Pictured on the front cover of this report is Mr Mohammed Bostan receiving his first COVID-19 vaccine from Dr James Thomas at Long Lee Surgery, Keighley.

Mr Bostan was one of the first local people to receive his vaccine in a local GP practice on Tuesday 15 December 2020.

He is 96 years-old and was a local textile worker before he retired, having spent most of the last 20 years caring for his wife Karamat after she suffered a stroke in 1997. She sadly passed away a few years ago and he now lives with his son, Mohammed Jhangir, close to Keighley town centre.

Mr Bostan said: “If I can help save just one person’s life by encouraging them to have their

Annual Report and Accounts2020/21

Happy, healthy at home in Bradford district and Craven

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

2

vaccination then I’ll be very happy.” He has since had his second dose and is now able to get out and about.

We would like to offer our sincere thanks to Mr Bostan and his son, Mohammed (pictured below) for helping us to promote the vaccine programme and encourage people to take up the offer to protect themselves, their loved ones and our local communities.

Mr Mohammed Bostan and his son,

Mr Mohammed Jhangir

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

3

To find out more about us:

Visit our website: www.bradfordcravenccg.nhs.uk/Follow us on Twitter: @NHSBfdCravenFacebook: NHSBradfordCravenInstagram: NHS.BradfordCravenYouTube: NHS Bradford District and Craven

Contact us: NHS Bradford District and Craven CCGScorex House (West)1 Bolton RoadBradford BD1 4ASTel: 01274 237324

If you would like this report in another format such as large print, please contact communications@bradford.nhs.uk or telephone 01274 237789.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

4

Contents

Page

Foreword: Dr James Thomas, clinical chair 5

Chapter 1: Performance report 8

Performance overview1.1 Our performance in 2020/21: a statement from the chief officer 81.2 About us 101.3 Our vision and principles 111.4 Organisational structure 121.5 Our population 131.6 How we are governed 171.7 Our main providers of service 181.8 The system in which we work 181.9 Sustainability and transformation: our plans and priorities 211.10 Key risks and issues 301.11 Performance summary 331.12 Improving quality 351.13 Our commitment to equality and diversity 421.14 Financial performance overview 441.15 Engaging people and communities 471.16 Highlights of the year 51

Chapter 2: Accountability report

Corporate governance report2.1 Members’ report 542.2 Statement of accountable officer’s responsibilities 612.3 Governance statement 63

Remuneration and staff report2.4 Remuneration report 1172.5 Staff report 122

Parliamentary accountability and audit report 133

Chapter 3: Annual accounts 134

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

5

Foreword: Dr James Thomas

I’d like to thank you for reading the annual report which charts our first – and likely penultimate - year as a clinical commissioning group.

This report looks back at our achievements over 2020/21 and shares some of the challenges we have faced as we have continued our work to prevent ill-health help local people to stay healthy and independent for as long as possible.

Written against the backdrop of the worldwide coronavirus (COVID-19) pandemic which started shortly before the start of the financial year and continues today, this report sets out our work in building ever stronger alliances with our staff, member GP practices, partners and local people, to provide the best care possible during the pandemic.

Clinical commissioning groups are membership organisations, made up of the general medical practices – family doctors and their staff – that work in the area. At their core they are clinically-led organisations, and this year leadership from our members has grown and strengthened.

Although we have been formally recognised as a new CCG this year, our staff and clinical leaders have been working together for a number of years as part of the shared management team of the three former CCGs – Bradford City; Bradford Districts and Airedale, Wharfedale and Craven. This has smoothed the transition, making working as one organisation a natural step to take.

From just about every perspective, the effects of the pandemic have been universally disruptive and damaging. Coronavirus has caused too many untimely deaths, including people near and dear to all of us. In Bradford district and Craven alone, at the time of writing, there have been 1,430 deaths due to COVID-19, and many more people hospitalised and/or fighting the long-term effects of the virus. There is no doubt that the effects of the pandemic on mental and physical health, as well as the economy, will be

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

6

with us for years to come.

But one positive effect of the pandemic locally has been the strong partnerships that we have created, or built upon, to deliver services locally – particularly to the most vulnerable people within our communities.

Public support for the NHS, care services and key workers has been overwhelmingly positive. It has included, for example, local people sewing clinical scrubs, volunteering at vaccine centres, providing food to workers, delivering food to vulnerable people, and so much more.

The pre-pandemic fledgling community partnerships and primary care networks (PCNs) – which are associations between GP practices, other health, care and voluntary services, and local people - have now become forces to be reckoned with. For example, PCNs and GPs practices, have delivered red hubs to provide primary care for people affected by COVID-19, whilst GP practices have run blue hubs for those who were otherwise needing care from their GP or other clinicians.

During the year, we set up a staff testing centre at Marley Fields in Keighley, to test NHS, care and other staff who may have become infected with COVID-19. A true partnership, this site was provided by Bradford Council, staffed by CCG and Bradford District Care NHS Foundation Trust personnel, and provided a service to thousands of staff until its closure earlier this year. On the back of its success, public testing centres were also launched across the district.

Our local partnerships have delivered schemes for PPE (personal protective equipment), urgent treatment, mental health services for patients and staff, and – more recently – vaccination hubs in GP practices, large scale hubs, and pop-up venues such as mosques and car parks. In addition, through our Care@Home partnership, we have supported people who are vulnerable and frail, whether living at home or in care homes in Bradford district and Craven.

Prior to the pandemic, we were working to reduce inequalities – particularly in the Bradford City area. But the pandemic has confirmed that inequalities in our local communities are more widespread and have far-reaching effects, particularly around the spread of the virus and the uptake in vaccination. Because of this, we have launched our Reducing Inequalities in Communities (RIC) scheme, working in partnership with a wide range of health, care and voluntary sector organisations to bring much-needed services to the communities that need, but don’t necessarily use, them. The projects involved deliver interventions across four life stages: birth; childhood and adolescence; adulthood; and later/end of life.

Despite everything, this year we have been able to provide health checks for 88% of people with learning disabilities. This is the first time we have achieved such an excellent response, and gives us plenty to build upon in future years.

Much has changed this year for us as an organisation. Not only have we started life as a new CCG, but – as a route to sustainability - we have also started on a new transformational journey to become on integrated care partnership for West Yorkshire and Harrogate. Whilst we will continue to deliver services at a local (‘place’) level, in April

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

7

2022 our staff will become part of a wider organisation. And whilst the organisation will change, the direction of travel will continue as we have been working towards this moment for a number of years.

As a CCG, and as a partner locally and regionally, we are in a strong position to deliver our vision and strategic ambitions (see page 11 of this report) for the people of Bradford district and Craven.

And finally, I would like to pay tribute to, and thank, CCG senior leaders, staff and our clinical leads, as well as GPs and practice staff.

In these unprecedented times, GP practices have delivered more care to more local people than ever before, whether face-to-face or through digital means, at the same time as setting up and delivering services in red hubs and vaccination centres, and caring for vulnerable people at home or in the places where they live.

And to our staff, who have also worked over and above their usual day-to-day roles, often working long hours, in difficult conditions and with changing mandates. A number of them took on new roles in red hubs, testing centres, or vaccination hubs, often whilst still doing the ‘day job’. Others returned to their clinical roots, helping out our local hospitals and community services by working in intensive care, the fast-track nursing team, the out-of-hospital discharge team and vaccination hubs.

Thank you to all of you, for everything you have done. You are simply awesome.

James ThomasDr James ThomasClinical chairNHS Bradford District and Craven CCG

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

8

Chapter 1: Performance report

1 Performance overview

The purpose of this section is to provide a short summary on our activities in 2020/21. In this section, you will find details of our main priorities, performance against these and the principal risks that we face.

1.1 Our performance in 2020/21: a statement from the accountable officer

Welcome to the first Annual Report for NHS Bradford District and Craven CCG. I hesitate to say it is also likely to be the last in this form because I am not certain what the requirements will be post-March 2022.

I write this after an unprecedented year and at a time when a new Health Bill is about to start its passage through parliament that will see the abolition of CCGs and the creation of Integrated Care Systems (ICSs) as NHS statutory bodies. It is anticipated that ICSs will assume legal responsibility for CCG functions. Our ICS, West Yorkshire and Harrogate Health and Care Partnership, will continue to discharge the majority of those functions in place on the same footprint as our CCG. The majority of CCG staff will technically

transfer to the ICS but will continue to do their work in Bradford district and Craven, as they do now. We have welcomed the changes as they mirror the direction we have been taking for the last few years and the changing role of commissioning is as set out in our new CCG strategy.

Usually in my part of the annual report I talk of our achievements. Of the meeting, or otherwise, of the performance and NHS constitution standards expected of us and of the additional work we are proud of. This last year we have seen the things we usually judge our performance on slip considerably and we are hugely concerned for those people who have missed appointments or had delays in their diagnosis and treatment.

I am so proud though of our colleagues in the CCG and the health and care system who have continued to pursue areas for change and transformation through our Act as One programmes. And through these programmes new innovative ways of delivering care will also help with our recovery work post-COVID.

We have invested significantly in our ability to support our people remotely. The Digital Hub, based at Airedale Hospital, has been the place from where we have supported every care home in the district remotely, with enhanced access to clinicians seven

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

9

days a week, and improved our offer to patients with different forms of respiratory disease. These investments, in both technology and people know-how have put us in a strong position so that we can further develop services of this nature in future.

Beyond our remote and digital services, and when restrictions have allowed, our work with young people in schools has been especially important to us this year. Through an apprenticeship scheme, a team of young people have developed the “kindness, compassion and understanding” campaign, designed to support young people with their mental health and wellbeing. To date they have presented to over 2,500 school age children. It’s a terrific example of how we have worked to support both mental and physical health in the last year.

COVID also shone a harsh light on the health inequalities in our district and has further increased our commitment to making targeted inroads into them. We want local people to live longer, healthier lives regardless of where they live.

Our Reducing Inequalities in Communities (RIC) programme has not stopped because of the pandemic and we have successfully launched 11 projects which focus on closing the health gap in the central locality of Bradford. These projects run across all stages of life, from birth to end of life by providing community and school based mental health support for children and young people; integrating health and community based support to providing proactive, holistic care for people with complex health needs and/or approaching end of life; and enhancing healthcare for people who are homeless. Ten further projects are currently mobilising and will be live in the next few months.

Implementing the RIC programme in this period illustrates the commitment of our partners in working together to reduce health inequalities. Over 50 organisations are involved, including the voluntary and community sector; primary, secondary, and community care; as well as the Bradford Inequalities Research Unit.

Where we have seen successes and proud achievement in the CCG has been in the testing and vaccination programmes and, at the time of writing, we have given vaccinations to over 540,000 local people. Prior to closing the local testing centre we managed 433,300 tests for local people and staff from Bradford and North Yorkshire districts.

The establishment of the red hubs in general practice and the super rota to support people in care homes were also significant challenges which helped to keep people safe during this challenging time. The work our communications and engagement team led to reach out into communities with clear and consistent messaging was praised by partners. CCG staff from all disciplines turned their hand to so many new things to support the COVID effort and I am so grateful to them for the way they adapted.

We were not able to put all of our work on pause. With our NHS Trust colleagues and Bradford Council, we continued to prioritise vulnerable children in our district. We have invested an additional £747,500 in 2020/21 in autism assessments to try and improve in this area.

Beyond Bradford district and Craven, our West Yorkshire and Harrogate Health and

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

10

Care Partnership has continued to develop and our CCG leaders have been visible in leading across West Yorkshire. Dr James Thomas took over from Dr Andy Withers as the chair of the clinical forum and, as well as continuing as joint senior responsible owner to the population health programme, he is also a clinical leader in the planned care alliance. Dr Dave Tatham is the clinical lead for urgent and emergency care, whilst Dr Louise Clarke is the clinical lead to the planned care delivery group and Dr Sohail Abbas has established the first integrated care system (ICS) inequalities academy. I lead on the system leadership and development programme as well as the integrated care partnership (ICP) development work.

Over the next few months we will be developing the successor arrangements for CCGs. Here in Bradford district and Craven this will be through the integrated care partnership for our place which, as well as progressing with our Act as One programmes, will be the principal partnership for health and care in our ‘place’. The governance and accountability between ICPs and the ICS are still to be developed but it is clear from the ICS conversations that primacy of place is the continuing philosophy of the West Yorkshire and Harrogate Partnership.

Helen HirstHelen HirstChief officerNHS Bradford District and Craven CCG

1.2 About us

NHS Bradford District and Craven CCG is the NHS organisation that plans, buys and monitors healthcare services. Most of those people are registered with our 73 member GP practices, although some are unregistered patients living in, or visiting, our area.

We are a clinically-led organisation and our membership comprised family doctor (GP) practices. They, along with other clinicians, are at the forefront of how we operate, the decisions we make, and how we interact with the public.

With the exception of dental, optical and pharmaceutical services and some specialised hospital services, we commission most hospital and healthcare services in the local area and are regulated by NHS England and NHS Improvement (NHSE/I). We have delegated authority from NHSE/I for commissioning GP services.

Through clinical commissioning, doctors have the power and freedom to make decisions about the care and services they commission for their local communities, within the context of the joint strategic needs assessment (JSNA), our own plans and priorities and the valuable feedback we receive from patients themselves.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

11

Although this list is not exhaustive, the services we commission include:

most planned hospital care rehabilitative care urgent and emergency care (including out-of-hours) most community health services mental health and learning disability services.

There are some NHS treatments that we don’t commission or fund. These include cosmetic procedures, various fertility services and treatments not approved by the National Institute for Health and Care Excellence (NICE). People who wish to have treatment that is not routinely funded can ask their GP to make an individual funding request (IFR) on their behalf.

You can read more about our commissioning policies on our website.

1.3 Our vision and principles

Our vision: our core purpose is that by 2023 every person living in Bradford district and Craven will have opportunities to spend more time enjoying life in the best health.

Our identity: our role is to ensure that people are supported to lead their best healthy lives. We are proud of our focus on wellness, not just illness, seeing wellbeing through the experiences of local people. We are committed to improving the health and wellbeing of local people, by concentrating our efforts on prevention and those changes that will close the gap on health inequalities.

Our strategic ambitions: the biggest factors that will help us achieve our vision, are:

• our population – improving health and equity for all local people;• our partnerships – as the vehicle for enabling people to take more responsibility

for their health and self-care;• our people – a skilled, motivated workforce with a culture of continuous

improvement;• our leadership – assuring the sustainability of our health and care system.

We are part of the Bradford district and Craven health and care partnership and, collectively, we have a shared ambition of keeping people ‘Happy, healthy at home’.

Our values are what unites us, and convey the behaviours, attitudes, and a way of engaging with each other that unite us as a team. We have focused on those things that matter the most. They capture how we engage with each other on our shared work. The importance for most of us is that they are lived well, hold us together and provide a touchstone when the going gets tough, our bedrock.

We value trust, inclusion, collaboration and compassion, and demonstrate these by:

believing in the dependability of self and others; valuing and celebrating differences and contributions so that we can all thrive and

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

12

belong; working together with common purpose to make a difference; caring for each other, ourselves, our communities and our environment.

Our strategy started us on our collective journey to living our strategy through the work we do, living the values that unite us and remembering our core purpose and identity. As our partnerships continue to evolve, we will move towards collaborative strategic planning for the needs of our whole population; our commissioning future.

1.4 Organisational structure

Our structure includes five hubs: population health and wellbeing; strategy and planning; finance and digital; quality improvement; and organisation effectiveness. All five work seamlessly together, and across partnerships within our ‘place’ (Bradford district and Craven) and the wider West Yorkshire and Harrogate (WY&H) Health and Care Partnership. More information about ways of working can be found on page 26.

Figure 1: CCG organisational structure

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

13

1.5 Our population

We are responsible for buying and contracting healthcare services for the people living in the area that we cover, 647,000 in total1, with wide variation in population demographics across our geographical area.

Bradford district is an ethnically diverse area, with the largest proportion of people of Pakistani ethnic origin in England. One in four people describe themselves as Asian/Asian British compared to one in 10 for England and there is a high proportion of our population in Bradford City and Keighley who identify as being from a Black, Asian or Ethnic Minority background. Conversely, the wards of Ilkley, Wharfedale and Craven are predominantly white.

More than a third of our population lives in poverty. However, whilst wards around central Bradford and Keighley appear in the 10% most deprived wards in the country, wards in the Wharfe Valley are in the 10% least deprived nationally,

We currently have a young population, with the fourth highest proportion of under-16 year olds in England and a higher proportion of babies, infants, children and young people than the average for England. The proportion of the working age population is lower in Bradford than the average for England. However, the largest increase in our population has been in older people, and this is predicted to further grow, bringing with it the challenges associated with managing increasing long term conditions and the potential impact on the social care sector.

1.5.1 Health inequalities

Health inequalities are unfair, unjust and avoidable differences in the health outcomes across the population and between different groups within society. Our diverse population itself creates challenges and the graphic below shows the stark health inequalities that exist across Bradford district and Craven. People living in the most deprived wards have a much shorter life expectancy than those living just a few miles away.

1 Patients registered at a GP practice in England (NHS Digital) https://app.powerbi.com/view?r=eyJrIjoiNjQxMTI5NTEtYzlkNi00MzljLWE0OGItNGVjM2QwNjAzZGQ0IiwidCI6IjUwZjYwNzFmLWJiZmUtNDAxYS04ODAzLTY3Mzc0OGU2MjllMiIsImMiOjh9

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

14

Figure 2: Life expectancy across Bradford district and Craven

In terms of healthy life expectancy (the average number of years that a person can expect to live in full health that is not hampered by disabling illnesses or injuries) then this gap increases to nearly 20 years – that is, people living in the areas of worst socio-economic deprivation spend on average 19 years of their lives in ill health.

We know that unhealthy behaviours - such as smoking, physical inactivity, poor diet, alcohol and stress - increase the risk of long-term illness and poor health. Inequalities also exist between groups according to other factors, such as gender, ethnic background, certain types of disability and sexual orientation. Wider determinants - such as deprivation, education, housing and the environment in which people live - also contribute towards widening inequalities.

The pandemic has further highlighted existing health inequalities. People living in more deprived areas are more likely to be infected and die from COVID-19 (mortality rates are more than twice as high in the most deprived areas) and the measures taken nationally to control the spread of the virus are also likely to create bigger gaps for some population groups (people from Black, Asian and Minority Ethnic backgrounds are at greater risk of infection and mortality than those from White British backgrounds). As a result, we have in general experienced higher infection rates locally than the national average.

1.5.2 Health indicators

There are a wide variety of measures that are used to assess health outcomes, and in general due to the inequalities above, our outcomes, although improving, remain below national averages. The following is our position against some of these indicators:

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

15

Life expectancy at birth:  Male life expectancy at birth in Bradford in 2017-2019 was 78 years compared to 81.5 years in Craven and an England average of 79.8 years. Female life expectancy in Bradford in 2017-2019 was also 81.9 years compared to 85.4 years in Craven and an England average of 83.4 years;

Smoking*: The estimated smoking prevalence in 2019/20 was 19.1% in Bradford district and Craven compared to an England average of 16.5%. 80.3% of children aged 14-19 years suffering with Asthma were recorded as smoking in the last 12 months in Bradford district and Craven in 2019/20 compared to 78.3% in England. The under-75 mortality rate from respiratory disease that is considered preventable in England in 2017-2019 was 20 per 100,000; in Bradford district and Craven, it was 27.3 per 100,000;

Infant mortality*: The infant mortality rate in Bradford City was 6.9 per 100,000 in 2017-2019, which had come down from seven in 2015-17 against a stable England figure of 3.9 per 100,000. In Bradford Districts it has come down from 6.1 per 100,000 to 5.9 over the same time period. However, in Airedale, Wharfedale and Craven (AWC), the rate has gone up from 2.8 in 2015-17 to 5.2 per 100,000 in 2017-19;

Obesity in adults*: In 2019/20, 13.4% of all adults over 18 years of age in Bradford Districts, 13.1% in Bradford City and 12.9% in AWC were classed as obese against an England average of 10.5%;

Child obesity*:  In 2017/18 to 2019/20, 12.2% of children in reception in Bradford City, 10.7% of children in Bradford Districts and 8.7% in AWC were classed as obese, compared to the England average of 10.7. In year six children, this had increased to 28.1% of children in Bradford City, 25.3% in Bradford City and 18.4% in AWC against an England average of 20.4. The two former Bradford CCGs were among the worst three CCGs in the North East and Yorkshire region;

People in contact with adult mental health services*: In 2018/19, Bradford City had a rate of 4,110 per 100,000 and Bradford Districts had a rate of 3,189 per 100,000 compared to an England rate of 2403;

Depression: The recorded prevalence of depression had increased to 12.2% in Bradford district and Craven in 2019/20 against an average in England of 11.6%. However, during the same time period, new diagnosis of depression remained at 1.5%, the same as England; and

Dementia prevalence in 2019/20 in Bradford district and Craven was 0.8% which was the same as the England average.

*Note: as the only figures currently available, the numbers/percentages shown in bullet points marked with an asterisk denote the areas for the former CCGs in Bradford district and Craven: Bradford City CCG, Bradford Districts CCG and Airedale, Wharfedale and Craven CCG. All three CCGs were replaced by NHS Bradford District and Craven CCG on 1 April 2020.

1.5.3 How we tackle health inequalities

Working with our partners in health and care, tackling health inequalities is a priority for us. It is a long-term process that requires partnership working to shape joint plans for the coming years.  

We are working with system partners to implement a population health management (PHM) approach to tackle health inequalities. This approach looks at poor health outcomes (using intelligence) to identify inequalities (at different population cohorts) in

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

16

order to develop and implement targeted interventions. These interventions don’t necessarily need to be healthcare focussed if the inequalities impacting upon our identified population cohorts are actually identified as being related to the wider determinants. For example, healthcare systems experiencing high numbers of admissions with poorly controlled childhood asthma from a particular locality could be due to a number of factors such as poor housing, damp environment, lack of education for parents and children about inhaler techniques and poor access to primary care for prevention and regular follow-ups. The interventions would need to take account of all these factors in order to be successful.

Our current focus is on the main causes of preventable deaths, including cardiovascular and respiratory diseases, and cancer, and these are reflected in our wider Act as One programme work (see page 24).

Our Reducing Inequalities in Communities (RIC) work is a PHM programme to reduce health inequalities in the 155,000 population living in our most deprived neighbourhoods. In partnership with Bradford Teaching Hospitals NHS Foundation Trust, Bradford District Care NHS Foundation Trust, Central Locality Community Partnerships, Central Locality Primary Care Networks, Bradford Metropolitan District Council, Public Health, the Voluntary Care Alliance and Bradford Institute of Health Research, we have identified a number of priorities and developed a range of projects to address health inequalities (see figure 3 below).

The projects are aimed at delivering interventions across the following four life stages:

Birth: we want to make sure that Bradford babies have the best start in life. We have chosen a group of projects that reduce the impact of known risk factors in pregnancy.

Childhood and adolescence: we want to make sure our children and young people have good mental and physical health.

Adulthood: we want to address the issues that cause early death in our area. This includes focusing on long-term conditions, such as Diabetes, and the health of the homeless.

Later life and end of life: we want to support people as they age, providing proactive care to help manage complex conditions. This includes a holistic approach to mental and physical health support, which is not always just medical.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

17

Figure 3: RIC projects at each stage of life

The RIC programme is working with the Bradford Inequalities Research Unit (BIRU) to support the design, delivery and evaluation of the RIC Programme. The BIRU is a collaboration between Born in Bradford (BiB), the University of York and Queen Mary’s University London. The academic expertise, and access to big data in the BIRU brings a unique element to the RIC programme, providing an opportunity to deliver the most relevant, feasible and evidence informed interventions to reduce health inequalities.

There’s lots of information about the RIC programme, its aims and projects, along with case studies, on our website.

1.6 How we are governed

The CCG council holds the governing body and senior leadership team (SLT) to account and is the voice of our member practices. It ensures effective engagement of all of our practices and represents their interests and statutory responsibilities as members of the CCG. Members of the CCG council are clinicians (usually GPs) and meet no fewer than twice a year.

Our governing body meets bi-monthly in public. It provides oversight and assurance of the commissioning of health and care services for people in our area. Everyone is welcome to attend and observe governing body meetings; we publish the agenda and papers on our website in advance of the meetings.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

18

Our SLT meets weekly with the aim of driving the commissioning process and leading the development and implementation of our commissioning strategy. It reviews and influences service re-design to ensure pathways of care and commissioned services meet the needs of the local population. It engages practices, localities and the population in the work of the CCG.

The primary care commissioning committee makes decisions on the review, planning and procurement of primary care services under delegated responsibility from NHS England. It meets every two months in public. We publish the agenda and papers for the primary care commissioning committee on our website in advance of the meetings.

Details of the membership and activities of these committees are on page 70 onwards of this annual report.

1.7 Our main providers of services

Predominantly, we buy services for patients from four main NHS service providers:

Bradford Teaching Hospitals NHS Foundation Trust (BTHFT) – which runs Bradford Royal Infirmary and St Luke’s Hospital;

Airedale NHS Foundation Trust (ANHSFT), and Bradford District Care NHS Foundation Trust (BDCFT), which cares for people

with community health, mental health and social care needs; and Leeds Teaching Hospitals NHS Trust (LTHT) – specialist services only.

We also work with the City of Bradford Metropolitan District Council (Bradford Council), Craven District Council and North Yorkshire County Council to engage with local people to improve the health of the district. We work alongside them in their roles of providers of social care and public health for the local population.

As well as these, we buy services from a number of voluntary and community sector organisations. They provide truly locally focussed projects aimed at improving people’s health and wellbeing, for example, by promoting awareness, prevention and healthy living.

There are some areas where we work with other local CCGs to commission services for a wider area - for example commissioning Yorkshire Ambulance Services (YAS), NHS 111 and the West Yorkshire GP out-of-hours service.

A copy of the procurement register is available on our website.

1.8 The system in which we work

We work with a number of other organisations and partnerships, including:

‘Act as One’ - collaborating across our system: Working with our partners, we have established ‘Act as One’ as our approach to our place partnership working. It focuses on three key areas: developing our partnership (across Bradford district and Craven);

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

19

delivering our core business; and transforming our services. As part of this, with our partners we have established:

an integrated care partnership (ICP) board, with responsibility for leadership of the health and care system;

a set of system committees and groups to provide assurance and oversight as a whole system; transformation change programmes for agreed priorities; and

a whole system approach to planning, recovery and priority setting which builds on the strong work we have done together over the last few years.

Health and wellbeing boards (HWB): We participate actively in the two local health and wellbeing boards that cover our area: Bradford district wellbeing board and North Yorkshire health and wellbeing board.

