Risk Management
Introduction
Risk is inherent in everything that we do, from determining service priorities, taking decisions about future strategies, or even deciding not to take any action at all. Good risk management awareness and practice at all levels is a critical success factor for Wolverhampton City NHS Primary Care Trust.
Commissioning a healthcare service is in itself a fundamentally risky activity, so it can be said that we already manage some risks on a continual basis, e.g. making assessments of health economy need, ensuring that we work in relatively risk free environment etc. We will approach management of risk in a structured, systematic and consistent manner.
The Risk Management Policy provides Wolverhampton City NHS Primary Care Trust with a framework for the development of a robust risk management strategy and related processes throughout the organization. Commissioning and Corporate Function will each adopt a risk management strategy appropriate to their objectives.
Risk Management Statement of Intent:
The overall aim of Wolverhampton City NHS Primary Care Trust (PCT) is to be a first class commissioner of healthcare services putting customers and patient/service users at the centre of what they do. As part of this aim, it is vital that the services that are commissioned are healthy, safe and of high a quality.
Integral to achieving this aim is the development and implementation of a robust and integrated system of managing all risks that could potentially impact on the ability of Wolverhampton City NHS Primary Care Trust to commission.
Wolverhampton City NHS Primary Care Trust seeks to develop a comprehensive system of internal controls that assists in the identification and management of risks of a commissioning, operational, corporate and financial nature including fraud, whilst avoiding any loss of flexibility and innovation in service provision.
The management of risk is therefore a key organisational responsibility which all management staff must accept as one of their fundamental duties, and every member of staff must have a real sense of ownership and commitment to identifying and minimising risks.
The Board endorses the Risk Management Policy, which is a proactive approach to:
- Identifying the risks that exist
- Analysing those risks for potential frequency and severity
- Eliminating the risks that reasonably and practicably can be eliminated
- Reducing the effect of those risks that cannot be eliminated
- Putting in place mechanisms to absorb the financial consequences of those residual risks that remain
What is Risk Management?
Risk management is having in place a corporate and systematic process for evaluating and addressing the impact of risk in a cost effective way and having staff with the appropriate skills to identify and assess the potential for risk to arise.
As an integrated governance approach is implemented, Wolverhampton City NHS Primary Care Trust will endeavour to manage risks in a way that takes into consideration all risk factors in order to achieve a ‘holistic’ picture of any issue that contains risks to be managed.
The Board's Commitment to Risk Management
The Board recognizes that risk management is an integral part of good management practice and to be most effective must become part of the Trust's culture. The Board is therefore committed to ensuring that risk management forms an integral part of its philosophy, practices and business plans rather than being viewed or practiced as a separate program, and that responsibility for implementation is accepted at all levels of the organisation.
The Board believes it is important to recognize that risk-taking can bring both rewards and penalties. Modernization of the NHS cannot be achieved without risks being taken. But by understanding fully the consequences of taking those risks staff can have greater confidence in what they do.
Principles of Risk Management
The following key principles are considered essential for the successful implementation of Wolverhampton City NHS Primary Care Trust management of risk:
- There is a true safety culture in which every person in the organisation recognizes their responsibility
- There is a recognition that mistakes and incidents will happen and that healthcare is not without risks
- There is commitment to management of risk at Board level
- Through contracts and quality monitoring, Commissioners will ensure the risk management process is applied to clinical practices in those services it commissions
- There is widespread employee participation and consultation in risk management processes, which will operate in a fair-blame culture.
- There is a mechanism for all incidents and complaints to be immediately reported, categorised by their potential consequences and investigated to determine system failures, without assigning blame.
- There are management systems in place that provide safe practices, premises and equipment in the working environment. Systems of work must be designed to reduce the likelihood of human error occurring.
- The risk management process must be applied to contract management especially when acquiring, expanding or outsourcing services, equipment or facilities.
- Contracts must be reviewed and written to ensure that only reasonable risks are accepted.
- There is a culture of prevention of fraud and deception by employees, contractors or the public.
- On all premises, whether owned or shared, safe systems of work must be in place to protect patients, service users, visitors and staff.
