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Claims management policy VOc


									      Claims Management
Policy type: Public Health Wales wide policy
Policy reference number: PHW16
Policy classification: Claims
Author: Cally Hamblyn, Legal Services & Governance Manager, Sharon
Atkins, Corporate Services Manager
Policy lead: Claims Manager
Executive lead: TBC
Date: 04 April 2012                Version: 0c
Publication/ Distribution:
     Public (Internet)
Review Date: TBC
Approval date: TBC
Approving body: Board
Purpose and Summary of Document:
To set out how Public Health Wales intends to manage clinical negligence,
personal injury and losses and compensation claims (excluding those which
fall under the policy for reporting loss or damage of personal property.)
Intended audience: All Staff
Interdependencies with other policies: Information Governance, Risk
Management policy, Incidents and Health and Safety policies
Standards for Health Services in Wales: Standard 23: Dealing with
concerns and managing incidents.
Public Health Wales                  Claims Management policy

Policy consultation circulation list

Group/lead policy circulated to      Date circulated

Information Governance leads         January 2012

Partnership Forum                    04/04/12

Risk Management Group

Health and Safety Group

Staff consultation

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Public Health Wales                               Claims Management policy

Contents Page
1    INTRODUCTION ...................................................................... 4

2    POLICY AIMS AND OBJECTIVES .............................................. 4

3    SCOPE ..................................................................................... 5

4    LEGISLATIVE AND NATIONAL INITIATIVES............................ 5

5    DEFINITIONS ......................................................................... 6

6    TIME LIMITS ........................................................................... 6

7    ROLES AND RESPONSIBILITIES.............................................. 6

8    DELEGATED FINANCIAL LIMITS .............................................. 8

     ARRANGEMENTS ..................................................................... 9

10 NATIONAL PATIENT SAFETY AGENCY ................................... 10

11 CLAIMS MANAGEMENT PROCEDURE ...................................... 11

12 NUISANCE CLAIMS ............................................................... 11

13 USE OF LEGAL ADVISORS ..................................................... 11

14 REPORTING TO THE WELSH RISK POOL ................................ 12

15 REPORTING TO THE WELSH GOVERNMENT ........................... 13

16 DATABASES .......................................................................... 13

   LESSONS LEARNED ............................................................... 14


19 MONITORING AND AUDITING............................................... 16

20 INFORMATION GOVERNANCE ............................................... 16

21 CONTACT INFORMATION ...................................................... 17

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Public Health Wales                     Claims Management policy

1           Introduction
This policy describes the management of clinical negligence claims,
personal injury claims and losses and compensation claims (excluding
those which fall under the policy for reporting loss or damage of personal

Public Health Wales has a legal duty of care towards services users, staff
and members of the general public, who come in to contact with the
services it provides. People who consider they have suffered harm from a
breach of this duty can make a claim for compensation and damages
against Public Health Wales.

Both the human costs of things going wrong and the financial costs of
providing redress are powerful incentives for effective risk management.
Funds spent on addressing and compensating could otherwise contribute
to the continuous improvement of public health services and working
environments. This policy therefore forms an integral part of the Public
Health Wales’ Quality, Safety and Risk Management practices. Learning
from claims can be used to make changes in organisational practice,
thereby reducing risk and improving safety for the future.

A claims management procedure            has    been   developed      to    support
implementation of this policy.

2           Policy aims and objectives
In line with the Civil Procedure Rules 1998, Public Health Wales aims to
manage all claims equitably, fairly and as quickly as possible, dealing with
each claim on its own merits, seeking legal advice and expert advice as

Public Health Wales will make every effort to resolve a claim before the
issue of court proceedings and will explore the option of alternative
dispute resolution methods where appropriate. Where formal legal action
is unavoidable, Public Health Wales will ensure that it conducts its defence
in a fair and timely manner, ensuring that legal costs incurred are
appropriate and proportionate.

The main objectives of this policy are to ensure that:

        There are appropriate reporting structures in place for claims
        Claims made against Public Health Wales are dealt with in a
         proactive and timely manner;

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Public Health Wales                      Claims Management policy

        Evidence is gathered as quickly as possible;
        Where liability is admitted, settlements are negotiated in the
         shortest possible time;
        The Quality and Safety Committee and Board are kept informed of
         key issues in relating to claims;
        Lessons are learned from claims to ensure the continued
         improvement in standards of services.