The Bradford district wellbeing board comprises the chairs of each of eight strategic partnerships covering everything from safer communities to economic regeneration. This includes our Integrated Care Partnership. Together, the goal is to improve the social, economic and environmental wellbeing of everyone who lives in the Bradford district, with a particular focus on tacking inequalities in all we do. Through this arrangement the CCG is able to get up-stream, tackling the root causes of ill-health, as well as improving access, effectiveness and quality of care.

North Yorkshire's health and wellbeing board is a formal committee of North Yorkshire County Council. The board is where leaders work in partnership to develop robust joint health and wellbeing strategies. These in turn set the North Yorkshire framework for commissioning of health care, social care and public health.

The North Yorkshire commissioners’ forum: This comprises of senior leaders across CCGs and North Yorkshire County Council. Accountable to the North Yorkshire HWB, the forum focusses on strengthening the integrated commissioning agenda to support the delivery of joint and local plans. As Craven is part of North Yorkshire, we work closely with both the county council and Craven District Council in developing local plans to integrate health and social care.

Local authority overview and scrutiny committees: We work with two health and social care overview and scrutiny committees, in Bradford and North Yorkshire. Amongst other things, these statutory committees scrutinise local NHS policy and planning, and the impact that these have in meeting local needs and reducing health inequalities. When we work on policies or plans affecting more than one CCG – for example, across WY&H – the committees may agree to work with one or more other local authorities to establish a joint health overview and scrutiny committee.

NHS England (NHSE) and NHS Improvement (NHSI): As independent arms-length bodies working on behalf of the Department of Health, NHSE/I work together to support the NHS to deliver improved care for patients. Amongst a number of activities, they commission primary care optical, pharmaceutical and dental services and some specialised services. They also handle patient complaints about GPs and GP practices. We have delegated authority from NHSE/I for commissioning GP services.

Healthwatch: as an independent public watchdog, Healthwatch works with people and

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

20

organisations to make positive change happen in health and social care services in the district. Healthwatch is also a key partner helping us to plan services. Healthwatch Bradford and District provides services to people living in the Bradford, Airedale and Wharfedale areas; and Healthwatch North Yorkshire to those living in the Craven area.

Community partnerships (CPs): these were established on the basis that health outcomes are driven, in large measure, by wider social and economic determinants. They engage proactively with communities, focusing strongly on prevention. CPs support service-based interventions through the delivery of integrated care, including anticipatory care to ensure ongoing problems are well managed and people are linked in to existing community supports.  

Each CP has a community leadership team working together to share their knowledge, ideas and expertise to support each other in understanding their roles and how they can work better together to improve the lives and experiences of people in the local community. This new way of working enables CPs to involve and empower their local teams to design, develop and set up new ways of delivering health, care and wellbeing services which they lead on. It provides opportunities for community staff to work in different ways with other organisations.

CPs have a key role to play in tackling health inequalities. They bring together key health, care and wider community services at a local/neighbourhood level. They are able to use data and local intelligence to agree priorities and they have a strengths-based ethos which supports and empowers individuals to be in control of their own health and wellbeing and works to enhance resilience in communities.

Primary care networks (PCNs): Our 12 PCNs are groupings of practices, super partnerships or federations of practices that work together across a 50,000 – 100,000 population footprint to deliver the PCN directed enhanced service which is set out by NHS England. This includes providing additional services - for example, working in conjunction with community providers to deliver services into care homes and providing structured medication reviews. The PCNs have been a critical part of COVID-19 vaccination delivery.

GP federations, super partnerships and other alliances: there are a number of GP federations, super partnership and other alliances with whom we work. These include City Health Limited, Trust Primary Care, Bradford Care Alliance, Wharfedale, Airedale and Craven Alliance, and the super practices, Affinity Care and Modality Partnership.

People’s Board: The People’s Board comprises members of the public from across our diverse communities. Their role is to challenge and support us, and to bring different perspectives into our decision-making.

We were one of the first areas of the NHS to try the idea of a People’s Board. It’s one of the ways that we make sure people’s voices influence the decisions we make. The board meets every month to have open and honest conversations about our strategies and plans. Their role is to represent the views of patients, carers and people in our area; give feedback on, and help develop, our strategies and plans; be proactive in discussing health and care services; and to work with us to identify trends and issues in our local communities.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

21

Patient participation groups and the patient network: At the heart of our approach to involving patients and the public are our member GP practices across the three CCG areas, and their patient participation groups (PPGs). There are so many volunteers working in practices and making a difference through a range of activities from setting up walking groups or self-care events, supporting clinics, or helping gather patient feedback.

The CCGs have brought these volunteers together into a patient network, a thriving forum for learning and sharing effective ways to engage with people at practice-level. As community partnerships and primary care networks develop, we are working to refresh the patient network model.

1.8.1 Organisations that provide services to the CCG

Airedale NHS Foundation Trust: as well as being a provider of healthcare services locally, the trust provides occupational health services on behalf of the CCG, and also supports us with procurement services, along with North of England Commissioning Support Unit (NECS).

Bradford District Care NHS Foundation Trust: as well as being a provider of healthcare services locally, the Trust supports us with health and safety, fire safety, learning and development, and human resources (HR) management.

Engaging People: Engaging People is a voluntary and community sector (VCS) partnership project, commissioned by the Bradford district and Craven CCGs to carry out public engagement on our behalf.  The partnership includes local organisations CNet, HALE, and Bradford Talking Media (BTM).  Engaging People do projects that link to CCG priorities and work streams, helping us reach out to hear the voices and views of diverse groups or communities, particularly potentially disadvantaged groups. 

The Health Informatics Service (THIS): hosted by Calderdale and Huddersfield NHS Foundation Trust, THIS is the provider of our information technology and information governance services

North of England Commissioning Support Unit (NECS): NECS supports us with the provision of data quality services and, along with Airedale NHSFT, procurement support.

West Yorkshire Research and Development: On behalf of the CCGs in WY&H, we host the staff of West Yorkshire Research and Development. In turn, they also provide services to the CCG by helping to transform research questions into research proposals, and working closely with clinicians and partners from academia to increase evidence-based innovation and knowledge exchange within clinical care settings.

1.9 Sustainability and transformation: our plans and priorities

Locally, our plans and priorities for sustainability and transformation are being managed through four distinct vehicles:

the re-setting of our strategy;

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

22

three health and care partnerships in Bradford, and Airedale, Wharfedale and Craven, which includes our determination to ‘Act as One’;

wider partnerships as active members of the West Yorkshire and Harrogate (WY&H) Health and Care Partnership; and

future arrangements for developing integrated care systems and place-based developments, as part of the government’s White Paper in February 2021.

These are set out in more detail at paragraphs 1.9.1 to 1.9.5 below:

1.9.1 Happy, healthy at home: a plan for the future of health and care in Bradford district and Craven

Work is currently underway, via a system wide project team led by Dr Louise Clarke, to replace our place-based health and care plan Happy Healthy at Home (published in November 2017). This re-setting of our whole system strategy is undertaken in the context of our developing integrated care partnership arrangements; and will reflect the strengthened focus on tackling inequalities and building a successful post-COVID future for the people of Bradford district and Craven over generations to come.

1.9.2 Local health and care partnerships

There are three health and care partnership boards (HCPBs) operating within our local area:

HCPB Airedale Wharfedale and Craven HCPB Bradford District HCPB Mental Health, Learning Disabilities and Neuro-Diversity

‘We are the health and care partnership for Bradford district and Craven. We Act as One with the ambition to help people live ‘happy, healthy at home’

The health and care partnerships are forums of health and care commissioners and providers that oversee the work of the transformational and enabling programmes through which we aim to develop new models of care for our population.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

23

Figure 4: Act as One system governance

Each area has a health and care partnership board that oversees the financial, governance and operational aspects of the strategic partnering agreement (SPA). The SPA sets out how they work together in partnership to ensure people stay happy, healthy at home.

The HCPBs will act as collaborative bodies that will ensure the engagement, alignment and refinement of resource allocation and shared programme decision making. This will included shared ownership of delivery for the system programme, relevant system targets and development of community action.

How we work together: Our core approach is to Act As One - putting the needs of our population first, and thinking about the whole person.

The HCPBs have no formal powers delegated by member organisations, but the members of the Board have authority by virtue of their roles, to act as system leaders and to seek to align the decisions of their own organisations with the collective decision making undertaken by the HCPBs.

Members of the HCPBs are expected to recommend that their organisations support agreements and decisions made by the Boards (always subject to each Partner’s compliance with internal governance and approval procedures).

Our approach to system oversight is geared towards performance improvement and development rather than traditional performance management. It will be data-driven, evidence-based and rigorous and will uphold the principles which underpin our Act As

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

24

One approach. The focus will be on improvement, supporting the spread and adoption of innovation and best practice between Partners.

Our vision: The Bradford district and Craven health and care system has agreed to work towards a common vision which is that:

people will be healthier, happier, and have access to high quality care that is clinically, operationally and financially stable;

people will take action, and be supported to stay healthy, well and independent through their whole life and will be supported by their families and communities through prevention and early intervention with greater focus on healthy lifestyle choices and self-care; and

when people need access to care and support it will be available to them through a proactive and joined up health, social care and wellbeing service designed around their needs and as close to where they live as possible.

In short … Happy, Healthy at Home

The HCPBs will also ensure the vision and aims of the WY&H Health and Care Partnership (our ICS) are reflected appropriately in the work and development of the Bradford district and Craven Health and Care System. Within the ICS, local place based partnerships are responsible for agreeing and implementing plans which are increasingly supported by integrated approaches to joint planning and budgeting. These plans should provide a greater focus on both individual and population health management, facilitate integration between providers of services around the individual’s needs, and focus on improving health and reducing inequalities.

1.9.3 Act as One system transformation programmes

‘Act As One’ is the way all of us across Bradford district and Craven operate together, supported by governance and shared decision making, to design, develop and deliver integration across care pathways which better meet the needs of our population. Our vision is to help people live ‘happy, healthy at home.’

Despite the need for services to respond to the pandemic, our Act as One programme continued to make progress during 2020-2021; we have highlighted one achievement per programme below. Our focus for 2021-2022 will be supporting the recovery of services with a clear mandate to tackle health inequalities that have been further exacerbated by the pandemic.

Access to care: we have recruited accident and emergency (A&E) navigators to help support victims and perpetrators of violent crime. The navigators include youth support workers from Breaking the Cycle, a local authority-led service, funded by the West Yorkshire Violence Reduction Unit. In addition, a substance misuse worker has also recently been recruited.

Navigators provide one-to-one support for young people (aged 13-25 years) in A&E who are involved in violence or risk-taking behaviour. Helping them to access ongoing support within the wider community. The A&E navigators include youth support workers from Breaking The Cycle, a local authority led service, funded by the West

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

25

Yorkshire Violence Reduction Unit. The navigators work with perpetrators to reduce the risk of repeat incidents of violent crime and supporting victims of violent crime by providing access to the most appropriate services within a community-based setting.

Another notable success has been our collaborative work with providers in the independent sector to secure additional theatre capacity. As a result we have been able to treat as many patients as possible who have been waiting for their procedures during the COVID pandemic.

Ageing well: we received funding from West Yorkshire and Harrogate Health and Care Partnership for a deconditioning project. We used part of the finding to set up an asset-based community development grants programme with the remaining funding being used to develop training and education resources to raise awareness of deconditioning. Allied health professionals are leading on this and working closely with the Race Equality Network to engage with wider ethnic groups through the provision of videos translated into languages such as Urdu and Bengali.

Better births: the health inequalities group has been reviewing opportunities to work together with local communities to co-produce services that better meet the needs of diverse communities. Work to date includes: expanding the Maternity Voices Partnership across Bradford district and Craven; learning from videos from diverse local community members sharing their experience on accessing care during the pandemic and designing a culturally competent education package in conjunction with faith leaders.

Children and young people’s mental health: Healthy Minds has six apprentices as part of its Youth in Mind service. The apprentices, aged 16 - 23 and living throughout the Bradford district, support the work of Healthy Minds. Their campaign, ‘Kindness, Compassion and Understanding’ aims to inspire people to make a conscious effort to do more of this. The campaign was launched in November 2020 as part of World Kindness Day and coincided with Anti-Bullying Week and Islamophobia Awareness Month.

Diabetes: a clinical forum has been established to lead change for diabetes services across our place. One area of focus has been the need to change the way services communicate and involve people from diverse backgrounds. During the year a targeted engagement programme has been pulled together to find out more about the experiences of people of Bangladeshi heritage on preventing or managing diabetes.

Healthy hearts: during the last year we have developed a number of work streams, including a multi-agency model to support those with a heart failure and those who are yet to be diagnosed.   Another notable success of the programme is the focus on greater self-management of hypertension through 170 blood pressure machines being distributed across our place for those living in the most economically challenged neighbourhoods.

Respiratory: a multi-disciplinary approach has been developed to support people post-COVID. Our long-COVID pathway involves partners across our health and care system including voluntary and community sector organisations and was featured nationally on Channel 4’s Dispatches programme. We have established a trial offering

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

26

digital support to help people self-manage chronic obstructive pulmonary disease (COPD). Early results show a 40% improvement in confidence in people managing their condition.

You can keep up to date with the latest news from Act as One by following us on Twitter @ActAsOneBDC

1.9.4 West Yorkshire and Harrogate Health and Care Partnership

We are proud to be part of WY&H Health and Care Partnership.

West Yorkshire and Harrogate is a large, complex system covering public, voluntary community and social enterprise organisations (VCSE). Collectively we support 2.7million people, including 260,000 unpaid carers. 23% (570,000) of the total WY&H population are children and young people. We are proud to be home to 20% of people from minority ethnic groups, and have a sense of pride in the richness, heritage and diversity of our communities.

Since the partnership began in 2016, we have worked hard with our partners and communities to build the relationships needed to deliver better health, care and wellbeing support to people across WY&H.

In doing so it has enabled us to create meaningful provider collaboratives, such as the West Yorkshire Association of Acute Trusts, the mental health, learning disabilities and autism committee in common, and our joint committee of CCGs. Supported by our politically led and inclusive partnership board (established in 2018) and all our places (Bradford district and Craven, Calderdale, Harrogate, Kirklees, Leeds and Wakefield), we have focused on the strength of joint working to improve people’s lives.

The way we work has led to genuine changes, for example in the delivery of the vaccine programme, hyper-acute stroke units (the critical care people receive in the first 72 hours), vascular services, and assessment and treatment units for people with complex learning disabilities, eating disorder services and a new specialised child and adolescent mental health services being built - to name a few.

It has led to good practice being shared, for example the award winning ‘Healthy Hearts’ programme, where around 6,300 patients have had a change to a more effective statin and 2,400 people who are at risk of CVD have been offered a statin. In total an estimated 1200 people could avoid a heart attack or stroke in the next five to 10 years across the area.  Another important example is the work on inequalities for our Black, Asian and minority ethnic communities and colleagues: understanding impact, reducing inequalities, supporting recovery, and our recently commission ed report on this topic focuses on real action, from housing and jobs to improved planning, representative leadership and improvements in mental health services.  The pandemic has strengthened relationships and trust. Without this solid foundation, our handling of the pandemic would have been much poorer. Issues like maintaining

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

27

personal protective equipment supply, coordinating testing, helping people who were shielding and mutual aid have been led by individuals working for the collective.

We have invested additional funding, over £2.5m in the VCSE to continue their essential work. This stretches to the delivery of care as equal partners, for example support for men’s mental health as part of our suicide prevention strategy; the grief and loss support service and our staff ‘Check-In’ campaign to help prevent staff suicide and our mental health and wellbeing hub for all colleagues.

This is underscored by the established ethical principles that underpin our work to help individual clinical decision makers and multidisciplinary teams have confidence and integrity during the pandemic and into the future.   Our Improving Population Health Management Annual Report (December 2020) sets out the collective difference we have made in the past 12months, including our ambitions to address climate change and housing for health. It also sets out actions for 2021, including violence reduction and the impact of childhood trauma. Just some of our big ambitions set out in our co-produced Five Year Plan.

Whilst the direct impacts of COVID-19 on health are recognised, it is important to acknowledge the economic and societal impacts associated with the long-term nature of the restrictions in West Yorkshire. Residents of West Yorkshire have been under a combination of national and local restrictions for all but two months since the end of March 2020 (accurate March 2021). The economic impact of the pandemic across WY&H has led to significant job losses and a recession which brings additional risks to the health of people.

The relationships we have with the West Yorkshire Combined Authority for the area’s economic recovery plan, Health Education England, the Academic Health Science Network, med-tech and the skills sector, including universities, helps us to look at what we can do together to develop and grow our workforce and support people into better jobs via our People Board work.

As a proud and valued partner, we are pleased with the progress we have made. Together we are sharing and spreading good practice across the area, and ultimately saving more lives by improving people’s health and wellbeing.

We know that more needs to be done to give everyone the very best start and every chance to live a long and healthy life. Only by working together can we truly achieve this.

You can find out more about the difference our Partnership is making here and also by visiting www.wyhpartnership.co.uk or follow @wyhpartnership on Twitter to find out more or get involved.

1.9.5 Developing integrated care partnerships

In February 2021 the Health and Social Care Secretary, with the support of NHS England and health and care system leaders, set out new proposals to build on the response to the pandemic as well as proposals which will bring health and care

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

28

services closer together.

New measures have been set out in a government White Paper which includes modernising the legal framework to make the health and care system fit for the future. The proposals it sets out support health and care partnerships like the WY&H Health and Care Partnership to deliver quality care to their communities, in a way that is less legally bureaucratic, more accountable and more joined up.

Many of the proposals in the White Paper are things that we already do as a Partnership, with local places continuing to manage and provide care locally.

Our Partnership will continue to be inclusive, with arrangements in place that work for us locally and at a West Yorkshire level, and most importantly for the people we support. The way local partners work together won’t change – at a high level it may be managed differently with many people not seeing any difference apart from the positives of joined up, seamless care. Public involvement at all levels is essential and will continue locally.

Under the proposals, our Partnership for West Yorkshire would become a statutory body with a board that takes on the commissioning functions of CCGs and financial accountability.

The Partnership will be able to delegate to place level (in our case, Bradford district and Craven), and to provider collaboratives such as the West Yorkshire Association of Acute Trusts and Mental Health Providers, for them to manage their work best for local people. Place-based arrangements between councils, the NHS and providers of health and care will be left to local organisations to arrange based on what works best for local people. This is all about putting people at the heart of everything we do rather than structures.

The draft White Paper proposal includes a commitment to seek stability of employment for current staff working in CCGs. This is essential as we need their skills and expertise at both a local and West Yorkshire level. One of our aims in West Yorkshire is to ensure as little disruption as possible while having the greatest possible impact. Any changes will build on our work to date and reflect and support what is already going on.

Any changes made will not impact on other colleagues or the running of local care services.

Work in local places is not wholly defined by the latest policy developments. It is a continuum that stretches back in time, especially for local leaders, and staff, who have decades of experience as councillors, clinicians, social workers, therapists, GPs and third sector leaders. Without them we would achieve nothing.

The government will look at the White Paper and decide the next steps over the summer. The approach set out in the White Paper could become law later during the next year with arrangements fully in place by April 2022, if it is agreed.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

29

1.9.6 Sustainable development summary

We are committed to continually developing its sustainable working practices, through our commissioning and with our member practices and staff, because sustainable development has good health and wellbeing at its heart.

People in the district will live longer and expect their lives to be healthier and happier than those of their predecessors. The system-wide vision described in the Bradford district and Craven plan for the future of health and care, happy, healthy at home, reflects this: to create a sustainable health and care economy that supports people to be healthy, well and independent.

Act as One is the approach we take with our partners across the system to deliver this vision, using our collective skills, knowledge and resources in the most effective and sustainable way to benefit local people.

Our year started with the creation of a single new organisation, NHS Bradford District and Craven CCG. The work to dissolve the three previous CCGs and establish the new single one, helped us to further streamline our governance and ways of working, building on our shared working arrangements and continuing our progress in reducing duplication and driving efficiencies.

The year has been marked with the global COVID pandemic and throughout the year, our working practices have significantly changed with the great majority of staff having worked from home throughout the year.

Our previous objectives of reducing our environmental impact have been accelerated during this time. Examples include:

reduction in paper use and printing costs in line with our paper free/clear desk aspirations;

reduced travel to work associated with lock down and working from home advice; and

the enhanced use of new technology enabling agile and remote working as well as more efficient ways of holding meetings, again reducing travel and therefore carbon emissions.

We have also consolidated our learning and development offer through a workforce development forum, to ensure all staff have a consistent offer which will equip them for the future infrastructure changes and further development of the integrated care partnership.

Our future direction of travel will help us to realise efficiencies in the way that we work across the district.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

30

1.10 Key risks and issues

1.10.1 Key issues from the risk register

The commissioning assurance framework (CAF) is the key mechanism for identifying and monitoring the management of the key strategic risks affecting the achievement of our strategic objectives. The CAF was developed during 2020/21 and approved by governing body on 9 March 2021 when it was accepted as a fair reflection of the CCG’s strategic risk position. The full CCG CAF can be found in our governing body papers and is summarised below:

Improving population health and reducing health inequalities – poor outcomes and health inequalities have been highlighted by the pandemic with both direct and indirect impacts on the economy, education, physical and mental wellbeing, particularly for those living in areas of the worst socio-economic deprivation.

Building strong relationships – the growing financial pressures created by an increase in demand for services could result in agreed strategic and operational plans to deliver health and care not being realised.

Developing and delivering targeted programmes to address gaps in quality and outcomes – unwarranted variations in quality and care cannot be effectively addressed due to shortfalls in workforce capacity, capability and skills resulting in failure to close the gap. Our efforts may not have the impact we desire due to some determinants of quality and outcomes which lie outside of the control of health and social care.

Working collaboratively in Bradford district and Craven through our ‘Act as One’ way of working – changes to health services models required to achieve clinical and financial sustainability may not be acceptable to key stakeholders, including patients, resulting in the failure of our approach.

Developing stronger collaborative partnerships locally to develop an integrated care partnership – we may fail to gain sufficient organisational traction through a range of factors, including leadership challenges, failure to agree governance arrangements and future form and function, resulting in failure to achieve a viable form in time to receive delegated responsibilities from the Integrated Care System.

Achieving our strategic objectives - CCG staff may struggle to adapt to new, externally facing, system-focussed roles as we move towards the new integrated care system and partnership operating model by 1 April 2022.

Maximising value for money - we may not be able to maximise value for money in the use of healthcare services to ensure we can make shared decisions on how to use our resources to improve population health.

In response to the pandemic, a separate register was established to record and monitor risks faced by the organisation associated with responding to the pandemic. Initially, the COVID-19 risk register was reported to the SLT on a fortnightly basis and then moved to reporting on a monthly basis. In March 2021, it was agreed that the two risk registers would be combined and both corporate and COVID-19 related risks would be reported on a bi-monthly basis. The governing body received regular updates on the response of the organisation to COVID-19 related risks through receipt of the

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

31

COVID risk log which was included as part of the public meeting papers which can be found on our website.

As reported to the governing body in March 2021

based on the three former CCGs’ governing body assurance framework the CCG has made progress in developing a new commissioning assurance framework aligned to the CCG’s commissioning strategy. The CAF identifies the principal strategic risks to delivery of Bradford district and Craven vision and strategic ambitions, from a commissioning perspective;

due to the proposed legislative changes to establish Integrated Care Systems (ICS) on a statutory footing and the abolition of CCGs, there has been one new risk relating to Integrated Care Partnership (ICP) readiness from 1 October 2021 in shadow form and to be in place from 1 April 2022. In addition, there is an adapted risk regarding CCG transition, which now reflects the transition of CCG and other associated staff to the ICS;

one of the financial strategic risks was closed due in large part to the place based development of our Act As One way of working, which negates the need to describe the way we allocate resources separately. Across Bradford district and Craven our partnership has evolved over the past year and all partners are signed up to the strategic partnering agreement (SPA) and are working together to allocate resources across Bradford district and Craven.

The CAF is supported by the corporate risk register which records the operational risks faced by the organisation. Risk register reports, focussing on high level risks (those scoring 15 or more) are provided to each of the governing body public meetings and can be found in the governing body papers on our website.

1.10.2 Emergency preparedness, resilience and response

NHS England is responsible for the management of any health response to major emergencies and for leading incidents involving public health outbreaks. The Civil Contingencies Act (CCA) 2004 places duties on CCGs to make local arrangements to deal with emergencies, at the same time as maintaining services to patients and assisting other responders in preparing for emergencies. The NHS EPRR framework also places a number of key responsibilities on CCGs.

Annual emergency planning assurance: For 2020, NHS organisations were asked to submit an EPRR assurance statement rather than a full self-assessment to reduce workload burden and allow organisations to focus on the management of COVID-19.

Our 2020 EPRR assurance statement covers three areas:

1. Updated assurance position of any organisations that were rated partially or non-compliant in 2019/20

We were rated as substantially compliant in the 2019/20 EPRR self-assurance exercise. Of the two standards where we were rated as partially compliant, we are now fully compliant with one of these standards (having an outbreak plan in place). We

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

32

have no plans to have loggists available 24/7 and so will remain partially compliant with that standard.

2. Assurance that all the relevant commissioners and providers of NHS-funded care have undertaken a thorough and systematic review of their response to the first wave of the pandemic, and a plan is in place to embed learning into practice

We have reviewed our response to the pandemic and done staff surveys. What we have learned has been continually incorporated into our management of COVID and applied to our re-start and recovery work. Where applicable, it will also be included into EPRR work streams. 

3. Confirmation that any key learning identified as part of this process is actively informing wider winter preparedness activities for your system.

We are working with the wider health economy to incorporate key lessons into winter planning.  We will expand the operational management of COVID-19 to include the consequences of winter and any resulting plans/mitigation required to address them.  This will ensure integration, both within the CCG and wider health economy, and also ensure response arrangements meet the requirements of both COVID-19 and winter.  A system winter plan for Bradford district and Craven has been developed that includes learning from COVID.

Incident response plans: We have incident response plans in place, and are an active member of the West Yorkshire Local Health Resilience Partnership (LHRP), working with other organisations to develop and share plans in preparation for any health incidents.

Together with our health and care partners, we have joint plans that describe how we will work together during periods, such as winter, when services are busy and under pressure. We have 24/7 on-call arrangements, where providers can escalate issues if they cannot maintain delivery of core services. This on call-rota is staffed by our directors and associate directors. We train our on-call staff on a regular basis so that they have the skills and knowledge to respond to incidents, and representatives attend exercises of other organisations to act as players and observers.

Exercises: In the past year, we have attended an exercise under the Control of Major Accident Hazards (COMAH) Regulations 2015. We also attended a multi-agency exercise to test plans to address the withdrawal of learning disability services by a private contractor.

