Enclosure: KAgenda item: 13
GOVERNING BODY
Title of paper: Governing Body Assurance Framework (GBAF) July Report
Date of meeting: 21 September 2016
Presented by: Diane Jones Title: Director of Integrated Governance& email contact: [email protected]
Prepared by: Diane Goodenough Title: Patient Safety Manager& email contact: [email protected]
Corporate Objective addressed by this paper (please select one or more with an X):
1. To commission sustainable high quality services to meet the health needs of thepopulation of Greenwich and reduce health inequalities. x
2. To ensure the CCG financial position recovers to meet all statutory financial duties.x
3. To continue to ensure that the CCG is a clinically driven organisation.x
4. To ensure diverse patient and public voices are fully considered.x
Purpose of the report:NHS Greenwich Clinical Commissioning Group (CCG) has a Governing Body AssuranceFramework (GBAF) that has been developed from the organisation’s strategic objectives asidentified by the Governing Body. The GBAF is the organisation’s main process through which theGoverning Body receives assurance on the management of high level risks to the achievement ofthe organisations strategic objectives.
Issues arising:The main risks to the CCG are the ability of the Governing Body to meet its statutory duties,particularly around managing the Emergency Department (ED) 4 hour wait target and the CCG’sdelivery on its quality, innovation, productivity and prevention (QIPP) target of £15.45m for2016/17.
The CCG continues to focus its efforts in recovering its financial position. The August 2016Finance Plan for 2016/17 shows that the CCG has identified £11.40m of QIPP savings and ofwhich, £4.99m has been delivered. There is still £4.05m to find. At month 5, the CCG isforecasting a £1.295m deficit, which is in line with our Financial Recovery Plan agreed with NHSEngland (NHSE).
Summary of actions, if any, following this meeting:NHS Greenwich CCG is working with partners at Bexley CCG, LGT and Oxleas to deliver threetransformation programmes aimed at optimising the emergency care pathway.
1. Home First Team: High level specification signed off by the Programme Board. Providers ofthe Joint Emergency Team (JET), Rapid Response, Hospital Integrated Discharge (HID)and Community Assessment and Reablement (CAR) have been asked to share activity
2
data.2. Immediate Care Bed Analysis: Analysis has been shared with the Programme Board for
comment.3. LEAN Discharge: Detailed discharge data modelled for LEAN including specific analysis of
discharge delays, Delayed Transfers of Care (DTOC), complex discharges and excess beddays. A draft business case is being developed following comments from the ProgrammeBoard.
A Remedial Action Plan approved by the Financial Recovery Board (FRB) has been implementedand a weekly progress meeting is held by the Interim Director of Commissioning. The current focusis on fulfilling the £4.05m assured QIPP gap by:
a) Fully assuring existing schemes (£2m).b) Identifying saving through Payment by Results (PbR) working and counting review and non-
elective re-design intentions.
The CCG’s action plan is closely monitored for its delivery by NHS England on a monthly basis.
The risks will be reviewed at the next Quality committee; Finance, performance and QIPP (FPQ)committee and the Greenwich Executive Group (GEG) prior to presentation at the next GoverningBody meeting.
Previous committee involvement:Quality Committee: Date: 05 September 2016 for consideration and approvalGreenwich Executive Group: Date: 07 September 2016 for consideration and approvalGoverning Body: Date: 27 July 2016 for consideration and approval
Recommendations to the Governing Body:The Governing Body is asked to:
To note the progress of the GBAF. To endorse and support the actions proposed.
(Please provide details below where Yes is indicated)
Impact on Governing Body Assurance Framework (x) Yes x No N/A
Impact on Environment (x) Yes No N/A x
Legal Implications (x) Yes x No N/A
Resource and or financial implications (x) Yes x No N/A
Equality impact assessment (x) Yes No N/A x
Privacy impact assessment (x) Yes No N/A x
Impact on current NHS Outcomes Framework areas (x) Yes x No N/A
Patient and Public Involvement (x) Yes No N/A x
Communications and Engagement (x) Yes No N/A x
Impact on CCG Constitution (x) Yes No N/A x
The September report has identified:
Impact on Governing Body Assurance Framework:
The current Governing Body Assurance Framework (GBAF) outlines details of all
identified organisational risks that may prevent the CCG from achieving its strategic
objectives. These are all high level risks that are scored 12 and above on the
3
organisation’s risk register.
Legal implications:
All risks detailed on the GBAF have legal implications attached to them as the CCG
is required to meet statutory financial duties, Civil Contingencies Act duties and
Section 11 duties.
Resource and or financial implications:All risks detailed on the GBAF have legal implications attached to them as the CCG
is required to meet statutory financial duties, Civil Contingencies Act duties and
Section 11 duties.
Impact on current NHS Outcomes Framework areas:Risks in relation in relation to providers not delivering quality and safety standards topatients which could impact on the current NHS Outcomes Framework (specificallyOutcome 5: treating and caring for people in a safe environment and protecting themfrom avoidable harm) linked to strategic objective 1.
Attachments:
i. Governing Body Assurance Framework (GBAF) report.ii. Governing Body Assurance Framework (GBAF).
iii. Corporate Risk Register.
Page 1 of 6
GOVERNING BODYGoverning Body Assurance Framework Report
September 2015
1. Introduction
NHS Greenwich Clinical Commissioning Group (CCG) has a Governing Body AssuranceFramework (GBAF) that has been developed from the organisation’s strategic objectives asidentified by the Governing Body. The GBAF is the organisation’s main process through which theGoverning Body receives assurance on the management of high level risks to the achievement ofthe organisations strategic objectives.
This report provides the Governing Body with an overview of the totality of risks affecting theorganisation’s strategic objectives together with the action plans to address them. The detailedreview and scrutiny of the GBAF ensures that appropriate controls and assurances are in place tomanage the mitigations of these risks. Analysis identifies any objectives that are at greater riskand provides opportunities for remedial action which will increase the level of assurance.
2. NHS Greenwich CCG’s Strategic Objectives 2016/17
1. To commission sustainable high quality services to meet the health needs of the populationof Greenwich and reduce inequalities.
2. To ensure the CCG’s financial position recovers to meet all statutory financial duties.
3. To continue to ensure that the CCG is a clinically driven organisation.
4. To ensure diverse patient and public voices are fully considered.
3. Overview of the organisation’s risk register with recommended actions
NHS Greenwich CCG’s GBAF risk register is detailed in Appendix A. There are currently 12 riskson the GBAF for the Governing Body to review. These relate to three out of the four CCG’sStrategic Objectives as stated above.
Table 1: Monitoring of identified risks:Objective Number of risks Monitoring
1 5 Quality Committee, FPQ Committee, GEG &Governing Body
2 2 FPQ Committee, GEG & Governing Body3 5 Quality Committee, GEG & Governing Body4 0 N/A
Total 12
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Table 2: Overview risk rating
4. New risks
Since the last Governing Body meeting on 27 July 2016, no new risks have been added to theregister.
5. Closed risks
No risks have been closed since the last report.
6. Reduced risk scores
No risks have had their scores reduced since the last meeting.
7. Increased risk scores
One risk has had its score increased since the last report.Table 3: Risk score increasedRisk Objective Detail
ID 180 1. To commission sustainablehigh quality services to meet thehealth needs of the populationof Greenwich and reduce healthinequalities.