3           Scope
This policy has been produced for the management of the following:

        Clinical negligence claims
        Personal injury claims
        Losses and compensation claims (excluding those which fall under
         the policy for reporting loss or damage of personal property)

For a claim to be successful, a claimant must prove:

        That he/she was owed a duty of care;
        That the duty was breached;
        That the breach of duty caused, or contributed materially to, the
         damage in question;
        That there were consequences and effects of the damage.

4           Legislative and national initiatives
This policy complies with the following legislation and guidance:

        The Civil Procedure Rules 1998
        WHC(97) 7 – Clinical Negligence and Personal Injury Litigation:
         Structured Settlements
        WHC(97)17 – Clinical Negligence and Personal Injury Litigation:
         Claims Handling
        WHC(98)8 -NHS Indemnity – Arrangements for Handling Clinical
         Negligence Claims against NHS Staff
        WHC(99)128 – Handling Clinical Negligence Claims: Pre-Action
        The Welsh Risk Pool Claims Management Standard (April 2007)
        The Welsh Risk Pool Reimbursement Procedure and other
        Public Health Wales’ Standing Orders and Standing Financial
        NHS (Complaints, Concerns & Redress Arrangements) (Wales
         Regulations 2010).

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5         Definitions
The various Welsh Health Circulars provide             definitions for      clinical
negligence and personal injury as follows:

5.1       Clinical Negligence
“A breach of duty of care by members of the health care professions
employed by NHS bodies or by others consequent on decisions or
judgments made by members of those professions acting in their
professional capacity in the course of employment, and which are
admitted as negligent by the employer or are determined as such through
the legal process.”

5.2       Personal Injury
“Any disease or impairment of a person’s physical or mental condition.”

6         Time limits
In line with the Limitation Act 1980, claims must be made within three
years of the date of the incident or three years from the date a claimant
became aware that he/she had suffered from an episode of negligence.
With minors, the three-year limitation period becomes effective once they
have reached the age of 18. However, there are no time limits for people
with a disability who cannot manage their own affairs. Claims exceeding
the three-year limitation period can, however, still be brought against
Public Health Wales at the discretion of the Court.

7         Roles and responsibilities

7.1       Chief Executive
The Chief Executive has overall responsibility for claims management and
for keeping the Board informed of major developments and significant
issues. The Chief Executive will ensure that there are sufficient resources
to support claims management.

7.2       Divisional Directors
Divisional Directors have delegated responsibility within their divisions for
the implementation of this policy. Directors are responsible for ensuring
that there are appropriate structures and processes in place to allow any

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issues identified and lessons learned from claims to be examined,
addressed, implemented and audited.

7.3       Claims Manager
In line with Welsh Health Circular (97)17, Health Boards and NHS Trusts
must appoint a ‘suitably qualified’ claims manager.

Public Health Wales has a service level agreement in place with Velindre
NHS Trust which provides access to Velindre’s Claims Manager. The Claims
Manager is responsible for the day to day management of claims, for
instructing solicitors and for managing the legal process through to
completion. The Claims Manager will ensure that all members of staff
and/or their line managers involved in a claim are kept informed of the
progress and outcome of the claim.

In order to fulfil the requirements of WHC (97) 17 Public Health Wales will
ensure that the Claims Manager has sufficient seniority and profile. The
Claims Manager will have direct access to the Chief Executive and
Executive Team and other Directors as necessary to achieve the objectives
for effective claims management.

An escalation procedure will be included in the claims management
procedure. This will ensure that all members of staff throughout Public
Health Wales acknowledge the importance of the claims management
process and will provide all necessary support to the furtherance of the
objectives set out in this policy to ensure that claims are managed
proactively, equitably and in an efficient and timely manner.

7.4       Staff
All members of staff are encouraged to report incidents and accidents,
including those that may lead to claims for compensation, in line with
Public Health Wales’ promotion of a fair, blame free culture.

The co-operation of all staff involved in the incident leading to a claim is
crucial to the early collation of information relating to that case. Public
Health Wales will ensure that such staff are encouraged to support the
Claims Manager and any duly appointed legal advisors, in the handling of
that claim. All members of staff are required to fully and openly co-
operate in the assessment, examination and investigation of any legal
claims and must to comply with this policy and the claims management

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Once an incident has been reported, the Claims Manager will establish an
objective account of the original incident at the earliest available
opportunity, taking advice from colleagues where appropriate.

