CCG: BOARD ASSURANCE FRAMEWORK INTRODUCTION 1. As a Clinical Commissioning Group (CCG) we have identified various risks. Many of these are low level and are managed at an operational level. This document highlights the top strategic risks facing us as an organisation therefore the scores for these risks are high, at least at the start of the year. 2. The CCG is part of a collaborative arrangement with other CCGs in North West London comprising Central London, West London, Hammersmith & Fulham, Hounslow and Ealing CCGs. The CCGs have worked together to identify a common set of risks and to develop common approaches to their management, as appropriate. 3. Workshops have taken place with each CCG governing body to identify the key risks to achieving our objectives for the year. The outputs were mapped and discussed with the chairs of the CCGs to reach a common set of 20 risks and subsequently discussed by Governing Bodies. The Board Assurance Framework takes those key risks to the delivery of the CCG’s strategic objectives and sets out the controls that have been put in place to manage the risks and the assurances that have been received that show if the controls are having the desired impact. It includes an action plan to further reduce the risks and an assessment of current performance. The table below sets out the strategic objectives and lists the various risks that relate to them. CCG Objective Objective 1: Empowering patients to take more control of their health and wellbeing through delivery of the ‘whole systems integrated care’ programme. Objective 2: Securing high quality services and improved outcomes for patients Initial Score Current Score Last Review 1 – Engagement with patients is not adequate to enable them to make informed choices about their care. 16 16 May 14 2 - Inability to specify outcomes that we want to see providers deliver leading to reduced impact of commissioning. 16 16 May 14 3 - Safeguarding Children – failure to meet statutory responsibilities leading to poor quality care 15 15 May 14 4 - Safeguarding Adults – failure to meet statutory responsibilities leading to poor quality care primarily in care homes but also other providers 20 20 May 14 5 – Imperial not delivering services to the agreed standard and lack of alignment between their strategy and our operational delivery 20 16 May 14 6 –Chelsea & Westminster do not deliver services to agreed standard 12 12 May 14 7 – Inability of West Middlesex to deliver services to agreed standard and impact of the transaction with Chelsea and Westminster 16 16 May 14 8 – Inability of Ealing Hospital to deliver services to agreed standard 20 20 May 14 Description of risk identified 1 CCG: BOARD ASSURANCE FRAMEWORK Objective 3: Putting in place the infrastructure to deliver high quality commissioning. Objective 4: Building relationships with local authorities and Health and Wellbeing Boards to deliver the Better Care Fund plan, and developing and delivering joint plans with other CCGs across North West London. Objective 5: Delivering the Out of Hospital Strategy and acute hospital changes as set out in the Shaping a Healthier Future Strategy. Objective 6: Delivering our statutory and organisational duties 9 – Inability of Central London Community Healthcare to deliver services to agreed standard 12 12 May 14 10 – Inability of West London Mental Health Trust to deliver services to agreed standard and to deliver elements of the out of hospital strategy 16 12 May 14 11 – Inability of Central & North West London Trust to deliver services to agreed standard and to deliver elements of the out of hospital strategy 20 20 May 14 12 – Failure to put systems in place to deliver improvements in commissioning support. 20 16 May 14 13 – Not managing the relationship between CCGs and member practices effectively 20 20 May 14 20 20 May 14 15 - Through unsustainable demand, uncontrolled delays to the delivery timelines and an inability to deliver the required clinical workforce Shaping a Healthier Future delivers precipitate, poorly planned change, which adversely impacts quality and safety 16 12 May 14 16 – Through an inability to meet the clinical standards, deliver the requisite workforce, deliver behavioural change, sustain expected patient experience and unsustainable demand on the system Shaping a Healthier Future does not deliver the planned benefits to improve quality and safety of health and care across NW London 16 16 May 14 17 - Primary care and community care providers are not able (due to organisational and workforce issues) to deliver the increase in activity required to deliver services as described in the Out of Hospital Strategy 16 16 May 14 18 - Failure to deliver IT systems which can deliver data CCGs need 16 16 May 14 19 - Failure to operate in a way that meets required Information Governance standards 12 12 May 14 20 - Failure to meet in year financial targets and to deliver the planned underlying surplus that underpins longer term financial sustainability 16 16 May 14 14 - Lack of alignment between approaches taken by CCGs and Local Authorities means that the benefits set out in the Better Care Fund workstreams are not realised and unmanageable cost pressures in 2015/16. 2 CCG: BOARD ASSURANCE FRAMEWORK Objective: Empowering patients to take more control of their health and wellbeing Director lead: Director of Quality & Patient Safety Risk: Engagement with patients is not adequate to enable them to make informed choices about their care. This leads to a lessening of our ability to move activity from acute to community settings. Date last reviewed: May 2014 25 20 15 10 5 0 Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 4 x 4 = 16 Current: 4 x 4 = 16 Appetite: 2 x 4 = 8 Risk Appetite Rationale for current score: Enabling patients to make the right choices is central to the CCG’s plans and will require significant behavioural change to achieve. Rationale for risk appetite: We want to reduce the likelihood of this risk through greater awareness of patients of their health and healthcare options. Controls: (What are we currently doing about the risk?) Mitigating actions: (What more should we do?): New quality schedules included in provider contracts will lead to Patient engagement strategies in place across the five CCGs which was informed by production of quarterly patient experience integrated reports. patients. Access to patient records via handheld devices A range of programmes being put in place as part of the Better Care Fund. Better Care Fund programme has identified resources to capture patient experience Using the Prime Minister’s Challenge Fund to support online appointment booking and ePrescription services across Health & Social Care which will be used to drive action. Assurances: (How do we know if the things we are doing are having an impact?) Each CCG has system in place for capturing patient experience and reported through PPE and Quality committee. Quarterly reports from providers will be reported to Care Quality Group meetings and given to each CCG Quality Committee. Regular reports from Healthwatch to Quality committee. Current