This risk identifies the CCG’s challenge in meeting its statutoryduties, particularly around managing the EmergencyDepartment (ED) 4 hour wait target. Due to its performancetrajectory, this risk has now been increased from a score of 12to a score of 16 (extreme risk).
8. Main risk
The main risks to the CCG are the ability of the Governing Body to meet its statutory duties,particularly around managing the Emergency Department (ED) 4 hour wait target and the CCG’sdelivery on its quality, innovation, productivity and prevention (QIPP) target of £15.45m for2016/17.
The CCG continues to focus its efforts in recovering its financial position. The August 2016Finance Plan for 2016/17 shows that the CCG has identified £11.40m of QIPP savings and ofwhich, £4.99m has been delivered. There is still £4.05m to find. At month 5, the CCG isforecasting a £1.295m deficit, which is in line with our Financial Recovery Plan agreed with NHSEngland (NHSE).
The CCG’s recovery plan recognises that it must deliver on the following 4 key areas to managethese risks:
1. Manage acute over-performance more effectively
2. Deliver QIPP programmes more consistently
3. Manage budgets more effectively not spending more money than we have
4. Build the capacity and capability to deliver this larger change programme
Number ofrisks
Risk score Rating
1 15 - 25 Extreme risk11 8-12 High risk0 4 - 6 Moderate risk0 1 - 3 Low risk
Page 3 of 6
Financial recovery remains the priority for the CCG, which is detailed in the Financial report.
9. Summary of risks
A summary of the GABF risks, controls, assurance and actions are outlined below.
Objectives:
1. To commission sustainable high quality services to meet the needs of the population ofGreenwich and reduce inequalities.
Five high level risks have been identified that could prevent the CCG from successfully deliveringthis objective. In Quarter 1 of 2016/17, significant actions have been taken to mitigate these risks.
Table 4: Risk ratings
Total of 5 risks High risks scoreID 180 16ID 73 12ID 181 12ID 245 12ID 258 12
Risks identified: ID 180: Failure to meet NHS Constitution Standards and NHSE priorities and outcome
framework. ID 73: Acute contracts may over perform in 2016/17. ID 181: Failure to ensure monitoring of quality and safety of main commissioned services. ID 245: Failure to ensure quality and safety of Care Homes. ID 258: To effectively manage and monitor the contracts commissioned by the CCG.
Controls: There are a number that have been put in place to mitigate these risks. A synopsis ofthis is shown below, while full details are shown on the risk register: Integrated performance report produced monthly within the CCG. System Resilience Group in place. Regular Contract Monitoring Boards (CMBs) with providers. Monthly CCG performance report to the Finance, Performance and QIPP (FPQ)
committee, the Greenwich Executive Group (GEG) and the Governing Body. Weekly progress meeting on the Remedial Action Plan held by the Interim Director of
Commissioning.
Gaps in controls: Data not available either in a timely fashion or in a format that enablesperformance to be assessed. The Community Education Provider Network (CEPN) needs tomove into Provider organisations by December 2016. The CCG is currently undergoing anorganisational re-structure process due to end by October 2016.
Assurances for Objective 1: NHSE (London) Assurance meetings. Monitoring through Commissioning Leadership Group. System Resilience Group (SRG) monitoring and developing system resilience compliance for
ED targets. Quality Report to the Governing Body. Escalation at Clinical Quality Review Groups (CQRGs) to Contract Monitoring Boards (CMBs). Quality Monitoring Visit Report to the Quality Committee.
Page 4 of 6
CQC inspection reports. Formal contract training programme.
Actions:1. Develop transformation plans for ED including the ‘Home First Project’, Immediate Care Bed
Analysis and LEAN Discharge.2. Improved analysis of forward order book for Elective Care through referral management and
referral data by source.3. Quality Strategy to be approved by the Quality Committee.4. Liaise with RBG regarding future integration work on the Provider Assurance Monitoring
System (PAMS).
2. To ensure the CCG’s financial position recovers to meet all statutory financial duties.
Two high level risks have been identified that could prevent the CCG from successfully deliveringthis objective. In Quarter 1 of 2016/17, significant actions have been taken to mitigate this risk.
Table 5: Risk ratings
Total of 2 risks High risks scoreID 205 12ID 246 12
Risks identified: ID 205: Failure to deliver the £15.45m QIPP target for 2016/17. ID 246: Ability of Governing Body to fulfil its statutory duties in relation to the financial position
in 2016/17.
Controls: There are a number that have been put in place to mitigate these risks. A synopsis ofthis is shown below, while full details are shown on the risk register: Monthly Financial Recovery Board (FRB) meetings. Monthly Financial, Performance and QIPP (FPQ) progress monitoring. Contract Monitoring Boards (CMBs). Governing Body oversight. System assurance for all schemes with QIPP programme. System tracking of delivery against all live schemes.
Gaps in controls include that some contract may not contain flexibilities, and that adherence tothe Project Management Office (PMO) Standard Operating Procedures (SOPs) cannot be shownat present. Further SOPs are required for continuing staff development and staff training.
Assurances for Objective 2: Weekly progress reports to the QIPP, Performance, Monitoring and Delivery (QPDM)
group. PMO leading on the QIPP delivery process. Minutes/papers to FRB, FPQ, GEG and Governing Body meetings.
Actions:1. Finalised Recovery Action Plan.2. Weekly QPDM tracking delivery of live schemes and development of new schemes.3. Financial Recovery Plan.
Page 5 of 6
3. To continue to ensure that the CCG is a clinically driven organisation.
Five risks have been identified that could prevent the CCG from successfully delivering thisobjective. In Quarter 1 of 2016/17, significant actions have been taken to mitigate these risks.
Table 6: Risk ratings
Total of 5 risks High risks scoreID 189 12ID 248 12ID 251 12ID 252 12ID 254 12
Risks identified: ID 189: Failure to deliver a realistic and sustainable organisational development (OD) plan for
the organisation. ID 248: Meeting statutory requirements of the Deprivation of Liberty Safeguards (DoLS). ID 251: Vacant Designated Doctor for Safeguarding Children post in the CCG. ID 252: Full-time Designated Nurse for Looked After Children (LAC) post required in the CCG. ID 254: Assurance that effective safeguarding for children processes are in place at the Urgent
Care Centre (UCC).
Controls: There are a number that have been put in place to mitigate these risks. A synopsis ofthis is shown below, while full details are shown on the risk register: Capability and Capacity plan. FRB. Appraisals. Regular management briefs. Designated Nurse for Safeguarding Children is providing strategic and governance role
within the CCG. Designated Nurse for Safeguarding Children provides information and support for service
development. CCG representation on monthly quality review meetings between LGT’s Emergency
Department (ED) and the Urgent Care Centre (UCC).
Gaps in controls have been identified as the CCG has yet to complete a scoping exercise todetermine how many patients might be affected by the statutory requirements for meeting theDeprivation of Liberty Safeguards (DoLS). The Designated Nurse for Safeguarding Children doesnot have the expertise in Looked After Children (LAC) services and has competing priorities withregards to workload.
Assurances for Objective 3: Staff survey. LAC Doctor in post (part-time). Designated Paediatrician for Child Death in post (part-time). Named GP for Safeguarding Children in post. Designated Nurse for Safeguarding Children in post. Designated Nurse for Adult Safeguarding in post.
Actions:1. The CCG is currently undergoing an organisation restructure aiming to end by October 2016
as part of its Capability and Capacity plan.2. Scoping exercise regarding DoLS is currently being undertaken with the Continuing Healthcare
(CHC) team.
