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Policy responses and statements
- Name of organisation:
- Heallthcare Improvement Scotland
- Name of policy document:
- Draft Healthcare Quality Standard - Assuring
Person-Centred, Safe and Effective Care: Clinical Governance and Risk
Management
- Deadline for response:
- 30 September 2011
Note: Healthcare Improvement Scotland is a health
body formed on 1 April 2011. It has been created by the Public
Services Reform (Scotland) Act 2010 and marks a change in the way the
quality of healthcare across Scotland will be supported nationally.
Its purpose is to support healthcare providers in Scotland to deliver
high quality, evidence-based, safe, effective and person-centred care;
and to scrutinise those services to provide public assurance about
the quality and safety of that care.
The draft Healthcare Quality Standard is the new core clinical governance
and risk management standard. NHS Boards have a Statutory Duty
to provide an assurance of the quality of care they provide: Healthcare
Improvement Scotland has a Statutory Duty to provide external assurance
of this.
COMMENTS ON
Healthcare Improvement Scotland
Draft Healthcare Quality Standard - Assuring
Person-Centred, Safe and Effective Care: Clinical Governance and
Risk Management
The Royal College of Physicians of Edinburgh welcomes the opportunity
to review this draft healthcare quality standard. Clinical governance
and risk management remain extremely important both internally as drivers
of improvement in the quality and safety of clinical services, and
externally in providing assurance to patients and the public. Comments
follow:
-
The College is particularly pleased
to note the inclusion of “effectiveness” in the clinical
governance and risk management principles and recommends this is
tightened further to encourage the use of “evidence-based best
practice” (page 5).
-
This latest iteration of these standards has four significant merits:
-
it is linked explicitly to the agenda of the NHS as set out
in the Quality Strategy;
-
its emphasis is on self-evaluation, providing HIS scrutiny
can be effective and NHS Boards are not allowed to avoid challenging
issues;
-
it seeks to link what takes place at board level on policy
and strategy with what happens at the 'sharp-end' of delivering
hands-on care and treatment (a particular weakness of previous
versions) although the development and use of frontline staff
should be given more emphasis; and
-
it is much shorter and simpler than previous attempts, relying
largely on data that is already being collected.
-
The detailed self-evaluation questions also seem generally appropriate
and comprehensive, with the only significant gap being reference
to partnership working with others, such as local authorities and
the third sector and which is so important in relation to long-term
conditions. However, these questions might be better phrased “How
does …” to avoid the temptation of closed answers.
-
The emphasis on clinical audit is most welcome and the College
seeks assurance that clinical benchmarks will be selected from
Scottish and UK comparators and after specialist advice including
from the Medical Royal Colleges.
-
The challenge is to develop robust measures that will enable HIS
to assess whether or not NHS Boards are achieving the required
standard and target support to those that are not. Page 10
states that ‘There
are effective risk management systems in operation which identify
clinical, legislative, finance and other risks and are focused
on the safety of patients’. However,
there is no definition of ‘effective’ and how will
NHS Boards be held to account for performance?
-
The use of a quality risk profile will be helpful for Boards and
HIS. The information examples at the top of page 8 should
also include clinical sources such as SASM and other national clinical
audits.
-
Under the capability and culture domain the omission of a clinical
governance committee or equivalent is surprising (page 12, 2a). Also,
in relation to this domain, it would be helpful to remind organisations
of the need to integrate the work of quality improvement teams
with front line clinical teams.
-
It would be reassuring to see explicit reference to feeding back
results to clinical teams to encourage sustained change. This
will help secure clinical engagement and avoid the perception of
a tick box exercise, especially at a time when the drive for financial
balance appears often to frustrate improvement.
-
Should there be mention of new ways of involving patients eg self-care
or self-management (page 16)?
All College responses are published on the College website
www.rcpe.ac.uk.
Further copies of this response are available from Lesley Lockhart
(tel: 0131 225 7324 ext 608 or email: l.lockhart@rcpe.ac.uk)
30 September 2011
Copies of this response are available from:
Lesley Lockhart,
Royal College of Physicians of Edinburgh,
9 Queen Street,
Edinburgh,
EH2 1JQ.
Tel: 0131 225 7324 ext 608
Fax: 0131 220 3939
[12 January 2011]
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