Reinforced Aerated Autoclaved Concrete (RAAC) planks: these were used when constructing public sector buildings in the 1960s, 70s and 80s, including a group of prefabricated hospitals under the government’s “Best Buy” building programme. However, RAAC planks used in buildings constructed prior to 1980 have now exceeded their useful life, meaning affected trusts need to carry out frequent inspections and expensive maintenance.

In May 2019, an alert was issued by the Standing Committee on Structural Safety relating to aerated concrete. Airedale General Hospital is constructed almost entirely of Siporex, a form of aerated concrete. Detailed monitoring and maintenance

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

33

arrangements have been put in place to ensure safety of patients and colleagues. A new hospital at the site is the preferred solution but, in the interim, ANHSFT has also put in place solutions to respond to any specific issues that occur for example cracking or panel deflection.

Business continuity planning has included a desktop exercise to test the activation and emergency receiving arrangements of regional partners in the event of a whole site evacuation of Airedale General Hospital as part of wider contingency planning and risk mitigation measures.

EU exit: Our EU exit action plan will ensure that we address all requirements of the guidance, with a lead identified for each area. We meet regularly with the local authority to ensure that our actions to respond to EU exit are co-ordinated.

COVID-19: We have been in formal command-and-control arrangements since March 2020, with established internal gold, silver and bronze work streams. A specific silver health and care system work stream has continued to operate throughout. We set up an incident control centre to ensure that we could respond promptly to COVID-related queries and issues.

A number of COVID work streams have been managed through action, and risk and issues, logs. Some of these work streams have been:

supporting primary care to run the red hubs to manage patients with COVID symptoms;

running a testing centre at Marley Fields that has been a national top performer;

re-designing services through the care at home work stream to support the COVID-19 response; and

supporting the delivery of the local vaccine delivery programme across hospital, primary care network (PCN) and community vaccination hubs.

1.11 Performance summary

In the absence, this year, of the performance analysis section of this annual report (as a result of organisations working on the pandemic), this report includes a shorter summary of the CCG’s performance.

During the pandemic we have worked to ensure that every patient with COVID-19 who needed an inpatient bed received one, and established sufficient capacity for those who needed mechanical ventilation. The actions taken to ensure this COVID-19 capacity was available during the peaks through 2020/21 have impacted on standard performance measures. The recovery of our waiting lists is now underway and we have secured additional elective recovery capacity with independent sector support.

1.11.1 Constitutional duties and national access targets

CCGs are statutory organisations responsible to their governing body for the delivery of both their statutory and constitutional duties, and improvements in the health outcomes of their population. Our constitutional duties include delivery of a range of national

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

34

access targets for both hospital and mental health services. Performance for 2020/21 is shown in the table below:

Table 1: NHS constitutional targetsTarget Q1 Q2 Q3 Q4 National

18 week referral to treatment waits 92% 62.7% 56.1% 72.2% 64.5% 62.1%

Diagnostics (within 6 weeks) <1% 35.0% 55.7% 67.8% 70.3% 63.9%A&E 4 hours # 95% 92.2% 91.0% 85.5% 86.0% 86.8%Cancer 2 Week Wait 93% 93.1% 95.8% 93.5% 94.7% 88.7%Cancer 2 Week Wait (Breast) 93% 93.1% 96.1% 69.5% 86.8% 76.0%Cancer 31 day (First Treatment) 96% 97.4% 93.8% 94.7% 91.9% 94.9%Cancer 31 day - (Subsequent Treatment - Surgery) 94% 84.7% 79.2% 82.0% 83.2% 88.0%

Cancer 31 day - (Subsequent Treatment - Anti-cancer drugs) 98% 98.7% 100% 100% 99.3% 99.1%

Cancer 31 day - (Subsequent Treatment - Radiotherapy) 94% 99.2% 97.9% 99.1% 97.9% 96.6%

Cancer 62 day 81% 79.9% 81.3% 72.1% 77.1% 74.3%Cancer 62 day (NHS Screening) 90% 56.4% 33.3% 57.8% 69.4% 74.9%Cancer 62 day (Consultant referral upgrade) 90% 78.4% 88.9% 60.2% 88.1% 82.5%

IAPT Access5.50% for 2019-

20 rising to 6.25% by end of

2020-21.

2.6% 3.2% 3.5% 3.5% *

IAPT 6 week waits 75% 95.8% 95.6% 97.7% 97.0% * 89.6%IAPT 18 week waits 95% 99.5% 99.2% 99.7% 99.6% * 97.9%IAPT Recovery 50% 51.1% 56.5% 57.1% 55.7% * 50.4%Early Intervention in Psychosis - % seen within 2 weeks

50% increasing to 60% by 2020/21

84.6% 80.7% 79.2% 74.8% 71.9%

Early Intervention in Psychosis - % seen within 2 weeks

50% increasing to 60% by 2020/21

84.6% 80.7% 79.2% 74.8% 72.0%

Notes: # A&E performance is an average performance for the two provider trusts* national IAPT access is not available and national waiting IAPT data is 11 months to February 2021 (March is not yet available)

The pandemic has had a big impact on both urgent and planned care performance.For most of 2020 the majority of clinical activity that didn’t fall into the emergency, urgent or cancer categories was initially paused. This involved closing to new referrals for patients not falling into these categories. Wherever possible, patients were invited for a telephone/virtual review.

All urgent and fast track referrals received during this time were clinically triaged. For any appointments that are still deemed necessary. The default position for necessary activity was carried out virtually rather than face to face in order to reduce the amount of footfall within the hospitals and to support the aim of social distancing wherever it is safe to do so.

During recent months the focus has been on a phased implementation plan to recommence/increase elective theatre activity.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

35

There is an ongoing impact of COVID-19 on inpatient mental health acuity resulting in an increase in the number of high levels of incidents involving managing violence and aggression and an increase in the number of episodes of full physical intervention, leading to high levels of occupancy, associated inpatient staffing pressures and increased out of area requirements. There has been a reduction in face to face contacts and an increase in digital interventions.

You can read more about our performance on our website and in regular reports included with our governing body papers.

1.11.2 NHS oversight frameworkNHS England and Improvement has a statutory duty to make an annual assessment of CCG performance and meets this duty through the NHS System Oversight Framework (NHS SOF).

During 2020/21 NHS England and Improvement held quarterly whole system review meetings with the Health and Care Executive Board which is made up of system leaders under our strategic partnering agreement for Bradford district and Craven.

The CCG year end assessment review process for 2020/21 has been simplified, due to the continued impact of Covid-19 and the change in priorities in response to this. There will be no algorithmic assessment to provide an overall CCG rating as there has been in previous years. A narrative assessment letter will be sent identifying areas of good/outstanding performance, and areas for improvement, including areas of particular challenge across five priority areas:

Improve the quality of service Reduce health inequalities Involve and consult the public Comply with financial duties Leadership and governance.

CCGs have the option to publish their assessment letter or a summary of key points and our letter will be available, by the 31 July 2021, on our CCG website.

1.12 Improving quality

CCGs are responsible for the quality of commissioned services. To fulfill this function we focus on: supporting and facilitating quality improvement; patient safety; delivering agreed outcomes; improving patient experience; flexible and sustainable models of care to meet individual need; and having the right leadership across the system.

We are dedicated to delivering and developing high quality, safe, effective and innovative healthcare services that meet the needs of local people.   To be assured that this is happening, our governing body receives regular reports on quality matters, the outcomes of deep dives (for example, into cancer services) and regular updates from our providers.

Under the direction of the system quality committee (SQC) and the quality committee

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

36

(QC), we take a methodical approach to understanding, monitoring, analysing and acting on a range of quality data and information, using curiosity and our ongoing relationships with provider colleagues as our underpinning principles. We triangulate and assess a range of quality metrics and associated information to identify exceptions, along with local intelligence and workforce data to elicit a quality position of services.

As part of our mainstream contractual process each main provider has a contract and quality management group (CQMG) which is supported by patient safety and quality assurance processes. These processes have been adapted to improve system working and include lean processes as part of the reset from the pandemic response. The latter provides an opportunity for us to delve deeper with the provider on quality areas and enables us to identify areas that may require further understanding or interrogation. This has also enabled us to form closer working relationships with Care Quality Commission (CQC) and Healthcare Safety Investigation Branch (HSIB) to streamline our assurance processes and learning for the benefit of improved patient safety.

Over the past 12 months, we have worked with providers to identify several quality areas which required a further ‘deep dive’ and subsequent presentation and discussion at the JQC. This has often resulted in further challenge or action for providers to ensure delivery of high quality, effective services of positive patient experience.

To deliver the NHS constitution standards and the ‘must dos’ we ensure all quality measures are based on the best available evidence and monitor them accordingly. We work with our providers to ensure that quality requirements are adhered to and co-ordinate rapid intervention when quality and safety is compromised, where appropriate.

Our providers must meet a number of essential quality and safety standards set out by the CQC. As service commissioners, our contracts include other quality requirements for providers that are above the essential CQC requirements. Alongside the CQC we support providers to celebrate areas of strength and improvement and target areas of challenge.

We are a member of the West Yorkshire quality surveillance group. This group enables commissioners and regulators to discuss and share system-wide quality concerns, areas of best practice and intelligence.

Quality accounts are a vehicle for shared understanding of quality improvement priorities with our providers, and include mandatory reporting on a core set of quality indicators. Importantly, providers are encouraged to celebrate excellence, champion quality improvements initiates and outline progress with external requirements such as national clinical audits.

As part of our delegated responsibility to commission GP primary care services, we have a duty to improve the quality of such services. Ultimately, this is discharged through the Primary Care Commissioning Committee (PCCC), the Contract Assurance Group (CAG) and the Quality Committee which oversee the roll out of the primary care quality assurance framework. 

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

37

We are continually reviewing available information and data to ensure effective and efficient service delivery and also that the best possible outcomes for people are provided. We use the monitoring of outcomes data to inform and review our priorities, areas of emphasis, and work plans through regular reporting to SLT, governing body and QC. We use nationally published data and regularly benchmark with similar CCGs to so that we can identify where we can learn from others to improve our outcomes.

Patient safety is about maximising the things that go right and minimising the things that go wrong. It is integral to the NHS definition of quality in healthcare, alongside effectiveness and patient experience. We are committed to fulfilling the ambitions outlined in the National Patient Safety Strategy (2019) and are in the process of ensuring that our Patient safety specialists are trained in line with the strategy.

The NHS Long Term Plan describes the development of new ways of working in primary and community care that can increase the focus on safety. Our primary care networks (PCNs) provide an opportunity to promote a safety culture and focus on continuous improvement.

The system which the CCG is part of has a collective intent to improve safety by recognising that we can improve the way we learn, treat staff and involve patients in incident investigations.

Responding appropriately when things go wrong in healthcare is a key way we can continually improve the safety of services delivered. We strive to reduce the occurrence of avoidable harm and have robust assurance mechanisms in place. We monitor patient safety with all our providers and ensure that all serious incidents (including ‘never events’) are reported and robustly investigated. Appropriate action plans are developed as a result of incidents and learning is shared and, most importantly, put in into practice.

We meet regularly with our main NHS providers, attend providers’ patient safety and learning assurance groups to discuss details and ensure any necessary actions are implemented to maximise learning to improve patient safety, and facilitate improvement through the WY learning forum.

Throughout the COVID pandemic quality improvement and quality assurance has been at the forefront of the response from the system and the CCG. Interventions supporting the system include:

facilitation of the development of services and pathways to support frail elderly living in their own homes and in care homes;

strategic and operational leadership of the discharge from hospital workstream. Ensuring that patients are discharged safely and effectively when medically fit to leave hospital;

COVID vaccinations – pathways, planning assurance and delivery; improvements to system wide Infection Prevention and Control support within the

care sector; completion of joint investigations and responding to incidents, stakeholder queries

and concerns across the health and care sector; management of processes for learning from deaths of people with a learning

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

38

disability (LeDeR), and hosting of West Yorkshire LeDeR service to deliver the programme in line with the NHS Long-term Plan and as part of the Learning from deaths initiative;

Bradford COVID-19 ethics committee (and Silver CERG) has been a successful way of system working with medical directors, Mental Capacity Act lead, chief nurse and primary care colleagues to support and work through challenges that occurred through the pandemic; and

the engagement and commitment of providers has allowed the CCG to help them address issues related directly to and secondary to the pandemic response and helped forge more system level working relationships across the board.

Regulatory assessment: In response to the pandemic the CQC adapted its regulatory approach and routine inspections and, to reduce duplication and avoid unnecessary burden for providers, it was agreed that the Annual Regulatory Reviews (ARRs) should cease from 1 April 2020. 

However, to ensure continued safety and assurance during the pandemic period the CQC developed an interim Emergency Support Framework (ESF).  This framework was introduced to primary care on 18 May 2020.  Only one practice in Bradford district and Craven received an ESF contact and following this no further action was required.

As the risks from the pandemic changed, the CQC process continued to evolve and the ESF was replaced with the Transitional Regulatory Approach, also known as Transitional Monitoring Approach (TMA).  The TMA is a risk based approach to monitoring services focussing on existing key lines of enquiry and patient and staff feedback.   The findings from the TMA are shared with the provider but not published. 

Currently, we have 67 GP practices rated by the CQC as ‘good’; three ‘outstanding’ and one ‘requires improvement.

For hospital services (including independent health and mental health services), the CQC continued with a risk-based approach to regulation, undertaking inspection activity where there was a clear risk to safety. Mental Health Act (MHA) monitoring visits to ensure the rights of vulnerable people continued. Outside of the CQC inspection regime, our three main hospital/community service providers have continued to engage monthly with CQC relationship teams. In response to findings of previous CQC inspections, progress against CQC improvement action plans continued with Trust Board oversight, as did assurance groups and reviews to test out the embedding of learning across the five key lines of enquiry. In response to regulatory concerns regarding Cygnet hospitals, action has taken place at both a national and local level, and included an organisational safeguarding enquiry (Cygnet Woodside), focused CQC inspections at Cygnet Woodside (September 2020). 

As similar quality concerns emerged nationally across Cygnet, further measures were put in place to support the regulatory response and share intelligence; this included enhanced wellbeing checks of placed service users. Alongside Bradford and Craven CCG, NHS England/Improvement and the CQC monitored the progress of the required improvements via a Quality Review Group.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

39

During the pandemic, the care sector, CCG, Bradford Council and stakeholders have found innovative ways to work in partnership across integrated care. However in what has been a difficult and unprecedented year, risks to the sustainability and resilience of the care home sector continue. Due to restrictions on attending care homes, fewer CQC inspections have taken place. However, where inspections have happened there appears to be a trend for reducing quality, with the number of inadequate homes in the district increasing over the last year.

As of May 2021, across Bradford and Craven CCG seven homes are inadequate and are in special measures, and we are outliers compared with both the regional and national averages. Table 2: comparison of care home CQC ratings

May Data Outstanding Good Requires Improvement Inadequate

National 4.43% (653) 78.06% (11508) 16.2% (2388) 1.29% (190)

Yorkshire & Humber 3.97% (56) 76.74% (1082) 17.87% (252) 1.42% (20)

Bradford district 5.41% (6) 69.37% (77) 18.92% (21) 6.31% (7)

Craven 0% (0) 81.81% (9) 18.18% (2) 0% (0)

Bradford district and Craven combined 4.91% (6) 70.91% (86) 18.85% (23) 5.73% (7)

We continue to work in collaboration with the council and system partners to support these homes via the council’s serious concerns and enhanced surveillance governance arrangements.

1.12.1 Safeguarding

Safeguarding adults and children remains a priority for us.  The safeguarding team works collaboratively across the health economy and ensures we are meeting our statutory duties.  These include discharging our functions with due regard to safeguarding children and adults at risk of abuse, within both internal processes and our role as commissioners of health care for the local population, in line with Safeguarding Children, Young People and Adults at Risk in the NHS: Safeguarding Accountability and Assurance Framework (updated 2019).

We are committed to working in partnership with provider organisations and all members of the local safeguarding adult boards and children partnerships, to help ensure that children and adults at risk of abuse are identified and protected from harm in the Bradford district and Craven. During the pandemic our safeguarding team has continued to work with the multi-agency partnerships, alongside supporting the wider CCG in responding to the safeguarding issues that have emerged and continue to emerge as a result of the pandemic.

You can read more about our safeguarding role on our website

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

40

1.12.2 Research and development

On behalf of CCGs across the area, we host West Yorkshire Research and Development. Its staff help us to meet our statutory functions under the Health and Social Care Act by: developing research ideas with local NHS partners and universities; ensuring that those research ideas are able to meet the requirements of reviews by

the Health Research Authority and Research Ethics Committee; enabling the recruitment of research participants through an ongoing programme of

engagement with our NHS providers; and making available the resulting evidence to both commissioners and service

providers.

Throughout 2020/21, the team has worked closely with acute providers to enable therapeutic COVID research trials, and with all providers to ensure the success of COVID vaccine trials. They have also worked with our general practices to ensure continued antibiotic stewardship by using an audit and feedback approach.

1.12.3 Personalised commissioning

We work across all sectors of the health and social care economy to meet our responsibilities to those who require personalised care commissioning, in line with the relevant frameworks and legislation. These include: the national framework for continuing healthcare, the national framework for children’s continuing care, care commissioned in line with s117 of the Mental Health Act and the Mental Capacity Act.

Core work on continuing healthcare - for people with long-term complex health needs who qualify for care arranged and funded solely by the NHS - was suspended until 1 September 2020 so that the majority of the clinical staff involved could be redeployed to support the system-wide response to the pandemic. When core work resumed, we were set a trajectory to complete the backlog of CHC cases created as a result of the suspension of services.

We continue to work to NHSE target that over 80% of new referrals should have an outcome within 28 days of referral, and to achieve the NHSE targets for people receiving a personal health budget.

A pathway has been developed to ensure individuals leaving hospital under’ discharge to assess’ funding are referred for assessment if required at the right time.

We are working closely, and with some success, with the local authority on service improvement such as joint training, improving pathways and processes, and the achievement of targets/trajectories.

You can read more about our personalised commissioning responsibilities on our website.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

41

1.12.4 Complaints and principles for remedy

We aim to have local people at the heart of our work, to hear what they think and to use this information as we make decisions about services. It’s also important that we tell people how we have used their views. Sometimes things go wrong and, when they do, we investigate concerns and complaints to help us learn lessons and improve services.

This year we have dealt with five formal complaints. These included two about continuing healthcare (CHC) funding decisions and processes; and two about decisions of our individual funding request (IFR) panel, involving funding of gynaecomastia (male breast) treatment; one was about British Sign Language (BSL) counselling. Two further complaints were withdrawn.           There were 41 concerns and/or enquiries about the CCG, of which the main issues involved individual funding request referrals (16), which included referrals for mental health services and autism assessments (4), breast reduction (3) and gynaecomastia (3). Concerns were also dealt with in relation to continuing healthcare funding, care packages, processes and communication (11) and commissioning and/or funding arrangements, such as for mental health services.

In addition, 314 complaints or concerns were raised with the CCG about our commissioned services. Of these 49% (153 cases) related to services provided by our GP practices - the vast majority were about accessing services, mainly the difficulties people experienced when telephoning their practice and in getting face-to-face consultations and; since January 2021 issues were raised relating to the roll out of the COVID-19 vaccination programme, which also involved our primary care networks –about the vaccination sites, the invites to the priority cohorts groups as set out by the Joint Committee on Vaccination and Immunisation (JCVI) and equal access of the vaccine across the district - And 35% (110) of cases involved secondary care – that is, those provided by our hospitals and other providers of NHS services.

We dealt with 151 enquiries from our local MPs and councillors who raised issues and concerns on behalf of their constituents about NHS services. Seven cases involved more than one organisation. This is an increase of 152% compared to 60 cases received in 2019-20. The majority of enquiries and concerns raised during 2020-21 have been due to the issues arising from the coronavirus pandemic and the vaccination programme. Twenty nine (19%) cases related to CCG commissioning responsibilities, including mental health services, continuing health care processes, delays in assessments and appeals caused by pause in this work due to national guidance during the coronavirus pandemic and subsequent realignment of staff. Fifteen per cent of cases (22) involved our hospitals and mental health, community and learning disability services.

However, the main issues of the enquiries raised by MPs and councillors related to primary care - 63 cases (42%). Of these, 37 cases (59%) related to the individual practices, mainly around access, telephone systems and face-to-face consultations and site closures due to safety reasons and managing the workforce through the pandemic - the other 26 cases, (41%), received between January and March 2021, were in connection with the roll out of the COVID-19 vaccination programme, which

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

42

also involved our primary care networks, their sites, access, invites to priority cohorts as set out be the JCVI and distribution of vaccines.

We were notified of four complaints where individuals had approached the Parliamentary and Health Service Ombudsman (PHSO) as they remained dissatisfied with the outcome of their complaints locally. Three were in relation to CHC funding and the additional charges requested by care homes. We followed a proactive approach, reviewing the cases ahead of a PHSO determination, and agreed to reimburse monies that had been paid by clients in relation to the provision of standard assessed care needs and/or standard accommodation costs of the individuals concerned. The other case involved a CHC eligibility decision where no further action was taken by the PHSO.

We have fully adopted the Parliamentary and Health Service Ombudsman’s Principles for Remedy which sets out six principles for remedy: getting it right, being customer-focussed, being open and accountable, acting fairly and proportionately, putting things right and seeking continuous improvement. These are referred to within our policy for the management of compliments, comments, concerns and complaints.

1.13 Our commitment to equality and diversity

We are committed to reducing health inequalities and to promoting equality and diversity for patients, communities and for our staff.

The Equality Act 2010 has two broad aspects, the first of which prohibits discrimination, harassment and victimisation against people with one or more protected characteristics (age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation).

In addition, the Public Sector Equality Duty (PSED) aims to help public authorities avoid discriminatory practices and integrate equality into core business and to be proactive in improving equality for people with one or more protected characteristics.

The Equality Act requires public bodies to publish at least one specific and measurable equality objective, at least every four years. In line with this, and following engagement with CCG staff networks, NHS partners and the local community and voluntary sector in early 2021, we agreed two objectives:

to use information to plan services to meet different groups of people’s needs through a population health management approach; and

to increase the numbers of Black, Asian and minority ethnic staff in our workforce, particularly in senior roles.

We use equality impact assessments (EIAs) to measure the impact of our decisions on equalities and to ensure that we carefully consider how they may affect the local population, particularly in relation to people with protected characteristics. The assessments also help to identify actions we can take to reduce or remove any negative impacts. They help us to analyse and consider a range of information, including engagement, to inform our decision making both as an employer and commissioner.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

43

During the last year, we have worked in partnership with other local NHS organisations and with Bradford Council and with local voluntary and community sector organisations so that our local response to the pandemic has been tailored to different population groups. This has included creating and distributing information about COVID-19 - including video messages - in accessible formats and community languages; and engaging with local people – particularly the young, BAME and disabled people – through community champions.

We have also:

worked with Bradford Talking Media to support general practices to implement the accessible information standard which requires health and social care organisations to identify record and share information to meet the needs of patients who have a learning disability, sensory loss or mental health problem.

trained 108 of our own staff as part of the NHS Rainbow Badge. We hope that this will mean that anyone wearing a badge is committed to playing their part in removing negative attitudes towards LGBT+ people from the NHS and providing or signposting to support to any LGBT+ person who needs it.

supported Affinity Care, a group of seven GP practices in Bradford, to join the Bradford NHS Rainbow Badge scheme.

set up and supported two staff networks – one for black and minority ethnic staff, and one for people with long-term health conditions and/or disabilities. Both networks have created a safe space where members are able to share and learn from each other’s working experience. Some of this powerful lived experience has been shared with our leadership teams and each network has two senior sponsors who help to maintain effective two-way communication between the staff networks and the CCG’s leaders.

started to implement a workforce equality plan and begun to address concerns raised by network members.

re-developed and delivered mandatory equality and diversity training online to staff who have been working at home due to the pandemic.

In April 2015, the NHS Workforce Race Equality Standard (WRES) became a mandatory requirement which requires NHS organisations to demonstrate progress against nine indicators. Our WRES report is available on the website along with its action plan and focuses particularly on increasing the numbers of BAME staff we employ, particularly in senior roles.

You can read more about our progress on equality and diversity on our website.

1.14 Financial performance overview

In 2020/21, to support the response to the pandemic, the CCG operated within a temporary finance regime established by NHSEI. Resource allocations were calculated nationally using a methodology developed to forecast our expected expenditure as opposed to using the current published CCG resource allocations. Therefore, comparison with funding levels received in 2019/20 is difficult given the very different funding arrangements that applied in 2020/21. Whilst different arrangements applied for the first half of the financial year compared to the second

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

44

half of the financial year, our financial performance is considered across the year as a whole.

For the first six months of the year, resources of £491.1m were available to us for the commissioning of healthcare services, supporting additional COVID-19 related costs and CCG administration costs. These resources included baseline resource allocations (calculated nationally) and additional resource allocations made to ensure that costs were fully covered in the first six months of the year.

For the second six months of the year, resources of £503.3m were available for the same purposes as the first six months, comprising fixed funding of £493.8m plus £9.5m for costs incurred under national reimbursement schemes.

Overall, for 2020/21 resources of £1,020.6m were available which included in-year resources of £994.4m and £26.2m of brought-forward surpluses. With respect to organisational running costs, the running cost allocation included in our resource allocation was less than the published running cost allocation for 2020/21 which remained the measure of the CCG’s running cost performance.

The in-year resources of £994.4m were deployed in line with national guidance regarding the temporary finance regime and in particular to:

maintain funding to NHS Providers with a standard uplift of 2.8%; maintain primary medical care capacity and pay for new national GP contract

commitments; pay for care package costs under the hospital discharge scheme to help

maintain hospital capacity for treating COVID-19 patients; ensure investment in mental health services in line with the requirements of

the mental health investment standard; continue with our investment to reduce health inequalities in inner City

Bradford; and fund additional COVID-19 related costs to support the pandemic response

(£17.7m). These costs included £10.9m for the hospital discharge programme, £3.2m for GP practice support and sustainability, £1.2m for primary care services, £1.3m for additional patient support services, £0.4m PPE, £0.7m staff and other system support costs.

Expenditure on running costs was also reduced to ensure that costs remained within the published running cost allowance (reduced from £12,967k in 2019/20 to £11,438k in 2020/21)

In-year resources excluded expenditure with acute independent sector providers where they were part of the national contracting arrangements for these services in 2020/21. For the CCG, this equated to expenditure with a value of £29m.

Overall, we adapted successfully to the temporary finance regime. We have continued to manage our resources effectively and have met our statutory financial duties to keep revenue expenditure within available revenue resources, and to keep administration costs within the running cost allocation.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

45

In 2020/21, we achieved a break-even position against our expenditure budget of £994.4m. Therefore, the total cumulative surplus for the CCG remains at £26.2m and this will be carried forward to 2021/22 for drawdown in future years.