Page 6 of 6
3. CCG considering options to optimise recruitment for a full-time Designated Nurse for LAC.4. CCG to advertise for the vacant Designated Doctor for Safeguarding Children post by the end
of July 2016.
4. To ensure diverse patient and public voices are fully considered.
There are no risks on the current GBAF that align to Objective 4. However, the Risk Register hasdetails of risk that align to this objective.
10. Conclusion
The CCG’s GBAF has identified risks that may prevent the organisation from achieving its strategicobjectives. Actions have been identified to mitigate these risks and the Governing Body willcontinue to monitor the progress on the action plans.
11. Recommendations
a) To note the progress of the CCG’s GBAF.b) To endorse and support the actions proposed.
Governing Body Assurance Framework as at 14/09/16
ID Risk Controls/Mitigation Gaps in
controls/mitigation
Assurance Gaps in assurance
Ratin
g
(Targ
et)
Ratin
g
(Initia
l)
Ratin
g
(Cu
rren
t)
CCG's Objectives Action Plan
GP
Lead
Dire
cto
r
Co
mm
ittee
Resp
on
sib
le
Due date Done date Review
date
180 Failure to meet
NHS
Constitution
Standards and
NHSE priorities
and outcome
framework
System Resilience
Implementation Executive
(SRIE).
Regular Contract
Monitoring Boards with
providers.
Monthly CCG
performance reports to
FPQ and GEG.
Submission of breach
reports to Commissioning
Support Team to enable
analysis.
Regular performance
reports to FPQ and SB.
62 Day Cancer Working
Group led by Lambeth
CCG for the sector
Data not available either
in a timely fashion or in
a format that enables
performance to be
assessed.
Continue to develop and be part of
the weekly telephone conferences
on Referel to Treatment (RTT) and
two weekly calls on cancer PTLS.
Performance issues raised with
providers via CMB and/or CQRG.
NHSE (London) Assurance
meetings.
Performance report to
FPQ/GEG/Governing Body.
Key issues are 4hr A&E waits and
62 day cancer waits (essentially
tertiary based referrals to GSTT &
Kings).
Cancer and RTT Recovery Plans in
place and agreed with NHSE.
System Resilience Group (SRG)
and SREI monitoring and
developing system resilience
compliance for A&E targets.
Regular monthly performance
'touchpoint' meetings with NHSE
involving CCG/CSU colleagues to
review progress against the orignal
operational plan.
New integrated performance report
produced within the CCG monthly.
Lewisham CCG, as Lead
Commissioner for LGT, need to
active manage performance
recovery with the Trust.
LGT has a performance
trajectory of 90.1% against the
target of 95% over the year in
2016/17.
8 16 16 1. To commission
sustainable high
quality services to
meet the health
needs of the
population of
Greenwich and
reduce health
inequalities
Home First Team: High
level specification signed off
by Programme Board.
Providers of the Joint
Emergency Team (JET),
Rapid Response, Hospital
Integrated Discharge (HID)
and Community
Assessment and
Reablement (CAR) have
been asked to share activity
data.
Immediate Care Bed
Analysis: Analysis has been
shared with Programme
Board for comment.
LEAN Discharge: Detailed
discharge data modelled for
LEAN including specific
analysis of discharge
delays, Delayed Transfers
of Care (DTOC), Complex
Discharges and excess bed
days. Draft business case
amended following
comments by Programme
Board.
Kris
hna S
ubbara
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Liz
Jam
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Fin
ance, P
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258 To effectively
manage and
monitor the
contracts
commissioned
by the CCG.
A Remedial Action Plan
has been developed,
accepted by the FRB and
a weekly progress
meeting is held by the
Interim Director of
Commissioning.
The CCG is consulting
on a revised
organisational structure
until 18 August.
The Remedial Action Plan.
Progress chasing on the Remedial
Action Plan.
Commissioning Directorate
Diagnostic.
Formal contract training
programme and attendance list.
The FRB capability & capacity
programme. The diagnostic of
capability has considered
contracting roles, responsibilities,
subject expertise and
requirements.
The Commissioning Directorate
Diagnostic is yet unpublished
and not consulted upon.
Implementation and embedding
of the Remedial Action Plan.
12 20 12 1. To commission
high quality, cost
effective services to
meet the needs of
local people which
improve health
outcomes and
reduce inequalities.
Capability and capacity
programmed.
Remedial Action Plan
Kris
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Governing Body Assurance Framework as at 14/09/16
ID Risk Controls/Mitigation Gaps in
controls/mitigation
Assurance Gaps in assurance
Ratin
g
(Targ
et)
Ratin
g
(Initia
l)
Ratin
g
(Cu
rren
t)
CCG's Objectives Action Plan
GP
Lead
Dire
cto
r
Co
mm
ittee
Resp
on
sib
le
Due date Done date Review
date
73 Acute contracts
may over
perform in
2016/17.
Blocks in place for 6
months for non-elective
for acute provider and a
full year for full activity at
Kings.
External counting and
coding review of non-
elective at LGT.
Contracts funded at
outturn and specific
growth levels for e.g. to
sustain cancer and
diagnostic activity and
generic demographic
growth editions.
Detailed examination of
activity level by point of
delivery by Southern CSU
and CCG MDT.
Controls on prior
approval and consultant
to consultant referral
require review.
Variance analysis planned to actual
by point of delivery by provider
monthly analysis.
Summary level to FPQ monthly.
Monthly Operational Plan reporting
to FRB
Notes and Action Trackers of
CMBs.
CSU and CCG MDT monthly
meetings.
Detailed analysis less available
for smaller acute contracts.
10 20 12 1. To commission
sustainable high
quality services to
meet the health
needs of the
population of
Greenwich and
reduce health
inequalities
Improved analysis of
forward order book for
Elective Care through
referral management and
referral data by source.
Strengthening of integration
of perfomance and finance
reports to FPQ.R
anil P
ere
ra
Liz
Jam
es
Fin
ance, P
erfo
rmance &
QIP
P
31/10/2016
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Governing Body Assurance Framework as at 14/09/16
ID Risk Controls/Mitigation Gaps in
controls/mitigation
Assurance Gaps in assurance
Ratin
g
(Targ
et)
Ratin
g
(Initia
l)
Ratin
g
(Cu
rren
t)
CCG's Objectives Action Plan
GP
Lead
Dire
cto
r
Co
mm
ittee
Resp
on
sib
le
Due date Done date Review
date
181 Failure to ensure
monitoring of
quality and
safety of main
commissioned
services.
Challenge and rigour of
the quality monitoring
systems in the Quality
Committee.
Receipt of Quality
Reports at Quality
Committee, GEG and
Governing Body.
Challenge and rigour of
the quality monitoring
systems in the Clinical
Quality Review Groups
(CQRGs).
Local intelligence sharing
group with Bexley, NHSE
and CQC.
Contract monitoring
meetings with our
providers..
Robust QIA & EIA
process.
Partnership working with
Public Health.
Memorandum of
Understanding with
Public Health.
Health & Wellbeing
Board.
Service contracts include
quality and safety
metrics.
Quality Assurance Visits
(QAVs) Protocol.
Contracts do not
prioritise quality issues /
Quality KPIs.
Contracts review
highlights lack of
commissioning
capacity.
Limited capacity to
monitor small providers.
PAMS/QAMS are still
new systems that need
to be embedded into
practice.
Evidence to support
Statutory Duty
Assurance Framework.