performance: (With these actions taken, how serious is the problem?) JW Dec 15 FF Dec 15 FF Co-design of care pathways and Out of Hospital Services On-going TSaw Improving the effectiveness of 111 service On-going tbc Extended access to primary care through redesigned LES services including care planning and care navigators. Summer 2014 TSan Gaps in assurance: (What additional assurances should we seek?) Analysis of trends and themes across providers relating to patient feedback. Additional Comments 3 July 14 1 CCG: BOARD ASSURANCE FRAMEWORK Objective: Securing high quality services and improved outcomes for patients Director lead: Chief Finance Officer Risk: Inability to specify outcomes that we want to see providers deliver leading to reduced impact of commissioning. Date last reviewed: May 2014 25 20 15 10 5 0 Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 4 x 4 = 16 Current: 4 x 4 = 16 Appetite: 2 x 4 = 8 Risk Appetite Controls: (What are we currently doing about the risk?) Review of commissioning intentions and contract reviews led to development of consistent strategy for implementing data quality and service delivery improvement programmes in our 2014/15 contracts with Providers. Rationale for current score: If we are unable to specify outcomes and measure performance accurately, desired quality improvements will not be delivered. Rationale for risk appetite: Obtaining the right data is difficult, but by improving collection and analysis of data, the risk this is should be reduced. Mitigating actions: (What more should we do?): Lessons learned workshop from contracting round leading to actions for improvement. June 14 OW Action plan to be developed and agreed June 14 OW Assurances: (How do we know if the things we are doing are having an impact?) Acute/Community Information Schedule Trackers used to inform Quality and Performance reports which go to Governing Bodies and committees. Gaps in assurance: (What additional assurances should we seek?) We have not yet identified learning from the 2014/15 contracting round. Current performance: (With these actions taken, how serious is the problem?) There is an acknowledged gap in our data quality standards Additional Comments 4 2 CCG: BOARD ASSURANCE FRAMEWORK Objective: Securing high quality services and improved outcomes for patients Director lead: Director of Patient Safety & Quality Risk: Safeguarding Children – failure to meet statutory responsibilities leading to poor quality care Date last reviewed: May 2014 Rationale for current score: 25 20 15 10 5 0 Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 3 x 5 = 15 Current: 3 x 5 = 15 Appetite: 2 x 5 = 10 Risk Appetite Controls: (What are we currently doing about the risk?) Failure in this area would have an impact on vulnerable members of the community and is therefore very serious. This is a challenging control environment in the context of multi-agency working and the wider commissioning environment. Steps have been taken to reduce the likelihood of problems occurring. Rationale for risk appetite: While the impact of failures could have a major impact on patients, the aim is to reduce the likelihood of this occurring. Risks can never be completely eliminated. Mitigating actions: (What more should we do?): Leadership roles for safeguarding clearly defined within key providers and CCG. Designated Nurses sit on each CCG Quality Committee. Established working relationships with the Safeguarding Children’s Boards. Reporting systems for serious incidents and framework to CCGs that identifies assurances. Reporting framework has been strengthened for providers via internal review, CQG scrutiny and CCG assurance using the outcomes framework. There are quarterly agenda reports by providers at CQG with exceptions as required monthly. Lead for health on serious case reviews as they occur. Multi Agency Safeguarding Hubs in place. Strengthen reporting of outcomes of Female Genital Mutilation work by providers Sept 14 Jonathan Webster Develop a consistent approach for CCGs to Looked After Children with improved reporting. July 14 Jonathan Webster Develop a robust contract for healthcare Out of Borough Looked After Children placements July 14 Jonathan Webster Sept 14 Jonathan Webster Sept 14 Jonathan Webster Review transition of care from children’s to adult services Recruit named GP (Central London) Assurances: (How do we know if the things we are doing are having an impact?) Quarterly written reports to CCG Quality committees with monthly verbal updates for exceptional issues. Minutes presented to governing body meetings. Reports to NHS England assurance meeting and Local Safeguarding Children’s Board. Gaps in assurance: (What additional assurances should we seek?) Current performance: (With these actions taken, how serious is the problem?) Additional Comments All main trusts are reporting in on a quarterly basis but this needs to be more effectively aligned to CQG agendas. Key risk factors are: FGM/ ensuring the CCGs are compliant re LAC responsibilities. Risks around systems to monitor mobile families. 5 Risks due to multiple commissioning organisations have not been resolved. Particular risk in relation to CAMHS tier 4 beds – commissioned by NHS England but a lack of beds nationally/ concerns re the quality of the provision. Impact on local children & young people placed on adult wards or general paediatric wards. No. children placed out of Borough/changes to payment systems. 3 CCG: BOARD ASSURANCE FRAMEWORK Objective: Securing high quality services and improved outcomes for patients Director lead: Director of Patient Safety & Quality Risk: Safeguarding Adults – failure to meet statutory responsibilities leading to poor quality care primarily in care homes but also other providers Date last reviewed: May 2014 25 20 15 10 5 0 Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 4 x 5 = 20 Current: 4 x 5 = 20 Appetite: 2 x 5 = 10 Risk Appetite Rationale for current score: CCGs have implemented governance structures to exercise this function. However risk remains high as systems are largely untested and legislative changes create new challenges in the system. Rationale for risk appetite: The aim is to reduce the likelihood to low, but the consequences of failure remain high. Controls: (What are we currently doing about the risk?) Leadership roles for Safeguarding Adults clearly defined within CCG and key providers. Establishment of systems in line with multi-agency working eg Continuing Healthcare Quality Assurance Group and Care Quality Group meetings. Established working relationship with Local Safeguarding Adults Board. Clear relationships with local authorities in relation to safeguarding and continuing healthcare. Reporting systems have been developed to provide a framework for assurance to the CCGs. Mitigating actions: (What more should we do?): Assurances: (How do we know if the things we are doing are having an impact?) CCG Quality & Safety Committee minutes showing quarterly Safeguarding Adults reports. Quality Assurance Group for Continuing Healthcare. Current performance: (With these actions taken, how serious is the problem?) Gaps in assurance: (What additional assurances should we seek?) Governing Bodies do not yet know if these new systems and processes are sufficiently robust and embedded in multi-agency working. Better reporting of causes of pressure ulcers. Additional Comments All trusts are aware of the need to report on a quarterly basis but not all are submitting using the framework developed by the safeguarding team. However, this needs to be better aligned with the CQG agenda. There is a concern that the complexity of the commissioning environment and public sector financial constraints lead to insufficient focus on quality. 