Primary Care Co Commissioning Committee Risk Register Agenda … · 2019-06-20 · Primary Care Co...

1 21 February 2018

Primary Care Co Commissioning Committee Risk Register Agenda Item 309.

December 2017

The table below provides a summary Risk Profile of the Primary Care Co Commissioning risk register for the risks that require further work to provide assurance that they are being managed effectively and any gaps in assurance or controls are being addressed,

Risk No

CCG Priority / Objective Risk Current risk

6 Commission sustainable high quality

services within available resources.

Risk to Business continuity from eMBED as provider of IM&T to GP practices.

20


services within available resources.

Risk to maintaining a sustainable workforce with appropriate skills due to difficulties in recruiting GPs and PNs at a time when the retirement rate will increase over next 2 years

16


services within available resources

There is a risk of some or all the ETTF bids being unsuccessful which may impact on the ability of primary care to expand the services delivered from their practices and maintain facilities to cope with increasing list sizes.

12



Risk of capacity of GPs not being able to respond to patient demand alongside need to provide mentoring to trainees, students and Advanced Nurse Practitioners

12



Risk associated with the change in funding formulae which means practices need to contribute 66% of funding and that all practices may not be able to raise this level of funding Note: Three funding streams required

- NHSE capital - Practice contribution

Revenue costs- CCG

12

11 Commission sustainable high quality services within available resources

Inability to deliver General Practice Forward View due to lack of management resources to drive forward plans.

12

2 21 February 2018

12 Commission sustainable high quality services within available resources

Inability to procure extended access to primary care services as set out in NHSE General Practice Forward View and Planning Guidance

16


services within available resources Inability of eMBED to deliver key IM&T projects within timelines set by NHSE or as required by capital improvement plans Risk added August 2017

20


services within available resources Inability of SRCCG to provide appropriate level of resource( skills and capacity) to support the GP International Recruitment project across the HCV STP Risk added August 2017

20

3 21 February 2018

Risk Threshold Matrix

The risk tolerance/appetite under which risks can be tolerated is a score of 11 or below where the assessment has been undertaken following the implementation of controls and assurances. Risks scored at 12 or above must have an associated action plan. Risks scored at 16 or above must be notified to the Board through the Assurance Framework or via exception reporting.

Monitoring of Provider Services Monitoring of CCG risks

1-5 Low No Commissioner action.

Minimal action may be required Manage/monitor situation within team

Clinical judgement regarding

specific risks may override thresholds

6-11 Medium No Commissioner action.

Minimal action may be required Manage/monitor situation within team

12-15 High

Commissioners will closely monitor the Provider action plan. Persistent risks which remain at this score for over 6 months

will be subject to a Commissioner Appreciative Enquiry. Where 6 or more areas of risk are scored as “High” at any

one time, a Commissioner Appreciative Enquiry will be considered based on clinical judgement.

Action/s within 6 – 8 months

Usually handled within the team by line manager

16-20 Very High

The Trust will be given 3 months to mitigate the risk. If the risk score is not reduced to at least “High” after a period of 3 months then it will be subject to a Commissioner Appreciative Enquiry

Action/s within 3 – 6 months

Senior managers to lead on management

25 Extreme

Immediate Commissioner Appreciative Enquiry.

Immediate action to remove/reduce risks. Action to be taken

on recommendations / further controls within 8 weeks. Action

/ treatment plan required.

Director to lead on the management. Escalate to Audit and Governance Committee

4 21 February 2018

Risk No

Risk Description Lead Person

Initial Risk Current Risk Key Controls Key Assurances (Internal and external)

Gaps in Control and Assurance

Actions required Last review date

C L Rating (CxL)

C L Rating (CxL)

6 Confidence in eMBED to provide level of expertise and resource to support practices. Risk added 13.05.15 Risk reduced to 9 Risk increased to 15 May 2017 Risk increased 28.06.17 Risk split to capture risks associated with Business as usual and project delivery Aug 2017

SC 5 3 15 5 4 20 Service specifications and SLA in place for all current services. IM&T account management meetings and reports review and monitor standard of service delivered. Weekly con calls around project delivery Service reviews discussed at transition Board IM&T strategy developed by IM&T Group now transferred to PCDG Number of complaints monitored Assurance reports from eMBED on action of

alerts and compliance with standards Practice and CS Business Continuity Plans updated, refresh and CCG holds copies of plans.

Involvement of wider practice membership in developing service specification. Escalate through contract management meetings Meetings with practices arranged as IT workshop so as to make clear roles and responsibilities.

IM&T delivery plan to be agreed. IM&T CCG dashboard to be accepted by eMBED and populated .