The CCG did not have a capital resource limit or any capital expenditure in 2020/21.

Our actual expenditure in 2020/21 across the main budget areas is shown below:

Total CCG net expenditure – 2020/21 (£994.4m)

Acute healthcare expenditure of £442.9m in 2020/21 was incurred as follows:

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

46

Notwithstanding the operation of the temporary finance regime, we had a savings target of £1.2m for 2020/21 which was achieved through savings on prescribing, primary care premises and support costs. An additional savings target of £2.8m relating to the national change in budget setting methodology for local independent sector services in the second half of the financial year was fully offset by commissioning budget underspends due to lower levels of elective activity.

For 2021/22, the financial arrangements that applied in the last six months of 2020/21 have been rolled forward for the first six months of 2021/22 and we expect to start to return to pre-COVID arrangements in the second half of the year. However, this will depend on COVID infection levels and hospitalisation rates continuing to fall.

Working with our local providers, we expect to start to address the backlog in elective activity and mental health services that has built up over the last year by using some of the £1.5bn national funding announced for this purpose in the last Spending Review. As we start to return to more normal funding arrangements, the challenges relating to increasing healthcare demand in excess of funding growth and the need to continue to address health inequalities remain.

Therefore, the financial outlook for our local health system in the medium term will be challenging and we are committed to continue to work collaboratively across our local health and care system to improve productivity and invest in community based services to ease the demand for secondary care services.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

47

1.14.1 Annual accounts – 2020/21

Our accounts have been prepared in accordance with the directions issued by the NHS Commissioning Board to show a true and fair view of the financial affairs of the CCG. These accounts comply with the requirements of the Department of Health group manual for accounts 2020/21.

The full accounts for the CCG are shown on page 134 onwards.

1.14.2 External audit

KPMG LLP acts as our external auditor and the following services have been provided during the year:

Statutory audit services - total fees of £84,000 including VAT.

The external auditors have also charged £28,800 (including VAT) – for assurance on the 2019/20 Mental Health Investment Standard for the predecessor CCGs.

1.15 Engaging people and communities

We are strongly committed to engaging with, and involving, local people in what we do; our long-standing investment in engagement structures has proved its worth during the pandemic, enabling us to adapt to involving people and communicating with our population in different ways during challenging times.

How we’ve engaged with local people and communities through the pandemic

Our engagement team has worked closely with partners across the system to support the cascade of key public health messages to local people and communities, particularly those who are most vulnerable. We have used our resources and networks to support the provision of information in community languages and accessible formats.

Working closely with VCS partners and local Healthwatch, we gathered informal insight about people’s experiences of accessing health and care services during this time. This data has been compiled through our Grassroots process and has also been shared widely; the engagement team worked with colleagues from Born in Bradford, local authority, VCS and Healthwatch to contribute soft intelligence from communities to influence our recovery plans. This insight has also contributed to reports compiled by the WY&H Health and Care Partnership, as well as being shared with our quality committee, population health team, and system partners, in order to inform decision-making.

COVID-19 beliefs and behaviours report: Responding to increasing concerns about trust and compliance with the local restrictions, the CCG’s engagement team carried out an informal engagement project over the summer of 2020 to rapidly gather insight which could shape the system’s communication approach. We aimed to understand the perspectives of people who are not following the local lockdown guidance and were particularly concerned with reaching multigenerational households and younger people.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

48

Key themes highlighted:

• Perceptions that restrictions target Muslim community;• Lack of evidence or direct experience of COVID-19;• Conspiracy theories and political motives;• Understanding of the rules - clarity and consistency of message;• Social norms and behaviours; • Specific issues and barriers e.g. Face coverings, Test and Trace; and• Trusted sources and community influencers.

Through Bradford’s Test and Trace programme the report has shared with regional/national partners and the national Equalities, Diversity and Inclusion Task Force to help inform and shape how BAME communities and local leaders are being engaged in test and trace.

People’s Board: Our People’s Board continued to have regular virtual meetings, and brought different views and perspectives into our work.

Discussions at the People’s Board this year have been dominated by the coronavirus pandemic and its impact on the NHS; for example, their views and questions have helped influence our plans for the restart of planned care services and emphasised the importance of how we communicate with patients about changes or delays.

The People’s Board were involved in helping shape the First 1,000 days strategy for the CCG. In the context of the new strategy and our Act as One ethos, we are working together to explore how the role of the People’s Board could develop and what opportunities exist for increased collaboration with involvement networks in other organisations.

Engaging People: Engaging People, our grant funded programme with voluntary and community sector partners, continues to help us develop trusted relationships with local people and build capacity within communities, particularly those facing inequalities.

Our Women’s Health Network and the Bradford district and Craven Maternity Voices Partnership both quickly adapted to the pandemic by moving meetings online. This new way of working has enabled participation from a wider range of people; meetings have been very well attended, with new connections and collaborations being established.

Bradford district and Craven maternity voices partnership (MVP) carried out engagement work in partnership with Bradford Teaching Hospitals, to gather experiences of maternity care during the coronavirus outbreak. Significant changes had to be made to the way services operated; both providers and commissioners needed to understand how this has affected women’s experience of birth and ante/post-natal care. Insight has been gathered through a survey and focus groups; data has been shared with the Trust and collated into our Grassroots database.

Working with VCSE organisations: Bradford district and Craven has a vibrant and

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

49

diverse Voluntary Community and Social Enterprise sector; this is an essential asset in our Act As One approach to engaging and communicating with our population.

Typically, the strength of our local approach to engagement has been built on having face to face conversations with individuals or groups, and being physically present in a community setting. These tried and tested ways of working are challenged by the current context, isolated individuals and excluded communities are potentially even more hidden; engagement with these groups is harder, but more important than ever.

To support VCSE and faith groups, we worked closely with Community Action Bradford and District and Engaging People partners to co-design a programme of training/support to build the skills and capacity to engage local people in new ways during the coronavirus outbreak and into the future. We held virtual workshops to co-design an online toolkit, which can be used by partners across Bradford district and Craven.

The Bradford district and Craven engagement toolkit is online at www.engageourplace.uk

COVID-19 Vaccine - supporting community conversations: Since planning began in 2020 for the vaccine programme in Bradford district and Craven, we have been focusing on engaging with people in our area to understand their perspectives, identify potential barriers and promote positive messages about vaccination.

In November 2020, we launched an engagement survey in partnership with local Healthwatch, Engaging People partners, Race Equality Network and council colleagues. The survey captured insight about people’s views about the vaccine prior to the roll out. Within three weeks we received over 3,000 responses reflecting the huge public interest in the vaccine.

From this insight and existing knowledge of our local population, we know that some communities are likely to be more hesitant in taking up vaccination and community engagement can play a key part of reaching people. Building confidence and trust in the vaccine with the support of many partners across our place, we are working hard to ensure that all communities have the information and support required to access the vaccine.

Voluntary and faith sector partners, community contacts and engagement networks have received regular updates since early December, including:

national NHS communications resources (social media clips, leaflets, FAQs); locally produced communications resources (e.g. video clips of patients receiving

first vaccines, video messages from GPs in different languages); and information and resource packs to support conversations about the vaccine.

Our engagement lead has worked closely with teams from Bradford Council to deliver ‘Train the trainer’ style interactive question-and-answer workshops for staff/volunteers working in community facing roles, such as the COVID ambassadors. This equipped staff to have direct conversations with residents about vaccination as part of their COVID-19 testing and neighbourhood engagement work. These briefing has also

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

50

been offered to VCSE groups and those involved with the Community Champions project.

CCG teams have taken part in online engagement sessions with groups such as the Black Health Forum, Deaf Groups and Roma organisations, to answer questions about the vaccine programme and develop partnership approaches to increasing uptake.

This engagement has enables innovative approaches to vaccine delivery, including outreach clinics in faith settings and mobile vaccination clinics to target areas of lower uptake.

Youth volunteering project: Our youth volunteering hub ‘Young People Can’, co-designed with young people in 2019/20 and run in partnership with Volunteering Bradford, has kept running digitally throughout the pandemic. The hub supports young people to develop the skills and confidence needed for participation and volunteering roles and connects them to roles across the system.

During this year a large amount of information has been shared through the WhatsApp group and Zoom sessions regarding training and volunteering opportunities.

The group identified that a lot of volunteering roles were for people 18 and over, so suggested a project for younger teenagers and children to write to isolated people living in care homes across our area. “Link up Letters” was set up in May 2020 by Volunteering Bradford and young people from the group and has proved very successful with positive benefits for people of all ages who were involved.

Young People Can has also connected with Bradford Council’s Young Covid Ambassadors project and worked to help spread positive, accurate information about COVID-19 and encouraging people to take up the vaccine.

North Street Surgery: We engaged with local people about the future of services at North Street surgery in Keighley, because the current contract is coming to an end in 2021. We wanted to find out about their current experience of GP services and what matters most to them for future services.

The survey was available online on the CCG’s website and a telephone line was set-up to offer support to complete the survey for people without online access or who needed information in another language.

We wrote to every household registered with North Street Surgery to invite them to share their views, and the practice also sent out a reminder text message with a link to the survey. The support of the practice and local community organisations has been invaluable. Healthwatch Bradford and District, the Engaging People team, local mosques, voluntary sector organisations and practice staff have helped the CCG team to shape the engagement approach and encouraged local people to take part.

A report detailing the findings from this engagement will be published soon.

Consultations: no formal consultations took place in 2020/21.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

51

On our website, you can read more about our approach to engagement and read feedback from engagement work with patients, the public and other stakeholders.

1.16 Highlights of the year

New hubs to help people with coronavirus symptoms see their GPWith our local GPs, we created four specialist GP hubs in April 2020 to make sure the right care was given to people who had possible symptoms of coronavirus, or were self-isolating, but urgently needed to see their GP practice for a different health concern. The temporary hubs, which were located in Silsden, Shipley, Manningham and Horton Bank Top, closed in September as numbers requiring treatment reduced. They were replaced by one red hub at Hillside Bridge Healthcare Centre which closed in May 2021. Patients are now being managed within their own practices.

GP practices are open and #StillHereToHelpIn April 2020, as the pandemic unfolded, we created the #StillHereToHelp campaign to encourage local people to get help from their GP practice. Health, care and support services in Bradford district and Craven also joined us in the campaign in a bid to reassure people that they were still here to help – albeit with some changes to their normal routines.

The campaign was created to ensure that people knew how, and when, to get urgent support when needed. It was felt that some people, who were unwell with symptoms unrelated to coronavirus, or who were in need of other types of care and support, were unsure how to get help or were not seeking it in fear that they are over-burdening health and care services.

New coronavirus bereavement support service launchedLocal counselling services came together to provide specialist bereavement support for families during the coronavirus pandemic.

In May 2020, the Bradford Counselling Collaborative received CCG funding to help people who were grieving the loss of family or friends, as a result of coronavirus. People needing support could contact the specialist counselling helpline and professional counsellors from the British Association for Counselling and Psychotherapy (BACP) were on hand to offer grief and loss counselling, with over 50 trained support volunteers.

This was a great example of counselling networks coming together with a shared vision and demonstrated a true collaborative approach that looked at how to best meet the needs of those people experiencing grief and loss during the pandemic.

Over 1,500 NHS staff pledged to make a difference for LGBT+ peopleIn the run up to NHS Virtual Pride, on Friday 26 June 2020, the local NHS revealed how many staff have volunteered to promote inclusivity and reduce health inequalities for lesbian, gay, bisexual and transgender (LGBT+) people through the NHS Rainbow Badge scheme.

The NHS Rainbow Badge raises awareness amongst NHS staff of the health inequalities facing LGBT+ people and ensures LGBT+ people feel safe and included

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

52

when accessing healthcare.

Since launching locally on 4 October 2019, over 1,500 staff working across Bradford district and Craven have attended specialist training and now wear an NHS Rainbow Badge with pride. The badges are one of the ways that the local NHS shows that when you come to see us, you are in an open, non-judgmental and inclusive place.

Along with the CCG, all local NHS organisations supported the rolling out the scheme.

T’verse is t’word for Yorkshire Day message For Yorkshire Day on 1 August 2020, health and care teams across Bradford district and Craven joined forces with celebrated poet, Ian McMillan to encourage people to stay safe during the pandemic, Yorkshire style.

A ‘Proper Yorkshire, Together’ poem, proudly written by Rach McCafferty, senior communications manager at the CCG, in the Yorkshire dialect was widely circulated to help share advice on staying safe in a bid to reduce the spread of infections in our area.

Taking inspiration from the annual celebration of all things Yorkshire, the poem helped to share very serious public health messages in a different way, following concerns around the rising number of cases of COVID-19. Bard of Yorkshire, Ian McMillan’s performance to camera meant that the messages could be shared more widely and in a different, more engaging way.

New online mental health support service for adults In the run up to World Mental Health Day (10 October), an online counselling and emotional wellbeing support service, Qwell was launched across Bradford district and Craven. www.qwell.io is for all adults over the age of 19 and the easy to use platform offers free anonymous emotional and mental health support, in a safe and confidential space. Commissioned by the CCG, in partnership with Bradford Council, the Qwell service is provided by Kooth, which is accredited by the British Association for Counselling and Psychotherapy.

COVID-19 Vaccination programmeTuesday 15 December 2020 was a landmark moment in the bid to defeat the COVID-19 virus as GP practices gave the first doses of the coronavirus vaccine to local patients.

Mohammed Bostan, age 95, was one of the first people to receive their vaccination at Long Lee Surgery, Keighley. Mohammed said, “If I can help save just one person’s life by encouraging them to have their vaccination then I’ll be very happy.

GP practice ‘hubs’ located across the district started to give vaccinations to patients aged 80 and above who were already attending hospital as an outpatient, and/or have been discharged home after a hospital stay. Some patients were also being offered vaccines at Bradford Royal Infirmary, if they are unable to travel to one of the hubs. During the year, the service was further developed by large scale hubs at Jacob’s Well

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

53

and Bradford College, a number of community sites, and some ‘pop up’ clinics in mosques and other local places..

By the end of March 2021, over 50% of people across Bradford district and Craven had received their first dose of the coronavirus vaccination – including nearly 80% of people within priority groups 1-9 – more than 250,000 people.

Care@HomeEstablished at the start of the pandemic, Care@Home supports people living in care homes and those who are frail and living in their own homes.

Care@Home has enabled us to rapidly implement new pathways and services. Access to advice, support, training and equipment has been provided and a range of system communication and engagement activity has taken place, including newsletters and resource packs on key COVID issues. This has really enhanced working relationships across Bradford district and Craven and has supported in delivering improved outcomes for our population

As a result of excellent collaborative working across the whole health and care system, a number of initiatives have been delivered including, in April, installing Telemedicine in all 126 care homes. Telemedicine is available 24 hours, every day of the year, and offers responsive healthcare advice to support people living in care homes. It aims to ensure people remain in their usual place of residence wherever possible.

Similarly, a “super rota” offers a range of virtual interventions for people in care homes who have COVID-19 by providing person-centred assessment, remote monitoring and advice to support them to stay out of hospital whenever possible.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

54

Chapter 2: Accountability report

Corporate governance report

2.1 Members’ report

2.1.1. Member profiles – governing body members

Dr James Thomas, clinical chair

James is originally from London where he carried out his medical training and initially worked. He moved to Yorkshire in 1995 and trained as a GP in the Airedale area. In 2002, James joined the Fisher Medical Centre in Skipton as GP partner. He has a keen clinical interest in sport and exercise medicine and was involved in the Olympics in 2012. He is also passionate about education in local primary care services and teaches medical students, young doctors and GPs. He was the school lead for GP trainers for Health Education England in Yorkshire and Humber. He was previously a GP executive and clinical chair at Airedale, Wharfedale and Craven CCG leading on children’s services and the New Models of Care programme.

James is the clinical chair at the CCG and clinical lead for standardisation of clinical policies across WY&H Health and Care Partnership. He is married to Kate who is also a GP and he likes to spend his free time with his family. He enjoys watching American football and rugby; and plays baseball when he is able!

Helen Hirst, accountable officer

Helen is the CCG’s accountable officer. From 2016, she was the chief officer of the three former Bradford district and Craven CCGs having previously been in the same role for Bradford City and Districts CCGs since their establishment in 2013. She has also previously had interim roles with NHS England (director of CCG development) and with the Vale of York CCG (accountable officer).

Helen has worked in Bradford since 1992 and was the deputy chief executive of the former Bradford and Airedale Teaching Primary Care Trust (PCT). In 2010

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

55

she took a two-year secondment with the Department of Health as programme director for primary care commissioning as part of the NHS Commissioning Board establishment team. Outside work, Helen spends her time with her family; she’s married with a 15-year-old daughter, a grown-up step-daughter and a three-year-old granddaughter.

Dr Louise Clarke, GP member of the SLT

Louise has been a GP in Bradford since 2010. Prior to that, she completed her GP training in Bradford and did various hospital rotations across West Yorkshire. She is passionate about improving the health and wellbeing of our population, and has a particular interest in child health. Louise was vice clinical chair of Bradford Districts CCG, and covered planned care as part of her portfolio. She is also a clinical specialty lead for children, and until 2018 held the post of named doctor for safeguarding children.

Angie Clegg, registered nurse

Angie qualified as a nurse at St James’ Hospital in Leeds in 1984. Since then she has worked as a nurse, clinical leader, consultant nurse, lecturer, senior manager and director in Leeds, Bradford and Airedale. She has been awarded a BSc in health studies from Leeds Metropolitan University and an MSc in leadership and advanced practice from her studies at Bradford University. As a nurse leader, Angie’s research, publications and area of expertise includes innovations in intermediate care, out of hospital care, advanced practice, clinical leadership and quality.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

56

Chief finance officer and senior information risk officer

Robert is a qualified accountant who has worked in the NHS since 1991 in a number of deputy finance director roles. His was deputy chief finance officer of Bradford City and Bradford Districts CCGs, covering the role of chief finance officer between 18 January 2016 and 1 May 2016. He became chief finance officer (interim) of the three Bradford district and Craven CCGs in summer 2019.

Bryan Millar, lay member for audit, governance and senior independent director

Bryan retired as chief executive of Bradford Teaching Hospitals NHS Foundation Trust (BTHFT) in August 2014, having worked in the NHS since 1977 in a variety of roles within Yorkshire and the North East of England. After occupying a number of posts at district and regional health authorities, he joined Northgate and Prudhoe NHS Trust becoming their director of finance and performance management in 1993.

He became director of finance at Bradford Community Health NHS Trust in 1999 before moving to Bradford South and West Primary Care Trust (PCT) where he was director of finance and deputy chief executive. Bryan joined BTHFT in October 2005. He is a fellow of the Association of Chartered Certified Accountants. In addition to his former role as chief executive of BTHFT, Bryan was also a board member of Health Education England, Yorkshire and the Humber (and chair of its finance, governance and risk committee), chair of the local comprehensive research network partnership group, and director of Medipex (an intellectual property company and NHS innovation hub).

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

57

Neil Fell, lay member for finance and performance

Neil has worked in numerous NHS roles over many years. After a short period in industry he began his NHS career in Rotherham in 1974. Between 1974 and 1986, he held a number of accounting positions with Rotherham and Sheffield Health Authorities. In 1986, he joined Bradford Area Health Authority as chief internal auditor and held a number of management roles before he was appointed as director of finance in 1993. He was an executive director at Bradford Health Authority and at the Airedale Primary Care Trust, until 2007. Since then, he has had roles as a finance consultant or finance director. Married with a grown-up family, he is a fellow of the Association of Chartered Certified Accountants. When not working he enjoys hill-walking, fishing and watching most sports – particularly football.

David Richardson, lay member for quality

After more than 30 years’ service, David retired as a senior police officer in 2004. He has also worked with the Government Office for Yorkshire and Humberside on community safety initiatives and to help reduce crime and disorder, and the use of drugs and alcohol.

In 2005, David became chairman of Bradford Teaching Hospitals NHS Foundation Trust, a post he held for nine years, whilst at the same time working as chief executive for Bradford Breakthrough Limited, the senior business leaders’ networking and advocacy partnership. He is currently a director of a property business in Leeds and an independent lay member of Bradford and Airedale Estates Partnership, a company created to improve healthcare buildings.

Ruby Bhatti OBE, lay member for primary care commissioning and communities, governing body deputy chair

Ruby is a solicitor with over 20 years’ experience in the legal field. As a lay member, she brings over 20 years’ experience in governance as a non-executive director, previously with Incommunities Housing Association, Action For Business Ltd, Arise Yorkshire Ltd (social enterprises), Bradford Diocesan Academies Trust, Rainbow Academy and Dixon Multi Academies Charitable Trust Ltd. Ruby sits as an independent member of the mental health panel which enables patients to have their cases considered independently. She chairs the governing bodies of numerous schools in

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

58

Bradford.

Ruby has been awarded an honorary doctorate from the University of Bradford. She has supported the university since 2007 and is currently a member of the Service User and Carers Advisory Board, advising on strategy and policy for the involvement of service users and carers in the Faculty of Health Studies. She is an associate lecturer at the university.

Dr Peter Brunskill, lay member for secondary care (shared role)

Peter is a consultant obstetrician and gynaecologist who held a post at Airedale General Hospital from 1991 to 2009 and worked as a Locum Consultant in various Hospitals in the UK and the Isle of Man from 2009 to 2017.

At Airedale Hospital he developed a number of new and innovative clinical services and led the gynaecological cancer team. From 1992-6, he was chair of the district audit committee and, from 2005-8, the theatre management group. He played an active role in the development of maternity IT services, maternity risk management and the gynaecology out-patient facilities.

Since leaving Airedale Hospital, Peter has continued to live in the area and as well as doing consultant locums, he works as a medicolegal expert witness in the UK, Ireland and elsewhere. He is an active medical teacher for the UK’s Advanced Life Support Group and the Liverpool School of Tropical Medicine in Africa.

His main passions outside work are golf and the success of Burnley Football Club.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

59

Professor John Young, lay member for secondary care (shared role)

John Young trained at the Middlesex Hospital, London and was appointed as a consultant geriatrician in Bradford in 1986 where he developed numerous new services including an elderly care assessment unit; a stroke unit; and an ortho-geriatric unit.

In 2005 he was appointed as head of the academic unit of elderly care and rehabilitation, University of Leeds (based in the Bradford Institute for Health Research), now one of the largest research units of its kind in the UK. John was seconded to the Department of Health (2001-2007) to assist with the national service framework for older people, and then to NHS England (2013-2016) as national clinical director for the frail elderly and integration.

Co-opted governing body members

There are also a number of co-opted members of the governing body. They have a standing invitation to attend meetings and contribute in a non-voting, advisory capacity. They are:

Pam Essler, lay chair of the individual funding request panel Sarah Muckle, director of public health, Bradford Council Charles Strachan, chair of the CCG council Liz Allen, strategic director of organisation effectiveness Nancy O’Neill, strategic director of transformation and change, deputy chief officer Ali Jan Haider, strategic director of keeping well at home

2.1.2 Member practices

Practice nameAddingham Medical Practice Little Horton Lane – Dr GilkarAshcroft Surgery Little Horton Lane Medical Centre –Dr I M

Raja and PartnersAshwell Medical Centre Low Moor Medical CentreAvicenna Medical Practice Manor Medical PracticeBaildon Medical Practice Moor Park Medical PracticeBevan Healthcare Moorside SurgeryBingley Medical Practice North Street SurgeryBowling Highfield Medical Practice Oak Glen SurgeryBilton Medical Centre Oakworth Medical PracticeBradford Student Health Service Park Grange Medical PracticeClarendon Medical Centre Parklands Medical PracticeCowgill Surgery Parkside Medical Practice

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

60

Cross Hills Group Practice Peel Park SurgeryDr Akhbar’s Surgery @ Hillside Bridge Picton Medical CentreDyneley House Surgery Primrose SurgeryEccleshill Village Surgery Rooley Lane Medical CentreFarfield Group Practice Shipley Medical Practice – Affinity CareFarrow Medical Centre Silsden and Steeton Medical PracticeFisher Medical Centre Springfield Medical PracticeFrizinghall Medical Centre Sunnybank Medical PracticeGrange Medical Centre The Bradford Moor PracticeGrange Park Surgery The City Medical PracticeHaigh Hall Medical Centre The Family PracticeHaworth Medical Practice The Lister SurgeryHollyns Health and Wellbeing The Ridge Medical PracticeHolycroft Surgery The Rockwell and Wrose Medical PracticeHorton Bank Top Practice The Saltaire and Windhill Medical PracticeHorton Park Medical Practice The Willows Medical CentreIdle Medical Centre The Wilsden Medical PracticeIlkley and Wharfedale Medical Practice Thornbury Medical CentreIG Medical (Ilkley Moor Medical Practice and Grassington Medical Centre)

Thornton-Denholme Medical Practice

Kensington Partnership Tong Medical PracticeKensington Street Surgery Townhead SurgeryKilmeny Group Medical Practice Valley View SurgeryLeylands Medical Practice Wibsey and Queensbury Medical PracticeLing House Medical Centre

Note: in December 2020 Dr Akbar moved premises from Barkerend Health Centre to Hillside Bridge Health Centre

2.1.3 Composition of governing body

The composition of the governing body can be found on page 67of this annual report.

2.1.4 Committee(s), including audit committee

The composition of the committees of the CCG and committees of the governing body can be found on page 70 onwards of this annual report.

2.1.5 Register of interests

Our register of interests can be found on our website.

2.1.6 Personal data related incidents

In 2020/21 NHS Bradford District and Craven CCG did not report any personal data related incidents to NHS Digital and the Information Commissioner’s Office (ICO).

Twenty two data/information governance related CCG incidents or near misses were reported internally during the year; none of these was classed as reportable to NHS Digital and the ICO.  All incidents reported within the CCG are reviewed by the audit

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

61

and governance committee.

2.1.7 Statement of disclosure to auditors

Each individual who is a member of the CCG at the time the members’ report is approved confirms:

so far as the member is aware, there is no relevant audit information of which the CCG’s auditor is unaware that would be relevant for the purposes of the audit report;

the member has taken all the steps that they ought to have taken in order to make him or herself aware of any relevant audit information and to establish that the CCG’s audit committee is aware of it.

2.1.8 Modern Slavery Act

We fully support the government’s objectives to eradicate modern slavery and human trafficking but do not meet the requirements for producing an annual slavery and human trafficking statement as set out in the Modern Slavery Act.

2.2 Statement of accountable officer’s responsibilities

The National Health Service Act 2006 (as amended) states that each CCG shall have an accountable officer and that officer shall be appointed by the NHS Commissioning Board (NHS England). NHS England has appointed Helen Hirst to be the accountable officer of Bradford Districts CCG.