6 Strengthen work with local authorities to develop services for learning disability following Winterbourne view report. Sept 14 Jonathan Webster Improve health response to Mental Capacity Act utilising NHS England funding. Dec 14 Jonathan Webster Commence implementing the findings from Quality dashboard to improve continuing healthcare provision in care homes and other units. June 14 Jonathan Webster Facilitate completion of Safeguarding Adults audit tool and use to improve the system across health economy June 14 Jonathan Webster 4 CCG: BOARD ASSURANCE FRAMEWORK Objective: Securing high quality services and improved outcomes for patients Director lead: Managing Director, Hammersmith & Fulham Risk: Imperial not delivering services to the agreed standard and lack of alignment between their strategy and Date last reviewed: May 2014 our operational delivery 25 20 15 10 5 0 Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 5 x 4 = 20 Current: 4 x 4 = 16 Appetite: 2 x 4 = 8 Risk Appetite Controls: (What are we currently doing about the risk?) Rationale for current score: Imperial is a major provider to the CCGs and therefore its performance has a big impact on patients in the area. There have been performance issues in the past. Rationale for risk appetite: Contract management and other process aim to ensure that problems do not arise. Mitigating actions: (What more should we do?): Imperial executive team attend CWHHE executive meetings every 6 weeks to discuss and agree strategy and explicit arrangements for CCGs to be involved in strategy development. Performance issues also discussed. Account Manager in place to lead on contract monitoring with Imperial. Clinical Quality Group meetings take place regularly. Local Transformation Incentive Scheme in place for 2014/15 to incentivise the Trust to implement change-behaviour and activity reductions consistent with Shaping a Healthier Future. We will issue contract query notices in line with the agreed national contract if performance falls below expected standards Development and approval of the Outline Business Case tbc Oct 14 CL TSaw Assurances: (How do we know if the things we are doing are having an impact?) Performance reports to governing bodies. Quality Committee minutes and Finance and Performance Committee minutes to the governing body. Gaps in assurance: (What additional assurances should we seek?) Information systems do not provide complete and up-to-date information on which to base commissioning decisions. Current performance: (With these actions taken, how serious is the problem?) Additional Comments Foundation Trust application and the delivery of the transformational elements in the contract to be monitored in-year. 7 5 CCG: BOARD ASSURANCE FRAMEWORK Director lead: Managing Director, West London Objective: Securing high quality services and improved outcomes for patients Date last reviewed: May 2014 Rationale for current score: There have been concerns about reporting processes. The Trust is currently working with the CCGs to address these concerns. Rationale for risk appetite: Contract management and other process aim to ensure that problems do not arise. Controls: (What are we currently doing about the risk?) Mitigating actions: (What more should we do?): Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk: Chelsea & Westminster do not deliver services to agreed standard Risk Rating 25 (likelihood x 20 Risk 15 consequence): Score 10 Initial: 3 x 4 = 12 5 Risk Current: 3 x 4 = 12 0 Appetite Appetite: 2 x 4 = 8 Contract review meetings. Clinical Quality Group meetings. Performance & Contracting Executive meeting responsible for oversight of contract inyear, assessing risks and identifying these for Finance & Performance and Quality meetings. Transformation Board: second year for urgent care, and first year for planned care. Continue to work through the Account Manager and the CSU to drive improvements Review communication flow between CQG and CCG Quality meeting Review of 2013/14 risk log to reduce likelihood of same risks appearing again Re-investment of RTT fines to support the Trust Ongoing June 2014 June 2014 Ongoing LP LP CP Assurances: (How do we know if the things we are doing are having an impact?) Gaps in assurance: (What additional assurances should we seek?) C&W to develop rigorous serious incident management programme to align with national standards Evidence to demonstrate progress against agreed plans to improve serious incident reporting and management required Quality and Performance reports to Committees and Governing Bodies Quality Committee and Finance and Performance Committee report into Governing Bodies Draft commissioner response to 2014/15 Quality Accounts being reviewed (April 2014) Reports to Care Quality Group Current performance: (With these actions taken, how serious is the problem?) C-section rates improving at month 11 (February 2014) 18 week RTT (referral to treatment) for subspecialty capacity (Trauma & Orthopaedics; Ophthalmology; Gastro; General Surgery; Plastic Surgery; Rheumatology) below target and will remain so until Q2, 2014/15 8 Additional Comments Should non-performance in serious incident reporting/ management continue, a Board to Board session may be considered 6 CCG: BOARD ASSURANCE FRAMEWORK Objective: Securing high quality services and improved outcomes for patients Director lead: Managing Director, Hounslow Risk: Inability of West Middlesex to deliver services to agreed standard and impact of the transaction with Chelsea & Westminster Date last reviewed: May 2014 25 20 15 10 5 0 Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 4 x 4 = 16 Current: 4 x 4 = 16 Appetite: 2 x 4 = 8 Risk Appetite Rationale for current score: There are uncertainties around the future of West Middlesex Hospital in the context of its proposed partnership with Chelsea & Westminster Hospital. Rationale for risk appetite: Contract management and other process aim to ensure that problems arising from uncertainty do not arise. Controls: (What are we currently doing about the risk?) Mitigating actions: (What more should we do?): Contract review meetings. Hounslow CCG to become a member of the Trust’s Clinical Quality Group meetings. Transformation Board. Representation from the Trust on the Urgent Care Board Contract with the Trust includes provision for a transformation programme management office June 2014 SJ Assurances: (How do we know if the things we are doing are having