What happens when things go wrong with an independent provider operating in your CCG patch where CCG itself has no contracts with the provider?
What if the provider, offering an extremely specialist service for vulnerable people from across the country, gets rated by the CQC as having serious quality concerns and the regulator shares their concerns with the local authority and the CCG? What if these concerns identify multiple inspection areas that were inadequate or required improvement leading to the closure of the provision and the transfer of patients?
In the case of NHS Coventry and Rugby CCG and NHS Warwickshire North CCGs quality team you develop a Geographical Hosting Policy that sets out actions and responsibilities for all players in the process.
The policy sets out a process to engage with colleagues both locally and nationally. The quality team take the view that “If you’re on our patch you’re a member of our population” and this aided them in developing an approach to co-ordinating the closure and patient transfer process in collaboration with the provider, their local authority and those CCGs with people placed in the facility.
What is a geographical host?
Simply, the CCG on the patch where the provision is based.
The policy gives the host CCG the responsibility for co-ordination and oversight when required and allows for agencies to work together to ensure patient safety and minimise risk.
The policy provides a conduit for professionals reviewing a patient accommodated by any provider on the patch to alert the geographical host CCG of any concerns they may have. Notification of these concerns would, then, set in-train the policy’s decision making matrix and identify whether those concerns need escalating.
This coordination of insights and intelligence allows the geographical host CCG to understand the provision in the round and improves overall patient safety.
“If you only see one patient, you’re only seeing one piece of the jigsaw, whereas if you’re hearing about other patients (and this is what the policy allows) it gives an over-view of what’s going on. It’s the coordination that keeps patients safe.
Why do we need such a policy?
To make sure that patients’ safety and wellbeing are kept at the forefront of decision making.
The actions that Coventry and Rugby CCG and Warwickshire North CCGs quality team undertook were beyond the expected responsibilities as determined by national current guidance, however they were taken to reflect the CCGs responsibility to uphold the NHS Constitution.
The Geographical Hosting Policy notes:
- The NHS aspires to the highest standards of excellence and professionalism
- The patient will be at the heart of everything the NHS does
- The NHS works across organisational boundaries and in partnership with other organizations in the interest of patients, local communities and the wider population.
Further to this the CCG is supported by the ‘Who Pays’ guidance when it states, “Since it is not possible to cover every eventuality within this guidance, the NHS is expected to act in the best interests of the patient at all times and work together in the spirit of partnership”.
The policy sets out a step-by-step procedure that includes sharing the policy with all the organisations involved and covers such things as identifying the professionals with responsibility for care coordination, the coordination of local clinical risk summits and ensuring accurate minutes are kept of these summits and other meetings.
The policy enabled the quality team to act as a coordinator for the closure of a care facility and work with the provider who found this an extremely useful role.
What has NHS Coventry and Rugby CCG and NHS Warwickshire North CCGs learnt from this process?
This process should sit within a quality team and that excellent administrative support for the quality lead is vital so that minutes are taken accurately and shared in a timely manner. In recognition of the need for ongoing quality surveillance that triangulates information across a range of sources (such as Healthwatch, patient experience data, provider key performance indicators) the CCG has created a new role within the quality team for a quality lead for other contracts (independent providers)
The CCG have recognised the importance of ongoing learning and reflection and, as part of the policy, set out a requirement to consider whether a post learning event is required.
NHS Coventry and Rugby CCG and NHS Warwickshire North CCGs commissioned PCC to facilitate a formal a review process to reflect on and share learning and insights gained.
This review process brought together CCGs with commissioned placements in the facility, the CQC, the provider and representatives from the quality team and others from NHS Coventry and Rugby CCG and NHS Warwickshire North CCGs.
Three two-hour online learning events explored the process of closure and captured lessons learnt and actions arising from them with participants taking the learning back into their own organisations.
NHS Coventry and Rugby CCG and NHS Warwickshire North CCGs have started sharing the policy, both locally and nationally.
In recognition of the unique nature of this work the CCG has been shortlisted for a prestigious Health Service Journal Award in the patient safety category.
For information on how PCC can support your organisation with online learning events or managing complex issues contact firstname.lastname@example.org