The responsibilities of an accountable officer are set out under the National Health Service Act 2006 (as amended), Managing Public Money and in the CCG accountable officer appointment letter. They include responsibilities for:

the propriety and regularity of the public finances for which the accountable officer is answerable;

keeping proper accounting records (which disclose with reasonable accuracy at any time the financial position of the CCG and enable them to ensure that the accounts comply with the requirements of the accounts direction;

safeguarding the CCG’s assets (and hence for taking reasonable steps for the prevention and detection of fraud and other irregularities);

the relevant responsibilities of accounting officers under Managing Public Money,

ensuring the CCG exercises its functions effectively, efficiently and economically (in accordance with Section 14Q of the National Health Service Act 2006 (as amended)) and with a view to securing continuous improvement in the quality of services (in accordance with Section14R of the National Health Service Act 2006 (as amended));

ensuring that the CCG complies with its financial duties under Sections 223H to 223J of the National Health Service Act 2006 (as amended).

Under the National Health Service Act 2006 (as amended), NHS England has directed each CCG to prepare for each financial year a statement of accounts in the form and on

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

62

the basis set out in the Accounts Direction.

The accounts are prepared on an accruals basis and must give a true and fair view of the state of affairs of the CCG and of its income and expenditure, statement of financial position and cash flows for the financial year.

In preparing the accounts, the accountable officer is required to comply with the requirements of the government financial reporting manual and in particular to:

observe the accounts direction issued by NHS England, including the relevant accounting and disclosure requirements, and apply suitable accounting policies on a consistent basis;

make judgements and estimates on a reasonable basis; state whether applicable accounting standards as set out in the government

financial reporting manual have been followed, and disclose and explain any material departures in the accounts; and

prepare the accounts on a going concern basis; and confirm that the annual report and accounts as a whole is fair, balanced and

understandable and take personal responsibility for the annual report and accounts and the judgements required for determining that it is fair, balanced and understandable.

To the best of my knowledge and belief, and subject to the disclosure set out below, (eg directions issued, s30 letter issued by external auditors), I have properly discharged the responsibilities set out under the National Health Service Act 2006 (as amended), Managing Public Money and in my CCG accountable officer appointment letter.

I also confirm that:

as far as I am aware, there is no relevant audit information of which the CCG’s auditors are unaware, and that as accountable officer, I have taken all the steps that I ought to have taken to make myself aware of any relevant audit information and to establish that the CCG’s auditors are aware of that information.

Helen HirstHelen HirstAccountable officerNHS Bradford District and Craven CCG

15 June 2021

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

63

2.3 Governance statement

2.3.1 Introduction

Under the NHS Act (2006) all NHS entities are required to prepare an annual governance statement. The statement considers internal controls and reports on any significant issues that have arisen during the financial year, including information and quality governance. The chief executive signs the document which forms part of the Annual Report.

2.3.2 Context

NHS Bradford District and Craven CCG is a body corporate established by NHS England on 1 April 2020 under the National Health Service Act 2006 (as amended).

The CCG’s statutory functions are set out under the National Health Service Act 2006 (as amended). The CCG’s general function is arranging the provision of services for persons for the purposes of the health service in England. The CCG is, in particular, required to arrange for the provision of certain health services to such extent as it considers necessary to meet the reasonable requirements of its local population.

As at 1 April 2020, the CCG is not subject to any directions from NHS England issued under Section 14Z21 of the National Health Service Act 2006

2.3.3 Scope of responsibility

As accountable officer, I have responsibility for maintaining a sound system of internal control that supports the achievement of the CCG’s policies, aims and objectives, whilst safeguarding the public funds and assets for which I am personally responsible, in accordance with the responsibilities assigned to me in Managing Public Money. I also acknowledge my responsibilities as set out under the National Health Service Act 2006 (as amended) and in my CCG accountable officer appointment letter.

I am responsible for ensuring that the CCG is administered prudently and economically and that resources are applied efficiently and effectively, safeguarding financial propriety and regularity. I also have responsibility for reviewing the effectiveness of the system of internal control within the CCG as set out in this governance statement.

2.3.4 Governance arrangements and effectiveness

The main function of the governing body is to ensure that the group has made appropriate arrangements for ensuring that it exercises its functions effectively, efficiently and economically and complies with such generally accepted principles of good governance as are relevant to it.

2.3.5 Constitution and governance structure

Our governance framework is clearly set out in the constitution. It sets out a commitment that we will promote good governance and proper stewardship of public

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

64

resources in pursuing our goals and in meeting our statutory duties. Good corporate governance arrangements are critical to achieving our objectives and are reflected in the duties of the committees and sub-committees; and in the roles of CCG officers.

The CCG’s scheme of reservation and delegation sets out those decisions that are:

reserved to the membership as a whole; and delegated to the CCG’s committees and sub-committees, the governing body,

its committees and sub-committees, individual members and employees.

On 24 February 2020 CCG members approved the new constitution which was developed in line with the new CCG model constitution and was approved by NHS England/NHS Improvement on 6 March 2020 and released with the grant of merger.

*Denotes terms of reference are available within our CCG constitution

Audit and governance committee* CCG council* Joint committee of the WY&H CCGs Finance and performance committee* Quality committee* Primary care commissioning committee* Remuneration committee* Senior leadership team* Associate leadership team

Figure 5: CCG governance structure 2020/21

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

65

2.3.6 Membership body and governing body

CCG council

Role: The CCG council plays a crucial role in ensuring engagement of all members in the development and operation of our CCG, including a key role in holding the SLT and governing body to account. The CCG council is accountable to the member practices.

Key responsibilities: The CCG council

agrees the overall vision, values and strategic direction of the group; reviews the effectiveness of the governing body and holds it to account for the

delivery of its functions; approves the selection and appointment process for governing body and, where

applicable, SLT members and arrangements for succession planning; recommends the appointment of the accountable officer to NHS England and

Improvement; works effectively with all GPs and primary care clinical and practice staff to

contribute practices’ views to commissioning decisions; considers and approves applications to NHS England and Improvement in

respect to changes to the CCG’s constitution, the standing orders and scheme of reservation and delegation;

maintains a positive and responsive relationship with NHS England and Improvement and the CCG’s member practices; and

sets a culture of continuously improving the services for patients, carers, communities and member practices.

Membership and attendance: A clinician from each of our member practices is represented on the CCG council; this representative cannot be an elected GP member of the SLT. Dr Charles Strachan is the elected chair of the CCG council and acts on behalf of the membership.

The CCG council has met three times during 2020/21, including the 2019/20 CCG annual general meeting held jointly in public with the governing body and SLT in July 2020. Attendance by practice is shown below:

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

66

Figure 6: 2020/21 attendance at CCG council

Addingham Medical Practice

Ashcroft Surgery

Ashwell Medical Centre

Avicenna Medical Practice

Baildon Medical Practice

Bevan Healthcare

Bingley Medical Practice

Bowling Highfield Medical Practice

Bilton Medical Centre

Bradford Student Health Service

Clarendon Medical Centre

Cowgill Surgery

Cross Hills Group Practice

Dr Akbar's Surgery@Hills ide Bridge

Dyneley House Surgery

Eccleshill Vil lage Surgery

Farfield Group Practice

Farrow Medical Centre

Fisher Medical Centre

Friz inghall Medical Centre

Grange Medical Centre

Grange Park Surgery

Haigh Hall Medical Centre

Haworth Medical Practice

Hollyns Health & Wellbeing

Holycroft Surgery

Horton Bank Top Practice

Horton Park Medical Practice

Idle Medical Centre

Ilk ley and Wharfedale Medical Practice

IG Medical (Ilkley Moor MP and Grassington MC)

Kensington Partnership

Kensington Street Surgery

Kilmeny Group Medical Practice

Leylands Medical Practice

Ling House Medical Centre

Little Horton Lane - Dr Gilkar

Little Horton Lane MC Dr I M Raja and Partners

Low Moor Medical Centre

Manor Medical Practice

Moor Park Medical Practice

Moorside Surgery

North Street Surgery

Oak Glen Surgery

Oakworth Medical Practice

Park Grange Medical Centre

Parklands Medical Practice

Parkside Medical Practice

Peel Park Surgery

Picton Medical Centre

Primrose Surgery

Rooley Lane Medical Practice

Shipley Medical Practice - Affinity Care

Silsden and Steeton Medical Practice

Springfield Medical Practice

Sunnybank Medical Practice

The Bradford Moor Practice

The City Medical Practice

The Family Practice

The Lister Surgery

The Ridge Medical Practice

The Rockwell & Wrose Medical Practice

The Saltaire and Windhill Medical Partnership

The Willows Medical Centre

The Wilsden Medical Practice

Thornbury Medical Centre

Thornton-Denholme Medical Practice

Tong Medical Practice

Townhead Surgery

Valley View Surgery

Wibsey & Queensbury Medical Practice

0 1 2 3

Actual

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

67

CCG council - highlights 2020/21

The CCG council endorsed Dr Charles Strachan as CCG

council chair and Robert Maden as CCG chief finance officer;

ratified the Bradford District and Craven CCG strategy;

discussed practice engagement and ways to discharge governance arrangements;

discussed addressing health inequalities; approved the terms of reference for the

SLT.

The CCG council received: the 2019/20 accounts and annual report at

a joint meeting in public with the governing body and SLT;

updates on the nationally determined financial regime following the suspension of the operational planning process in order to respond to the COVID-19 pandemic;

updates from the WY&H Health and Care Partnership;

updates on the development of primary care networks and community partnerships;

regular updates on the system principle of ‘Act as One’ and the shared transformation programmes.

100%

Membership: Practice

Representatives

Standing agenda Items

Declaration of interests Minutes of previous meetings Action log Clinical chair’s update Members’ questions and answers –

this is a significant agenda item at all meetings

Updates on local, system and national developments

Conclusion: The CCG council has fulfilled its role and responsibilities.

Governing body

The governing body normally meets in public six times a year. In addition to the public meetings, the governing body, SLT and associate leadership team have regular strategy and development sessions.

Role: The governing body is responsible for ensuring that the CCG has appropriate arrangements in place to exercise its functions effectively, efficiently and economically; and in accordance with our principles of good governance.

Key responsibilities: The governing body has responsibility for:

ensuring that the CCG has appropriate arrangements in place to exercise its functions effectively, efficiently and economically and in accordance with the CCG’s principles of good governance (its main function);

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

68

determining the remuneration, fees and other allowances payable to employees or other persons providing services to the CCG and the allowances payable under any pension scheme established;

any other function connected with the exercise of its main function as set out in the constitution or specified in regulations;

receiving assurance on the development of commissioning plans and strategies by the SLT;

approving the CCG’s annual financial plan; monitoring performance in line with the CCG’s reporting mechanisms; providing assurance to the CCG that its committees are undertaking their

functions in accordance with the constitution.

Membership and attendance:

Dr James ThomasDr Sohail Abbas

Ruby BhattiPeter BrunskillDr Louise ClarkeAngie CleggNeil FellHelen HirstRobert MadenBryan MillarMichelle TurnerAdele Thornburn (deputy)

John YoungDavid Richardson

Clinical chair and elected GPDeputy clinical chair and strategic clinical director, population health and wellbeingLay member, primary care commissioningSecondary care consultantStrategic director of strategy and planning and elected GPRegistered nurseLay member for finance and governanceChief officerChief finance officerLay member for audit and governanceStrategic director of quality and nursingAssociate director of quality and nursing (to 31 December 2020) – deputising for Michelle TurnerSecondary care consultantLay member for quality

In addition to the members above, the following co-opted members attend governing body meetings in a non-voting capacity:

Sarah Muckle Director of public health, Bradford CouncilPam Essler Lay chair of the individual funding panelCharles Strachan Chair of the CCG councilNancy O’Neill Strategic director of transformation and change and

deputy chief officerVicki Wallace Interim strategic director of transformation and changeLiz Allen Strategic director of organisation effectivenessAli Jan Haider Strategic director of keeping well at homeRichard Wilkinson Lay member for governance (to July 2020)

Figure 7: 2020/21 attendance at governing body

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

69

Governing body highlights 2020/21

The governing body: ratified the decision of the chief

officer and clinical chair to adopt all existing policies and procedures of the CCG’s predecessor organisations;

received regular updates on the CCG’s response to the COVID-19 pandemic both within the organisation and across ‘place’, including updates relating to restart and recovery of services;

received assurance on key actions taken by the CCG to manage quality and safety issues and risks, including those arising from COVID-19;

received regular financial performance updates against the national arrangements that were implemented following the suspension of the operational planning process for 2020/21 in

Standing agenda items: Declaration of interests Minutes of previous meetings Chief officer and clinical chairs’ report Reports from committee chairs Finance update report Patient safety and quality

improvement report High level risk report

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

70

order to respond to the pandemic; supported the CCG Strategy, Our

first 1,000 days; undertook a review of its

effectiveness and addressed any actions arising from this;

approved pay awards for staff and contractors outside of agenda for change, in line with recommendations from the remuneration committee;

received the annual report of the WY&H joint committee of CCGs and approved the revised memorandum of understanding for collaborative commissioning;

approved the revised WY&H health and care partnership memorandum of understanding;

ratified the terms of reference of the audit and governance and finance and performance committees, and approved the proposed amendments to the terms of reference of the primary care commissioning, remuneration committee and quality committees;

received assurance on progress against outstanding actions relating to the creation of one CCG for Bradford district and Craven;

received an update on the work of the organisation to establish a BAME network and received an update on the WY&H health and care partnership’s BAME review and endorsed the review recommendations;

reviewed and approved the emergency planning, preparedness and resilience assurance statement and annual report;

approved amendments to the CCGs’ policy on conflicts of interests and standards of business conduct, the updated policy on joint working with the pharmaceutical and related industries and the policy on the offer and receipt of gifts, hospitality and sponsorship;

Minutes of governing body committees

Questions from the public

Annual reports received:

Audit and governance committee External audit letter Safeguarding Emergency planning, preparedness

and resilience Workforce report

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

71

approved the commissioning assurance framework as a fair reflection of the CCGs’ strategic risk position;

received an update on the review of the strategic partnering agreement and the development of the WY&H integrated care system (ICS).

Conclusion: The governing body has fulfilled its role and responsibilities.

2.3.7 Committees of the CCG and committees of the governing body

Senior leadership team (SLT)

Role: The SLT’s role is to lead the development of CCG vision and strategy; develop and approve commissioning plans and policies; oversee the commission process and the operating plans of the CCG.

Responsibilities: The responsibilities of the SLT include:

approving the CCG’s commissioning plan, policies and strategies; approving any arrangements for the joint commissioning of services with local

authorities, other CCGs or NHS England, including approval of any terms of reference for joint committees, unless otherwise delegated to the governing body;

making decisions on the review, planning and procurement of services (except those where authority has been delegated to another group, for example the primary care commissioning committee or the joint committee of WY&H CCGs);

informing CCG input and voting at the joint committee of WY&H CCGs; approving arrangements for managing individual funding requests; and approving human resource policies for employees and for other persons working

on behalf of the CCG, following consultation with the BDCFT staff partnership forum and, where agreed, CCG staff networks.

The SLT business meetings are jointly chaired by the clinical chair and chief officer.

There is a standing invitation for a representative from public health (Bradford Council) to attend SLT meetings in an advisory, non-voting capacity, as well as for the programme director integrated care programme board (James Drury) and system finance executive lead (Andrew Copley). Members of the BAME staff network and WellbeingAndAble staff network are invited to join the business meetings.

Associate directors (ALT) are invited to join a business meeting on a monthly basis (known as extended SLT) where they have dedicated time to discuss a topic of their choice. Staff members and external colleagues are invited to discuss agenda items which are pertinent to them.

The majority of the year has been focused on the CCG response to the pandemic;

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

72

given these exceptional circumstances from April 2020 to November 2020 this was the main focus of the SLT, working closely with partners across the system, monitoring and managing our services. Alongside this SLT received regular updates on risk, quality, finance, restart/ recovery and the wider system, the integrated care system and integrated care partnership.

There have been six SLT/ALT development sessions held this year where the following has been discussed:

CCG strategy; Operating model; Act as one/commissioning futures work/finances 2021; Joint session held with the BAME staff network; Aligning the Commissioning Assurance Framework (our strategic risk log), with

our commissioning strategy, priorities and incorporate the proposed legislation changes on integration;

Reflection session of what has worked well, how far have we come, what next after COVID (which included the further developing Bradford district and Craven Integrated Care Partnership and preparations for establishing the West Yorkshire Integrated Care System). The role of population health management to reduce health inequalities as a key aim within a further integrated way of working across Health, Social Care and Voluntary and Community Sector;

Integrated Care System legislation - impact on our ways of working.

Name RoleDr James Thomas Clinical chair (chair)Helen Hirst Chief officer (chair)Nancy O’Neill Deputy chief officerDr Sohail Abbas Strategic clinical director (SCD) – population health

and wellbeing/deputy clinical chairDr Louise Clarke SCD – strategy and planningDr Dave Tatham SCD – keeping wellDr Junaid Azam SCD – transformation and changeDr Taz Aldawoud Chief clinical information officerRobert Maden Chief finance officerMichelle Turner Strategic Director (SD) – quality and nursingAli Jan Haider SD – keeping wellLiz Allen SD – organisation effectivenessVicki Wallace Acting SD – transformation and change (from 1

December 2020)

SLT met 44 times and attendance is set out below:

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

73

Figure 8: 2020/21 attendance at SLT

SLT highlights 2020/21

Approved a number of policies and procedures: Home-based working policy; Flexible working procedures; Recruitment, selection and promotion policy

Supported a restructure of the population health and wellbeing (PHW) hub in order to create resilience around personalisation

Agreed to remain within the parameters of the West Yorkshire agreement for IFR requests for blood glucose monitoring equipment

Provided leadership and direction around the transition to an integrated care partnership, looking at the impact for staff, partners, commissioning services and the population

Confirmed the commitment to the Keighley health and wellbeing initiative as the CCG’s estate priority and supported the engagement activities with the registered population of the North Street surgery

Confirmed their commitment to of support for community partnerships and requested that a strategy for the development of community partnerships is produced

Approved the Workforce Race Equality Standard (WRES) action

Standing or regular agenda items have changed - April to July 2020 Notes from previous meeting COVID actions: current and for next

two to three weeks CCG risk log - current (especially

COVID Sitrep – staffing, sickness and

redeployment Sitrep - additional expenses Quality and safety risks of providers Children's services Discharges - secondary care to

primary care/community care Communications requirements

Other item(s) of urgent business: Only if essential

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

74

plan Following the release of the new

host commissioner guidance and surveillance, SLT agreed a direction of travel in line with an ICS/ICP footprint

Supported a proposal to move to a single tariff structure for the three musculo-skeletal services

Supported a practice engagement proposal which enables and support practices to engage with the commissioning role of the CCG in the wider system and to support general practice engagement in system-wide changes

Supported a provision of assessment and treatment unit beds

Received presentations from each of the hubs in which they shared their successes and challenges from the past year

Conclusion: The SLT has fulfilled its role and responsibilities.

Quality committee (QC)

Role: The role of the quality committee is to provide assurance of the degree to which services commissioned by the CCG are safe, effective and deliver the best outcomes for local populations.

The scope of the quality committee encompasses all services commissioned by the CCG for children, young people and adults, including those services that are jointly commissioned with the local authority, delegated by NHS England and services commissioned from the voluntary and community sectors.

A full list of committee’s detailed responsibilities and terms of reference is available within the CCG’s Constitution is available on our website.

Membership and attendance

David Richardson (chair)

Lay member for quality BD&C CCG

Ruby Bhatti Lay member primary care commissioning BD&C CCGHelen Rushworth Lay representative HealthwatchDr James Thomas SLT representative BD&C CCGFiona Jeffrey Associate director of organisation effectiveness BD&C CCGJohn Young Secondary care consultant BTHFTMichelle Turner Strategic director quality and nursing BD&C CCG

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

75

Angie Clegg Independent registered nurse BD&C CCG

The committee held 12 meetings during 2020/21 and attendance is detailed below:

Figure 9: 2020/21 attendance at quality committee

Quality committee highlights 2020/21

The committee has met on a monthly basis and has had the opportunity to be presented with showcases of areas where there have been significant achievements as well as collaborations with partners to identify and address areas where there are quality concerns. The terms of reference have been reviewed to ensure fairness and equity of all parties who attend the meetings.

Quality updates have been given regularly. The updates have included a reflection of the overall work of the CCG and inclusion of the independent sector.

Risk updates have been given, including those related to the pandemic. These again have allowed an opportunity for all committee members to remain updated and be able to share learning with other organisations as required

Standing/regular agenda items Declarations of interest Notes of last meeting An action log is updated with

any actions and identifies names of responsible persons for each action.

Quality report – this includes updates from all areas and services for which the CCG is responsible.

Risk register – an explanation and update is given of any risks which have increased/decreased in score as well as additional new items which have been added within the month.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

76

Any issues that the committee feel should be escalated to system quality committee

Conclusion: The quality committee has achieved and delivered its role, responsibilities and functions.

Finance and performance committee (FPC)

Role: The role of the FPC is to advise and support the governing body through performance oversight of key financial indicators/targets, including QIPP, as specified in the CCG’s strategic and operational plans.

The financial year 2020/21 was exceptional in that the operations of the newly formed Bradford District and Craven CCG were dominated by the need to respond to the pandemic and operate within a nationally determined financial regime. Nationally, the operational planning process and agreement of contracts was suspended for the year and it was recognised that it would not be possible to deliver the expected productivity gains and realise financial savings in the usual way.

Changes to the financial governance arrangements were changed and overseen by the committee in order to support the response to the pandemic.

Membership and attendance:

Neil Fell Lay member for finance and performance (chair)Bryan Millar Lay member for audit and governanceRobert Maden Chief finance officerLouise Clarke Strategic clinical director, strategy and planning

The committee has met monthly during the year. At each meeting it has monitored the finance and performance position of the CCG. Attendance at meetings has been as follows:

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

77

Figure 10: 2020/21 attendance at finance and performance committee

Finance and performance committee highlights 2020/21

Reports to the committee have charted the CCG’s performance within the local care system. The committee has been apprised of the arrangements in place during lockdown to deliver services in line with NHS Constitution commitments. Latterly the committee has been able to monitor provision of acute care against performance trajectories designed to restore services back to pre-pandemic levels.

Contracting has largely been reported against block contracts over the year. The second half of the year has seen a change in the contracting arrangements for independent sector providers. The committee has been apprised of the local implementation of these arrangements along with the risks.

Members have reviewed the financial performance of the CCG against the national financial arrangements covering April to September and October to March. Key areas for attention in the first half of the year were to monitor block contract arrangements and COVID-related

Standing agenda items

Declarations of InterestMinutes of the last meeting and action logPerformance reportContracting reportCOVID-19 cost report (separate to September, within finance report from October)Finance reportFinance and performance risk log (every second meeting)Issues to highlight to SLT and GB

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

78

expenditure in order to reclaim funding to facilitate a breakeven position from NHS England.

The fixed resource funding arrangements introduced for the second half of the year presented some financial challenges to achieve a breakeven. To be assured that financial obligations have been met, the committee has monitored financial performance within the CCG and in its relationship across the local care system and the wider WY&H Health and Care Partnership.

To reflect the changed operating arrangements the committee has received and reviewed additional reports covering particular areas of risk and sensitivity, including:

briefings on the operation and risks in connection with the temporary finance regime arrangements introduced by NHSE;

approving financial governance arrangements allowing flexibility to expenditure controls within standing financial instructions with enhanced approval arrangements,

monthly reports covering budgets and expenditures in relation to COVID-19 expenditure prior to reclaim.

considering a monthly update of risks and actions to mitigate the impact of COVID within the CCG.

Conclusion: FPC has assessed its performance against its terms of reference and concluded that the committee works effectively, has a good level of support and has fulfilled its role and responsibilities. In addition, looking forward, the committee has reviewed its membership and terms of reference to reflect the operation of the CCG the context in which it operates in the local and West Yorkshire integrated care systems.

Joint committee of the West Yorkshire and Harrogate CCGs

Role: The committee has delegated authority from the West Yorkshire CCGs to take joint decisions on agreed priorities. It makes recommendations when a collaborative approach across WY&H will help to achieve better outcomes. The committee has an independent lay chair, three CCG lay members and two representatives from each WY

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

79

CCG. North Yorkshire CCG is an associate member. As a result of the pandemic, all meetings were held virtually in 2020/21 and were live streamed. The attendance record is below.

Table 3: attendance record Organisation and role Member Attendanc

e(eligible)

Independent Lay Chair Marie Burnham 3 (3)CCG Lay members

(to 7 July 2020) (from 6 October 2020

(from 6 October 2020)

Stephen HardyRichard WilkinsonRuby BhattiJohn Mallalieu

3 (3)1 (1)2 (2)2 (2)

NHS Bradford, District and Craven CCGClinical ChairChief OfficerStrategic Director of Quality and Nursing

Dr James Thomas Helen HirstMichelle Turner (Deputy for Helen Hirst)

3 (3)2 (3)1 (1)

NHS Calderdale CCGClinical ChairDeputy Chief Officer (to 6 October 2020)Chief Officer (from 21 January 2021)

Dr Steven CleasbyNeil SmurthwaiteRobin Tuddenham

2 (3)2 (2)1 (1)

NHS Greater Huddersfield CCGClinical Chair Dr Steve Ollerton 3 (3)NHS North Kirklees CCGClinical Chair Dr Khalid Naeem 2 (3)NHS Greater Huddersfield and North Kirklees CCGsChief Officer Carol McKenna 3 (3)NHS Leeds CCGClinical ChairChief Executive

Dr Jason BrochTim Ryley

3 (3)3 (3)

NHS Wakefield CCGClinical Chair

Chief Officer

Dr Adam SheppardJo Webster

3 (3)3 (3)

Associate memberNHS North Yorkshire CCGClinical ChairChief Officer

Dr Charles ParkerAmanda Bloor

2 (3)1 (3)

The committee has a public and patient involvement assurance group made up of lay members from each CCG. The group provides assurance that public and patient voice informs the committee’s decisions.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

80

Joint committee of WY&H CCGs highlights 2020/21

Improving outcomes

Responding to COVID-19: The committee considered how WY&H health and care programmes had refocused to support the response to the pandemic. It agreed that its work during the year would need to evolve to reflect the new priorities arising from it.

West Yorkshire and Harrogate Healthy Hearts: In 2018, the committee asked CCGs to adopt the Healthy Hearts improvement project, building on successful work in Bradford. The project aims to identify more people with high blood pressure, help them to control it better and reduce the risk of heart attacks and strokes. As a result, 22,000 more people have had their blood pressure controlled to target numbers. WY&H Healthy Hearts won the Health Service Journal Cardiovascular Initiative of the Year award in 2020.