Unless there are exceptional circumstances, any member of staff asked to
do so should provide the Claims Manager with a witness statement and
information regarding the investigation of the relevant claim in a timely

Public Health Wales recognises that providing a statement and giving
evidence can be a stressful experience and will ensure that full support
and guidance is provided to members of staff who are asked to give
evidence on behalf of Public Health Wales.

For further information on the claims process please refer to the Claims
Management procedure.

7.4.1       Health professionals

Public Health Wales will take full responsibility for managing and where
appropriate settling claims in clinical negligence cases meeting all financial
obligations and will not seek to recover any costs from health
professionals save in very exceptional cases, where the health professional
was legally found to be acting outside of his/her remit.

8           Delegated financial limits
Public Health Wales has formal delegated responsibility from the Welsh
Government for the management and settlement of clinical negligence and
personal injury claims valued under £1 million. Thereafter approval must
be sought from the Welsh Government. Public Health Wales must however
ensure that it fulfils the following minimum requirements:

        Adopts a clear policy for the handling of claims which satisfies the
         requirements of WHC(97)17 and any subsequent agreed
         requirements from the Welsh Risk Pool;

        Ensures that the requirements of WHC(97)17 form the basis of the
         procedure for the day to day management of claims;

        Ensures that either an Annex B checklist is completed for every
         settlement authorised by Public Health Wales above £1000 but
         within the delegated limit or Public Health Wales can demonstrate
         that remedial action has been taken and an action plan
         implemented. The Annex B Checklist is contained within the Claims
         Management Procedure.

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8.1         Internal delegated limits
The levels of delegated authority within Public Health Wales are detailed in
the Public Health Wales’ Scheme of Delegation. Details are attached in
Appendix 2.

For significant claims (over the Chief Executive’s delegated limits) where
settlement is advised, Public Health Wales Board will agree the range of
value, which the Chief Executive has discretion to negotiate. All
settlements within the negotiated range will be reported to the next
available meeting of Public Health Wales Board.

8.1.1       Chairperson’s action

There may, occasionally, be circumstances where it is not practicable
to call a meeting of the Board. In these circumstances, the Chair and
the Chief Executive, supported by the Board Secretary, may deal with
the matter on behalf of the Board - after first consulting with at least
two Independent Members. The Board Secretary must ensure that
any such action is formally recorded and reported to the next meeting
of the Board for consideration and ratification.

9           Committee responsibilities and reporting

9.1         Quality and Safety Committee
The role of the Quality and Safety Committee, in the context of claims
management, is to provide assurance to the Board that lessons are
learned from patient safety incidents, complaints and claims. This is
reflected in the Committee’s terms of reference.

The Quality & Safety Committee will receive and review quarterly reports
on the management and status of claims against Public Health Wales.

In line with format specified by WHC (97)17, the claims report will include
the following information:

        Public Health Wales’ claims profile and claims management record;
        The number and aggregate value of claims;
        Key issues and/or major developments affecting Public Health
        Details of any major individual claims;
        Progress and likely outcome of ongoing claims including expected
         settlement dates;

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       Value of claims settled including the expected settlement date;
       Relevant trends i.e. divisional trends;
       Information regarding any proposed remedial action as appropriate.

The chair of the Quality and Safety Committee, along with the Chief
Executive is responsible for keeping the Board informed of significant
issues in relation to claims. The chair of the Quality and Safety Committee
will prepare a quarterly report for the Board, which will include details of
significant claims and any associated issues.

An Annual Claims Report will be produced and received at the Quality and
Safety Committee.

Divisional Directors, members of the Executive Team and Managers will
attend Committee meetings for claims which fall within their portfolio, to
help determine any action necessary.

The reporting requirements relating to the reimbursement process
managed by the Welsh Risk Pool are set out in paragraph 14.

The reporting requirements relating to the Welsh Government are set out
in paragraph 15.

9.2        Audit Committee
Summaries of claims and trends will be provided to the Audit Committee
as requested. The Director of Finance will report the value and incidence
of Losses and Compensation payments to the Audit Committee.

9.3        Risk Management Group
The Risk Management Group reports directly to the Quality and Safety
Group. The Risk Management Group receives quarterly claims reports
from the Claims Manager. The Risk Management Group is responsible for
monitoring and reviewing the management of claims, identifying and
examining any trends and ensuring that action is taken to minimise the
possibility of reoccurrence. The Risk Management Group will monitor
lessons learned and ensure that they are implemented.

