The Burden of Bureaucracy

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							The Burden of
Bureaucracy
Standards for Better Health and
the NHSLA Risk management
Standards for Acute Trusts – a
duplicated process?
NHSLA Risk Management
Standards for Acute Trusts (previously
CNST and RPST)

   A „three tier‟ assessment process to assure Trusts and
    external stakeholders that clinical and a proportion* of
    non clinical risk is being managed appropriately by the
    organisation. Safety and Financial benefits to
    achievement.
   Achievement dependant on external assessment
   Assessment schedule dependant on level of
    achievement


       * Finance and performance covered by other assessments.
Standards for Better Health
   Component part of the Annual Health Check,
    examines in detail the management of aspects
    of clinical and non clinical risk.
   Annual process based on self assessment and
    „spot check‟ review
   „Ratings‟ benefits to Trusts
   More public process
Overlap


 NHSLA Standards part of cross checking
  process for Healthcare Commission
 Duplicate submission still required
Standar


NHSLA Standards
   d                    1                         2                             3                       4                         5
   
Criterio
                                         Competent &                        Safe                     Clinical            Learning from
   n             Governance
                                       Capable Workforce                Environment                   Care                Experience
   
   1       Risk management            Corporate induction         Secure environment       Patient identification    Incident reporting
           strategy
   2       Policy on procedural       Local induction of          Child protection         Patient information       Raising concerns
           documents                  permanent staff
   3       Risk management            Local induction of          Vulnerable adults        Consent                   Complaints
           committee(s)               temporary staff
   4       Risk awareness training    Supervision of medical      Moving & handling        Clinical record-keeping   Claims
           for senior management      staff in training                                    standards
   5       Risk management            Risk management             Slips, trips & falls     Transfer of patients      Investigations
           process                    training
   6       Risk register              Training needs analysis     Inoculation incidents    Medicines management      Analysis
   7       Responding to external     Medical devices training    Maintenance of medical   Blood transfusion         Improvement
           recommendations specific                               devices & equipment
           to the organisation
   8       Clinical records           Hand hygiene training       Harassment & bullying    Resuscitation             Best practice - NICE,
           management                                                                                                NCEs & national
                                                                                                                     guidance
   9       Professional clinical      Moving & handling           Violence & aggression    Infection control         Best practice - NSFs &
           registration               training                                                                       high level enquiries
  10       Employment checks          Supporting staff involved   Stress                   Discharge of patients     Being open
                                      in an incident, complaint
                                      or claim


                                                       TOTAL 50 STANDARDS
Standards for Better Health
 Domain 1 – Safety (9 Core + 1 Dev.)
 Domain 2 – Clinical Cost Effectiveness (5
  Core + 1Dev.)
 Domain 3 – Governance (14 Core + 5
  Dev.)
 Domain 4 – Patient Focus (9 Core + 3
  Dev.)
Standards cont.
   Domain 5 – Accessible and Responsive Care (3
    Core + 1 Dev.)
   Domain 6 – Environment and Amenities (3 Core
    1 Dev.)
   Domain 7 – Public Health (4 Core + 1 Dev.)

     TOTAL   60 STANDARDS
Standards for Better Health - assurance
DATE                                          19 February 2007

DOMAIN                                        Safety

CORE / DEVELOPMENTAL STANDARD                 NO.       DETAIL
                                              C4d       Element 1:
                                                        The Healthcare organisation has systems in place to ensure that medicines are
                                                        handled safely and securely, taking into account Building a safer NHS: improving
                                                        medication safety [Department of Health, 2004], and in accordance with the statutory
                                                        requirements of the Medicines Act 1968.
                                                        Element 2:
                                                        The healthcare organisation has systems in place to ensure that controlled drugs are
                                                        managed in accordance with the Misuse of Drugs Act 1971, the Misuse of Drugs Act
                                                        1971 (Modification) Order 2001 and Safer Management of Controlled Drugs: Guidance
                                                        on strengthened governance arrangements [Department of Health, 2006]


LEAD EXECUTIVE DIRECTOR                       Martin Hodgson

LEAD MANAGER                                  Richard Hey & Alastair Gibson

CURRENT POSITION                              Element 1: Compliant
                                              Element 2:Planned compliance by 31st March 2007