Minutes and reports from Quality
Committee.
Quality Report to the Governing
Body.
Quality Issues Log.
Monthly joint
performance/quality/finance
integrated report.
Integrated Quality Dashboard.
Escalation at CQRG to Contract
Monitoring Board.
Data from PAMS/QAMS used in
reports to the Joint Safeguarding
Group/Quality Committee.
Annual Governance Statement and
Report.
Reports and minutes from the SI
Review Panel.
QAMS only recently beginning to
see more utilisation by GPs from
April 2016 - therefore, limited
data to inform quality of services
at present.
PAMS re-started with all nursing
care homes on 1st April 2016 -
therefore limited data at present.
Limited information/data on small
providers.
Quality Strategy not ratified as
yet.
10 20 12 1. To commission
sustainable high
quality services to
meet the health
needs of the
population of
Greenwich and
reduce health
inequalities
Quality Strategy to be
approved by the Quality
Committee in September.
Reports on QAMs and
PAMs usage and
effectivess as part of the
quarterly Quality Report.
Kris
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ubbara
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ones
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Com
mitte
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245 Failure to ensure
quality and
safety of Care
Homes
Quality Committee.
Local intelligence sharing
group with Bexley, NHSE
and CQC
Collaborative working
with other boroughs.
Care Home Quality
Monitoring Meeting.
Limited data on
performance.
CQC inspections, liaison with CQC
inspectors.
Soft intelligence from Care Home
Support Team (CHST) and
Continuing Healthcare Team
(CHC).
Links with RBG quality and
safeguarding teams.
Relationships with neighbouring
boroughs and CCGs.
Visits to Care Homes.
Monthly quarterly data reporting
from any qualified provider (AQP)
homes.
Provider Assurance Monitoring
System (PAM) not embedded.
9 12 12 1. To commission
sustainable high
quality services to
meet the health
needs of the
population of
Greenwich and
reduce health
inequalities
Liaise with RBG regarding
future integration work on
PAMS.
Provider Assurance
Monitoring System (PAMS)
restarted on 1st April with
all nursing care homes - 11
+ 2 mental health/LD
homes.
Hany W
ahba
Dia
ne J
ones
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xecutiv
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Governing Body Assurance Framework as at 14/09/16
ID Risk Controls/Mitigation Gaps in
controls/mitigation
Assurance Gaps in assurance
Ratin
g
(Targ
et)
Ratin
g
(Initia
l)
Ratin
g
(Cu
rren
t)
CCG's Objectives Action Plan
GP
Lead
Dire
cto
r
Co
mm
ittee
Resp
on
sib
le
Due date Done date Review
date
205 Failure to deliver
the £15.45m
QIPP target for
2016/17.
Monthly reporting on
progress to the Financial
Recovery Board (FRB).
Weekly QIPP,
Performance, Monitoring
and Delivery (QPMD)
tracking of live schemes
and development of new
schemes.
Schematic assurance for
all schemes within the
QIPP programme.
System tracking of
delivery against all live
schemes by project plan
milestones.
Continuous review of
development
opportunities in QIPP
pipeline.
Staffed Programme
Management Office
(PMO).
CCG wide launch of
PMO Operating
Procedures.
Adherence to PMO
Standard Operating
procedures cannot be
shown but with weekly
PMO/Project Lead
reviews are improving
rapidly.
SOPs required on
continuing staff
development and staff
training.
Minutes and trackers of QPDM
Group.
External assurance report in June
2016 by Deloitte.
Minutes/papers to FRB.
Minutes/papers to FPQ.
Minutes/papers to Governing Body.
SOPs.
Attendance register of PMO SOP
launch on 07/07/16.
None identified. 8 15 12 2. To ensure the
CCG financial
position recovers to
meet all statutory
financial duties.
Current focus is on fulfilling
the £4.3m assured QIPP
gap by: a) Fully assuring
existing schemes (£2m). b)
Identifying savings through
PbR working and counting
review and non-elective re-
design intentions. E
llen W
right
Gin
a S
hakespeare
Fin
ance, P
erfo
rmance &
QIP
P
30/11/2016 03/10/16
246 Ability of
Governing Body
to fulfill its
statutory duties
in relation to the
financial position
2016/17.
Monthtly Financial
Recovery Board (FRB)
meetings.
Monthly FPQ progress
monitoring.
Contract monitoring
boards.
Governing Body
oversight.
None. Weekly QIPP, Peformance,
Delivery and Monitoring (QPMD)
meetings.
Project Management Office (PMO)
leading on QIPP delivery process.
Monthly FPQ monitoring.
Regular meetings with budget
managers.
Monthtly Financial Recovery Board
(FRB) monitoring.
Quarterly Audit Committee
monitoring.
Inability to deliver recovery in
QIPP schemes.
The August 2016 Finance Plan
for 2016/17 shows a QIPP target
of £15.45m. Identified £11.40m
assured QIPP savings and
delivered £4.99m from this
already. There is still £4.05m to
find.
At month 5, the CCG is
forecasting a £1.295m deficit,
which is in line with our Financial
Recovery Plan agreed with NHS
England (NHSE).
10 15 12 2. To ensure the
CCG financial
position recovers to
meet all statutory
financial duties.
Financial Recovery Plan
Elle
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Ian F
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Fin
ance, P
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rmance &
QIP
P
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189 Failure to deliver
a realistic and
sustainable OD
plan for the
organisation
Capability and Capacity
Plan.
Financial Recovery
Board.
Syndicate Leads.
CPLs clear role.
Directorate structure.
Appraisals.
PDPs.
Internal communications.
Regular management
briefs.
Commissioning Voice.
Development days.
Access to education and
training.
Internal structure review.
Constitution and
Governing Body review.
Audit Committee.
Staff Health & Wellbeing
Group.
Lack of team meetings
or developmental
events within
Directorates.
Appraisal membership
for SLs and CPLs not
delivered.
Lack of structure
between CPLs/GP
Execs/SMT.
Stakeholder Survey.
Staff Survey.
HR Staff report to GEG on staff
turnover, sickness and absence
rates.
Intranet.
Policy refresh via the Health
Wellbeing Board group and GEG.
Data on Appraisals and Training.
"Growing Success" programme.
Building Capability and Capacity.
Financial value of this risk
materialising: N/A
Mitigation: N/A
Action plan to respond to staff
and stakeholder survey.
Incorrect information populated
onto ESR system, meaning
workforce reports inaccurate.
4 12 12 3. To continue to
ensure that the
CCG is a clinically
driven organisation
Capacity and capability
review.
Develop a Workforce
Strategy.
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248 Meeting
statutory
requirements of
the Deprivation
of Liberty
Safeguards
(DoLS)
Liaise with Continuing
Health Care (CHC) team
to scope approximate
numbers where this
ruling may apply.
Legal support available on
a case by case basis.
Raised with National
Safeguarding Steering
Group/MCA & DoLS sub-
group (discussed on 25
January 2016 and next
steps to be confirmed).
CCG scoping exercise
not yet undertaken.
CHC activity is controlled in-house
and hence it is easier to seek
assurance. It is likely that this ruling
will apply to a small number of
patients.
Control measures not yet
effective.
Numbers of patient to whom this
ruling may or would apply to.
8 12 12 3. To continue to
ensure that the
CCG is a clinically
driven organisation
Scoping exercise being
undertaken with CHC team.