10         National Patient Safety Agency
If a claim has been identified as a patient safety incident but was not
previously reported through the incident reporting process, the relevant
section of the claims management procedure should be followed. The
individual with responsibility for risk management within Public Health
Wales should be informed and a retrospective report should be sent to the

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National Patient Safety Agency by the National Reporting and Learning

11        Claims management procedure
Public Health Wales will ensure that a claims management procedure is
developed which supports and embraces the objectives contained in this
policy and WHC(91) 17.

The claims management procedure will detail the processes for the day to
day practical management of claims and associated matters.

The Board delegates the authority for the approval of the claims
management procedure to the Quality and Safety Committee.

12        Nuisance claims
Public Health Wales will not settle claims of doubtful merit, however small,
purely on a ‘nuisance’ value basis. Similarly, claims will not be
inappropriately defended.

The decision to settle a claim will always be based upon an assessment of
Public Health Wales’ legal liability and the risks and costs associated with
the defence of that claim, including the prospects of recovering those
costs in the event that the defence is successful.

13        Use of legal advisors
Public Health Wales will use legal advisors in the defence or settlement of
clinical negligence and significant personal injury claims. Public Health
Wales has access to legal advice via the NHS Wales Legal Services
Framework Contract. Responsibility for the management of clinical
negligence claims remains the responsibility of Legal & Risk Services-
Shared Services Partnership.

Where external legal advice is sought, Public Health Wales will direct its
solicitors in respect of liability admission, defence, settlement and general
tactics. Public Health Wales will however, always take due account of
qualified legal advice in making such decisions.

Legal advice will cover:
    Liability and causation
    An assessment of the strength of the available defence and
      probability of success
    The likely valuation of quantum of damages including best and worst
      case scenarios and

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       Estimates of legal costs for plaintiff and defence

The final decision to settle a claim or to continue with its defence should
be taken by the Board or Chief Executive within the delegated limits.

14         Reporting to the Welsh Risk Pool
The Welsh Risk Pool is a risk pooling scheme run for the benefit of
members of NHS Wales and it is funded by the Welsh Government.

Public Health Wales is assessed annually against the Welsh Risk Pool
Standard for concerns and compensation management. The Claims
Manager is the Lead Officer for the section of the standard relating to
claims (claims which fall outside of redress) and is responsible for self-
assessment against these standards.

Public Health Wales will comply with the various rules and procedures of
the Welsh Risk Pool.

The Claims Manager will report details of claims settled with a quantum of
under £25,000 (excluding claims dealt with under ‘putting things right’
regulations) to the Welsh Risk Pool using the WRP 3 form or such other
format as may be required by the Welsh Risk Pool.

Claims with a quantum in excess of £25,000 will be similarly reported to
notify the Welsh Risk Pool of a potential claim against the pool using the
WRP 2 form or such other format as may be required by the Welsh Risk

In order to be reimbursed by the Welsh Risk Pool, Public Health Wales is
required to submit a WRP 1 form, Costs Schedule, Annex B Checklist and
evidence to demonstrate that the ‘learning from events process’ has
commenced. The organisation must have instigated remedial action within
28 days of conceding liability or agreeing to settle a claim in order to be

Public Health Wales acknowledges that the Welsh Risk Pool will periodically
undertake claims reviews of claims managed by Public Health Wales and
will ensure the co-operation of its members of staff with such reviews
through the development of a formal claims review procedure to be
contained in the Claims Management Procedure.

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15         Reporting to the Welsh Government

15.1.1 Novel, contentious or repercussive Claims

Despite the general approach to delegation, in line with WHC(97)17, all
claims which are “novel, contentious or repercussive” should be referred
to the Welsh Government for approval.

These may include claims involving some unusual and new features which
if not correctly handled, might set an unfortunate precedent for other NHS
litigation, or which appear to represent test cases for a potential class
action, or cases although not formally part of a class action appear to be
very similar in kind to concurrent claims against other NHS bodies. In such
cases, the Claims Manager will contact the Welsh Government for advice
regarding management.

15.1.2 Claims Exceeding the Delegated Authority

The Claims Manager will ensure that any claims with damages estimated
to exceed Public Health Wales’ delegated authority of £1 million are
reported to the Welsh Government and prior approval is obtained in
advance of liability being conceded and the claim being settled.