an impact?) Quality and Performance report to the governing body Gaps in assurance: (What additional assurances should we seek?) We will need to receive the minutes and reports from the Transformation Board Current performance: (With these actions taken, how serious is the problem?) Additional Comments 9 7 CCG: BOARD ASSURANCE FRAMEWORK Objective: Securing high quality services and improved outcomes for patients Director lead: Managing Director, Ealing Risk: Inability of Ealing Hospital to deliver services to agreed standard Date last reviewed: May 2014 25 20 15 10 5 0 Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 5 x 4 = 20 Current: 5 x 4 = 20 Appetite: 2 x 4 = 8 Risk Appetite Rationale for current score: There are serious concerns with the sustainability of the Trust and the quality of care provided. Rationale for risk appetite: Contract management and other process aim to ensure that problems do not arise. Controls: (What are we currently doing about the risk?) Contract review meetings. Clinical Quality Group meetings. Quality measures agreed as part of the 2014/5 contract Board to Board and PCE meetings. Mitigating actions: (What more should we do?): Assurances: (How do we know if the things we are doing are having an impact?) Quality and Performance report Monitoring performance and quality via contract meetings and the Clinical Quality Group meetings. Current performance: (With these actions taken, how serious is the problem?) Gaps in assurance: (What additional assurances should we seek?) We need a comprehensive plan for addressing identified quality issues 10 Proposed merger is a key mitigation We are expecting an update in the summer. Aug 14 Special quality committee set up to review recent quality information and to agree next steps. June 14 Additional Comments KM JWeb 8 CCG: BOARD ASSURANCE FRAMEWORK Objective: Securing high quality services and improved outcomes for patients Director lead: Managing Director, Central London Risk: Inability of Central London Community Healthcare (CLCH) to deliver services to agreed standard Date last reviewed: May 2014 25 20 15 10 5 0 Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 3 x 4 = 12 Current: 3 x 4 = 12 Appetite: 2 x 4 = 8 Risk Appetite Controls: (What are we currently doing about the risk?) A new contract will be in place for 2014/15 to include a number of agreed approaches to improving models of care. Community Nursing review underway. Central London Community Healthcare agreed to adopt an IT single system. A programme to oversee delivery of the improvement plan has been established which reports to the CLCH contract performance committee. CLCH have agreed with the principle that we pass day to day management of community nurses to GP localities. Assurances: (How do we know if the things we are doing are having an impact?) Quality and Performance report. Feedback from CCG Chairs, Governing Bodies, members and patients. Current performance: (With these actions taken, how serious is the problem?) 11 Rationale for current score: Delivery of Out of Hospital strategy is dependent on the community nursing model being implemented. Plans in place reduce the risk score achievement of milestones but improved outcomes need to be seen before the risk can be reduced. Rationale for risk appetite: Successful design and implementation will potentially deliver improvements to patient experience and outcomes. Mitigating actions: (What more should we do?): Expansion of use of common IT system across multiple community services in tri-Borough CCGs Service Delivery Improvement Plan to be agreed Dec 14 MB June 14 MB Gaps in assurance: (What additional assurances should we seek?) To be confirmed based on implementation of 2014/15 contact. Additional Comments 9 CCG: BOARD ASSURANCE FRAMEWORK Objective: Securing high quality services and improved outcomes for patients Director lead: Managing Director, Ealing Risk: Inability of West London Mental Health Trust to deliver services to agreed standard and to deliver elements of the out of hospital strategy Date last reviewed: May 2014 25 20 15 10 5 0 Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 4 x 4 = 16 Current: 3 x 4 = 12 Appetite: 2 x 4 = 8 Risk Appetite Rationale for current score: West London Mental Health Trust has a significant role to play in the successful delivery of out of hospital strategy. Agreement of priorities reduced the risk score in May. Rationale for risk appetite: Measures are being put in place aiming to reduce the likelihood of problems with service levels. Controls: (What are we currently doing about the risk?) Transformation Board is in place and co-chaired by a Hounslow GP Governing Body Member and West London Mental Health Trust Medical Director. Board has agreed priorities including psychiatric liaison and shifting settings of care. Mitigating actions: (What more should we do?): Assurances: (How do we know if the things we are doing are having an impact?) Updates and mental health issues presented to governing bodies by the lead commissioner. Current performance: (With these actions taken, how serious is the problem?) Gaps in assurance: (What additional assurances should we seek?) Structured and systematic reporting process not in place. Concerns about the ability of WLMHT management to deliver actions. Additional Comments Action plan to be developed. Jun 14 KM 10 12 CCG: BOARD ASSURANCE FRAMEWORK Objective: Securing high quality services and improved outcomes for patients Director lead: Managing Director, West London Risk: Inability of Central & North West London Trust to deliver services to agreed standard and to deliver elements of the out of hospital strategy Date last reviewed: May 2014 25 20 15 10 5 0 Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 5 x 4 = 20 Current: 5 x 4 = 20 Appetite: 2 x 4 = 8 Risk Appetite Controls: (What are we currently doing about the risk?) Contract review meetings Quality Improvement Group established in responses to CQC conditions Clinical Quality Group NHS England Clinical Quality Summit with CCG input Rationale for current score: There are serious concerns that the quality of services provided by the Trust is currently not meeting expectations as evidenced by the Care Quality Commission reviews and Monitor investigation. Rationale for risk appetite: Measures are being put in place aiming to reduce likelihood of problems with service levels. Mitigating actions: (What more should we do?): Continue to work through the Account Manager and the CSU to drive improvements Continued leadership of QIG Review communication flow between CQG/CCG Quality meeting CQG focussing on how the new CQC regime will operate to understand provider and commissioner responses On-going LP On-going LP June 2014 LP CQG Assurances: (How do we know if the things we are doing are having an impact?) Gaps in assurance: (What additional assurances should we seek?) Quality & Performance reports to Committees and Governing Bodies Quality and Finance & Performance Committee report into Governing Bodies Updates on action plans and accelerated service improvement plans to Quality Improvement Group and CQG Reports to Care Quality Group Draft 2014/15 Quality Accounts, presented to West London CCG Quality, Patient Safety & Risk Committee in April 2014, did not demonstrate how the trust would be responding to CQC conditions Current performance: (With these actions taken, how serious is the problem?) Additional Comments In April 2014, Monitor announced it has launched an investigation into the way Central North West London NHS Foundation Trust is run. Given the expansion to provide services at Milton Keynes and the current two enforcement notices, concerns remain. 