Connecting Local Health and Social Care Services Appendix B Core Care Links Ltd Incident Reporting Policy Any locally held old paper copies must be destroyed. When this document is viewed as a paper copy, the reader is responsible for checking that it is the most current version. This can be checked on Core Care Links website Date Agreed at Directors Meeting: 2nd January 2013 To be reviewed: November 2013 Core Care Links Incident Reporting Policy – November 2012 Document Reference No: CCL –IR-2012 Version 1 Lead Director: Dr Martin Clausen Director Lead - Governance, Compliance and Complaints. Author: Anna Morgan Manager – Core Care Links Ltd First Version Issued On: TBC Review Date: November 2013 (To be reviewed annually) Approved By: CCL Directors Date: 2nd January 2013 Target Audience: All staff working for or on behalf of Core Care Links Dissemination: CCL Website (staff Section) Email to all Staff CCL Incident Reporting Policy November 2012 CORE CARE LINKS INCIDENT AND ACCIDENT REPORTING POLICY 1. INTRODUCTION As part of Core Care Links Ltd (CCL) commitment to the management of risk and to improve the quality of care provided, an organisation-wide incident reporting system for reporting incidents or accidents is in operation. This is an essential element of CCLs Risk Management Strategy and its effectiveness depends upon the cooperation and involvement of all staff working for and on behalf of CCL. If used effectively the incident reporting system provides an 'early warning' of actual and potential claims, complaints, or adverse publicity and means the CCL is prepared for such an occurrence. It strengthens the CCL’s position in the event of litigation by enabling CCL to obtain the necessary information at the time of the incident when memories are fresh. Where actual incidents of loss or harm have occurred, it enables early notification and explanation to the 'injured' party to occur and, where necessary, swift compensation to the justified claimant. The purpose of incident reporting is to ensure all accidents or incidents (actual and potential) are recorded, reported and managed. This enables the CCL to learn lessons from mistakes made and take prompt action to prevent and minimise recurrence. It enhances CCL’s ability to continually develop good practice and improve the quality of care. It also protects the individual: patients, staff, contractors, volunteers and visitors through the provision of a safer environment. The incident reporting system also sets out the procedure to be followed to ensure that sufficient information is obtained to meet statutory reporting requirement. 2. FAIR AND EQUITABLE CULTURE Fear from disciplinary hearing and subsequent sanctions may deter staff from reporting incidents. CCL's incident reporting system has therefore been developed within a culture of 'fairness and equity'. Where errors have occurred and are openly reported, an investigation into the facts may take place but the disciplinary process will not be instigated against any member of staff except in well defined circumstances as follows: An incident which is a fundamental breach of professional practice; An incident which might lead any professional registration body to review the individual's professional status; Further occurrences of an incident where the individual has previously received counselling relating to rectifying the type of error that might have led to the incident; Where an incident has led to criminal actions involving the police or a registration or regulatory body with statutory powers; Failure or significant delay in reporting an incident in which a member of staff was directly involved or about which they were aware. CCL Incident Reporting Policy November 2012 This recognises the fact that most errors are made because of a system failure and the purpose of incident reporting is to improve the system. It should be noted that when any error is being considered, whether within the Incident/Accident Reporting Policy structure or not, it is universally recognised that when a member of staff is open in admitting to the error and reporting it to the appropriate individual, a considerably more positive and supportive approach may be taken by CCL in addressing the matter. Conversely, it is also the case that when a member of staff decides to either delay reporting, or to attempt to conceal the occurrence of an error, CCL’s response to it is likely to be less favourable and will indeed specifically address this delay or failure to report as a further element of the issue. 3. FIRST ACTIONS Timescales for reporting are detailed within this Policy as are how to report an Incident/Accident. The first action of staff must be to ensure the immediate safety of the situation that caused the incident/accident. The action required is obviously dependent on the individual occurrence but, as a general rule, the area must be made safe. Advice can be sought from the Operational Supervisor on call on 07535 650873. Patients, the public and service users must be kept informed on any issues that may endanger their safety. Any remedial action taken by staff should be documented on the incident report, as should any discussions with patients or relatives. If an incident occurs because of malfunctioning equipment, this should be removed and consideration given to the probability of the incident reoccurring either with this piece of equipment or others in use at other premises. Any faulty equipment should be reported to CCLs Operational Supervisor. Staff must ensure that any witness statements are taken and their details recorded on the Incident/Accident report. 