policy or Procedure is delivering on its purpose every Strategy, Policy and Procedure will have a section on Audit and Monitoring. This section must make it clear how the efficacy of the Strategy, Policy and Procedure will be measured. A few examples are included below: What standards / key Method of Monitoring performance indicators monitoring information will you use to confirm this prepared by document is working / being implemented Minimum Monitoring frequency of reported to monitoring All staff will attend record Monitoring Governance keeping training. of training Team uptake Quarterly Senior Management Team 3 Responsibilities The following members of CCG staff have the following responsibilities under this procedure. Role Responsibilities Management Lead The lead for Strategy, Policy or Procedure creation. Champions the Strategy, Policy or Procedure at Committees or the Governing Body. Informs the Senior Management Team of Strategy, Policy or Procedure creation and ensures that: It is dovetailed with objectives is not duplicated in other teams is completed is removed when no longer required. Governing Body Lead To provide support and review of the Strategy, Policy or Procedure. Committee with delegated Provide approval as allocated by the Governing Body authority for approval Monitor the development and review process for each document. Date ratified: June 2013 THCCGCG0020 Policy Approval Procedure 9 Document author The lead for creation of Strategy, Policy or Procedure. Ensures that: It is compliant with the requirements laid out in this procedure. It reflects current practice. It has received the appropriate level of scrutiny. Is completed within declared timescales. Governance Team Provide oversight of the policy approval process Operational management of the systems for controlling and delivering the Trust Policies and Procedures Manual. 4 Review, audit and monitoring This document will be reviewed every 2 years. What standards / key Method of Monitoring performance monitoring information indicators will you prepared by use to confirm this document is working / being implemented Minimum Monitoring frequency of reported to monitoring All Strategies, Policies and Procedures in use by the CCG will be compliant with the style and format requirements of this document Every Strategy, Policy and Procedure Date ratified: June 2013 Review of all Strategies, Policies and Procedures Governance Team will review the document prior to storage in the shared drive and uploading to the Intranet and internet. THCCGCG0020 Policy Approval Procedure Senior Management Team on a monthly basis 10