13 Greater input to North West London Mental Health Transformation Programme Board 11 CCG: BOARD ASSURANCE FRAMEWORK Objective: Putting in place the infrastructure to deliver high quality commissioning. Director lead: Chief Officer Risk: Failure to put systems in place to deliver improvements in commissioning support Date last reviewed: May 2014 25 20 15 10 5 0 Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 5 x 4 = 20 Current: 4 x 4 = 16 Appetite: 2 x 3 = 6 Risk Appetite Controls: (What are we currently doing about the risk?) Rationale for current score: A decision has been taken to change how commissioning support is secured and transition arrangements need to be put in place to achieve this. Risk reduced followed approval from NHS England to in-house services. Rationale for risk appetite: Systems are being put in place to ensure that commissioning support functions meet the needs of the CCGs more closely. Mitigating actions: (What more should we do?): Joint approach agreed by all eight CCGs across North West London to in-house services. Business case produced and approved by NHS England to demonstrate how we can inhouse functions. Communications plan now in place. Paper on transition governance going to July Governing Body meetings. Assurances: (How do we know if the things we are doing are having an impact?) NHS England have assured themselves that the business case is robust Reports to each governing body via Chair and Chief Officer at each meeting Current performance: (With these actions taken, how serious is the problem?) An engagement event for CSU staff took place on 23rd June. New structures to be developed and being consulted on. Describe the future governance arrangements for overseeing the effectiveness of ‘in-housing’ of commissioning support services Jun/ July 14 BW July 14 BW Gaps in assurance: (What additional assurances should we seek?) Regular updates are required on progress of the business case, plans to operationalize it and any slippage in timeframes. Additional Comments 14 12 CCG: BOARD ASSURANCE FRAMEWORK Objective: Putting in place the infrastructure to deliver high quality commissioning. Director lead: Chief Officer Risk: Not managing the relationship between CCGs and member practices effectively Date last reviewed: May 2014 25 20 15 10 5 0 Risk Score Risk Appetite Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 4 x 5 = 20 Current: 4 x 5 = 20 Appetite: 2 x 5 = 10 Controls: (What are we currently doing about the risk?) Members meetings set up and in the diary meetings with LMC reps in place and LMC involvement in the CCG’s activities. Mitigating actions: (What more should we do?): Assurances: (How do we know if the things we are doing are having an impact?) Rationale for current score: Implementation of contracts to replace LESs, exploration of co-commissioning primary care with NHS England and the development of networks to deliver different services all carry a risk. A risk that is heightened given that we are a membership organisation with GP practices as embers. Rationale for risk appetite: By engaging with our members and the LMC we aim to reduce the likelihood of this risk materialising. Implementing new contracts for out of hospital services July 14 TSan Bid for co-commissioning of primary care services to be submitted to NHS England by 20 June June 14 TSaw Meeting being set up with the LMC to explore how we can identify common goals and work together to achieve them, particularly across the eight CCGs in NW London Jul 14 BW Implementing learning from the 360 degree stakeholder survey results. Sept 14 DE Gaps in assurance: (What additional assurances should we seek?) Need to strengthen reporting of member engagement and feedback to governing bodies. reports to governing bodies from members meetings. 360 degree stakeholder feedback survey Current performance: (With these actions taken, how serious is the problem?) Risk remains high at start of year as arrangements are being put in place. Additional Comments: 15 13 CCG: BOARD ASSURANCE FRAMEWORK Objective: Building relationships with local authorities and Health and Wellbeing Boards to deliver the Better Director lead: Chief Officer Care Fund plan, and developing and delivering joint plans with other CCGs across North West London. Risk: Lack of alignment between approaches taken by CCGs and Local Authorities means that the benefits set out in the Better Care Fund workstreams are not realised and unmanageable cost pressures in 2015/16 25 20 15 10 5 0 Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 5 x 4 = 20 Current: 5 x 4 = 20 Appetite: 2 x 4 = 8 Risk Appetite Controls: (What are we currently doing about the risk?) Date last reviewed: May 2014 Rationale for current score: Close working between CCGs and local authorities is increasingly important to the achievement of CCG plans. The financial impact of the BCF is significant, with around 3% of budget included within the BCF. If the identified schemes do not generate savings within health and social care, this will be unaffordable. There are a number of schemes that require work to deliver and implement them and the governance of the Fund is complex. Rationale for risk appetite: By putting robust governance arrangements and joint plans in place the risks can be minimised. Mitigating actions: (What more should we do?): Health & Wellbeing Boards in place with representation from CCG Governing Body. Joint Health & Wellbeing Strategy has been agreed. Tri-Borough: Integration Partnership Board brings parties together to develop agreed approaches and Joint Executive Team in place for each of tri-borough, Hounslow and Ealing. BCF has been agreed for each borough. Tri-borough, Hounslow and Ealing Project areas identified and leads assigned. Resource plans being put in place. Greater internal governance of the tri borough plan is being considered BCF plans rated as ‘green’ by NHS England Confirm with accountable authorities how the BCF contributes to the delivery of their corporate agendas, to ensure commitment to the programme. Jun 14 CA/MDs Develop wider communications and engagement programme to embed BCF in practice for both NHS and Local Authorities, commissioners and providers, customers and communities Sept 14 CA/MDs Further work in progress to revise Terms of Reference for Health and Wellbeing Boards Sept 14 CA/MDs Develop project support to implement the programme June 14 CA/MDs Assurances: (How do we know if the things we are doing are having an impact?) Reports on joint projects brought to governing body on an ad hoc basis. Current performance: (With these actions taken, how serious is the problem?) Gaps in assurance: (What additional assurances should we seek?) Change of administration in Hammersmith & Fulham means new relationships need to be built. Need to develop clear reporting lines to the Governing Bodies On-going assurance that Health & Wellbeing Strategy is being implemented. Additional Comments 16 14 CCG: BOARD ASSURANCE FRAMEWORK Objective: Delivering the Out of Hospital Strategy and acute hospital changes as set out in the Shaping a Director lead: Chief Officer Healthier Future Strategy. Risk: Through unsustainable demand, uncontrolled delays to the delivery timelines and an inability to deliver the required clinical workforce Shaping a Healthier Future delivers precipitate, poorly planned change, which adversely impacts quality and safety Rationale for current score: 25 20 15 10 5 0 This is one of the largest reconfigurations programmes in the country and is in the initial phases of implementation. Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 4 x 4 = 16 Current: 3 x 4 = 12 Appetite: 2 x 4 = 8 Rationale for risk appetite: Risk Appetite Controls: (What are we currently doing about the risk?) Date last reviewed: May 2014 If these changes are delivered in an uncontrolled manner it will quickly impact quality and safety of services across NWL Mitigating actions: (What more should we do?): Clinical Board - brings together all of NW London’s medical leaders to ensure transition is being safely planned and managed and will coordinate collective action to address any issues as required. Monitoring - Clinical Board and Programme board continue to review monitor key metrics on activity, quality and shape change. Stakeholder Engagement – The Programme Board is engaging with the NTDA, NHSE and DH capture all assurance requirements and ensure external support is maintained Maternity Contingency Plan now in place. Continue to review programme governance structures as we progress through implementation June 14 TSa Central Middlesex and Hammersmith A&E Closure impact and mitigating actions. Sept 14 TSw Assurances: (How do we know if the things we are doing are having an impact?) Implementations decisions are being monitored through a CCG assurance framework Gaps in assurance: (What additional assurances should we seek?) Current performance: (With these actions taken, how serious is the problem?) Additional Comments These will (if any) be identified through the external review that is underway and managed through the programmes governance structures in place The governance process in place is well supported by all organisations indicating all organisation are working together to mitigate this risk. Dates have now been proposed for the closure of Hammersmith and Central Middlesex A&E in September. 17 15 CCG: BOARD ASSURANCE FRAMEWORK Objective: Delivering the Out of Hospital Strategy and acute hospital changes as set out in the Shaping a Director lead: Director of Strategy & Transformation Healthier Future Strategy. Risk: Through an inability to meet the clinical standards, deliver the requisite workforce, deliver behavioural change, sustain expected patient experience and unsustainable demand on the system Shaping a Healthier Future does not deliver the planned benefits to improve quality and safety of health and care across NW London Rationale for current score: 25 20 15 10 5 0 This is one of the largest reconfigurations programmes in the country and is in the initial phases of implementation Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 4 x 4 = 16 Current: 4 x 4 = 16 Appetite: 2 x 4 = 8 Date last reviewed: May 2014 Rationale for risk appetite: Risk Appetite Controls: (What are we currently doing about the risk?) If these changes are delivered in an uncontrolled manner it will quickly impact quality and safety of services across NWL Mitigating actions: (What more should we do?): Clinical standards were approved in the DMBC and all providers are now creating plans which support the delivery of these standards Clinical Workforce – a steering group for the development of a NW London wide workforce has been implemented, working with HE NWL. A baseline of all acute, community and primary care workers has been defined. Unsustainable demand – All provider CIP and commissioner QIPP plans have been designed in support of the activity shift and system wide shape change. A finance and activity modelling group consisting of all commissioner and provider Finance Directors has been established to ensure a common view for the creation of all business cases. A programme wide tracker to review activity, quality and shape change is reviewed by the programme quarterly. Assurances: (How do we know if the things we are doing are having an impact?) Benefits framework –DMBC included a benefits framework to ensure that the programme was designed to deliver the specified benefits and this will continue to be reviewed Current performance: (With these actions taken, how serious is the problem?) The programme is continuing to develop to deliver two services transitions this year and complete the Outline Business Cases 18 Continue to review programme governance structures as we progress through implementation June 14 TSaw Gaps in assurance: (What additional assurances should we seek?) These will (if any) be identified through the external review that is underway and managed through the programmes governance structures in place Additional Comments 16 CCG: BOARD ASSURANCE FRAMEWORK Objective: Delivering the Out of Hospital Strategy and acute hospital changes as set out in the Shaping a Healthier Director lead: Managing Director for each CCG Future Strategy. Risk: Primary care and community care providers are not able (due to organisational and workforce issues) to deliver the increase in activity required to deliver services as described in the Out of Hospital Strategy 25 20 15 10 5 0 Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 4 x 4 = 16 Current: 4 x 4 = 16 Appetite: 2 x 4 = 8 Controls: (What are we currently doing about the risk?) An approach Local Enhanced Services and Local Incentive Schemes has been agreed. An application to the Prime Minister’s Challenge Fund has been approved and forms part of a £10m investment across CWHHE CCGs. Whole systems strategy has been agreed. Network development programme in all CCGs underway IT investments underway Each CCG has an Out of Hospital Strategy and staff in post to deliver. Workforce strategy in the Shaping a Healthier Future programme Risk Appetite Date last reviewed: May 2014 Rationale for current score: Changes to Primary Care services are vital to the delivery of strategies but face challenges to deliver. Rationale for risk appetite: By investing in Primary Care the risk of failure will be reduced. Mitigating actions: (What more should we do?): Service models and supporting infrastructure for 7-day access are being developed 14/15 TSaw Services previously commissioned as Local Enhanced Schemes are being commissioned July 2014 TSan Need to define