- Effective system(s) of emergency preparedness, emergency response and contingency planning will be maintained.
- There is a mechanism to measure the effectiveness of risk management strategies, policies, plans and processes against NHS best practice and other risk management standards i.e. ISO 31000.
- Wolverhampton City NHS Primary Care Trust provides realistic resources to implement and support effective risk management throughout the organisation.
These principles apply to all areas of Wolverhampton City NHS Primary Care Trust.
Approach to Risk Management
Wolverhampton City PCT will adopt a risk and safety management system that enables planning, organising, controlling, monitoring, measuring, reviewing of risks and auditing of the risk management process.
Risk Management Policies
Risk Management Policy
Risk is the inevitable accompaniment to any human endeavour. An essential element in the corporate management of any complex organisation is the responsibility to minimise risk.
Link: Risk Management Policy to follow
Procedure for the Management of Risk and the Risk Register
In order to create an organisation where integrated governance can flourish, it is necessary to build a framework by which Wolverhampton City Primary Care Trust is accountable for continuously improving the quality of its services and safeguarding high standards of care. A risk management process, based on the requirements of OSHAS 18001, ISO 31000, and incorporating the Australian/New Zealand standard, and covering all risk, strategic, financial, organisational and clinical is an essential pillar of this governance process.
Datix software will be sued to capture and monitor all risks to the organisation.
Link: Policy for Risk Assessment, Risk Grading and Risk Register to follow
Adverse Incident Reporting and Investigation Procedure
The reporting and investigation of adverse incidents and near misses, to staff, patients/ clients and other persons affected by our business, is a vital element of the Trusts Risk Management Strategy, as well as providing a retrospective view so that structured incident investigation procedures can be performed, remedial action plans implemented and lessons learnt shared within the organisation and with key stakeholders. Datix software is used to report and monitor all incidents across the organisation.
There are also systems in place to monitor serious incident reported by those services commissioned by Wolverhampton City PCT.
Link:Adverse Incident Reporting and Investigation Procedure to follow
Notification of Serious Incidents in Commissioned Services to follow
Alerts
The PCT receives different types of alerts from a range of sources within/outside the NHS. It is critical to the business that all alerts are received are processed in a clear and systematic process.
The MHRA is an executive agency of the Department of Health. Its role is to take reasonable steps to protect the health and safeguard the interest of patients and users by ensuring that medical devices meet appropriate standards of safety, quality and performance ant that they comply with relevant directorates of the European Union.
One way in which they do this is by investigating reports of adverse incidents involving medical devices and where appropriate instigating corrective action to reduce the risk of recurrence. Where the results of investigations or other information received, have implications for patients or users a hazard notice device alert or safety notice is issued advising of hazardous products or unsafe procedures. The National Patient Safety Agency (NPSA) also issue patient safety alerts.
The PCT has introduced Datix software to manage the process of alerts. Response to alert are monitored by the strategic Health Authority and compliance is published on the Action Against Medical Devices site. The PCT is also responsible for cascading alerts to Independent contractors and for monitoring of compliance with alerts by services it commissions.
Link: Policy for Management of Alerts to follow
Being Open Policy and Procedures
This policy is designed to support the rights of patient accessing services to be given honesty, transparency, apology and an explanation of what has happened. For services commissioned in Wolverhampton we ensure that all services are adopting and following the guidance outlined for ‘Being Open’.
‘Being Open’ - The policy is aimed at any staff responsible for ensuring the infrastructures in place to support openness between healthcare professionals and patients and/or their carers following an incident .This document gives advice on the ‘dos and don’ts of communicating with patients and/or their carers following harm. This policy is based on guidance from the National Patient Safety Agency, Seven Steps to Patient Safety, Involve and Communicate with Patients and the public’, the National Health Service Litigation Authority (NHSLA) circular 02/02. These documents encourage healthcare staff to apologies to patients harmed as a result of healthcare treatment and explain that an apology is not an admission of liability.
Wolverhampton City PCT Business Continuity Strategy
Inpatient Mortality Summary Report May 2010 – Apr 2011