Assessment and Treatment Units (ATUs) for people with complex learning disabilities: The committee supported a proposal to commission a new care model for people with a learning disability. This involved collaborative commissioning between commissioners and providers across the whole pathway for people with learning disabilities. The aim is to develop a single system and centre of excellence. Members noted plans for engaging with people who had accessed care in ATUs, their carers and staff. Formal approval for the proposals will be sought at a meeting in 2021/22, following further engagement.

Urgent and emergency care: The committee supported a national programme which built on learning from COVID-19. It encouraged people to phone 111 as an alternative to ‘walking’ unannounced into emergency departments (EDs). The integrated offer included alternative pathways, for example GPs, pharmacists and mental health advice. Patients are remotely triaged to determine if there is a clinical need to be seen face to face.

The Committee also considered a report on primary medical care services in West Yorkshire, which were provided by Local Care Direct (LCD). The response to the pandemic, changes in national policy and potential changes to the commissioner landscape meant that there was uncertainty about what should be commissioned for the future. The committee felt that in the current circumstances a pragmatic approach should be taken and agreed to extend the service from LCD for three years. Improving planned care: The committee supported changes to the improving planned care programme, which focused on restarting planned care following the first wave of COVID-19. This included improving access to diagnostic testing services and more shared decision making between primary and secondary care.

The committee also approved an amendment to a WY&H policy for flash glucose monitors - small sensors worn on the skin for monitoring the glucose levels of people with diabetes. The amendment covered type 2 diabetes patients with learning disabilities who need to use insulin. Self-management of diabetes by patients with learning disabilities would promote independence and reduce health inequalities.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

81

Members had previously agreed a number of clinical threshold policies, which had improved equality of access across WY&H and reduced levels of surgery where non-surgical interventions could be more effective.

Stroke: In 2018, the committee agreed a common approach for commissioning hyper acute stroke services and all stages from prevention to recovery. The specialist hyper-acute stroke pathways are now well established, with four units providing hyper-acute care during the first 72 hours following stroke across WY&H. A sustainable stroke clinical network has been established, working to provide the best stroke services possible and further improve quality and stroke outcomes in each of our six places. Priorities include preventing strokes, delivering effective care when people have a stroke and ensuring that there is good support and rehabilitation for people after a stroke.

Working better together

The committee led new approaches to collaborative working between commissioners and providers. The commissioning futures programme was developed in collaboration with partners across the health and care system, based on our successful model of place-based working. Work is only carried out at WY&H level if it adds value to our places

The committee also supported collaboration between commissioners and providers through the Cancer Alliance, improving planned care programme, local maternity system and mental health, Learning Disability and Autism Alliance. The Committee supported the Yorkshire and Humber framework for integrated commissioning of Integrated Urgent and Emergency Care Services provided by Yorkshire Ambulance Service.

Governance

In 2020, the WY CCGs agreed a revised memorandum of understanding for collaborative commissioning, which included a new work plan and the delegation of new commissioning decisions to the joint committee.

The committee maintains a register of members’ interests and declarations of interest are a standing item on all agendas. At each meeting, the committee reviews the significant risks to the delivery of its work programme and assesses how these risks are being mitigated.

For further details, including meeting highlights and attendance during 2020/21, please see the committee’s annual report which is available on its website.

Primary care commissioning committee (PCCC)

The PCCC meets in public six times per annum.

Role: NHS England has delegated to the CCG authority to exercise the primary care commissioning functions set out in schedule 2 in accordance with section 13Z of the NHS Act. The committee has been established in accordance with these statutory

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

82

provisions to enable the members to make collective decisions on the review, planning and procurement of primary care services in the Bradford district and Craven area under delegated authority from NHS England.

Key responsibilities: The committee carries out the following functions relating to the commissioning of primary medical services under section 83 of the NHS Act including:

• GP contracts: GMS, PMS and APMS contracts (including the design of PMS and APMS contracts, monitoring of contracts, taking contractual action such as issuing branch/remedial notices, and removing a contract);

• newly designed enhanced services (“local enhanced services” and “directed enhanced services”);

• design of local incentive schemes as an alternative to the quality outcomes framework (QOF);

• decision making on whether to establish new GP practices in an area;• approving practice mergers;• making decisions on ‘discretionary’ payments (eg returner/retainer schemes).• planning primary medical care services - including needs assessment; reviewing

primary medical care services;• co-ordinating a common approach to the commissioning of primary care

services generally.

Membership and attendance: As required by the delegation agreement with NHS England and CCG guidance on conflicts of interest management:

• the PCCC has a lay and executive majority (the two GPs on the PCCC have a non-voting role); and

• the chair of the PCCC does not also act as the chair of the CCG’s audit committee.

Ruby Bhatti (Chair) Lay member for primary care commissioning (chair)David Richardson Lay member for qualityBryan Millar Lay member for audit and governanceNeil Fell Lay member for finance and performanceAngie Clegg Registered nursePeter Brunskill Secondary care consultantJohn Young Secondary care consultantHelen Hirst Chief officerRobert Maden Chief finance officerMichelle Turner Strategic director of quality and nursingDr James Thomas Clinical chairDr Louise Clarke Strategic clinical director strategy and planningDr Val Wilson YORLMC Ltd (in attendance)

In addition to the members above, the following groups have standing invitations to attend PCCC meetings: NHS England, Healthwatch Bradford and Public Health (CBMDC)

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

83

The PCCC has met six times during 2020/21 and attendance is detailed below:

Figure 11: 2020/21 attendance at PCCC

Primary care commissioning committee highlights 2020/21

Highlights of the PCCC’s work have included:

receipt of regular practice quality and performance reports, including detailed reports of any practices on ‘enhanced surveillance’;

a review of the contract and quality assurance process to establish more efficient ways of working and to reduce bureaucracy for practices;

receiving assurance on the process followed by the CCG to allocate the additional roles reimbursement scheme unallocated funding;

monitoring service provision during COVID-19 receiving updates on national contact changes including being appraised of business continuity plans to support GP practices during outbreaks to ensure continuity of primary care offering;

receiving regular updates on practice closures, mergers and developments within GP practices within the CCG;

receipt of the GP annual e-

Standing agenda items

Declarations of interest Minutes of the last meeting and

matters arising Primary medical care: service

provision during the pandemic Contract assurance and performance

report GP enhanced surveillance report Questions from the public on agenda

items Key messages for governing body

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

84

declaration report; approval of local policies and

guidance: contract mergers, list closures, temporary assignment of lists and managed patient allocation; and

review of the effectiveness of the PCCC.

Conclusion: The PCCC has fulfilled its role and responsibilities.

Audit and governance committee (A&GC)

Role: To review and provide assurance to the governing body on the adequate and effective operation of the CCG’s overall internal control system, with particular responsibilities related to financial reporting and management.

Responsibilities:

monitors the integrity of the financial statements and any formal announcements relating to the CCG’s financial performance;

ensures that there is an effective internal audit function that meets mandatory NHS internal audit standards and provides appropriate independent assurance to the committee, accountable officer and CCG;

reviews the arrangements for integrated governance and risk management activities within the CCG;

critically reviews the CCG’s financial reporting and internal control principles; acts as the ‘auditor panel’ for the appointment of the external auditor, as

required by the Local Audit and Accountability Act 2014 and the Local Audit (Health Service Bodies Auditor Panel and Independence) Regulations 2015;

ensures there is an appropriate relationship with both internal and external auditors;

reviews the work and findings of the external auditors and consider the implications and management’s responses to their work;

ensures adequate arrangements are in place for countering fraud, bribery and corruption;

maintains an overview of the adequacy and effectiveness of information governance (IG) activities and provides assurance to the governing body that risks associated with IG are being managed;

maintains an overview of the adequacy and effectiveness of health and safety (H&S) activities and provides assurance to the governing body that risks associated with H&S are being managed; and

reviews the findings of other significant assurance functions, both internal and external and consider the implications for the governance of the CCG.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

85

Membership and attendance

Bryan Millar Lay member for audit and governance (chair)Ruby Bhatti Lay member for primary care commissioningNeil Fell Lay member finance and performanceDavid Richardson Lay member quality

The audit and governance committee has met five times during 2020/21; two meetings in June 2020 relating to the review and approval of the 2019/20 accounts and annual report, and three standard committee meetings. Attendance at these meetings is detailed below:

Figure 12: 2020/21 attendance at A&GC

Audit and governance committee highlights 2020/21

Together with West Yorkshire and CCGs it was agreed to undertake a joint procurement process. With one process underpinned by a specification and evaluation framework and a consensus of appointment of a new external auditor;

approved the 2019/20 annual report and accounts;

received the 2019/20 head of internal audit opinion and external audit’s ISA 260 summary of audit findings report;

Following a full review approved the internal audit plan for 2021/22, the counter fraud annual plan 2021/22 and the external audit annual plan 2021/22;

monitored the work of internal and

100%

Membership

Lay & Professional

List of Standing Agenda Items declarations of interests minutes of the last meeting and

action log internal audit and counter fraud

progress update external audit progress and

technical report

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

86

external audit and CCG implementation of recommendations arising;

reviewed the performance of internal and external audit;

reviewed and approved a number of information governance and health and safety policies;

reviewed the committee’s own effectiveness and its terms of reference;

will review the results of effectiveness assessments undertaken by other committees in May 2021.

corporate risk and assurance report (includes risk register, CAF, conflicts of interest management, compliance with standing orders and standing financial instructions, CCG corporate incidents, mandatory training compliance, etc)

information governance update health and safety report and audit and governance work

programme

Conclusion: The audit and governance committee has fulfilled its role and responsibilities.

Remuneration committee

Role: The committee makes recommendations to the governing body on pay, remuneration and conditions of service for employees of the CCG who are outside of the national Agenda for Change pay system (such as very senior managers) and people who provide services to the CCG (such as clinical leaders). In addition, the committee receives assurance on the objective setting and performance review processes for elected GPs and senior management.

Membership and attendance:

Ruby Bhatti Lay member for primary care commissioning and communities

Neil Fell Lay member for finance and performanceBryan Millar Lay member for audit and governanceDavid Richardson Lay member for quality

The committee is supported by independent advice from our HR providers, Bradford District Care NHS Foundation Trust.

There have been two meetings of the remuneration committee during 2020/21. Attendance details are shown below:

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

87

Figure 13: 2020/21 attendance at remuneration committee

Remuneration committee highlights 2020/21

Received assurance on the 2019/20 performance review process for the chief officer, clinical chair and all remaining members of the SLT and details of their 2020/21 objectives.

Considered national guidance and made recommendations to the governing body on a pay award for those outside of agenda for change

Reviewed the committee’s effectiveness and its terms of reference

100%

Membership

Lay & Professional

Standing items Declaration of interests Minutes of previous meeting and

action log

Conclusion: The remuneration committee has fulfilled its role and responsibilities

2.3.8 UK corporate governance code

Whilst the UK corporate governance code is not mandatory for NHS bodies, compliance, where applicable, is considered to be good practice. This governance statement is intended to demonstrate our compliance with the applicable principles set out in the code.

For the financial year ended 31 March 2021, and up to the date of signing this statement, we have had regard to the provisions set out in the code and complied with the spirit of the code, insofar as they are applicable to the public sector and the responsibilities of CCGs as established under the Health and Social Care Act 2012.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

88

Whilst no review of our compliance against the UK corporate governance code was conducted during 2020/21, we continue to conduct our business in compliance with the code.

2.3.9 Discharge of statutory functions

In light of recommendations of the 1983 Harris Review, the CCG has reviewed all of the statutory duties and powers conferred on it by the National Health Service Act 2006 (as amended) and other associated legislative and regulations. As a result, I can confirm that the CCG is clear about the legislative requirements associated with each of the statutory functions for which it is responsible, including any restrictions on delegation of those functions.

Responsibility for each duty and power has been clearly allocated to a lead director. Directorates have confirmed that their structures provide the necessary capability and capacity to undertake all of the CCG’s statutory duties.

2.3.10 Risk management arrangements and effectiveness We have had a comprehensive integrated risk management framework (IRMF) in place since establishment. The IRMF was reviewed and updated in November 2020. It describes our approach to managing risk, our risk appetite, our risk management objectives and the processes in place to ensure these objectives are achieved.

Our risk management objectives are to:

effectively identify, report and manage risk; ensure clear accountability for the management and reporting of risk; effectively capture and learn from mistakes to reduce future risks; ensure and evidence statutory and regulatory compliance; effectively manage partnership and project risks.

We monitor and report on risk in two key ways:

The combined (three former) CCGs’ governing body assurance framework was used as the basis for the new NHS Bradford District and Craven CCG commissioning assurance framework (CAF). The commissioning assurance framework (CAF) was approved by the governing body in March 2021 and focuses on strategic/long-term risks to the delivery of our strategic objectives. The CAF will be reviewed and made available to the governing body four times per annum.

The corporate risk register focuses on more operational risks that may rise and fall within relatively short time periods. It is reviewed and updated six times a year.

In response to the pandemic, a separate register was established to record and monitor risks faced by the organisation associated with responding to the pandemic. Initially, the COVID-19 risk register was reported to the SLT on a fortnightly basis and then moved to reporting on a monthly basis. In March 2021, it was agreed that the two risk registers would be combined and both corporate

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

89

and COVID-19 related risks would be reported on a bi-monthly basis. The governing body received regular updates on the response of the organisation to COVID-19 related risks through receipt of the COVID risk log which was included as part of the public meeting papers which can be found on our website .

Risk appetite

Our aim is to minimise the risk of harm wherever possible to service users, the public, staff, members and other stakeholders. However, we also recognise the need to take considered risks in some areas (for example, transformation/re-design of services) and that an overly risk averse approach can be a threat to the achievement of some strategic objectives.

All risks on our risk register and assurance framework specify the target risk score (that is, the level at which the risk can be tolerated). The acceptability of the target risk score is subject to review by senior management and the relevant committee as part of the normal review and reporting process for the risk register and assurance framework.

Other controls to manage risk

Our key control mechanisms of the corporate risk register, CAF and incident reporting and learning systems, are complemented by a range of other control mechanisms designed to deliver assurance on the prevention of risk and management of current risks. These include:

an approved standards of business conduct and conflicts of interest policy, which has been reinforced by training for governing body and SLT members and senior staff involved with service development and contracting;

approval of a counter fraud, bribery and corruption policy, which has been reinforced by mandatory training for both employees and governing body members;

a business continuity plan which sets out our contingency plans to maintain an effective service in the event of a critical incident;

doing regular health and safety, fire and premises risk assessments;

All of our staff have participated in equality and diversity training appropriate to their role. This equips them to identify our policies, governing body papers and improvement programmes that will need a detailed equality impact assessment to identify and mitigate any potential adverse impact on any group of local people with an Equality Act protected characteristic.

Involving public stakeholders in managing risks which impact on them

We engage with patients and carers to improve current services and inform the development of new or reviewed services. In addition, we produce a monthly Grass Roots report of patient views/feedback which is reported to the joint quality committee. This insight helps us to identify any gaps or potential risks to current or future service delivery. You can read more about our approach to involving the public and other stakeholders on page 46 of this report.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

90

Capacity to handle risk

Effectiveness of governance structures

All committees of the CCG and committees of the governing body have documented terms of reference, approved by the body to whom they are accountable, which are reviewed annually, or more regularly if required. Work programmes are maintained and regularly reviewed for all key groups and committees.

The effectiveness of the governing body and its committees is reviewed regularly. Committee reviews were undertaken during the fourth quarter of the year, with findings and opportunities to strengthen arrangements considered by each committee. Due to of the organisation’s response to the pandemic, it had been agreed to take a ‘light touch’ approach when conducting the effectiveness reviews. The committee effectiveness review report will be taken to the May 2021 audit and governance committee.

Internal audit review our risk management and board assurance framework annually and their conclusion for 2020/21 was:

Significant

The audit has provided an opinion of Significant Assurance that a comprehensive integrated risk management framework (IRMF) has been implemented across the CCG and has operated effectively during 2020/2021.

The corporate risk register has continued to be monitored and reviewed in line with the approved framework. A critical risk has been included on the register to reflect the impact of the pandemic.

The risk management process has been supplemented during the year by the adoption of a COVID-19 risk register that has also been kept under review and reported extensively through the CCG's governance structure. This has now been integrated with the corporate risk register.

Towards the end of the year the CCG approved a new commissioning assurance framework which has been developed from the new CCG’s strategy (Our Strategy – Our first 1,000 days). This has also reflected the impact of COVID-19 with a strategic risk being included.

One recommendation remains outstanding from the 2019/20 audit report (04/2020). Three minor recommendations have been made in this report to support the risk register review process.

Internal audit reviewed our governance framework for 2020/21 and their conclusion was:

Significant An overall opinion of significant assurance has been provided in

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

91

relation to the progress made by the CCG in implementing the revised governance framework following the authorisation of the new CCG and the amended arrangements put in place during the COVID-19 pandemic.

It has been confirmed that the revised governance arrangements have been clearly documented and key component elements revised and approved to support its implementation. A small number of minor priority recommendations have been made to address some administrative points.

The revised arrangements put in place ensure the key responsibilities of the CCG receive scrutiny and oversight. The previous model constitution more clearly identified where the responsibility for securing the discharge of functions and statutory duties was delegated to in the CCG. This section has been removed from the new model constitution. There is scope for strengthening clarity in the new governance documents as to where responsibilities for the discharge of these previously specified functions sit.

Significant progress has been made in putting in place arrangements to ensure the business conducted by the key governance forums meets the functions delegated to them. Where appropriate forward planners have been adjusted for COVID-19. Recommendations have been made to ensure all committees have arrangements in place to effectively plan the business they cover.

With the exception of some queries highlighted in regards to consistency across key governance documents, provided within the audit report, it has been confirmed that the decision making authorities of each governance forum is clearly and consistently specified.

Finally, it has been confirmed that the revised governance arrangements during the COVID-19 pandemic as presented to the governing body have been implemented with the incident command arrangements in particular being kept under review as the pandemic has progressed.

Internal audit reviewed freedom of information annually and their conclusion for 2020/21 was:

Significant The review confirmed that there are adequate systems in place which ensures that the CCG complies with its Freedom of Information (FoI) and Environmental Information Regulations (EIR) policy and procedures and thereby satisfactorily discharges its responsibilities. To date, the CCG has not received any EIR requests.

The current FoI and EIR policy and procedure, dated March 2019,

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

92

were transferred over from the previous three CCGs and were due for review in March 2021. The FoI and EIR procedures were updated in July 2019 to reflect the FoI team transferring in-house from eMBED. However, the policy on the CCG’s website includes the old procedures and needs to be updated to reflect this.

The audit and governance committee has responsibility for FoI and EIR, including the review and monitoring of FoI performance. Review of agenda and minutes noted that FoI performance reports are provided at each of its business meetings and an annual report.

The CCG’s website has a page for FoI and EIR which includes the publication scheme. The CCG has adopted the Information Commissioners Office’s (ICO) model publication scheme.

FoI requests are recorded centrally and a process for collecting information from within the CCG is in place. However, it was noted that there is no sign off process prior to responses being sent out and no information is recorded in respect of approval of the response on the central spreadsheet. The Act states that requests must be responded to within 20 working days. Testing found that the CCG is meeting its 20 working days for responding to requests and two working days for acknowledgments.

If the request to provide information takes one person more than 18 hours to complete then the CCG is able to apply a charge for the information; however no evidence was seen or provided to illustrate that departments estimate whether this will be exceeded. There is also no record of the actual time spent.

Responsibilities of the senior leadership team and committees

Our principal risks to achieving our strategic objectives are set out in the commissioning assurance framework. Each of the principal risks has an identified SLT lead. Four times per annum the risk lead is responsible for reviewing the risk, assessing the key controls for mitigating the risk and sources of assurance, identifying positive assurance and any gaps in control or assurance, as well as taking forward specific actions within the timescales outlined.

The roles and responsibilities of staff as owners of risks on the corporate risk register and SLT as reviewers are clearly set out in the integrated risk management framework. This ensures that there is clarity about the levels of accountability for the management and monitoring of risks. The SLT is expected to ensure that there are robust control measures in place to manage identified risks and that the appropriate assurances are generated.

Reporting lines and accountabilities between the governing body, committees and the SLT.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

93

The reporting lines and accountabilities are set out in the integrated risk management framework and reflected in committee terms of reference. As stated earlier, the SLT undertakes a formal review of all risks at the beginning of each reporting cycle and identifies any new risks or changes to risk score as they arise.

Following review by the SLT, the risk register is submitted to the appropriate committee (quality committee or finance and performance committee) for review. Each committee has clear responsibility for the monitoring of existing risks and identification of further risks as set out in its terms of reference. The CCG risk register is then reported in full to the SLT once more. High level risks (those scoring 15 or more on a matrix with a maximum score of 25) are reported to the governing body, as well as details of new and closed risks.

The audit and governance committee provides assurance on the effectiveness of the risk management system to the governing body. It is supported in this by annual review of the system by internal audit.

Timely and accurate information to assess risks to compliance with the CCG’s licence.

The assessment of risks is a continuous process informed by:

staff or the SLT identifying new risks or changes to risk profile; financial, contracting and performance reports, which are submitted on a

monthly basis to the joint finance and performance committee; quality reports submitted monthly to the joint quality committee; discussions taking place at partnership meetings, committees and governing

body.

Degree and rigour of oversight of our performance by the governing body

At each of its meetings, the governing body provides challenge and scrutiny of a suite of reports which focus on the delivery of the key performance targets, quality, safety, financial and contractual requirements. They are:

Chief officer and clinical chair’s report (including updates on the work of the joint committee of WY&H CCGs, wellbeing board and system leadership executive of WY&H Health and Care Partnership);

Finance update report; Patient safety and quality improvement report; High level risk register; Minutes from the finance and performance committee, the quality committee, the

primary care commissioning committee, the audit and governance committee and the remuneration committee.

The reducing burden and releasing capacity at NHS providers and commissioners to manage the pandemic letter sent by Amanda Pritchard, Chief Operating Officer, NHSE&I on 28 March 2020 provided instruction to CCGs in regards to how to conduct governing bodies and to streamline papers, focus agendas. In addition, the letter outlined how paused a number of routine national data collections/reporting and the suspension of a number of NHS constitution standards. Therefore, performance

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

94

reporting during 2020/21 to governing body has been limited. Reporting has focussed on delivery of service response to the pandemic.

Staff training to manage risk as appropriate to their authority and duties

All staff are required to do mandatory training on data security awareness, fire safety, health and safety, manual handling, fraud awareness, safeguarding (including adults, children and the ‘Prevent’ anti-radicalisation initiative) and equality, diversity and human rights. Staff receive other mandatory training appropriate to their roles (eg infection prevention for clinical staff, conflicts of interest for ‘decision taking staff’) and further training as agreed with line managers and detailed in personal development plans.

Learning from incidents, near misses and from good practice is shared via our normal communication channels (team meetings, staff briefings, etc) and via reporting to committees.

A comprehensive suite of policies and procedures is available for staff and the maintenance of our policy framework is reviewed by the audit and governance committee. Detailed guidance is available for users of the on-line risk register system and to support the maintenance of the CAF. Support on any aspect of our risk management framework is available to staff via the governance team or external advisors as required (IG, data protection officer, health and safety, counter fraud, internal audit, etc).

Risk assessment

Risk assessments in relation to governance, risk management and internal control are carried out through a number of mechanisms including:

Through internal governance arrangements taking account of: risk assessment guidance in the IRMF, self-assessment activity, review of our constitution, new national guidance or regulations and external inquiries.

Through the annual internal audit plan by Audit Yorkshire. The plan is developed from a risk assessment of all areas of our activities and work undertaken in line with the plan is reported to the audit and governance committee.

Through external audit throughout the year by KPMG, which includes attendance at the audit and governance committee and focused pieces of external audit work as set out in the auditors annual work plan, culminating in the risk review undertaken prior to annual reporting and accounts.

Detailed guidance on risk assessment is provided in our integrated risk management framework.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

95

Major risks to governance, risk management and internal control

We have identified ten key risks to the achievement of strategic objectives. These are detailed in the CAF, along with the controls in place to manage these risks, the mechanisms by which we receive assurance on the management of these risks and planned actions to address any gaps in control and/or assurance. The commissioning assurance framework was established following the ratification of the Commissioning Strategy in November 2021 and, in March 2021, the governing body approved the commissioning assurance framework. The framework review cycle will include: update and submission to the governing body for approval three times per year. The commissioning assurance framework can be viewed in the governing body papers for March 2021. Of these strategic risks, only risk six related to CCG transition is considered to relate directly to governance, risk management or internal control; details of this risk are provided below. The CCG’s other strategic risks are related to our population, our partnerships, our people and our leadership.

Table 4: commissioning assurance framework strategic risksRisk Key actions to mitigate risk Means to assess

outcome1 There is a risk of failure to

improve population health outcomes and to reduce health inequalities due to COVID-19.  Poor outcomes and health inequalities have been highlighted by the COVID-19 pandemic with both direct and indirect impacts of COVID-19 on the economy, education as well as the physical health and mental wellbeing of our population particularly those living in the areas of worst socio-economic deprivation.

Workshop scheduled to begin discussion around population health management enabling programme (February 2021)

Workshop with wellbeing board on inequalities

Act as One programme workshops – Population Health Management / Health Improvement presentations (March 2021)

Ad-hoc reporting on specific initiatives and projects as required including: population health management presentation to the SLT in December

Performance reporting to both the quality committee and to the finance and performance committee

Reporting to wellbeing board and Act as One health and care executive board

2 There is a risk due to the growing financial pressures created by an increase in demand for services could result in agreed strategic and operational plans to deliver improved health and care not being realised.

Continue to influence partners and negotiate practical solutions in regards to the unpredictability of financial pressures

Address the lack of transparency and openness regarding funding and decommissioning decisions

Collaborate with partners to redress the reduction in true spend on self-care

Reports and updates to Bradford District Wellbeing Board

Minutes of Bradford Council executive meeting in relation to plans, funding and service changes

Reports to the health and care executive board

Reports to health and social care overview and scrutiny committees

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

96

and prevention Analysis of the impact of

COVID to re-determine priorities for the Living Well programme

Resolve the limited training available for staff in motivational interviewing and normalising self-care

Personalised commissioning and continuing health care joint policy in place

Complete the review of the process for shared responsibilities in relation to children in educational establishments out-of-area

and the wellbeing board

3.1 There is a risk that unwarranted variations in quality and care cannot be effectively addressed due to shortfalls in workforce capacity, capability and skills resulting in failure to close the care and quality gap (across BdC)

Discussions are ongoing with Health Education England and Health Education Institution to identify priority areas and agree engagement required when such decisions are made, to ensure sustainability of local care services.

Raise with the West Yorkshire quality surveillance group and local CCGs across the health and care partnership footprint, approach to workforce challenges

Development of a co-ordinated system delivery plan for workforce.