Hany W
ahba
Dia
ne J
ones
Safe
guard
ing E
xecutiv
e
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251 Vacant
Designated
Doctor for
Safeguarding
Children post in
the CCG
Designated Nurse for
Safeguarding Children is
able to provide specilist
advice and guidance to
the Governing Body and
GSCG when required on
all matters relating to
safeguarding children
including regulation and
inspections.
Responsible for
monitoring safeguarding
standards and ensures
that safeguarding
standards are integrated
into all commissioning
processes and service
specifications.
Monitoris services across
the health community to
ensure adherence to
legislation, policy and key
statutory and non-
statutory guidance.
Designated Nurse for
Safeguarding Children
cannot provide
supervision to the
named doctors and
Named GP.
Looked After Children (LAC) Doctor
in post (part-time).
Designated Paediatrician for Child
Death in post (part-time).
Named GP in post.
Designated Nurse for Safeguarding
Children in post.
Vacant Designated Doctor for
Safeguarding Children post in the
CCG.
5 12 12 3. To continue to
ensure that the
CCG is a clinically
driven organisation
CCG to recruit into post.
Advert sent to NHSE and
the Royal College of
Paediatricians for approval
as aiming to go out to
advert before the end of
September.
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252 Full time
Designated
Nurse for
Looked After
Children (LAC)
post required in
the CCG
Designated Nurse for
Safeguarding Children is
providing strategic and
governance role within
the CCG.
Designated Nurse for
Safeguarding Children
provides information and
support for service
development.
Designated Nurse for
Safeguarding Children is
working with the current
part-time Designated
Nurse for Looked After
Children (LAC) to develop
a service which reflects
current national guidance
and statutory regulation.
Designated Nurse for
Safeguarding Children
does not have the
expertise in LAC
services and has
competing priorities
with regards to
workload.
Looked After Children (LAC) Doctor
in post (part-time).
LAC Nurse (part-time) in post.
Designated Nurse for Safeguarding
Children in post.
Regular meetings with Designated
professionals to review LAC.
The CCG does not a current
budget for a full-time Designated
Looked After Children (LAC)
Nurse post and the cost of
employing a full-time nurse will
be about £60,000 (including on
cost).
6 12 12 3. To continue to
ensure that the
CCG is a clinically
driven organisation
CCG considering options to
optimise recruitment.
Dr S
abah S
alm
an
Dia
ne J
ones
Safe
guard
ing E
xecutiv
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254 Assurance that
effective
safeguarding for
children
processes are in
place at the
Urgent Care
Centre (UCC).
CCG representation
agreed for ongoing
monthly quality review
meeting between LGT ED
and UCC.
None. CCG has monthly contract
meetings with UCC.
CCG Quality representative at the
LGT ED/UCC Quality Review
meetings from February 2016.
Dates for Safeguarding assurance
meetings sent to UCC's
Safeguarding Lead to attend.
Information presented at monthly
contract meetings lack specific
safeguarding KPIs.
6 12 12 3. To continue to
ensure that the
CCG is a clinically
driven organisation
Safeguarding KPIs sent to
UCC. Meeting being
arranged for 08/09/16
between UCC and GCC to
discuss details of
safeguarding KPIs.
Dr S
abah S
alm
an
Dia
ne J
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Safe
guard
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180 Failure to meetNHS ConstitutionStandards andNHSE prioritiesand outcomeframework
System ResilienceImplementation Executive(SRIE).Regular Contract MonitoringBoards with providers.Monthly CCG performancereports to FPQ and GEG.Submission of breach reports toCommissioning Support Team toenable analysis.Regular performance reports toFPQ and SB.62 Day Cancer Working Groupled by Lambeth CCG for thesector
Data not available either in atimely fashion or in a formatthat enables performance tobe assessed.
Continue to develop and be part of theweekly telephone conferences onReferel to Treatment (RTT) and twoweekly calls on cancer PTLS.Performance issues raised withproviders via CMB and/or CQRG.NHSE (London) Assurance meetings.Performance report toFPQ/GEG/Governing Body.Key issues are 4hr A&E waits and 62day cancer waits (essentially tertiarybased referrals to GSTT & Kings).Cancer and RTT Recovery Plans inplace and agreed with NHSE.System Resilience Group (SRG) andSREI monitoring and developing systemresilience compliance for A&E targets.Regular monthly performance'touchpoint' meetings with NHSEinvolving CCG/CSU colleagues toreview progress against the orignaloperational plan.New integrated performance reportproduced within the CCG monthly.
Lewisham CCG, as LeadCommissioner for LGT, need toactive manage performancerecovery with the Trust.LGT has a performancetrajectory of 90.1% against thetarget of 95% over the year in2016/17.
8 16 16 Home First Team: Highlevel specificationsigned off byProgramme Board.Providers of the JointEmergency Team(JET), RapidResponse, HospitalIntegrated Discharge(HID) and CommunityAssessment andReablement (CAR)have been asked toshare activity data.Immediate Care BedAnalysis: Analysis hasbeen shared withProgramme Board forcomment.LEAN Discharge:Detailed discharge datamodelled for LEANincluding specificanalysis of dischargedelays, DelayedTransfers of Care(DTOC), ComplexDischarges and excessbed days. Draftbusiness caseamended followingcomments byProgramme Board.
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73 Acute contractsmay over performin 2016/17.
Blocks in place for 6 months fornon-elective for acute providerand a full year for full activity atKings.External counting and codingreview of non-elective at LGT.Contracts funded at outturn andspecific growth levels for e.g. tosustain cancer and diagnosticactivity and generic demographicgrowth editions.Detailed examination of activitylevel by point of delivery bySouthern CSU and CCG MDT.
Controls on prior approvaland consultant to consultantreferral require review.
Variance analysis planned to actual bypoint of delivery by provider monthlyanalysis.Summary level to FPQ monthly.Monthly Operational Plan reporting toFRBNotes and Action Trackers of CMBs.CSU and CCG MDT monthly meetings.
Detailed analysis less availablefor smaller acute contracts.
10 20 12 Improved analysis offorward order book forElective Care throughreferral managementand referral data bysource.Strengthening ofintegration ofperfomance andfinance reports to FPQ.
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Page 1 of 11
Risk Register as at 14/09/16
ID Risk Controls/Mitigation Gaps in controls/mitigation Assurance Gaps in assurance
Ra
ting
(Ta
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ting
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Ra
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181 Failure to ensuremonitoring ofquality and safetyof maincommissionedservices.
Challenge and rigour of thequality monitoring systems in theQuality Committee.Receipt of Quality Reports atQuality Committee, GEG andGoverning Body.Challenge and rigour of thequality monitoring systems in theClinical Quality Review Groups(CQRGs).Local intelligence sharing groupwith Bexley, NHSE and CQC.Contract monitoring meetingswith our providers..Robust QIA & EIA process.Partnership working with PublicHealth.
Contracts do not prioritisequality issues / Quality KPIs.Contracts review highlightslack of commissioningcapacity.Limited capacity to monitorsmall providers.PAMS/QAMS are still newsystems that need to beembedded into practice.Evidence to support StatutoryDuty Assurance Framework.
Minutes and reports from QualityCommittee.Quality Report to the Governing Body.Quality Issues Log.Monthly jointperformance/quality/finance integratedreport.Integrated Quality Dashboard.Escalation at CQRG to ContractMonitoring Board.Data from PAMS/QAMS used in reportsto the Joint Safeguarding Group/QualityCommittee.Annual Governance Statement andReport.Reports and minutes from the SIReview Panel.