Improve communications to practices Assess eMBED resilience and ability to deliver projects Continue to raise issues at CMB Ensure contract variations and project end reports reflect status

Decem

ber

20

17

5 21 February 2018

Risk No





C L Rating (CxL)

C L Rating (CxL)

7

Risk to maintaining a

sustainable workforce with

appropriate skills due to

difficulties in recruiting GPs

and PNs at a time when the

retirement rate will increase

over next 2 years

PG 4 4 16 4 4 16 CCG is member of workforce planning Group and attends Y&H HEE meetings from Jan 2016. LMC acting as a coordinator of output from different groups and committees Practices submitting work force data through Y&H HEE and CCG receives quarterly reports but all practices need to be encouraged to use this portal. Workforce development plan includes multidisciplinary recruitment plan. Complaints and Patient Relations reports PTL schedule of events commenced for 2017-18 with in house coordinator Branded recruitment plan in place

Access reports Patient satisfaction surveys Health watch survey being carried to assess access to primary care Patient Participation Group work and planned engagement events CQC reports Work plan and progress reports provided to PCDG. Retirement plans assessment completed in May 2017 and informs recruitment and retention plan Member of LWAB

Progress report on International GP Recruitment from Programme Board

Develop career paths in Primary care Establish diary of recruitment events over next 12 months and CCG to attend. Identify workforce planning tool

Strategic workforce plan for 2015-2020 against which to measure progress being drafted.

Decem

ber

20

17

6 21 February 2018

Risk No





C L Rating (CxL)

C L Rating (CxL)

8

Following outcome of ETTF bids into cohort 1 & 2 there are risks associated with timeliness of delivery of the projects which may impact on the access to funds after 2019 and on the ability of primary care to expand the services delivered from their practices and maintain facilities to cope with increasing list sizes and services delivered. Risk added June 2016 Risk amended Dec 2016 Risk details amended 28.06.17

RM 3 3 9 3 4 12 Scoring matrix agreed by CCG and subgroup assessed all bids against criteria Threshold for submission agreed Strategic Feasibility study carried out to assess CCG area requirements alongside individual bids NHS PS engaged to work up detailed business case for Scarborough South Schedule of meetings with partners and landlords to progress projects Updates provided to PCCC

F&C committee over see submissions and impact on revenue assessed.

Timeline chart required for each project against which to monitor delivery

Consider measuring utilisation of premises to identify under utilisation. Explore opportunities to retain clinical functions in practices with back office functions relocated/centralised. Review impact of revenue following DV valuation

Decem

ber

20

17

7 21 February 2018

Risk No





C L Rating (CxL)

C L Rating (CxL)

9 Risk of capacity of GPs not being able to respond to patient demand alongside need to provide mentoring to trainees, students and Advanced Nurse Practitioners Risk increased to 12 May 2017

3 3 9 4 3 12 Patient satisfaction survey annual report Complaint reports Ability to recruit trainees Member of Y&H HEE Member of LWAB

Number of training practices and mentors in practices to support students

Combined assessment framework for ACP

Develop a workforce recruitment and retention plan by Oct 2017

Decem

ber

20

17

8 21 February 2018

10

Risk associated with the change in funding formulae which means practices need to contribute 66% of funding and that all practices may not be able to raise this level of funding Note: Three funding streams required

- NHSE capital - Practice contribution - Revenue costs- CCG

RM 3 3 9 3 4 12 Strategic Feasibility study carried out to assess CCG area requirements alongside individual bids NHS PS engaged to work up detailed business case for Scarborough South Schedule of meetings with partners and landlords to progress projects Updates provided to PCCC

F&C committee over see submissions and impact on revenue assessed.

Timeline chart required for each project against which to monitor delivery

Review impact of revenue following DV valuation Work with practices and architects to ensure cost efficient design and delivery of projects

Octo

ber

20

17

9 21 February 2018

11

Inability to deliver General Practice Forward View due to lack of management resources to drive forward plans.

SB 4 3 12 4 3 12 Primary care strategy approved GPFV delivery plan approved and updated quarterly Progress reported to PCCC Updates provided to Business Committee, Governing Body and CoCR RAG rated reports to NHSE and LMC

GPFV STP monthly meetings

Resource allocation to delivery plan not yet approved Work plan not approved

Resource allocation to delivery plan to be completed Primary care work plan , including GPFV actions, QIPP projects and contract changes to be documented and signed off by Business Committee and PCCC GPFV STP meeting minutes to be taken to PCDG/PCCC

Octo

ber

20

17

10 21 February 2018

12

Inability to procure extended access to primary care services as set out in NHSE General Practice Forward View and Planning Guidance

SB 4 4 16 4 4 16 Risk to delivery discussed at PCDG and PCCC Resources agreed as interim solution and work commenced and service specification

Lack of delivery plan

Awaiting NHSE guidance on procurement routes

Develop engagement plan with patients and stakeholders to inform service specification. Draft service specification being progressed Combined work with VoYCCG about Ryedale solution. Establish governance for procurement committee.