4. WHAT TO REPORT Staff must report all incidents, accidents, concerns or potential (i.e. ‘near miss’) incidents that have or could adversely affect the individual(s) involved (i.e. lead to loss, harm or damage), lead to dissatisfaction or further action and ultimately loss to the CCL’s reputation and assets. This applies whether the ‘affected’ person is a patient, member of staff, contractor or visitor to CCL. The following 'trigger list' has been developed as a guide to the type of incident that should be reported. The list, however, is not exhaustive: Failure or delay in referring or admitting to hospital or delay in providing treatment Failure or delay in diagnosis, incorrect diagnosis, incorrect treatment Treatment problems, allergic reactions, unexpected complications, unexpected death Failure of follow-up arrangements Failure to act on abnormal test results Slips, Trips and Falls Medication errors, immunisation or vaccination errors CCL Incident Reporting Policy November 2012 Consent issues Medical records problems Infection control issues Lack of adequate facilities/equipment/resources (including staffing levels) Medical and Non Medical Equipment malfunction Security - theft, vandalism, violent and abusive behaviour, including verbal abuse Accident with or without injury Needle stick injury Administrative errors such as unreadable handwriting In addition, events will often occur which are unexpected. These events are usually not related to negligence but may be viewed as such by the patient or their relatives. To the doctor or healthcare professional the unexpected event may be a recognised complication of a particular treatment. Given the potential for dissatisfaction, such events should also be reported. It should be stressed, however, that this list is not exhaustive. An element of judgement is, therefore, required as to whether an incident should be reported but where doubt exists the safest option will be to report the incident. Advice can also be sought from the Operational Supervisor. The completion of an Incident/Accident report does not constitute an admission of liability, either on the part of the person making the report or any other individual involved. It is important, however, that only the facts pertaining to the incident and not opinions are recorded. NOTE: Anonymous reporting is viewed as the exception rather than the rule as it can often prohibit a thorough or adequate investigation but would be acceptable if the incident would not otherwise be reported. All incidents/accidents relating to patient safety are reported to the National Patient Safety Agency (NPSA) via the National Reporting and Learning System (NRLS). This is undertaken via the NPSA website by CCL Management. There are certain incidents that must also be reported to the regulator of NHS services (Care Quality Commission). This is also done by CCL management, therefore all staff have a duty to report an incident or accident as per Section 5 of this policy without delay. 4.1 Being open - communicating patient safety incidents with patients and their carers Communicating honestly and sympathetically with patients and their families when things go wrong is a vital component in dealing effectively with errors or mistakes in their care. The NPSA’s Being Open policy is part of a national drive to help healthcare staff with this difficult task. The principles of Being Open are: Acknowledgement Truthfulness, timeliness and clarity of communication Apology Recognising patients and carer expectations Professional support Risk management systems and improvement CCL Incident Reporting Policy November 2012 Multidisciplinary responsibility Clinical Governance Confidentiality Continuity of care Comprehensive guidance can be found at: http://www.nrls.npsa.nhs.uk/resources/?entryid45=65077 Being Open Framework 4.2 Serious Incidents (SI) A SI may be defined as an incident where a patient, member of staff, or member of the public has suffered serious injury, major permanent harm, or unexpected death or where there is cluster/pattern of incidents or actions by staff which have caused or are likely to cause significant public concern. ‘Near misses’ may also constitute Serious Incidents, where the contributory causes are serious and under different circumstances they may have led to serious injury, major permanent harm, or unexpected death, but no actual harm resulted on that occasion. A possible example is that of a system failure, the result of which is incorrect/delayed diagnosis. This may not have any serious consequences for some patients, but for others could lead to the wrong treatment/serious delay in treatment and ultimately to death. For more information on how to report an SI, please speak to CCLs Operational Supervisor. 