FORCAST POSITION                              Compliant

ASSURANCE REPORT

This Standard has been modified for 2006/7.
Element 1 remains unchanged and the Trust remains compliant.
Element 2 introduces additional governance requirements around the safer management of controlled drugs following the recommendations of the
Shipman inquiry. Final DoH guidance was published in January 2007 and the Trust is undertaking a self-audit against the guidance to assure
compliance. Once complete it is expected the Trust will be able to indicate compliance in readiness for the Healthcare Commission commencing full
assessment of Trusts from 1st April 2007.
Continued

•   EVIDENCE
•   See attached index of evidence, which is under review following modification of this standard.

•   DETAIL                              LOCATION
•   See attached index of evidence.     Director of Pharmacy Office – MRI / BH


•   AUDIT DETAIL                        See attached index of evidence

•   SIGNED


•   LEAD EXEC DIRECTOR                              LEAD MANAGER                              PEER REVIEWER
•   Martin Hodgson                      Richard Hey & Alastair Gibson                         Richard Hey &
                                                                                              Alastair Gibson
Description of Evidence                                                                                          In portfolio         Ref #
Assurance Report - Standard C4d                                                                                                      01
Healthcare Commission – Inspection guide C4d                                                                                         02
Index of Evidence cont:



Background to Pharmacy Services
Director of Pharmacy Job Description                                                                                                 03
Central & Children’s Pharmacy Organisation Charts                                                                                    04




“The healthcare organisation should have clearly defined processes for obtaining medication, and should ensure staff, including prescribers, are
      confident and competent in their handling of medicines”
Clinical Mandatory Training – Medicines Management session                                                                           05
Trust wide Medicines policy (index only included)                                                                                    05
Unlicensed Medicines policy and procedures                                                                                           06
Application for new medicines policies and procedures                                                                                07
Medicines Management Committee – Terms of Reference, membership and recent Agenda and                                                08
     minutes.
Medicines Clinical Guidelines web page                                                                                               09
Clinical Trials Pharmacist & Senior Technician Job Descriptions                                                                      10


                          Evidence Documents
Pharmacy staff induction programme
Pharmacy staff training programmes (various examples e.g. Aseptics, Ward Based Techs)
                                                                                                                 
                                                                                                                 
                                                                                                                                      11
                                                                                                                                      12
Pharmacy SOP’s                                                                                                                       13
Chemotherapy policy (adults & children’s) (Front page & index)                                                                       14
Intrathecal Chemotherapy Policy, registers and training records (held in aseptic services office)                                    15
Duplication / Direct Overlaps
Incident reporting
   SfBH                                  NHSLA
       C1a – Health care                     1.5.1 The organisation has
        organisations protect                  approved documentation
        patients through systems               which describes the
        that identify and learn from           process for managing the
        all patient safety incidents           risks associated with the
        and other reportable                   reporting of all internally
        incidents, and make                    and externally reportable
        improvements in practice               incidents.
        based on local and national           1.5.6 Analysis
        experience and information            1.5.7 Improvement
        derived from the analysis of
        incidents.
Child Protection
   SfBH                          NHSLA
     C2 Health care                1.3.2The organisation
     organisations protect           has approved
     children by following           documentation which
     national child                  describes the process
     protection guidance             for managing the risks
     within their own                associated with child
     activities and in their         protection
     dealings with other
     organisations.
Best Practice
   SfBH                                  NHSLA
     C3 Health care organisations            1.5.8 The organisation has
      protect patients by following            approved documentation
      NICE Interventional                      which describes the process
      Procedures guidance.                     for ensuring that agreed best
     C5a Health care                          practice as defined in NICE
      organisations ensure that they           clinical guidelines, national
      conform to NICE technology               confidential enquiries and
      appraisals and, where it is              other nationally agreed
      available, take into account             guidance is taken into account
      nationally agreed guidance               in the context of the clinical
      when planning and delivering             services provided by the
      treatment and care;                      organisation.
Infection Control
   SfBH                                     NHSLA
       C4a Health care organisations          1.2.8 The organisation has
        keep patients, staff and                approved documentation
        visitors safe by having                 which describes the process
        systems to ensure that the risk         for ensuring the delivery of
        of health care acquired                 effective hand hygiene training
        infection to patients is                for all relevant permanent staff
        reduced, with particular                groups.
        emphasis on high standards of          1.4.8 The organisation has
        hygiene and cleanliness,                approved documentation
        achieving year-on-year                  which describes the process
        reductions in MRSA;                     for managing the risks
                                                associated with infection
                                                prevention and control.
28 Further overlaps
   C4b Medical Devices        1.2.7/1.3.7 Medical
                                Devices
   C4d Medicines              1.4.6 Medicines
    Management                  Management
   D1 Patient Safety and      1.4.5 Transfer, Standard
    Transfer                    5 1-10 Patient Safety