how we will work with NHSE to improve quality of primary care services July 2014 DE Sept 14 EY Implement the recommendations of Community Services Review We will review community services and commission in a different way so as to help make roles more attractive and improve recruitment and retention of staff. June 2014 EY Setting up a new health education network. July 2014 TSaw Plan being developed to improve practice nursing July 2014 JWeb Assurances: (How do we know if the things we are doing are having an impact?) Gaps in assurance: (What additional assurances should we seek?) We don’t have a mechanism for understanding the relative impacts of the various schemes in place to develop primary care e.g. Prime Minister’s Challenge Fund, whole systems integrated care, and network development. Out of Hospital group to monitor progress; minutes go to governing body meetings. Urgent care board minutes go to governing body meetings Shaping a Healthier Future delivery tracker Performance report showing progress with delivering local priorities Current performance: (With these actions taken, how serious is the problem?) Additional Comments Vacancies in key staff groups such as health visitors. Productive General Practice programme being rolled out in Hounslow. 19 17 CCG: BOARD ASSURANCE FRAMEWORK Objective: Delivering our statutory and organisational duties Director lead: Chief Information Officer Risk: Failure to deliver IT systems which can deliver data CCGs need Date last reviewed: May 2014 25 20 15 10 5 0 Risk Score Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 4 x 4 = 16 Current: 4 x 4 = 16 Appetite: 2 x 4 = 8 Risk Appetite Controls: (What are we currently doing about the risk?) Collaborative Information Strategy & Information Governance committee in place and meeting regularly. CQUIN agreed with Providers on the use of information. Assurances: (How do we know if the things we are doing are having an impact?) Highlight reports to Information Strategy & Information Governance committee and by exception to Governing Bodies. Current performance: (With these actions taken, how serious is the problem?) 20 Rationale for current score: There are a large number of stakeholders with varying priorities making consensus difficult to achieve and not getting the required value from the Hitachi contract for the data warehouse. Rationale for risk appetite: Information Strategy currently being developed with the aim of bringing parties together and securing the data that the CCGs require. Mitigating actions: (What more should we do?): Agree Information Strategy July 14 AG June 14 BW IT governance structure being strengthened July 14 BW Benefits realisation plan for SystmOne-Health being put in place. July 14 AG SystmOne support team looking at use of strategic reporting module to feed direct GP data to CSU to allow better reporting on out of hospital contracts/ developments. Sept 14 AG Assurances being sought from GP practices and risk stratification tool providers that data is being used safely and lawfully to produce care plans Gaps in assurance: (What additional assurances should we seek?) Additional Comments 18 CCG: BOARD ASSURANCE FRAMEWORK Objective: Delivering our statutory and organisational duties Director lead: Director of Compliance Risk: Failure to operate in a way that meets required Information Governance standards Date last reviewed: May 2014 25 20 15 10 5 0 Risk Score Risk Appetite Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 3 x 4 = 12 Current: 3 x 4 = 12 Appetite: 2 x 4 = 8 Rationale for current score: Failure in this area could lead to breach of legal requirements or reputational damage. It could also lead to prevention of delivering strategic change e.g. risk stratification for care planning. Rationale for risk appetite: Resources and procedures will be put in place to allow the risk to be properly controlled. Controls: (What are we currently doing about the risk?) Mitigating actions: (What more should we do?): Each CCG has a dedicated Information Governance lead. Information Governance NHS England reviewing a sample of Practice working group is in place. Independent Information Governance advice contract in compliance place. Plan to be developed for increasing CCG compliance Information Governance policies approved and circulated. Training plan to be developed to ensure 100% staff Information Strategy & Information Governance Committee in place to oversee IG compliance compliance and progress. All practices to become level 2 IG compliant. Memorandum of understanding near finalisation. With regard to risk stratification, we are working with HSCIC and TPP to get risk stratification incorporated within SystmOne as quickly as possible. June 14 BW June 14 BW June 14 BW Assurances: (How do we know if the things we are doing are having an impact?) Gaps in assurance: (What additional assurances should we seek?) Once the training plan is in place, will need updates The CCGs have achieved level 2 against the Information Governance toolkit (v11). Internal Audit Report produced (April 2014). Current performance: (With these actions taken, how serious is the problem?) Additional Comments: 21 19 CCG: BOARD ASSURANCE FRAMEWORK Objective: Delivering our statutory and organisational duties Director lead: Chief Finance Officer Risk: Failure to meet in year financial targets and to deliver the planned underlying surplus that underpins longer term financial sustainability Date last reviewed: May 2014 Rationale for current score: 25 20 15 10 5 0 Risk Score Risk Appetite Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Risk Rating (likelihood x consequence): Initial: 4 x 4 = 16 Current: 4 x 4 = 16 Appetite: 1 x 4 = 4 Rationale for risk appetite: By systematically identifying and addressing financial risks, we aim to reduce the likelihood of problems occurring. Controls: (What are we currently doing about the risk?) Mitigating actions: (What more should we do?): Budgets approved by governing bodies. Contracts agreed with all but one key provider, with transformation outcomes explicit Local CCG Finance & Performance committees are scrutinising finance reports and monitor QIPP and investment plans. Risk pooling across the CCG’s in CWHHE is in place. The 5 CCGs have strong plans for 2014/15 and many in year risks have been mitigated by the agreement of contracts with little or no activity related element. However, the focus in year is on transformation of both acute and out of hospital services, through contracts and the Better Care Fund, and delivering this transformation will be critical to ensuring that the underlying surplus at the end of March 2015 is in line with plans and promotes future financial sustainability. This requires whole systems working and is high risk. Assurances: (How do we know if the things we are doing are having an impact?) Governing Bodies receive regular finance reports including investment and QIPP plans. Audit committee receives reports from internal audit on the operation of system controls. Current performance: (With these actions taken, how serious is the problem?) Risk remains high at start of year as arrangements are being put into place. Implement the agreed governance and oversight arrangements with each provider to ensure joint working is delivered June 2014 MDs Increase reporting within the CCGs of the delivery against the contract transformation elements June 2014 OW July 2014 MDs Increase clinical leadership and support to transformation programmes Gaps in assurance: (What additional assurances should we seek?) Need to strengthen the governance links from contract monitoring through committees to the governing body. Additional Comments: NHS England have now asked the CCGs in North West London to increase their surplus by £5, of which £3.1m is for CWHHE. 