4.3 RIDDOR Incidents Under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR), the CCL has a responsibility to report to the Health and Safety Executive (HSE) certain incidents or accidents that occur. Early notification of accidents or incidents means that the CCL is able to comply with RIDDOR requirements. Cases of over-three day injuries must be notified within ten days of the incident occurring to the HSE. This also includes where a member of staff is unable to perform their full range of duties after a three-day period. Staff must indicate RIDDOR-reportable incidents when completing the Incident/Accident report form Duties for the CCL as an employer As an employer, CCL must report any work-related deaths, injuries, cases of disease, or near misses involving its employees wherever they are working. If you are an employee If you are a member of CCL staff or work on behalf of CCL and have been injured at work, seen a dangerous occurrence, or your doctor has certified that you have a work related reportable disease, you must complete an Incident/Accident report form. CCL Incident Reporting Policy November 2012 4.4 IT Security Incidents In accordance with the Care Trust Plus’ IT Security Policy, and CCLs Confidentiality Policy, which aims to ensure that security requirements and the requirements of the Data Protection Act are met, all breaches or potential breaches of security on IT and related systems should be reported to the Operational Supervisor immediately and reported via an Incident/Accident reporting form including immediate actions taken. This will allow for identification of trends in incidents. 4.5 Violence, Abuse and Harassment Any incidents or near misses that involve violence, abuse or harassment should be report via the standard Incident Reporting Form. In addition, a Violence, Abuse and Harassment form should be completed (Appendix B). 4.6 Fraud Where an incident involves or suspected involvement of fraud, advice should be sought from the Care Trust Plus’s Local Counter Fraud Specialist (LCFS) (contact details available via the CTPs Intranet). All incidents of actual or suspected fraud must be reported via an Incident/Accident report form. CCL will ensure that the LCFS is informed. 4.7 Safeguarding All incidents, when initially reported as well as when reviewed by ccl should always consider that they may be an element of adult or children’s safeguarding that requires specific input during the incident reporting and Investigation. If a member of staff suspects a safeguarding issue, or wishes to raise this for specialised safeguarding review and input, s/he must make this clear on the incident reporting form. This will prompt CCL to engaged the relevant safeguarding lead, who will state whether the safeguarding review process is necessary for this incident or not. 4.8 External reporting As per Section 4.0 all clinical incidents must be reported to the National Patient Safety Agency and should be reported by clinical areas via the incident reporting form without delay. This includes incidents such as safeguarding allegations and any serious incidents. Disruption to registered provider services for more than one day must also be reported directly to the Care Quality Commission and should be notified via the incident reporting form without delay. 5. HOW TO REPORT AN INCIDENT OR ACCIDENT The CCL has adopted a universal process for the reporting and recording of all incidents including ‘near misses’. Incidents and Accidents are logged and reported on the Incident Reporting form (Appendix A) which is available to all staff via CCLs Website. CCL Incident Reporting Policy November 2012 All staff must use this form to report incidents. Completed forms must be forwarded to CCLs Operational Supervisor (Sophie.cooper4@nhs.net) immediately. In the first instance, incidents and accidents should be reported within one day of the incident. If the incident/accident has led to death or serious injury, the incident must be reported immediately and the person reporting the incident should follow this up with a telephone call to the Director for Governance, Compliance and Complaints. If neither is available, one of the other Directors should be contacted. Such incidents may be classified as Serious Incidents and require immediate and more detailed investigation. 6. INVESTIGATION OF INCIDENTS Unless the causes of adverse incidents are properly understood, lessons will not be learnt and suitable improvements will not be made to secure a reduction in the risk of harm to future patients, staff and visitors. However, not all incidents need to be investigated to the same extent or depth. In the majority of instances, incidents will be minor or near miss and the cause of the incident will be clear and it will be the responsibility of CCL Operational Supervisor to ensure that the appropriate remedial action is taken to ensure, as far as possible, there is no recurrence. Incidents will be routinely discussed at Team meetings to review the outcome and learning from the events. Health and Safety and Waste Management Incidents and Accidents For Incidents in relation to Health and Safety or waste management, the Correctable Cause Analysis should be completed and appropriate action taken to address the cause of the incident. If further advice is needed on assessing or addressing Health and Safety or Waste Management incidents, further advice can be sought via CCLs Operational Supervisor. 