16         Databases
Public Health Wales has a service level agreement in place with Velindre
NHS Trust for the maintenance of the following databases:

       Datix –The system contains a claims management database and
        contains information prescribed in the claims management

       LaSPaR –The Losses and Special Payments Register (LaSPaR) is a
        computerised database and is used as a finance management tool.
        It was introduced by the Welsh Government to replace previous
        paper based systems with a national standardised format for
        actioning write-offs or special payments approval.

All clinical negligence and personal injury claims will be entered onto both
databases by an authorised member of staff. Other losses and special
payment details will be similarly input.

Public Health Wales will ensure that patient and staff confidentiality is

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17        Links between claims, complaints, incidents
          and lessons learned

17.1      Putting things right - Handling Concerns,
          Complaints and Claims policy
Public Health Wales recognises the need for close connections between
complaints, incidents, claims and other risk related information.

A policy has been developed to provide a mechanism for incidents,
concerns and claims to be dealt with under a single governance
arrangement and meet the requirements of the NHS (Concerns,
Complaints and Redress Arrangements) (Wales) Regulations 2011

The policy establishes a process for the investigation and handling of
concerns, complaints and claims. The outcome of all investigations will be
reviewed through the appropriate forum i.e. by the relevant divisional
management group to ensure that any lapse in action/provision of service
identified during the investigation is acted upon and monitored.

In line with the regulations, Public Health Wales has appointed a Senior
Investigations Manager to oversee the management of concerns and the
investigation process. The investigation process will be the same
regardless of whether the issue is reported as an incident, concern or
claim, but the investigation team will be tailored according to the nature of
the investigation. The Senior Investigations Manager is supported by lead
investigation    managers,      senior   managers      from    the    various
programme/team/service areas and claims manager where the
investigation relates to a claim.

Lessons learned must be identified as part of the investigation process and
remedial actions must be implemented, monitored and evaluated in order
to improve the services provided and seek to avoid such errors recurring.

The Claims Manager will also assist in this process by producing an Annex
B Checklist and an associated action plan for all claims exceeding Public
Health Wales’ excess of £25,000. This will be used as the basis for
learning, monitoring and evaluating the efficacy of actions undertaken as a
result of the lessons learned from claims.

The relevant Divisional Director has responsibility for liaising with
appropriate staff and ensuring any identified and agreed actions are
implemented and monitored.

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17.2       Reporting arrangements
The primary means of ensuring practical linkages between incidents,
complaints, claims and lessons learned will be via regular reporting at the
Risk Management Group.

The Senior Investigations Manager is a member of the Risk Management
Group and is responsible for preparing a combined report on complaints,
claims, risks and incidents for the Risk Management Group for the purpose
of identifying any trends and remedial action necessary. The Claims
Manager will provide the information for the claims section of the report.
Where appropriate, this information will be shared throughout the

17.2.1 Reporting to the Claims Manager

Adverse incidents or outcomes which could lead to a claim for negligence
must also be identified and reported to the Claims Manager as soon as
they occur, along with the following information:

       Details of the potential claimant;
       Date and details of incident/outcome from which the claim might
       Names and contact details of relevant members of staff involved in
        or witnessing the incident;
       Statements by such relevant members of staff and witnesses;
       Relevant documentation.

The     Claims     Manager,     Senior    Investigations   Manager      and
concerns/investigation leads within divisions will work together to identify
complaints which involve potential breaches of the legal duty of care by
Public Health Wales. An appropriate joint investigation will be undertaken
to enable Public Health Wales adopt a pro-active stance to the
management and resolution of potential claims identified through the
‘putting things right’ process.

The Risk Management Group or Executive Director will direct the nature
and involvement of the Claims Manager in any subsequent investigation of
an incident or reported concern which may involve a potential breach of
the legal duty of care by Public Health Wales.

The DATIX system identifies where a potential claim has previously been
reported as an incident or complaint. This facilitates the gathering of
information to comply with the relevant Pre-Action Protocols.

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18        Training and/or Communication with Staff
Public Health Wales will ensure that the staff involved in the management
of claims will have access to appropriate and ongoing training at a level
appropriate to their role and responsibilities in accordance with the Welsh
Risk Pool Standard for concerns, compensation and claims.