Integrated People Board discussion and reporting shared with system quality committee, CCG quality committee and programme work streams

Reporting of gaps in care and workforce challenges across our providers reported monthly to the system quality committee

Quality assurance mechanisms of providers identify gaps and workforce challenges and agreement of actions required in place

Quality assurance and performance monitoring to address care delivery gaps actioned via provider contractual meetings including use of incentives such as CQUINS is in place/ CQC inspections

3.2 There is a risk that our efforts may not have the

No existing agreed action plan is in place; however

Monthly reporting to SLT and to CCG

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

97

impact we desire due to some determinants of quality and outcomes which lie outside of the control of health and social care resulting in a failure to close the care and quality gap (quality improvement /assurance)

we anticipate that a combination of sector action and response to improve the health, well-being, social determinants/living standards and employability will over time impact positively to improve outcomes for the people of Bradford and Airedale localities.

System quality assurance framework for agreement by system quality committee February 2021 and then to be rolled out incrementally

System agreement on prioritisation of resources to address safety issues through planning and prioritisation processes and governance protocols supported by system partners i.e. planning forum, F&PC, SQC, system strategy group

quality committee and system quality committee

Quality report to governing body (bi-monthly)

Monthly primary care contract assurance and contract management groups (CAG & PCCC)

Risk register to include ongoing risk regarding quality of service provision – reviewed as part of the risk cycle

Regulators (CQC, NHSE/I, OFSTED, MHRA and HSE etc)

Safeguarding boards Overview and

scrutiny committees

4 There is a risk that the changes to health services models required to achieve clinical and financial sustainability are not acceptable to key stakeholders, e.g. patients, the public or elected representatives, and cannot be implemented. This would result in the failure of the act as one approach

Completed strategic partnering agreement refresh March 2021

Bradford district and Craven risk management framework including strategic risk assurance framework and risk register April 2022

Integrated care partnership establishment development plan April/May 2021

Monthly report on Act as One to the CCG SLT

Monthly system and place (ICS and ICP) report to the SLT

Chief officer's report to governing body

Whole system quarterly review with NHSE/I and WY&H ICS

Bradford District Wellbeing Board monitor progress against the metrics developed by LGA

Minutes of Bradford District Wellbeing Board

Attendance at overview and scrutiny committees

5 New ICP establishment: There is a risk that we fail to gain sufficient organisational traction

ICP development framework - led by Helen Hirst for WYH ICS April 2021

BD&C strategic partnering agreement

Section 75

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

98

towards Integrated Care Partnership for Bradford district and Craven place, due to a range of factors. This includes: leadership challenges, failure to agree governance arrangements and future form and function, resulting in failure to achieve a viable form in time to receive delegated responsibilities from the integrated care system

Transition to ICS/P team to be established in response to the legislation (system group to support the creation and readiness of the ICP) April 2021

Complete strategic partnering agreement refresh March 2021

BdC risk management framework including strategic risk assurance framework and risk register April 2022

ICP organisation development plan April/May 2021

Lack detail on the organisational form at WY and BdC and on readiness criteria to start, however deadline is to be ready April 22 June 2021

agreement Engagement with

NHS, LA and VCS partners

Governance structure including wellbeing boards, health and care executive board, system finance and performance committee, system quality committee and health and care partnership boards

Monthly system and place (ICS and ICP) report to the SLT

Chief officer's report to governing body

System oversight including quarterly whole system review meetings held at place, mutual accountability framework and measures that matter with NHSEI and WYH ICS with partners across BdC

Bradford District Wellbeing Board monitors progress against the metrics developed by LGA

Minutes of Bradford District Wellbeing Board

Attendance at overview and scrutiny committees

6 New ICS people transition: There is a risk of CCG staff struggling to adapt to revised system- and partnership-focussed roles as we move towards the new ICS and ICP operating model by 1 April 2022. This is due to the need for different organisational forms and individual CCG staff role flexibility and the normal

CCG People Plan - action plan due to be completed by summer 2021;

Workforce development framework which was launched at staff engagement event in April 2021;

Workforce development action plan to expand offer of blended learning and development opportunities for all staff;

Workforce reporting to associate leadership team (ALT) including HR metrics;

Annual workforce report to governing body;

Reporting against WRES action plan to ALT;

EDI reporting in the CCG annual report;

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

99

factors associated with change, exacerbated by the impact of the COVID pandemic upon ways of working, resulting in failure to successfully transition our CCG staff.

Develop common process for learning and development (L&D) applications;

Revise HR and L&D service specification to address priorities for the transition period;

Discussion required with ICP partners to consider provision of equality, diversity and inclusion specialist support ;

Mandatory manager engagement sessions concerning new/revised HR policies and procedures to be rolled out;

Allocation of leads for workforce equality plans being finalised;

Mapping and audit of total wellbeing offer to staff required.

Feedback from staff networks to extended SLT (includes ALT members);

National NHS staff survey;

WRES national comparators.

7 There is a risk that we do not address the underlying financial deficit and establish a financially sustainable position over the medium term as we exit the pandemic

Establish underlying financial position and 2020/21 exit expenditure runs rates to inform resource requirement for Q1 2021/22 March 2021

Model expenditure forecasts for Q2 to Q4 2021/22 based on two scenarios by April 2021o return to business as

usual trajectorieso the capacity and

resource required to address the backlog of activity

Use prioritisation framework to clarify investment priorities and cost pressures for inclusion in the 2021/22 plan May 2021

Scope efficiency opportunities and expected implementation timescales in light of impact of the pandemic; June 2021

Involvement of SLT and governing body members in development of plans

Sign-off of plans by finance and performance committee and governing body

Monthly financial reporting to SLT, CCG finance and performance, system finance and performance and Bradford place forums and health and care executive board

Reporting to finance and performance committee, SLT, governing body

Financial plan sign off by NHSE&I

Collaborative agreement of plans by the WY&H Health

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

100

Confirm local place-based approvals processes status

Target dates for the above to be confirmed after a place-wide discussion status

and Care Partnership

Reporting to system finance and performance committee, health and care partnership boards and WY&H Health and Care Partnership

Role of NHSE/Ias regulators

Act as One system programme boards and WYH HCP 10 ambitions

The commissioning assurance framework was supported by the corporate risk register and COVID risk register which detailed the CCG’s operational risks and their management and the risks associated with COVID.

As at 31 March 2021 there were a total of 47 open risks on the corporate risk register, with 21 of these risks classed as ‘major’ (that is, scoring 15 or more). Of these ‘major’ risks, no risks are considered to relate to governance, risk management or internal control. The major risk, identified in March/April 2020, relates to the impact of the pandemic.

2.3.11 Other sources of assurance

Internal control

The system of internal control is the set of processes and procedures in place in the CCG to ensure it delivers its policies, aims and objectives. It is designed to identify and prioritise the risks, to evaluate the likelihood of those risks being realised and the impact should they be realised, and to manage them efficiently, effectively and economically.

The system of internal control allows risk to be managed to a reasonable level rather than eliminating all risk; it can therefore only provide reasonable and not absolute assurance of effectiveness.

The effective working of the system of internal control is achieved through the:

operation of the governing body and committees in accordance with clear terms of reference and delegated responsibilities as described in the scheme of delegation and reservation;

annual review of governing body and committee effectiveness; management of key risks to the achievement of our strategic objectives as

identified in the commissioning assurance framework; management of operational risks as identified in the corporate risk register; establishment, maintenance and review of operational policies across all areas of

business, including reviews on the application of those policies;

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

101

application of appropriate financial accounting and financial management procedures as described in the standing financial instructions;

regular reporting of performance on our duties and responsibilities to the governing body and SLT;

review of the effectiveness of the system of internal control carried out by the internal and external audit functions; and

quarterly whole system review meetings held in our health and care executive board and with NHSEI and WY&H Health and Care Partnership.

Annual audit of conflicts of interest management

The revised statutory guidance on managing conflicts of interest for CCGs (published June 2017) requires us to do an annual internal audit of conflicts of interest management. To support us in this task, NHS England has published a template audit framework. Audit Yorkshire, our internal auditors, has done this on our behalf and their conclusion is detailed below:

Significant The CCG can demonstrate that there are effective arrangements in place to manage conflicts of interest in how the CCG conducts its business. The CCG’s conflicts of interest and business conduct policy and policy on offer or receipt of gifts, hospitality and sponsorship comply with the Managing Conflicts of Interest: Revised Statutory Guidance for CCGs issued in June 2017.

Testing found that the CCG arrangements are largely compliant with the NHS Oversight Framework probity and corporate governance indicator, and the majority of areas for improvement in the NHS England best practice update on conflicts of interest management have been adopted in practice. Areas identified where compliance could be strengthened relate to:

minor amendment to the CCG policies to reflect organisational changes.

compliance with self-certification categories within the NHS Oversight Framework indicator relating to mandatory conflicts of interest training and up to date registers for conflicts of interest.

annual review of declarations of interest in the registers of interest.

minor update to the format of the registers of interest and gifts and hospitality.

Work has been undertaken since the previous audit to implement the recommendations made. Some progress during 2020/21 was impacted by the CCG response to COVID-19 and subsequent prioritisation of actions undertaken, and gaps in resource in the corporate governance team. Two previous audit recommendations remain outstanding, and are included in a separate table in section 3 of the audit report.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

102

The audit and governance committee is informed of the CCG position for the management of conflicts of interest on a regular basis as part of the corporate risk and assurance report, which includes linked risks from the corporate risk register, and updates on the current suspension of the quarterly and annual self-certification assessments to NHS England.

2.3.12 Data quality

Under the current arrangements around the handling of confidential data we are not permitted to handle, process or view any patient identifiable data which includes NHS number, postcode or date of birth. The exception to this is under the current COVID pandemic where short term changes to the information governance rules allow us to share and analyse patient level information where it supports direct patient care.

All processing of provider supplied confidential data is undertaken by the Yorkshire DSCRO (Data Services for Commissioners regional office).  At present this team is hosted by NECS (North of England Commissioning Support Unit) and all staff have the required legal status under NHS Digital’s terms and conditions.

The business intelligence service is part of our population health and wellbeing hub and transferred in-house on the 1 April 2020. Key analyses are done on a regular basis to support us in monitoring key performance targets, as well as providing intelligence to assist with our contracting and commissioning functions.  In addition, the team regularly monitors the flow of information from providers to ensure they are meeting their contractual obligations.  The team is also responsible for monitoring the quality of the data being submitted and this is discussed with the main providers at regular meetings.  Where issues around data quality or non-receipt of datasets are unresolved at this level, this is escalated to the finance and performance committee and included on the corporate risk register, where appropriate.

All information provided to the CCG undergoes rigorous data quality checking processes to ensure the highest quality of data is provided to the governing body and CCG council. 

2.3.13 Information governance

The NHS Information Governance Framework sets the processes and procedures by which the NHS handles information about patients and employees, in particular personal identifiable information. The NHS Information Governance Framework is supported by an information governance toolkit and the annual submission process provides assurances to the CCG, other organisations and to individuals that personal information is dealt with legally, securely, efficiently and effectively. The baseline submission of the data security and protection toolkit (DSPT) was completed 26 February 2021, with 30 of 37 mandatory assertions met. In total there are 42 assertions, five of which are non-mandatory. The DSPT includes submission on training compliance and the CCG’s data security awareness training was 95% and the CCG also managed ten Data Protection Impact Assessments (DPIAs) during 2020/21.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

103

We are on track to complete a full DSPT return by the extended submission date of 30 June 2021. In addition internal audit of our DPST is currently underway.

We place high importance on ensuring there are robust information governance systems and processes in place to help protect patient and corporate information. We have established an information governance management framework and have developed information governance processes and procedures in line with the information governance toolkit. We have ensured all staff do annual information governance training and have a staff information governance handbook to ensure they are aware of their information governance roles and responsibilities.

There are processes in place for incident reporting and investigation of serious incidents. We have an information risk assessment and management procedures and a programme is established to fully embed an information risk culture throughout the organisation against identified risks (see paragraph 2.6.10 in this report).

Table 5: data security and protection incidents

Category of incident Qtr 1 Qtr 2 Qtr 3 Qtr 4 Totalnumber

Disclosed in error/data breach 0 6 5 2 13Lost in transit 1 1 0 0 2Cyber security 0 0 0 0 0other 2 1 3 2 8Third party information governance incidents identified 2 0 1 0 3

Total 5 8 9 4 26

Freedom of Information requests

People have the right to ask for information held by the CCG under the Freedom of Information Act. For a freedom of information (FOI) request to be valid under the Act, the request must be in writing, include the requester's real name and an address for correspondence, and describe the information requested. During 2020/21 we received a total of 186 requests, with just one FOI request which breached the 20 working days standard and this was completed within 21 working days. The top five areas for FOIs include: contracts/service level agreements, medicines management, primary care, mental health and corporate.

2.3.14 Business critical models

In the Macpherson report Review of Quality Assurance of Government Analytical Models, published in March 2013, it was recommended that the governance statement should include confirmation that an appropriate quality assurance framework is in place and is used for all business critical models. Business critical models were deemed to be analytical models that informed government policy. We can confirm that in 2020/21 the CCG has not developed any analytical models which have informed government policy.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

104

Our information governance framework ensures that business critical systems are identified and managed effectively. As part of this framework information, asset owners have been identified that cover the range of business systems used by the CCG. The responsibility of information asset owners includes the maintenance of an information asset register and data flow map relevant to their organisational remit, the maintenance of service continuity plans for business critical systems and the continuity of key skills to operate such systems.

2.3.15 Third party assurances

For functions that are carried out on behalf of the CCG by third parties, we receive assurance from the organisation or their auditors that appropriate systems and internal control are in operation. We receive services from the following organisations and details of assurances received for 2019/20 are provided below:

NHS Shared Business Services (SBS) (provision of financial and accounting services and primary care payments services) – service auditor’s report: reasonable assurance with the exception of qualified opinions for the nine control objectives set out in the report.  Due to the COVID pandemic it was not possible to undertake testing of these controls at SBS’s site in India or to test these controls by any other means.

NHS Digital (payments to GP contractors) [excluding work undertaken by sub-service excluding work undertaken by organisations Capita and NHS Shared Business Services organisations Capita and NHS Shared Business Services] – service auditor’s report: reasonable assurance with the exception of a qualified opinion relating to controls over the system (technical architecture) change process.

Capita (payments to GP contractors) – service auditors report: delayed due to pandemic, this report was not available at the time the annual report was published.

NHS Business Services Authority (prescription pricing services) – service auditors report: reasonable assurance.

The Health Informatics Service (THIS) (provision of IT and information governance) – assurance provided via contract management arrangements.

North East Commissioning Service (NECS) (provision of data services for commissioners) – assurance provided via contract management arrangements.

Bradford District Care NHS Foundation Trust (provision of payroll services, HR, learning and development and health and safety services) – assurance on payroll services provided to consortium members, including the CCG; assurance on other services provided via contract management arrangements.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

105

2.3.16 Control issues

There were no significant control issues arising during 2020/21.

However, following a CQC rating of ‘inadequate’ for one of our GP practices in 2018/19, we have supported the practice team in addressing the findings of the review. Progress has been reported on this to each meeting of the Primary Care Commissioning Committee via the GP enhanced surveillance report.

In response to the pandemic the CQC adapted its regulatory approach and routine inspections and, to reduce duplication and avoid unnecessary burden for providers, it was agreed that the annual regulatory reviews (ARRs) should cease from 1 April 2020.  From April 2021, we the CQC will have a phased re-start of regulatory activity which includes the following activity:

For hospital services (including independent health and mental health services), there will be a continued risk-based approach to regulation, undertaking inspection activity where there is a clear risk to safety

For primary medical services, in addition to undertaking inspection activity where there is a clear risk to safety and will resume inspections of independent primary care providers, focusing on high/medium risk providers that have never been inspected or that were inspected but not rated

Further details of the updated CQC regulatory approach can be found on the CQCs regulatory approach web page. 2.3.17 Review of economy, efficiency and effectiveness of the use of

resources

The governing body reviews and approves the budget for the financial year to ensure that the use of resources reflect our commissioning priorities and are applied to the delivery of key performance targets, including efficiency targets and financial balance.

The governing body receives a comprehensive finance, performance and contracting report from the chief finance officer at each of its meetings.  The joint finance and performance committee advises and supports the governing body in providing assurance on the delivery of key targets.

The SLT scrutinises and tracks the delivery of key financial and service priorities, outcomes and targets, as well as leading the development and monitoring of remedial action where performance is below plan.

Our audit and governance committee takes the lead role, on behalf of the accountable officer and governing body, in maintaining and reviewing the effectiveness of the system of internal control, including financial control.  The audit and governance committee advises and assures the governing body upon the adequacy and effective operation of the organisation’s overall internal control system focusing upon the framework of risks, controls and assurances that underpin the delivery of the organisations objectives and to review the disclosure statements that flow from those assurance processes.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

106

In 2020/21 we were operating within a temporary finance regime but continued to manage and deliver a programme of QIPP savings.  The governing body receives regular updates on the QIPP programme through the finance and contracting reports whilst detailed scrutiny of performance against the QIPP plan is undertaken by the finance and performance committee.   

Our external auditor, KPMG LLP, has done a range of work against their 2020/21 plan.  Our internal auditor, Audit Yorkshire, has completed the programme of a risk-based plan of work, agreed with management and approved by the audit committee, which was designed to provide a reasonable level of assurance, for 2020/21.  We have agreed action plans with auditors to improve our control environment.

NHS Oversight Framework

NHS England and Improvement has a statutory duty to make an annual assessment of CCG performance and meets this duty through the NHS System Oversight Framework (NHS SOF).

During 2020/21 NHS England and Improvement held quarterly whole system review meetings with the Health and Care Executive Board which is made up of system leaders under our strategic partnering agreement for Bradford district and Craven.

The CCG year-end assessment review process for 2020/21 has been simplified, due to the continued impact of COVID-19 and the change in priorities in response to this. There will be no algorithmic assessment to provide an overall CCG rating as there has been in previous years. A narrative assessment letter will be sent identifying areas of good/outstanding performance, and areas for improvement, including areas of particular challenge across five priority areas:

Improve the quality of service Reduce health inequalities Involve and consult the public Comply with financial duties Leadership and governance

CCGs have the option to publish their assessment letter or a summary of key points and our letter will be available, by the 31 July 2021, on our CCG website.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

107

2.3.18 Delegation of functions

The CCG council has oversight of the functions delegated to the governing body, SLT and committees via reporting to its meetings and on its review and receipt of the CCG annual report.

The governing body has oversight of the functions delegated to committees through its overview of CCG performance and specifically via:

receipt and review of performance reports (finance and contracting, performance and quality);

receipt and review of the clinical chair’s report (which provides updates on SLT and the joint committee of the West Yorkshire and Harrogate Health and Care Partnership);

receipt and review of committee minutes (FPC, QC, PCCC, A&GC and remuneration committee).

Where functions are carried out on behalf of the CCG by third parties, there are regular meetings to review performance against contracts and work programmes. In addition we receive an annual assurance statement from the auditors of these third parties that appropriate systems and internal control are in operation. These organisations are specified in the third party assurance section of this report (page 103).

2.3.19 Counter-fraud arrangements

We have access to a local counter-fraud specialist (LCFS) to meet the requirements set out in the standard commissioning contract. Their work is risk-based and in-line with the Government’s National Fraud Strategy and Chartered Institute of Public Finance and Accountancy (CIPFA) Managing the Risk of Fraud document, which are considered as best practice when countering fraud. A counter fraud, bribery and corruption policy is in place and the chief finance officer is the executive lead for this area.

A counter-fraud, bribery and corruption plan is developed by the LCFS annually and is approved by the audit and governance committee. The plan includes a significant proactive element. The committee receives reporting against this plan at each of its meetings.

The LCFS has provided alerts throughout the year including: fraud alerts, cyber enabled salary diversion fraud, salary diversion alert, NHS Counter Fraud Authority guidance regarding timesheet overpayments and general public targeted by COVID-19 vaccination scams.

Although the LCFS suspended face-to-face training sessions due to the pandemic, for staff and governing body members they organised and have held virtual sessions via Microsoft Teams throughout the year. LCFS publishes a counter fraud newsletter which was widely circulated.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

108

New counter fraud requirements which will enable NHS organisations to meet the government counter fraud functional standard were published in June 2020 and the LCFS will support us in making a successful transition to the new functional standard.

2.3.20 Head of internal audit opinion on the effectiveness of the system of internal control at Bradford District and Craven CCG for the year ended 31 March 2021

1. Introduction

The purpose of this Head of Internal Audit Opinion is to contribute to the assurances available to the Accountable Officer and the Governing Body which underpin the Governing Body’s own assessment of the effectiveness of the organisation’s system of internal control. This Opinion will assist the Governing Body in the completion of its Annual Governance Statement, along with considerations of organisational performance, regulatory compliance, the wider operating environment and health and social care transformation.

This opinion is provided in the context that the Clinical Commissioning Group like other organisations across the NHS have faced unprecedented challenges due to COVID-19.

2. Executive Summary

This Head of Audit Opinion forms part of the Annual Report for NHS Bradford District and Craven Clinical Commissioning Group, in which the planned internal audit coverage and outputs during 2020/21 and Audit Yorkshire’s Key Performance Indicators (KPIs) are detailed.

Key Area SummaryHead of Internal Audit Opinion & the Role of Internal Audit During the Pandemic

The overall opinion for the period 1st April 2020 to 31st March 2021 provides Significant Assurance that that there is a good system of internal control designed to meet the organisation’s objectives, and that controls are generally being applied consistently.

The Internal Audit Standards Advisory Board (IASAB) issued guidance regarding conformance with the Public Sector Internal Audit Standards (PSIAS) during the coronavirus pandemic (May 2020). All our work has continued to be delivered in full compliance with the PSIAS.

Audit Yorkshire adopted a pragmatic approach to the delivery of your Internal Audit Service during 2020/21, with the focus on the delivery of your Head of Internal Audit Opinion. This again, was in line with the IASAB guidance.

We supported you through the provision of a wide range of briefings, updates and benchmarking materials focused on helping you manage the challenges of COVID-19. We also supported the wider NHS systems across Audit Yorkshire’s client base / geographies through the redeployment of our staff to maintain the effective delivery of services.

Planned Audit Coverage and Outputs

The 2020/21 Internal Audit Plan has been delivered with the focus on completion of high priority or ‘must do’ audits to support the provision of a meaningful Head of Internal Audit Opinion. This position has been reported within the progress reports across the financial year.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

109

Key Area Summary

The impact on the organisation of COVID-19 required us to review your internal audit risk assessment and plan for 2020/21 on a regular basis, in liaison with yourselves. As part of this assessment we took account of the following:

How the organisation has implemented NHSE/I guidance, issued to support them in responding to COVID-19, whilst still discharging their stewardship responsibilities;

Any revisions to the organisation’s strategic priorities as well as liaising with you to review areas for internal audit focus;

Independent assurance requirements on how COVID-19 costs have been captured and claimed across a range of areas (ongoing); and

Mandated review requirements and audits which from a professional internal audit perspective are pre-requisite to ensuring sufficient coverage for a robust Head of Internal Audit Opinion.

Therefore review coverage has been focused on: The organisation’s Assurance Framework Core and mandated reviews, including follow up; and A range of individual risk based assurance reviews.

Due to the impact of the pandemic, there was limited coverage of the quality section originally included in the plan for 2021/21. These areas have been considered as part of the 2021/22 risk assessment and planning process.

Quality of Service Indicators

The External Quality Assessment, undertaken by CIPFA (2020), provides assurance of Audit Yorkshire’s full compliance with the Public Sector Internal Audit Standards.

3. Roles and responsibilities

The whole Governing Body is collectively accountable for maintaining a sound system of internal control and is responsible for putting in place arrangements for gaining assurance about the effectiveness of that overall system.

The Annual Governance Statement is an annual statement by the Accounting Officer, on behalf of the Governing Body, setting out:

how the individual responsibilities of the Accounting Officer are discharged with regard to maintaining a sound system of internal control that supports the achievement of policies, aims and objectives;

the purpose of the system of internal control as evidenced by a description of the risk management and review processes, including the Assurance Framework process;

the conduct and results of the review of the effectiveness of the system of internal control including any disclosures of significant control failures together with assurances that actions are or will be taken where appropriate to address issues arising.

The organisation’s Assurance Framework should bring together all of the evidence required to support the Annual Governance Statement requirements.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

110

In accordance with Public Sector Internal Audit Standards, the Head of Internal Audit (HoIA) is required to provide an annual opinion, based upon and limited to the work performed, on the overall adequacy and effectiveness of the organisation’s risk management, control and governance processes (i.e. the organisation’s system of internal control). This is achieved through a risk-based plan of work, agreed with management and approved by the Audit Committee, which should provide a reasonable level of assurance, subject to the inherent limitations described below.

The opinion does not imply that Internal Audit has reviewed all risks and assurances relating to the organisation. The opinion is substantially derived from the conduct of risk-based plans generated from a robust and organisation-led Assurance Framework. As such, it is one component that the Governing Body takes into account in making its Annual Governance Statement.

4. The Opinion

My opinion is set out as follows:

1. Basis for the opinion;2. Overall opinion;3. Opinion Definitions4. Commentary.5. Considerations for your Annual Governance Statement6. Looking Ahead

4.1 The basis for forming my opinion is as follows:

An assessment of the design and operation of the underpinning Assurance Framework and supporting processes; and

An assessment of the range of individual opinions arising from risk-based audit assignments contained within internal audit risk-based plans that have been reported throughout the year. This assessment has taken account of the relative materiality of these areas and management’s progress in respect of addressing control weaknesses.

An assessment of the organisation’s response to Internal Audit recommendations, and the extent to which they have been implemented.

Unless explicitly detailed within our reports, third party assurances have not been relied upon.

4.2 Overall Opinion

Our overall opinion for the period 1 April 2020 to 31 March 2021 is:

Significant assurance can be given that there is a good system of governance, risk management and internal control designed to meet the organisation’s objectives and that controls are generally being applied consistently.

4.3 Opinion Definitions

The following potential opinion levels are available when determining the overall Head of Internal Opinion. These levels link closely with our standard definitions for report opinions:

Opinion Level HOIA Opinion DefinitionHigh High assurance can be given that there is a strong system of

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

111

Opinion Level HOIA Opinion Definition

(Strong)

governance, risk management and internal control designed to meet the organisation’s objectives and that controls are being applied consistently in all areas reviewed.

Significant(Good)

Significant assurance can be given that there is a good system of governance, risk management and internal control designed to meet the organisation’s objectives and that controls are generally being applied consistently.

Limited (Improvement Required)

Limited assurance can be given as there are weaknesses in the design and/or inconsistent application of the framework of governance, risk management and internal control that could result in failure to achieve the organisation’s objectives.