Octo

ber

20

17

11 21 February 2018

13 Ability of eMBED to deliver key IM&T projects within timelines set by NHSE or as required by capital improvement plans Risk added August 2017

5 3 15 5 4 20 Monthly CMB meetings SLA in place Monthly service review meetings Draft dashboard in place from June 2017

Project end reports Contract variation requests Robust assurance reports from eMBED

Customer satisfaction reports

Raise at Contract Management meetings Request agreed timeline and project management framework from eMBED Monitor project development and delivery closely through weekly calls Review CCG expertise and capacity on delivery of LDR and associated IM&T projects

Octo

ber

20

17

12 21 February 2018

14 Ability of SRCCG to provide appropriate level of resource( skills and capacity) to support the GP International Recruitment project across the HCV STP Risk added August 2017

Governing Body lead GP identified Minimal local Project Management ( one day/week) secured NHSE STP clinical advisor included in steering group.

NHSE and HEE requirements Y&H Responsible Officer included in discussions.

Formal steering group to be established across HCV STP

Discuss appointment of STP project manager as per funding bid at meeting in October 2017 Agree funding for local PM with NHSE and steering group Establish local steering group Progress reports to be established and presented to PCCC

Octo

ber

20

17

Definitions

Initial Risk = risk without controls.

Current risk = risk with controls or controls which have yet to be put in place

13 21 February 2018

Risk Scoring Matrix Methodology Table 1 Consequence score (C) Choose the most appropriate domain for the identified risk from the left hand side of the table. Then work along the columns in same row to assess the severity of the risk on the scale of 1 to 5 to determine the consequence score, which is the number given at the top of the column.

Consequence score (severity levels) and examples of descriptors

1 2 3 4 5

Domains Negligible Minor Moderate Major Extreme

Patient and staff safety

Minimal injury requiring no / minimal intervention or

treatment.

No time off work

Minor injury or illness, requiring minor intervention

Requiring time off work for

>3 days

Moderate injury requiring professional intervention

Requiring time off work for 4-14 days. RIDDOR reportable

incident

An event which impacts on a small number of patients

Major injury leading to long-term incapacity / disability

Requiring time off work for

>14 days

Mismanagement of patient care with long-term effects

Incident leading to death

Multiple permanent injuries or irreversible health effects

An event which impacts on a

large number of patients

14 21 February 2018


1 2 3 4 5


Quality

Peripheral element of treatment or service

suboptimal

Informal complaint/ inquiry

Overall treatment or service suboptimal

Formal complaint

Local resolution

Single failure to meet internal

standards

Minor implications for patient safety if unresolved

Reduced performance rating

if unresolved

Treatment or service has significantly reduced

effectiveness

Local resolution (with potential to go to

independent review)

Repeated failure to meet internal standards

Major patient safety

implications if findings are not acted on

Non-compliance with national standards with

significant risk to patients if unresolved

Multiple complaints / independent review

Low performance rating

Critical report

Unacceptable level or quality of treatment / service

Gross failure of patient

safety if findings not acted on

Inquest / ombudsman inquiry

Gross failure to meet national standards

Human Resources / Organisational Development

Short-term low staffing level that temporarily reduces service quality (< 1 day)

Low staffing level that reduces the service quality

Late delivery of key objective/ service due to lack

of staff

Unsafe staffing level or competence (>1 day)

Low staff morale

Poor staff attendance for mandatory/key training

Uncertain delivery of key objective/service due to lack

of staff

Unsafe staffing level or competence (>5 days)

Loss of key staff

Very low staff morale

No staff attending

mandatory/ key training

Non-delivery of key objective/service due to lack

of staff

Ongoing unsafe staffing levels or competence

Loss of several key staff

No staff attending mandatory

training /key training on an ongoing basis

15 21 February 2018


1 2 3 4 5


Statutory duty / inspections

No or minimal impact or breech of guidance/ statutory

duty

Breech of statutory legislation

Reduced performance rating

if unresolved

Single breech in statutory duty

Challenging external recommendations / improvement notice

Enforcement action

Multiple breeches in statutory duty

Improvement notices

Low performance rating

Critical report

Multiple breeches in statutory duty

Prosecution

Complete systems change

required

Zero performance rating

Severely critical report

Adverse publicity / Reputation

Rumours

Potential for public concern

Local media coverage – short-term reduction in public

confidence

Elements of public expectation not being met

Local media coverage – long-term reduction in public

confidence

National media coverage with <3 days service well below reasonable public

expectation

National media coverage with >3 days service well below reasonable public

expectation. MP concerned (questions in the House)