   C5b Supervision and        1.2.4 Supervision of
    Leadership                  Medical staff in training
28 Further overlaps
   C5c Update of skills       Standard 2 1-10,
                                Competent and
                                Capable Workforce
   C5d Clinical Audit         All NHSLA Standards
                                at Level 2
                               1.4.5 Transfer of
   C6 Co-operation with        patients, 1.4.10
    partner organisations       Discharge of patients
28 Further overlaps
   D2a NICE / NSF          1.5.8 NICE, NCEs
    planned care, D2d        and National
    Evidence based           Guidance, 1.5.9 NSFs
    practice                 and high level
                             enquiries
   C7a Sound Clinical      Standard 1, 1-10,
    and Corporate            Governance
    Governance
28 Further overlaps
   C7c Risk        1.1.1 Risk
    Management       Management Strategy
                     1.1.3 Risk
                     Committees
                     1.1.5 Risk Process
                     1.1.6 Risk Register
28 Further overlaps
   C7e Equality and      1.3.8 Harassment and
    human rights           Bullying
   C8a Raising           1.5.2 Raising
    Concerns               Concerns
   C9 Management of      1.1.8 Clinical records
    Records                Management, 1.4.4
                           Clinical Record
                           keeping Standards
28 Further overlaps
   C10a Employment            1.1.10 Employment
    Checks                      Checks
   C11a Staff Recruited,      1.1.9 Professional
    Trained and Qualified       Registration, 1.1.10
                                Employment Checks
   C11c Further               1.2.6 Training Needs
    Professional                Analysis
    development
28 Further overlaps
   C11b Mandatory Training      1.2.1 Corporate Induction
    Program                       1.2.3 Local Induction
                                  1.2.6 Training Needs
                                  Analysis
                                  1.2.8 Hand Hygiene
                                  Training
                                  1.2.9 Moving and
                                  Handling training
28 Further overlaps
   C13b Consent                 1.4.3 Consent
   C14a Complaints              1.5.3 Complaints
    C14b Discrimination
    Following Complaints
   C14c Acting on Concerns      1.5.7 Improvement
   C16 Information
                                 1.4.2 Patient Information
   C20a Safe and Secure         1.3.1 Secure
    Environment                   Environment
    Aims of the NHSLA Standards
   The standards and assessment process are designed to:
       provide a structured framework within which to focus effective risk
        management activities in order to deliver quality improvements in
        organisational governance, patient care and the safety of patients,
        staff, contractors, volunteers and visitors
       increase awareness and encourage implementation of the national
        agenda for the NHS
       encourage and support organisations in taking a proactive
        approach to improvement
       reflect risk exposure and empower organisations to determine how
        to manage their own risks
       contribute to embedding risk management into the organisation's
        culture
       reduce the level of claims by reducing the number of incidents and
        the likelihood of recurrence
       assist in the management of adverse incidents and claims
       provide assurance to the organisation, other inspecting bodies and
        stakeholders, including patients.
Aim of the Annual Health Check
   The aim of the annual health check is to
    promote improvements in healthcare for
    patients and the public. It replaces the old
    system of 'star ratings' and looks at a
    much broader range of issues than ever
    before.
Solution
              Agree areas for
               regulation
              Agree evidence formats
              Assess each area once
              Share information
              Evaluate within realistic
               timescales
What do we want?
                 Maintain system of
                  regulation / accreditation
                  – but streamline it.
                 Allow Trusts the time to
                  complete the
                  developmental work
                  required to demonstrate
                  progression by reducing
                  the administrative burden
                  of regulation.

                 Questions?

						
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