19        Monitoring and auditing
Internal Audit will undertake a review of a sample of claims where
reimbursement was sought from the Welsh Risk Pool on an annual basis to
monitor compliance with the Welsh Risk Pool reimbursement rules.

The effectiveness of the policy will be reviewed on an annual basis by
internal and external audit undertaken by the Welsh Risk Pool, in relation
to claims management and the compliance with the Welsh Risk Pool
reimbursement rules.

The Quality and Safety Committee will monitor the claims performance
through receipt of the Audit Performance and compliance with key
performance indicators which is reported in the claims report submitted to
the Committee.

The Claims Manager will also provide an annual claims report which will
include audit compliance and performance and identify themes and trends
for the period of the report. This report will be received by the Quality and
Safety Committee in approximately July each year.

20        Information Governance
This policy has the potential to deal with extremely sensitive information
and Public Health Wales staff involved in any claim need to be fully aware
of the material they are handling. The preferred method of information
exchange should be via the Royal Mail or via the internal mail system,
however in exceptional circumstances and due to time constraints the use
of password protected emails is permitted.

Any sensitive materials/documents that form part of the claim should be
transported in a secure manner to ensure maintenance of confidentiality
and minimise risk of loss and the following security measures should be
    1. Documents should be sent by recorded delivery post with double
       enveloped contents.
    2. Documentation for the claim should be viewed on a “need to know

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   3. All documents should be stored in the appropriate secured storage
      facilities and destroyed confidentially in accordance with Public
      Health Wales retention and destruction guidelines.
   4. Use of e-mail to transmit documentation relating to a claim is
      permitted provided that appropriate security measures are taken. E-
      mails sent within the NHS Wales network are deemed reasonably
      secure, however this is not true of any external (non NHS) email
      system and the appropriate extra security measures must be taken
      i.e. password protection. Though it should be noted that some E-
      mail systems will block password protected emails, therefore
      confirmation of receipt must be confirmed.
   5. Information and passwords must be sent in separate emails if extra
      security measures are deemed necessary.
   6. With all email systems the sender must however check that the
      recipient is correctly addressed.
   7. Emails can be used to arrange meetings, although careful wording of
      the appointment and who can see the calendar must be considered.

21        Contact information

The Claims Manager at Velindre NHS Trust can be contacted at:

Unit 2, Charnwood Court,
Parc Nantgarw, Cardiff,
CF15 7QZ

Telphone number: 02920 196161 (Velindre Trust HQ)

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Reporting framework                                                Appendix 1

                            Public Health Wales Board

                                                                       Chief Executive
    Audit Committee            Quality & Safety

                              Risk Management Group                   Claims Manager

      Director of
   Finance (reports
      losses and
    compensation                 Health & Safety           Infection Control and
        claims)                      Group                 Clinical Safety Group

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Scheme of Delegation                               Appendix 2

Approving individual        losses   and Delegated authority
special payment claims

    Up to £1,000 (for disbursements Claims Manager

    Up to £500,000                          Chief Executive

    £500,000 up to £1 million               Public Health Wales Board

  Over £1 million                           Welsh Government

These limits relate to damages
and/or costs payable

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                                                                Appendix 3

Report Requirements under WHC(97)17

 Item                               Location
 Number of claims                    Number of new claims received for
                                      the relevant period set out in
                                      Quarterly reports
                                     Cumulative number of ongoing
                                      claims included in Quarterly report

 Aggregate value of claims in               Set out in Appendix to
 progress                                    Quarterly report
 Details of any major individual            Set out in the body of the
 claims                                      Quarterly report
 Progress and likely outcome of             Set out in Appendix to
 ongoing claims including                    Quarterly report as ‘Stage of
 expected settlement date                    Claims’ & ‘Expected Settlement

 Value of claims settled and                Set out in Appendix to
 final outcomes                              Quarterly report

 Trends of                                  Set out in the body of the
 specialities/departments/indi               Quarterly report
 viduals involved

 Proposals regarding remedial               Set out examples in the body
 action arising out of claims                of the Quarterly report
 There are reports on claims to             Set out in the body of the
 the Board or duly authorised                Quarterly report
 committee by the designated
 Board member, advising of
 key    issues   and/or    major            Included a section in the report
 issues     or    developments               on Key Issues in Claims and
 affecting the organisation                  where there are none, it is
                                             reported as such

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