QAMS only recently beginningto see more utilisation by GPsfrom April 2016 - therefore,limited data to inform quality ofservices at present.PAMS re-started with allnursing care homes on 1stApril 2016 - therefore limiteddata at present.Limited information/data onsmall providers.Quality Strategy not ratified asyet.
10 20 12 Quality Strategy to beapproved by the QualityCommittee inSeptember.Reports on QAMs andPAMs usage andeffectivess as part ofthe quarterly QualityReport.
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189 Failure to deliver arealistic andsustainable ODplan for theorganisation
Capability and Capacity Plan.Financial Recovery Board.Syndicate Leads.CPLs clear role.Directorate structure.Appraisals.PDPs.Internal communications.Regular management briefs.Commissioning Voice.Development days.Access to education and training.Internal structure review.Constitution and Governing Bodyreview.Audit Committee.Staff Health & Wellbeing Group.
Lack of team meetings ordevelopmental events withinDirectorates.Appraisal membership forSLs and CPLs not delivered.Lack of structure betweenCPLs/GP Execs/SMT.
Stakeholder Survey.Staff Survey.HR Staff report to GEG on staffturnover, sickness and absence rates.Intranet.Policy refresh via the Health WellbeingBoard group and GEG.Data on Appraisals and Training."Growing Success" programme.Building Capability and Capacity.Financial value of this risk materialising:N/AMitigation: N/A
Action plan to respond to staffand stakeholder survey.Incorrect information populatedonto ESR system, meaningworkforce reports inaccurate.
4 12 12 Capacity and capabilityreview.Develop a WorkforceStrategy.
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Ra
ting
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ting
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Ra
ting
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rren
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205 Failure to deliverthe £15.45mQIPP target for2016/17.
Monthly reporting on progress tothe Financial Recovery Board(FRB).Weekly QIPP, Performance,Monitoring and Delivery (QPMD)tracking of live schemes anddevelopment of new schemes.Schematic assurance for allschemes within the QIPPprogramme.System tracking of deliveryagainst all live schemes byproject plan milestones.Continuous review ofdevelopment opportunities inQIPP pipeline.Staffed Programme
Adherence to PMO StandardOperating procedures cannotbe shown but with weeklyPMO/Project Lead reviewsare improving rapidly.SOPs required on continuingstaff development and stafftraining.
Minutes and trackers of QPDM Group.External assurance report in June 2016by Deloitte.Minutes/papers to FRB.Minutes/papers to FPQ.Minutes/papers to Governing Body.SOPs.Attendance register of PMO SOPlaunch on 07/07/16.
None identified. 8 15 12 Current focus is onfulfilling the £4.3massured QIPP gap by:a) Fully assuringexisting schemes(£2m). b) Identifyingsavings through PbRworking and countingreview and non-electivere-design intentions.
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245 Failure to ensurequality and safetyof Care Homes
Quality Committee.Local intelligence sharing groupwith Bexley, NHSE and CQCCollaborative working with otherboroughs.Care Home Quality MonitoringMeeting.
Limited data on performance. CQC inspections, liaison with CQCinspectors.Soft intelligence from Care HomeSupport Team (CHST) and ContinuingHealthcare Team (CHC).Links with RBG quality andsafeguarding teams.Relationships with neighbouringboroughs and CCGs.Visits to Care Homes.Monthly quarterly data reporting fromany qualified provider (AQP) homes.
Provider Assurance MonitoringSystem (PAM) not embedded.
9 12 12 Liaise with RBGregarding futureintegration work onPAMS.Provider AssuranceMonitoring System(PAMS) restarted on1st April with all nursingcare homes - 11 + 2mental health/LDhomes.
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246 Ability ofGoverning Bodyto fulfill itsstatutory duties inrelation to thefinancial position2016/17.
Monthtly Financial RecoveryBoard (FRB) meetings.Monthly FPQ progressmonitoring.Contract monitoring boards.Governing Body oversight.
None. Weekly QIPP, Peformance, Deliveryand Monitoring (QPMD) meetings.Project Management Office (PMO)leading on QIPP delivery process.Monthly FPQ monitoring.Regular meetings with budgetmanagers.Monthtly Financial Recovery Board(FRB) monitoring.Quarterly Audit Committee monitoring.
Inability to deliver recovery inQIPP schemes.The August 2016 Finance Planfor 2016/17 shows a QIPPtarget of £15.45m. Identified£11.40m assured QIPPsavings and delivered £4.99mfrom this already. There is still£4.05m to find.At month 5, the CCG isforecasting a £1.295m deficit,which is in line with ourFinancial Recovery Planagreed with NHS England(NHSE).
10 15 12 Financial RecoveryPlan
Elle
nW
righ
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Ian
Fis
he
r
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31/03/2017 30/09/16
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ting
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248 Meeting statutoryrequirements ofthe Deprivation ofLibertySafeguards(DoLS)
Liaise with Continuing HealthCare (CHC) team to scopeapproximate numbers where thisruling may apply.Legal support available on acase by case basis.Raised with NationalSafeguarding SteeringGroup/MCA & DoLS sub-group(discussed on 25 January 2016and next steps to be confirmed).
CCG scoping exercise notyet undertaken.
CHC activity is controlled in-house andhence it is easier to seek assurance. Itis likely that this ruling will apply to asmall number of patients.
Control measures not yeteffective.Numbers of patient to whomthis ruling may or would applyto.
8 12 12 Scoping exercise beingundertaken with CHCteam.
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251 VacantDesignatedDoctor forSafeguardingChildren post inthe CCG
Designated Nurse forSafeguarding Children is able toprovide specilist advice andguidance to the Governing Bodyand GSCG when required on allmatters relating to safeguardingchildren including regulation andinspections.Responsible for monitoringsafeguarding standards andensures that safeguardingstandards are integrated into all
Designated Nurse forSafeguarding Childrencannot provide supervision tothe named doctors andNamed GP.
Looked After Children (LAC) Doctor inpost (part-time).Designated Paediatrician for ChildDeath in post (part-time).Named GP in post.Designated Nurse for SafeguardingChildren in post.
Vacant Designated Doctor forSafeguarding Children post inthe CCG.
5 12 12 CCG to recruit intopost. Advert sent toNHSE and the RoyalCollege ofPaediatricians forapproval as aiming togo out to advert beforethe end of September.
Dr
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252 Full timeDesignated Nursefor Looked AfterChildren (LAC)post required inthe CCG
Designated Nurse forSafeguarding Children isproviding strategic andgovernance role within the CCG.Designated Nurse forSafeguarding Children providesinformation and support forservice development.Designated Nurse forSafeguarding Children is workingwith the current part-timeDesignated Nurse for LookedAfter Children (LAC) to develop aservice which reflects currentnational guidance and statutoryregulation.
Designated Nurse forSafeguarding Children doesnot have the expertise in LACservices and has competingpriorities with regards toworkload.
Looked After Children (LAC) Doctor inpost (part-time).LAC Nurse (part-time) in post.Designated Nurse for SafeguardingChildren in post.Regular meetings with Designatedprofessionals to review LAC.
The CCG does not a currentbudget for a full-timeDesignated Looked AfterChildren (LAC) Nurse post andthe cost of employing a full-time nurse will be about£60,000 (including on cost).
6 12 12 CCG consideringoptions to optimiserecruitment.
Dr
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254 Assurance thateffectivesafeguarding forchildrenprocesses are inplace at theUrgent CareCentre (UCC).