22 20 CCG: BOARD ASSURANCE FRAMEWORK 23 CCG: BOARD ASSURANCE FRAMEWORK Risk Scoring Matrix (Source – National Patient Safety Agency) Consequence scores Choose the most appropriate domain for the identified risk from the left hand side of the table Then work along the columns in same row to assess the severity of the risk on the scale of 1 to 5 to determine the consequence score, which is the number given at the top of the column. Consequence score (severity levels) and examples of descriptors 1 2 3 4 5 Domains Negligible Minor Moderate Major Catastrophic Impact on the safety of patients, staff or public (physical/ psychological harm) Minimal injury requiring no/minimal intervention or treatment. Minor injury or illness, requiring minor intervention Moderate injury requiring professional intervention Major injury leading to long-term incapacity/disability Incident leading to death Requiring time off work for >3 days Requiring time off work for 4-14 days Requiring time off work for >14 days Multiple permanent injuries or irreversible health effects Increase in length of hospital stay by >15 days An event which impacts on a large number of patients No time off work Increase in length of hospital stay by 1-3 days Increase in length of hospital stay by 4-15 days RIDDOR/agency reportable incident Mismanagement of patient care with longterm effects An event which impacts on a small number of patients Quality/complaint s/ audit Peripheral element of treatment or service suboptimal Overall treatment or service suboptimal Treatment or service has significantly reduced effectiveness Non-compliance with national standards with significant risk to patients if unresolved Totally unacceptable level or quality of treatment/service Formal complaint (stage 1) / Local resolution Formal complaint (stage 2) complaint Multiple complaints/ independent review Gross failure of patient safety if findings not acted on Informal complaint/inquiry Single failure to meet internal standards Local resolution (with potential to go to independent review) Minor implications for patient safety if unresolved Repeated failure to meet internal standards Reduced performance rating if unresolved Major patient safety implications if findings are not acted on Low performance rating Inquest/ombudsman inquiry Critical report Gross failure to meet national standards 24 CCG: BOARD ASSURANCE FRAMEWORK Human resources/ organisational development/staff ing/ competence Statutory duty/ inspections Adverse publicity/ reputation Short-term low staffing level that temporarily reduces service quality (< 1 day) No or minimal impact or breech of guidance/ statutory duty Rumours Potential for public concern Low staffing level that reduces the service quality Late delivery of key objective/ service due to lack of staff Uncertain delivery of key objective/service due to lack of staff Non-delivery of key objective/service due to lack of staff Unsafe staffing level or competence (>1 day) Unsafe staffing level or competence (>5 days) Ongoing unsafe staffing levels or competence / Loss of several key staff Low staff morale / Poor staff attendance for mandatory/key training Loss of key staff /Very low staff morale No staff attending mandatory training /key training on an ongoing basis Breech of statutory legislation Single breech in statutory duty Reduced performance rating if unresolved Challenging external recommendations/ improvement notice Local media coverage – short-term reduction in public confidence Local media coverage – long-term reduction in public confidence No staff attending mandatory/ key training Enforcement action Multiple breeches in statutory duty Multiple breeches in statutory duty Prosecution Improvement notices Complete systems change required Low performance rating Zero performance rating Critical report National media coverage with <3 days service well below reasonable public expectation Severely critical report National media coverage with >3 days service well below reasonable public expectation. MP concerned (questions in the House) Total loss of public confidence Elements of public expectation not being met Business objectives/ projects Finance including claims Service/ business interruption Environmental impact Insignificant cost increase/ schedule slippage Small loss Risk of claim remote Loss/interruption of >1 hour/ Minimal or no impact on the environment <5 per cent over project budget 5–10 per cent over project budget Schedule slippage Schedule slippage Loss of 0.1–0.25 per cent of budget Loss of 0.25–0.5 per cent of budget Claim less than £10,000 Claim(s) between £10,000 and £100,000 Non-compliance with national 10–25 per cent over project budget Incident leading >25 per cent over project budget Schedule slippage Schedule slippage Key objectives not met Uncertain delivery of key objective/Loss of 0.5–1.0 per cent of budget Key objectives not met Non-delivery of key objective/ Loss of >1 per cent of budget Claim(s) between £100,000 and £1 million Failure to meet specification/ slippage Purchasers failing to pay on time Loss of contract / payment by results Loss/interruption of >8 hours Loss/interruption of >1 day Loss/interruption of >1 week Claim(s) >£1 million Permanent loss of service or facility Minor impact on environment Moderate impact on environment Major impact on environment Catastrophic impact on environment 25 CCG: BOARD ASSURANCE FRAMEWORK Table 2 Likelihood score (L) What is the likelihood of the consequence occurring? used whenever it is possible to identify a frequency. The frequency-based score is appropriate in most circumstances and is easier to identify. It should be Likelihood score 1 2 3 4 5 Descriptor Rare Unlikely Possible Likely Almost certain Frequency This will probably never happen/recur Do not expect it to happen/recur but it is possible it may do so Might happen or recur occasionally Will probably happen/recur but it is not a persisting issue Will undoubtedly happen/recur, possibly frequently How often might it/does it happen Table 3 Risk scoring = consequence x likelihood ( C x L ) Likelihood Likelihood score 1 2 3 4 5 Rare Unlikely Possible Likely Almost certain 5 Catastrophic 5 10 15 20 25 4 Major 4 8 12 16 20 3 Moderate 3 6 9 12 15 2 Minor 2 4 6 8 10 1 Negligible 1 2 3 4 5 For grading risk, the scores obtained from the risk matrix are assigned grades as follows 1-3 Low risk 4-6 Moderate risk 8 - 12 High risk 15 - 25 Extreme risk 26