7. Learning the Lessons Follow-up and ‘closing the loop’ following incidents is a key requirement of the incident reporting process. Without learning and change arising from incidents, aggregate review and wider experiences, the quality of care provided to patients and the safety of staff, patients and visitors will not improve. As indicated above, in the majority of instances, incidents will be minor or near miss and the appropriate remedial action can be taken at the time the incident occurs. Where relevant, following more serious incidents, an action plan will need to be prepared and shared with the relevant staff. Where training is part of an action plan it should be appropriate, identify competencies to be achieved and evaluated. There should be a clear indication of how training will be continued and developed in the future. 8. MONITORING AND AUDIT Incident and accidents are monitored by the Directors and Management of CCL to ensure appropriate reporting and actions are being taken. Individual reports are also discussed on a monthly basis with the Care Trust Plus. CCL Incident Reporting Policy November 2012 APPENDIX A INCIDENT / ACCIDENT FORM Please note that facts, not opinions should be recorded. All entries will be treated in the strictest confidence What is it You Wish to Report? Near miss Actual incident / Accident Incident Type Affecting Patient/Service user Core Care Links Concern Staff Other Organisation Visitor / Member of public Contractors / Sub Contractors Person Affected Surname: First Name: Address: Contact Number: Date of Birth: Work Email: IF PATIENT/SERVICE USER ID number e.g. SWIFT / NHS No: Details of Incident Date of Incident: Time of Incident: Type of Location (Please enter the type of location where the incident/accident occurred or is thought to have occurred) i.e. Hospital, Pt / Service User Home Exact location (Please enter the exact location where the incident/accident occurred or is thought to have occurred) i.e. Ward 6, Description of incident: Immediate Actions Taken Did the Incident / Accident involve Medication Medication Incident Details Administration / Supply of medicine from a Clinical area Preparation of medicines dispensing in pharmacy Equipment Violence (please fill out Appendix A) Advice Monitoring / follow up of medicine use Prescribing Supply or use of over the counter medicine Medical & Non Medical Equipment Did faulty equipment play a part in this incident? Yes If yes: Product Type: Serial Number: Description of Device CCL Incident Reporting Policy November 2012 No Brand Name: Manufacturer: Have you notified anyone of the equipment shortfall/failure? *Yes No *If yes, who: Details of Injury Was the individual affected injured by the incident? *Yes No *If yes: Description of the injury: i.e. Allergic Reaction Body part affected: Left Leg, Sacrum Was a staff member off sick due to the incident? *If yes, please specify the number of days: Was the injured person taken to hospital? Yes *Yes No No Treatment Received None 999 Called Referred to Dr on site Referred to Nurse on site Assessed & Treated Referred to Occupational Health First Aid On Sick Leave Referred to A&E dept Referred to own GP Treatment Given Other Description of treatment: People Involved Person Affected Surname: Witness Other Contact First Name: Date of Birth: Address: Assailant Contact Number: IF PATIENT/SERVICE USER ID number e.g. SWIFT / NHS No: Person Affected Surname: Witness Other Contact First Name: Date of Birth: Address: Assailant Contact Number: IF PATIENT/SERVICE USER ID number e.g. SWIFT / NHS No: Person Reporting/Filling in this Form Surname: First name: Job Title: Directorate/Department: Address: (if staff work base) Contact number: (if staff work number) Date reported: Signature: Incident notified to: Patient/Service User *If other please specify: Next of kin Manager *Other Completed forms should be sent to Sophie Cooper, Operational Supervisor (Sophie.cooper4@nhs.net) / 07535 650873 CCL Incident Reporting Policy November 2012 Violence/Abuse/Harassment - Incident / Accident Appendix A Please note that facts, not opinions should be recorded. All entries will be treated in the strictest confidence. Details of Assailant/Aggressor: Full Name: Gender: M / F Type of Incident (Please tick the classification box (es) which most closely resembles the incident) Verbal Abuse / Assault Criminal Damage Attempted Assault Actual Physical Assault Robbery Theft Racial Abuse Sexual Offence Contributory Factors (Please tick the contributory factors box (es) which most closely resembles the incident) Drugs/Alcohol Angry during 1:1 counselling/interview Argument with another client/patient Disagreement about care programme *If other, please specify: Objecting to personal care given Objecting to taking medication Response to staff requests Response to staff restraining Persecutory delusions In pain (physical) Attempting to leave Confused state Command hallucinations In/out of seclusion Burglary Other Action Taken Successful de-escalation Restraint – escorted/assisted (standing) Given Rapid Tranquilisation Seclusion Restraint – full restraint (on floor, or knees or force used) Completed forms should be sent to Sophie Cooper, Operational Supervisor (Sophie.cooper4@nhs.net) / 07535 650873 Feedback Section Name of Reporter Name of Line Manager CCL Incident Reporting Policy November 2012