CCG representation agreed forongoing monthly quality reviewmeeting between LGT ED andUCC.
None. CCG has monthly contract meetingswith UCC.CCG Quality representative at the LGTED/UCC Quality Review meetings fromFebruary 2016.Dates for Safeguarding assurancemeetings sent to UCC's SafeguardingLead to attend.
Information presented atmonthly contract meetings lackspecific safeguarding KPIs.
6 12 12 Safeguarding KPIs sentto UCC. Meeting beingarranged for 08/09/16between UCC andGCC to discuss detailsof safeguarding KPIs.
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258 To effectivelymanage andmonitor thecontractscommissioned bythe CCG.
A Remedial Action Plan hasbeen developed, accepted by theFRB and a weekly progressmeeting is held by the InterimDirector of Commissioning.
The CCG is consulting on arevised organisationalstructure until 18 August.
The Remedial Action Plan.Progress chasing on the RemedialAction Plan.Commissioning Directorate Diagnostic.Formal contract training programmeand attendance list.The FRB capability & capacityprogramme. The diagnostic of capabilityhas considered contracting roles,
The CommissioningDirectorate Diagnostic is yetunpublished and not consultedupon.Implementation and embeddingof the Remedial Action Plan.
12 20 12 Capability and capacityprogrammed.Remedial Action Plan
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261 Implementation ofthe new 2 weekwait cancerreferral formsacross allGrenwich GPpractices.
SMT agreement for the ServiceRedesign & ProcurementManager to support GP practiceson technical solutions.Collating feedback frompractices to ensuire all isses arehighligted.User guide in development tohelp support practices in the newsystem.LGT pathway and contactnumbers have already been sentout to all GPs.Task and Finish Group set up tomonitor actions and progresswhich include LGT and CSU.Cancer Steering Group tomonitor and advise.
Resources not identified forthose practices who will needtraining on the new process.No control over what GPscurrently have access toregarding diagnostic tests -this has been raised to theCSU and will be acommissioning issue.
Control measure presented to theCCG's cancer group.Local Risk Register created to log allissues as they arise and monthlysubmission to the Cancer SteeringGroup Meeting for monitoring.Engagement in solving issues from boththe Trust and CSU.Engagement with Vision in resolvingtechnical issues.
Access to 'straight to test'diagnosis is a commissioningissue which will needengagement from the LeadCommissioner for Cancer.
6 20 12 Survey going topractices weekbeginning 29/08/16 andclosing on 05/09/16 toascertain anyoutstanding issues -practice visits will resultwhere necessary.LGT to provideinformation on whichpractices are still faxingreferrals to help theCCG focus practicevisits.
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243 Failure toimplement thecommunity basedcare - STPImplementationPlan.
GP Forward View ProgrammeBoard established with Task andFinish Groups for each keyinitiative in the programme.National Development resourcesavailable.
Programme plan timetableand milestones are not yetpopulated fully (due dates setfor 30/10/16).
Programme Board minutes and papers.CCG submissions to SEL PMO.
Programme infrastructure isnew and material is thereforelimited.
9 12 10 Completion of a fullypopulated ProgrammePlan for all milestonesby 30/09/16.
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253 Assurance ofsafeguardingtrainingcompliance forchildren acrossthe whole ofprimary care.
Designated Nurse forSafeguarding Children andDesignated Named GP deliversafeguarding training monthlyand also provide practice visitswhen required.Designated Nurse forSafeguarding Children providessafeguarding advice and supportto local GPs.
Capacity to provide cover forGPs to attend safeguardingwhich is organised duringsurgery hours.
GP safeguarding training data hasimproved to 80% in July 2016. This ratecontinues to improve.
Gaps in assurance informationfor Dentists and Pharmacistsas this data is held by NHSE.
6 9 9 CCG formally escalatedto GreenwichSafeguarding Board inJune to seek assurancedata. Reminder sent toGSB Chair inSeptember. Awaitingresponse.
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194 Ability of theGoverning Bodyto fulfill its non-financial statutoryduties.
Reports to Quality Committee.Governance Framework.Patient Reference Group.Internal and external audits to theAudit Committee.
Quality Strategy and workprogramme yet to be ratified.Evidence to support StatutoryDuty Assurance Framework.
Reports and minutes of the QualityCommittee.Reports and minutes of the AuditCommittee.
Internal audit review ofstatutory duties as part of theannual Audit Programme.
6 12 8 SMT review DirectorLed (Nov 2016).Collect evidenceagainst statutory dutiesand add evidence ontoDatix.
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196 Legal basis foraccess topersonalidentifiable dataprevents CCG’sfrom makinginformeddecisions
Caldicott Guardian and SIROappointed.IG Steering Group.IG Programme.Communications to staff.Development of currentinformation provided tomembership and make available
Lack of Business Intelligence(BI) and IT strategy.
IG Toolkit compliance Audited at Level2.ASH status.NHSCIC Risk Stratification statusapproved.Greenwich Reporting & InformationPortal (GRIP)
None. 6 8 8
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197 Difficulty in linkingand synthesisinginformation fromdifferent sourcesto inform strategiccommissioningdecisions
IG Steering Group. Information Strategy. Implementation of virtual patient recordin Greenwich by November 2015.Financial value of this risk materialising:N/A.Mitigation: N/A.
None. 6 8 8 Develop informationstrategy
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201 Failure to usedata effectively
Training.Information Governance SteeringGroup.
Information Strategy.Organisational Developmentplan.
Information Strategy.Organisational Development Plan.Develop Greenwich InformationProtocol.Financial value of this risk materialising:There is a risk that contracts will be setat unaffordable level.sMitigation: All contracts are agreed to
None. 6 8 8 Develop InformationStrategy
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232 Failure to meetStatutory dutiesset out in the CivilContingencies Act2004 to haverobust businesscontinuity plans inplace
The CCG has a BusinessContinuity Policy in place settingout CCG BC arrangements andresponsibilitiesCompleted Business ImpactAnalysis for the CCG detailingbusiness critical functions overtimeCCG Business Continuity Plansdetailing processes forinvocation; roles andresponsibilities; Critical CCG
Current Business ContinuityPlan being tested
Pandemic Flu exercise carried out inMay 2016.NHS England seeks assurance onbehalf of CCGs from the CSU on ITDisaster Recovery arrangements.Annual NHS England EPRR AssuranceReview.Weekly updates from NHS England onterrorism level; industrial action; publicorder and weather warning.EPRR Lead in post since 21/03/16.
6 12 8 Refresh BusinessContinuity Plans for2016/17.Completion ofDirectorate BusinessContinuity Plans.Refresh BusinesContinuity Plans(BCPs) for theWoolwich Centre.Telephone cascadeexercise to be repeated
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263 Potentialdeterioration ofstakeholder andpublicrelationships asthe CCG mayreduce servicesaccording toguidance.
Chief Executive and chair toMedical Director discussions.Tailored briefings compiled andshared with fellow stakeholders.Meetings with Patient ReferenceGroup in place since March2016.Arrangements put in place withGP Executives to strengthenarrangements for them to reviewbusiness cases.Meeting of Clinical Chair andsenior CCG staff with RBGLeader and senior staff to agreeprotocol for close workingbetween partners.
None identified. Written briefings.Notes of meetings from PRGs.Busines Case front sheetsdemonstrating Clinical Leaderownership.Named GP Executive ownership foreach QIPP scheme.Notes of public engagement activitiesand events.Project Level engagement logs for allnew QIPP schemes from August 2016.