Total loss of public

confidence

Business Objectives Insignificant cost increase /

schedule slippage

<5 per cent over project budget

Schedule slippage

5–10 per cent over project budget

Schedule slippage

Non-compliance with national 10–25 per cent over

project budget

Schedule slippage

Key objectives not met

Incident leading >25 per cent over project budget

Schedule slippage

Key objectives not met

16 21 February 2018


1 2 3 4 5


Finance Small loss Risk of claim

remote

Loss of 0.1–0.25 per cent of budget

Claim less than £10,000

Loss of 0.25–0.5 per cent of budget

Claim(s) between £10,000

and £100,000

Uncertain delivery of key objective/Loss of 0.5–1.0 per

cent of budget

Claim(s) between £100,000 and £1 million

Purchasers failing to pay on

time

Non-delivery of key objective/ Loss of >1 per

cent of budget

Failure to meet specification/ slippage

Loss of contract / payment

by results

Claim(s) >£1 million

Service / business interruption

Impact on environment

Loss/interruption of >1 hour

Minimal or no impact on the environment

Loss/interruption of >8 hours

Minor impact on environment

Loss/interruption of >1 day

Moderate impact on environment

Loss/interruption of >1 week

Major impact on environment

Permanent loss of service or facility

Extreme impact on

environment

17 21 February 2018

Table 2 Likelihood score (L) What is the likelihood of the consequence occurring? The frequency-based score is appropriate in most circumstances and is easier to identify. It should be used whenever it is possible to identify a frequency.

Likelihood score

1 2 3 4 5

Descriptor Rare Unlikely Possible Likely Almost certain

Frequency How often might it / does it

happen

This will probably never happen/recur

Do not expect it to happen/recur but it is possible it may do so

Might happen or recur occasionally

Will probably happen/recur but it is not a persisting issue

Will undoubtedly happen / recur, possibly frequently

Probability Percentage likelihood of

occurrence 0-5% 6-20% 21-50% 51-80% 81-100%

18 21 February 2018

Table 3 Risk scoring = consequence x likelihood (C x L) Calculate the risk score by multiplying the consequence score by the likelihood score.

Risk Matrix

Likelihood

(1) Rare

(2) Unlikely

(3) Possible

(4) Likely

(5) Almost certain

Consequence (1) Negligible

1 2 3 4 5

(2) Minor

2 4 6 8 10

(3) Moderate

3 6 9 12 15

(4) Major

4 8 12 16 20

(5) Extreme

5 10 15 20 25

1-5 Low

6-11 Medium

12-15 High

16-20 Very High

25 Extreme

The risk tolerance/appetite under which risks can be tolerated is a score of 11 or below where the assessment has been undertaken following the implementation of controls and assurances.

19 21 February 2018

Committee roles & responsibilities – January 2014

Senior Management Team Business Quality & Performance Finance & Contracting Communication &

Engagement

Business continuity

Policy management

Information governance

Freedom of Information

Corporate records keeping

Access to Health Records

SIRO

Caldicott Guardian

Employment rights

Training provision for persons

working in – lead for liaison with

Deanery & WFP

Equality & Human Rights

Whistle blowing

Health & Safety

Human Resources

Co-operation with Prison Service

Vehicles for Disabled (section 5)

Sustainability

Research Governance

Security

Crime & Disorder Act – work with

Police on strategy for drugs &

alcohol

NHS Outcomes Framework and

delivery against domains

Compliance with Children’s Acts

Compliance with Mental Health Act

Delivery of operational

plans (including QIPP ,

and OD, plans)

Service redesign and

project delivery (CCG

objectives and priorities)

Winter planning

National Strategy

Implementation (e.g.

autism, dementia)

NHS 111

Medicines Management

Recommendations to

Governing Body

Emergency Planning

MAJAX

Risk Management

Choice Agenda

End of Life

Autism strategy

Safeguarding

Infection Control

NICE guidance

Serious Incident Reviews

Quality & Patient Safety-

provider reports

Quality of 1⁰ care

(support to NHS CB)

Quality of specialist

commissioning

NHS Outcomes

Framework and delivery

against domains

Continuing Health Care

Complaints ( providers)

IFR process

AQP

Ability to make direct

payments to patients

Power to generate

income

Data Quality – policies /

strategy (inc data group)

Partnership Contracting

Medicines Management

(financial)

Continuing Care Funding

Monitoring delivery of

QIPP initiatives

Monitoring delivery of

financial plan

(commissioning and

management budgets)

Communications &

Engagement

Patient Experience

Media Management

Consultation

Equality & Diversity

Satisfaction surveys (staff)

Complaints (commissioning)

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