None as yet. 6 8 8 Meeting between seniorRBG and CCG staff toensure mutual briefingsfrom September 2016as agreed betweenCCG Chair and CouncilLeader.
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145 Inappropriateaccess to andprocessing of PIDmay breach theData ProtectionAct and inability toevidenceoperationalcontrols
CCG has achieved theaccredited Safe Haven statusfrom the HSCIC. This enablesthe CCG to review a range ofcommissioning data sets forspecific purposes.Baseline assessment refreshed.Undertake data flow mapping forCCG.Refresh Information AssetRegister.
SIRO has to provide assurance toGoverning Body for compliance.SIRO has undertaken training.Caldicott Guardian has undertakentraining.IG Workprogramme has beendeveloped.Register of staff with access to PIDcompleted.Financial value of this risk materialising:£500,000 can be imposed for Data Act
Governing Body meets everyother month.
4 16 6 Information Strategy tobe produced
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203 To develop andagree with RBG arevised BetterCare Fund (BCF)programme whichis assured byNHSE for2016/17.
GEG to oversee strategicdiscussions.Health and Wellbeing Boardhave received revised Terms ofReference.The Joint CommissioningExecutive (JCE) is now theprogramme board with delegatedresponsibilities for the BCF as of06/07/16.
NHSE Assurance process isextensive within a shorttimescale.Patient engagment remainsoutstanding.
BCF is now linked to our ServiceTransformation Plan (STP).Monthly JCE meetings. Senior leadersfrom CCG and RBG in attendance tofacilitate good partnership working andtarget alignments.
Patient engagement to bedeveloped with communities.
4 16 6 To deliver the Section75 agreement by theend of September2016.
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249 Implementation ofPrevent statutoryguidance acrossCCG andproviders,launched in April2016.
Prevent Training compliance isroutinely reported to the CCGJoint Safeguarding Group (JSG)and Quality Committee.All CCG staff are required tocomplete mandatory Channelawareness e-learning packageas Prevent Level 1 and Level 2awareness training.Prevent duties are listed withinthe NHS contract. Both mainproviders (Oxleas and LGT) havethe required Prevent policies andtraining in place and are workingtowards compliance with WRAPtraining.CCG and Oxleas safeguardingleads are members of the
CCG compliance withChannel e-learning is at 89%and improving.Provider compliance withWRAP is at a low baseline(Oxleas at 15% and LGT at35%). Trusts are required toreach compliance (85%)within 3 years (by April 2018).
Greenwich has a well-developedPrevent/Channel process and thePrevent Coordinator (RBG lead) isassured that health agencies areappropriately represented.Health providers contribute toinformation gathering forPrevent/Channel cases through theiradult safeguarding leads.Designated Adult SafeguardingManager (DASM) has regular contactwith the Prevent Coordinator.The CCG is copied into quarterly NHSE(London) provider returns.2 training sessions delivered in Juneand July 2016.
Awareness and knowledge ofprimary care providers(especially GPs). NHSE haverecognised this and allocatednon-recurrent resources toimprove compliance.
4 6 6 Third and final batch oftraining for CCG staff tobe completed bySeptember.
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250 Meeting statutoryresponsibilitiesregarding adultsafeguardingtrainingcompliance (CCGand providers).
Membership of SAB L&D sub-group.Provision of e-learning asstatutory training for all CCGstaff.High levels of compliance forLevel 1 and Level 2 training inOxleas and LGT.
No provision of Level 3 AdultSafeguarding training forCCG staff.Oxleas unable to report onLevel 3 or Level 4 AdultSafeguarding trainingnumbers as the training isprovided by the localauthority.
2 training sessions have been deliveredin June and July 2016.Good compliance for awareness-e-learning training in main providers asevidenced through quarterly adultsafeguarding dashboard returns.
The number of staff that haveattended external trainingprovided through RBG learningplatform (Me Learning).
4 6 6 09/05/16: Still awaitingfor final publication ofIntercollegiateDocument for adultsafeguarding outliningstaff competencies.37 CCG staff identifiedto receive adultsafeguarding Level 3training. All training tobe completed bySeptember 2016.
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259 Lack of availablesocial workersfrom the boroughto jointly completethe ContinuingHealthcare (CHC)Assessment.
The CCG has a jintly fundedsocial worker that works 2 days aweek with the ContinuingHealthcare (CHC) team but thepost focuses on strategic work.The jointly funded social workerin the CCG attends thehome/care home assessmentswith the CHC staff. When thisoccurs, another social workerfrom RBG will attend the weeklyCHC Panel meetings and sign offthe paperwork as required.
Process is still new andneeds embedding intopractice.
Since April 2016, all home/care homeassessments have been jintlyundertaken with a social worker and amember of the CHC team.July audit results showed 83%adherence to joint assessments beingcompleted.
None identified. 3 12 6 Second audit to becompleted regardingcompliance of socialworker presence athome/care homeassessments byOctober 2016.
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262 Overperformancein cost andvolume contractsthat may negatethe benefits of theQIPP programmedelivery.
Blocking of key contracts or partsthereof.External due diligienceconducted on all high riskcontracts and project plan inplace to strengthen.Careful contract monitoring ofkey items by named budgetmanagers.
Establishing a monitoring toolto assure the CCG thatplanned activity levels drivenby QIPP are occuringappropriately.Establishing a report toidentify contract over spendsat an early point so they canbe addressed and mitigatedwhere possible.
Monitoring tool linking QIPP schemevalues planned and actualperformance.
None as yet. 4 6 6 Early initiation of the2017/18Commissioning andContracting intentionsprocess to remove costand volume risks.
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206 CCGs in SEL withNHSE fail toagree on astrategic directionwith partners.
Service TransformationProgramme (STP) beingdeveloped across the sectorwhich covers the strategicdirection for Greenwich CCG andits partners. Sign off by end ofSeptember 2016.
STP to be embedded intoCCG.
Involvement with STP ExecutiveGroup/Project Board.Governing Body and GEG receivereports on impact and implications.PMO in place to advise CCG on theframework for implementation.Regular reports on the review planningguidance and STP regularly provided tothe Greenwich HWB Board.CCG Commissioning Intentions for2017/18 will include analysis andimplementation of the STP workstreams.
Recognition by CCGmembership.
4 4 4 NHSE to assure allSTPs by end ofSeptember.
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186 Failure tocommunicate andengage with thepublic and localstakeholders
Patient and Public EngagementStrategy Action Plan.Ensure PPG representation atPatient Reference Group.Patient Reference Group (PRG).Embedded engagement as aclause in procurementspecification to inform KPIs.Joint working with GAVs andHealthwatch to reach seldomheard communities.Healthwatch on CCG committees(e.g. MMP committee, QualityCommittee etc).Governing Body Q&A.Website.Introduced Engagement andCommuniocations template forProject Managers to supportbusines case development.
Lack of resource to deliverstrategy and proactiveengagement.
Implement monitoring of Patient andPublic Engagement Strategy Actionplan at PRG.Governing Body Q&A.Stakeholder survey results.Regular updates to the GoverningBody.Annual PPG report to NHSE informedby action plan.Ongoing review of PPG andEngagement activity.
Slow progress of plans toimprove PPGs.Pressure to return to financialbalance constraints the breadthof engagement.
3 3 3 Finalise outcome onhow the CCG candemonstratemeasurable actionstaken from feedbackreceived.
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