Low(Weak)

Low assurance can be given as there is a weak system of internal control and/or significant weaknesses in the application of controls that will result in failure to achieve the organisation’s objectives.

Where limited or low assurance is given the management of the Governing Body must consider the impact of this upon their overall Governing Body Assurance Framework and their Annual Governance Statement.

4.4. The commentary below provides the context for my opinion and together with the opinion should be read in its entirety.

The design and operation of the Assurance Framework and associated processes.

Bradford District and Craven Clinical Commissioning Group was formed on 1 April 2020. The risk management framework has been reviewed and updated for the new CCG. This was approved in November 2020.

An audit of the risk management and assurance framework has been undertaken in 2020/21. The audit provided an opinion of Significant Assurance.

Towards the end of the year the CCG approved a new Commissioning Assurance Framework which has been developed from the new CCG’s strategy (Our Strategy – Our first 1,000 days). This has also reflected the impact of Covid-19 with a strategic risk being included.

Risk management has taken place in the context of the Covid-19 pandemic and throughout the year the corporate risk register has continued to be monitored and reviewed in line with the approved framework. The Governing Body and its sub committees have been regularly sighted on the high level risks to the organisation. A critical risk has also been included on the register to reflect the impact of the pandemic.

The risk management process has been supplemented during the year by the adoption of a Covid-19 risk register that has also been kept under review and reported extensively through the CCG's governance structure. This has now been integrated into the corporate risk register.

Central to an effective system of internal control is the governance arrangements put in place by an organisation. These have been of increased importance as NHS organisations have responded to the Covid-19 pandemic. In 2020/21 a Significant Assurance opinion has been provided in relation to the progress made by the CCG in implementing the revised governance framework following the authorisation of the new CCG and the amended arrangements put in place during the COVID-19 pandemic. The revised governance

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

112

arrangements put in place during the COVID-19 pandemic were approved by the Governing Body. These arrangements have been kept under review, with the incident command arrangements in particular being adapted as the pandemic has progressed.

The range of individual opinions arising from risk-based audit assignments, contained within risk-based plans that have been reported throughout the year.

Core and risk based reviews issued

1 high assurance opinion: Covid-19 Costs Expenditure Declaration

11 significant assurance opinions

Governance Framework

Risk Management and Assurance Framework

Freedom of Information

Individual Funding Requests

Conflicts of Interest

Core Financial Systems

Mental Health Act Section 117 (Follow Up)*

Primary Care Commissioning and Contracting (NHSE/I Substantial)

Reducing Inequalities

Programme Management**Data Security and Protection Toolkit** (See note below)

Note: An Independent Assessment was conducted in accordance with the new national Data Security and Protection audit framework, Strengthening Assurance. An overall risk rating of ‘moderate’ was assigned to the review as per the overall risk rating methodology set out in the framework. This assurance rating would be the equivalent of an Audit Yorkshire significant assurance rating. A high assurance opinion was issued within this report in respect of the confidence level of the Independent Assessor in the veracity of the self-assessment.

3 limited assurance opinions:

Continuing Healthcare*** – see page 6 for update

Personal Health Budgets (Follow Up) - see page 7 for update

Childrens Continuing Care**

0 low assurance opinions: N/A

0 reviews without an assurance rating

N/A

* Scope of opinion limited to design. Implementation of revised processes is to be tested for effectiveness and embeddedness in 2021/22.

** Report in draft.

*** Opinion increased to Significant for design following work undertaken to implement the

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

113

recommendations. Implementation of revised processes is to be tested for effectiveness and embeddedness in 2021/22.

Follow Up

A total of 197 Internal Audit recommendations have been live during 2020/2021 (this includes recommendations from previous years’ reports that were still live at 1 April 2020).

During the course of the year we have undertaken work to track the implementation of Internal Audit Recommendations. The recommendation clear up summary 2020/21 was as follows:

Overdue Overdue with Revised Date Not Yet Due Implemente

d Total % Overdue

2 27 38 130 197 1.0%

We can conclude that the organisation has made good progress with regards to the implementation of recommendations. This is particularly the case given the context of progressing actions during the Covid-19 pandemic. As detailed some recommendations are overdue in comparison to their original agreed action dates. However, revised action dates have been agreed for the vast majority of overdue actions. Progress on outstanding audit actions is monitored at each meeting by the Audit and Governance Committee.

4.5. Consideration for your Annual Governance Statement

The Head of Internal Audit Opinion is one source of assurance that the organisation has in providing its Annual Governance Statement. In addition the organisation should take account of other third party / independent assurances that are considered relevant. We recommend that the Executive Summary above (page 1) is used in your Annual Governance Statement.

A Significant Assurance overall opinion has been provided. However, attention is drawn to the fact that two final reports have been issued in 2020/21 with a “limited assurance” opinion:

01/2021 Continuing Healthcare

This was a joint audit with the internal audit team at Bradford Metropolitan District Council (BMDC). The audit was undertaken in 2019/20 when the three former CCGs (Airedale, Wharfedale and Craven; Bradford City and Bradford Districts) were separate statutory bodies. However, due to COVID-19, issue of the draft report was delayed. Whilst the audit, including testing, was carried out on the three different organisations, the recommendations in the report were made for the new CCG, established on 1 April 2020, to take forward.

Whilst an overall opinion of Limited Assurance was awarded the audit identified examples of good practice as follows:

Assessment and eligibility decision making was aligned to the National CHC Framework. There had been improvement in the level of compliance with the 28 days assessment

target during 2019/20. LA billing records were accurate and compliant with charging expectations. Invoicing was prompt, methodical and supported by evidence for the charges.

The key areas for improvement in the audit related to the:

Governance framework in which CHC operates Monitoring and oversight of CHC activity and the reliability of data

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

114

Elements of the National CHC Framework that were not being met IT systems to support the CHC framework Timeliness of invoice checks and payment.

The audit report was issued as a final in November 2020 with a preliminary action plan. A Task and Finish Group was established to refine and implement the action plan. All actions were due for implementation by 30 April 2021.

The CCG has made very good progress in implementing the actions. Of the 24 recommendations made in the report a total of 19 have been implemented. Of the remaining five the action date has been extended for one action to allow for the procurement of a new system to support the administration of CHC. In the meantime a compensating control to capture activity data has been put in place. The remaining four actions are work in progress or are largely complete.

In recognition of the good progress made in implementing the agreed action plan we are in a position to improve the level of assurance for the design of the system to Significant Assurance. A further audit of Continuing Healthcare has been included in the audit plan for 2021/22 where further testing will be undertaken to test the effective and consistent application of the revised processes. This will inform whether the overall opinion for both design and effective implementation can be improved to Significant Assurance.

06/2021 Personal Health Budgets

An audit of Personal Health Budgets (PHBs) was undertaken in 2018/19. An opinion of Limited Assurance was given and a total of 10 recommendations were made (Report 06/2019). It was scheduled to undertake a follow up audit in 2019/20 but the ability to complete this was impacted by a delay in implementing some of the recommendations and subsequently the Covid-19 pandemic.

The audit in 2020/21 identified that whilst the CCG has largely put in place arrangements to comply with guidance from the Department of Health and as mandated by NHS England there were some points to address in terms of application.

In relation to effective financial governance arrangements gaps in arrangements still existed from the previous audit report where recommendations had not been effectively implemented. The key impact of this was an absence of monitoring and oversight of the valid use of funds allocated via PHBs and the effective recovery of funds where applicable. In addition, there was no formal process in place for deceased patients with a direct payment or for closing the Professional Financial Services (PFS) accounts and reclaiming any monies.

Six of the 10 previous recommendations had not been effectively implemented and three had been partially implemented. A further recommendation was no longer applicable.

Whilst a further Limited Assurance opinion has been provided for the 2020/21 audit it is recognised that the CCG is actively taking steps to improve governance and monitoring of PHBs. A formal Finance and Activity Group has been established to monitor PHBs and processes, standardise procedures and address the backlog of three month and annual reviews.

The CCG has taken positive action to address the recommendations made in the report, with a number of actions being completed prior to the issue of the final report. Of the 19 recommendations six have been implemented with 13 not yet due. One of the actions aligns with the action in the Continuing Healthcare report to procure a new administration system. The primary outstanding issues to address relate to strengthening the financial governance

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

115

controls.

A further audit of Personal Health Budgets will be undertaken in 2021/22 where further testing will be undertaken to confirm the implementation of the remaining recommendations and to test the effective and consistent application of the revised processes. This will inform whether the overall opinion for both design and effective implementation can be improved to Significant Assurance.

13/2021 Children’s Continuing Care

The audit has provided Limited Assurance that the CCG has effective systems and processes in place to manage Childrens Continuing Care (CCC). The audit report is currently in draft and a meeting has been arranged to agree an action plan with management. Initial discussions with management indicate the draft opinion level and findings are accepted.

Previous Year Limited Assurance Opinions

No Limited Opinion assurance reports were issued in 2019/20. However, two Limited Assurance opinion reports issued in 2018/19 were still extant at the start of 2020/21. An update on report 06/2019 Personal Health Budgets is provided above. The second report related to:

Mental Health Act Section 117 (07/2019)

Internal Audit undertook an audit of Mental Health Act Section 117 – After-Care Services in 2018/19 (Report 07/2019) where an opinion of Limited Assurance was given and 16 recommendations were made. Internal Audit had planned to undertake a follow up of the audit in 2019/20. However, due to a delay in developing a revised policy framework the audit was deferred to March 2020 and was then subsequently impacted by the Covid-19 pandemic. The follow up audit was carried forward to the current audit year (2020/21).

Covid-19 resulted in further delay in approving a revised policy with the Inter Agency S117 Policy and Procedure being ratified by the CCG and the Local Authority in February 2021. A two stage follow up audit approach has therefore been undertaken.

We have undertaken an initial review of the redesign of the framework as documented in the new agreed policy, and will subsequently test its effective implementation once rolled out. The Significant Assurance opinion provided in the report in 2020/21 is therefore primarily limited to work undertaken to redesign the policy framework. A review of the effective implementation of the revised policy has been incorporated into the 2021/22 internal audit programme.

6. Looking Ahead

This opinion is provided in the context that NHS Bradford and Craven CCG, like other organisations across the NHS, continues to face a number of challenging issues and wider organisational factors particularly with regards to the ongoing pandemic response and COVID-19 recovery. The COVID-19 pandemic led to changes to the NHS financial framework, the establishment of the control and command structures both regionally and within individual organisations and an ongoing focus on the emergency response. This has required NHS organisations to operate in a different way to previous ‘business as usual’ practice. Guidance was clear that financial constraints must not stand in the way of taking immediate and necessary action but that there was no relaxation in fiduciary duties.

Bold decision making will continue to be needed as organisations recover from COVID-19

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

116

whilst at the same time maintaining due focus on governance, probity and internal control. The maintenance of robust financial and organisational control is at the heart of the Head of Internal Audit Opinion and we will continue to work with the organisations we serve to provide timely advice and insight throughout 2021/22.

During the COVID-19 response, there has been an increased collaboration between organisations as they have come together to develop new ways of delivering services safely and to coordinate their responses to the pandemic. This focus on collaboration will continue as the NHS progresses on its journey towards integrated care systems.

Audit Yorkshire has refreshed its planning approach for 2021/22 to take account of the impact of COVID-19 and the moves towards integrating care. Our plans for 2021/22 therefore focus on post-COVID recovery, on how our work can make a real difference on patient care and on maximising opportunities for sharing knowledge and learning.In particular, the strategy we have adopted has ring fenced provision in plans to carry out co-ordinated audits across all Audit Yorkshire Members and clients, or at Place, ICS or Sector level. We have provided for flexibility in our CCG plans to support CCGs as they transition to ICS and Place arrangements. Our plans for 2021/22 leave us very well placed to support organisations in their delivery of the six key priority areas listed in the NHS Operational Planning Guidance issued on 25 March 2021.

Helen Kemp-TaylorHead of Internal Audit and Managing DirectorAudit YorkshireMay 2021

2.3.21 Review of the effectiveness of governance, risk management and internal control

My review of the effectiveness of the system of internal control is informed by the work of the internal auditors, executive managers and clinical leads within the CCG who have responsibility for the development and maintenance of the internal control framework. I have drawn on performance information available to me. My review is also informed by comments made by the external auditors in their annual audit letter and other reports.

Our assurance framework provides me with evidence that the effectiveness of controls that manage risks to the CCG achieving its principles objectives have been reviewed.

I have been advised on the implications of the result of this review by: the governing body the senior leadership team the audit and governance committee the quality committee the finance and performance committee internal audit

At the time of writing this annual report, the 2020/21 year-end assessment for the performance of the CCG was not available but will be published on the NHSE website in July 2021. .

Conclusion

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

117

It is my conclusion, based on the information submitted and my belief about the effectiveness of the systems and processes within the CCG that no significant internal control issues have been experienced during the year.

Helen HirstHelen Hirst Accountable officerNHS Bradford District and Craven CCG

15 June 2021

Remuneration and staff report

2.4 Remuneration report

This report provides details of the policy regarding the remuneration of senior managers employed by the clinical commissioning group, how this policy has been implemented and the amounts awarded in 2020/21. As this is the first year that the CCG has been in existence followings its establishment in April 2020, there are no direct prior year comparators.

For the purposes of this report senior managers are defined as members of the governing body and director level members of the SLT.

2.4.1 Remuneration committee

Details of the remuneration committee, including its role, responsibilities and membership, can be found on page 85 of this report.

2.4.2 Policy on the remuneration of senior managers

The remuneration committee sets senior manager remuneration levels on the following basis:

Accountable officer/chief finance officer/lay members

Remuneration guidance for CCGs as issued by NHS England

Other CCG directors Very senior managers’ pay framework

Clinical officers Annual equivalent salary based on GP remuneration levels

Annual pay uplifts are made in line with Secretary of State determinations for basic

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

118

pay uplifts and the application of local performance review processes for any other changes in remuneration.

As part of our assurance process, personal objectives are set for clinical commissioning group directors and performance against these objectives is reviewed formally by the accountable officer each year. The remuneration committee assesses the performance of the accountable officer, chief finance officer and staff on very senior manager contracts and makes appropriate recommendations to the governing body regarding any proposed changes in remuneration, taking into account relevant guidance, benchmarking information and local circumstances

2.4.3 Senior managers’ contract terms

The CCG’s senior managers are employed on the following contract terms:

Table 6: employment contract terms for senior managersPost Status Duration Notice period

Accountable officer Officer Not fixed 6 monthsChief finance officer Officer Not fixed 6 monthsDirector Officer Not fixed 3 monthsClinical chair Office holder Fixed (3 years) 3 monthsClinical/lay members Office holder Fixed (up to 3 years) 3 months

There are no special payments due on termination of a contract. In the event of early contract termination, a senior manager would receive any applicable statutory entitlement to a redundancy payment and any entitlements due under the NHS pension scheme if they are a member of this.

On 1 April 2020 Bradford Districts, Bradford City and Airedale, Wharfedale and Craven Clinical Commissioning Groups merged to form the Bradford District and Craven Clinical Commissioning Group. Senior managers transferred to the new clinical commissioning group on 1 April 2020 under new contracts effective from that date.

Service contract details for each senior manager who served during the year were:

Table 7: service contract details for senior managersName Contract start

dateContract end date (where applicable)

Notice period

Dr James Thomas 1 April 2020 31 March 2023 3 monthsHelen Hirst 1 April 2020 N/A 6 monthsRobert Maden 1 April 2020 N/A 6 monthsPeter Brunskill 1 April 2020 31 March 2022 3 monthsAngie Clegg 1 April 2020 31 March 2022 3 monthsNeil Fell 1 April 2020 31 March 2022 3 monthsBryan Millar 1 April 2020 31 March 2022 3 monthsRuby Bhatti 1 April 2020 31 March 2022 3 months

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

119

David Richardson 1 April 2020 31 March 2022 3 monthsJohn Young 1 April 2020 31 March 2022 3 monthsNancy O’Neill 1 April 2020 N/A 3 monthsMichelle Turner 1 April 2020 N/A 3 monthsAli Jan Haider 1 April 2020 N/A 3 monthsElizabeth Allen 1 April 2020 N/A 3 monthsDr Louise Clarke 1 April 2020 31 March 2023 3 monthsDr Mutaz Aldawoud 1 April 2020 31 March 2023 3 monthsDr Sohail Abbas 1 April 2020 31 March 2023 3 monthsDr David Tatham 1 April 2020 31 March 2023 3 monthsDr Junaid Azam 1 April 2020 31 March 2023 3 months

2.4.4 Senior manager remuneration (including salary and pension entitlements)

Table 8 (subject to audit): provides details of the remuneration paid to each senior manager employed by the CCG in 2020/21.

Table 9 (subject to audit): provides details of the accrued benefits under the NHS pension scheme for each senior manager employed by the CCG in 2020/21, where the CCG paid superannuation contributions into the NHS pension scheme.

120

Table 8: single total figure remunerationName Title Salary

(bands of £5,000)

£000

Expense payments (taxable)

Rounded to £00

£00

Performance pay and bonuses

(bands of £5,000)

£000

Long-term performance pay and bonuses(bands of £5,000)

£000

All pension related benefits

(bands of £2,500)

£000

Total

(bands of £5,000)

£000Dr James Thomas Clinical chair 95-100 30-32.5 130-135Helen Hirst Chief officer 140-145 140-145Robert Maden Chief finance officer 105-110 112.5-115 220-225Neil Fell Governing body lay member 15-20 15-20Angie Clegg Governing body registered nurse 10-15 10-15Bryan Millar Governing body lay member 20-25 20-25Ruby Bhatti Governing body lay member 15-20 15-20David Richardson Governing body lay member 15-20 15-20John Young Governing body lay member 5-10 5-10Peter Brunskill Governing body lay member 5-10 5-10Michelle Turner Strategic director 105-110 30-32.5 140-145Ali Jan Haider Strategic director 105-110 20-22.5 125-130Elizabeth Allen Strategic director 105-110 42.5-45 150-155Nancy O’Neill Strategic director 110-115 20-22.5 130-135Dr Louise Clarke SLT member* 80-85 35-37.5 115-120Dr Mutaz Aldawoud SLT member 50-55 20-22.5 75-80Dr Sohail Abbas SLT member 80-85 0-2.5 80-85Dr David Tatham SLT member 50-55 12.5-15 65-70Dr Junaid Azam SLT member 45-50 45-50

*SLT members’ salary includes one session for clinical specialty lead; £000 (0-5)**All pensions-related benefits represent those benefits accruing to senior managers from membership of the NHS Pension Scheme, calculated using values supplied by NHS Business Services Authority and used in applying the “HMRC” method formula set out in the NHS Manual For Accounts and Greenbury disclosure guidance.

121

Table 9: pensions entitlementName Title Real

increase in pension at pension age(bands of £2,500)

£000

Real increase in pension lump sum at pension age(bands of £2,500)

£000

Total accrued pension at pension age related to accrued pension at 31 March 2021(bands of £5,000)

£000

Lump sum at pension age related to accrued pension at 31 March 2021(bands of £5,000)

£000

Cash equivalent transfer value at 1 April 2020***

£000

Real increase in cash equivalent transfer value at 31 March 2021****

£000

Cash equivalent transfer value at 31 March 2021***

£000

Employer’s contribution to stakeholder pension

£000Dr James Thomas Clinical chair 0-2.5 0 15-20 30-35 295 23 329 0Robert Maden Chief finance officer 5-7.5 15-17.5 45-50 135-140 975 146 1144 0Michelle Turner Strategic director 0-2.5 0 45-50 105-110 874 38 933 0Ali Jan Haider Strategic director 0-2.5 0.25 25-30 70-75 555 28 598 0Elizabeth Allen Strategic director 0-2.5 5-7.5 35-40 105-110 0 0 0 0Nancy O’Neill Strategic director 0-2.5 2.5-5 25-30 85-90 657 39 714 0Dr Louise Clarke SLT member 0-2.5 0-2.5 15-20 25-30 188 21 217 0Dr Mutaz Aldawoud SLT member 0-2.5 0 20-25 30-35 283 14 307 0Dr Sohail Abbas SLT member 0-2.5 0 20-25 35-40 312 0 323 0Dr David Tatham SLT member 0-2.5 0 10-15 25-30 180 7 195 0

***A cash equivalent transfer value (CETV) is the actuarially assessed capital value of the pension scheme benefits accrued by a member at a particular point in time. The benefits are the member’s accrued benefits and any contingent spouse’s (or other allowable beneficiary’s) pension payable from the scheme. A CETV is a payment made by a pension scheme or arrangement to secure pension benefits in another pension scheme or arrangement when the member leaves a scheme and chooses to transfer the benefits accrued in their former scheme. The pension figures shown relate to the benefits that the individual has accrued as a consequence of their total membership of the pension scheme, not just their service in a senior capacity to which disclosure applies.

The CETV figures and the other pension details include the value of any pension benefits in another scheme or arrangement which the individual has transferred to the NHS Pension Scheme. They also include any additional pension benefit accrued to the member as a result of their purchasing additional years of pension service in the scheme at their own cost. CETVs are calculated within the guidelines and framework prescribed by the Institute and Faculty of Actuaries.

****The real increase in CETV reflects the increase in CETV that is funded by the employer. It does not include the increase in accrued pension due to inflation or contributions paid by the employee (including the value of any benefits transferred from another pension scheme or arrangement).

Some individuals included o the remuneration table are not included on the pension table. This is because some posts are not pensionable (governing body lay members) or individuals have chosen to opt out of the pension scheme.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

122

2.4.5 Pension benefits as at 31 March 2021

See table 8 on page 120.

2.4.6 Cash equivalent transfer values

See table 9 on page 121.

Real increase in CETVs

See table 9 on page 121.

2.4.7 Compensation on early retirement or loss of office

There were no payments made in 2020/21 relating to compensation on early retirement or for loss of office.

2.4.8 Payments to past members

There were no payments made to past senior managers in 2020/21.

2.4.9 Fair pay disclosure (subject to audit)

Reporting bodies are required to disclose the relationship between the remuneration of the highest-paid director/Member in their organisation and the median remuneration of the organisation’s workforce.

The banded remuneration of the highest paid director in the clinical commissioning group in financial year 2020/21 was £142,500. This was 3.66 times the median remuneration of the workforce, which was £38,890.

In 2020/21, no employees received remuneration in excess of the highest paid member of the governing body.

Total remuneration includes salary, non-consolidated performance-related pay, benefits-in-kind, but not severance payments. It does not include employer pension contributions and the cash equivalent transfer value of pensions. In 2020/21 remuneration ranged from £3,216 to £142,500.

2.5 Staff report 2.5.1 Number of senior managersFor the purpose of these figures senior managers by band are any employees of band 8a and above, including board/director, medical and dental staff. The number of senior managers employed by the CCG at 31 March 2021 was as follows:

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

123

Table 10: number of senior managers at 31 March 2021Band Permanently

employedOther

Band 8a 23 0Band 8b 26 3Band 8c 4 1Band 8d 9 0Band 9 1 0Board/director 6 0Medical staff 5 0Total 74 4

2.5.2 Staff numbers and costs (subject to audit)

Staff composition

At 31 March 2021, the total number of staff employed by the CCG was 223, of whom 170 were female and 53 male; 148 worked full-time and 75 worked part-time. These figures exclude non-executive directors/lay governing body members, those employed on contract for services, and staff on external secondment.

Table 11: staff by band Table 12: staff by gender

BandFull-time

Part-time Band Male

Female

Band 1 0  0 Band 1  0 0Band 2 2  0 Band 2 0 2Band 3 10 7 Band 3 1 16Band 4 14 7 Band 4 6 15Band 5 12 12 Band 5 9 15Band 6 26 17 Band 6 8 35Band 7 32 6 Band 7 6 32Band 8a 14 9 Band 8a 6 17Band 8b 22 7 Band 8b 9 20Band 8c 3 2 Band 8c 1 4Band 8d 7 2 Band 8d 1 8Band 9 1 0 Band 9 0 1Board/director 5 1

Board/director 2 4

Medical staff  0 5 Medical staff  4 1Total 148 75 Total 53 170

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

124

Figure 14: staff by band and employee category

Band 1

Band 2

Band 3

Band 4

Band 5

Band 6

Band 7

Band 8a

Band 8b

Band 8c

Band 8d

Band 9

Board/d

irecto

r

Medica

l staff

0

5

10

15

20

25

30

35

Full-timePart-time

Figure 15: staff by band and gender

Band 1

Band 2

Band 3

Band 4

Band 5

Band 6

Band 7

Band 8a

Band 8b

Band 8c

Band 8d

Band 9

Board/d

irecto

r

Medica

l staff

05

10152025303540

FemaleMale

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

125

Table 13: staff costs

Employee benefitsAdmin Programme Total

Permanent employees£000

Other

£000

Total

£000

Permanent employees£000

Other

£000

Total

£000

Permanent employees£000

Other

£000

Total

£000Salaries and wages 6,603 323 6,926 3,212 99 3,312 9,816 422 10,238Social security costs 727 0 727 314 0 314 1,041 0 1,041Employer contributions to the NHS Pension Scheme

1,408 0 1,408 370 0 370 1,778 0 1,778

Other pension costs 3 0 3 1 0 1 4 0 4Apprenticeship levy 35 0 35 0 0 0 35 0 35Other post-employment benefits 0 0 0 0 0 0 0 0 0Other employment benefits 0 0 0 0 0 0 0 0 0Termination benefits 0 0 0 0 0 0 0 0 0Gross employee benefits expenditure 8,776 323 9,099 3,898 99 3,997 12,674 422 13,096

Less recoveries in respect of employee benefits (note 4.1.2)

(346) 0 (346) (136) 0 (136) (482) 0 (482)

Total – not admin employee benefits including capitalised funds

8,431 323 8,753 3,761 99 3,861 12,192 422 12,614

Less employee costs capitalised 0 0 0 0 0 0 0 0 0Not employee benefits excluding capitalised costs

8,431 323 8,753 3,761 99 3,861 12,192 422 12,614

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

126

2.5.3 Sickness absence dataThe average for sickness absence for the 12-month period from April 2020 to March 2021 was 2.09% (against a target of 2.5% set by NHS England for organisations that are not patient-facing). The total number of full-time equivalent days lost due to sickness absence during this period was 1570.85 days (an average of 130.90 days per month). This information relates to the total number of staff we employ and is provided centrally by the NHS England.

Sickness absence is managed under the our policy for absence management. This requires employees and managers to actively report and discuss periods of sickness absence, including return to work interviews and attending formal absence management meetings once ‘triggers’ for absence have been invoked.

Occupational health ensures that employees are supported in a timely and appropriate manner and employee wellbeing initiative supports staff to have access to interventions needed.

2.5.4 Staff turnover percentages

The table below shows the starters, leavers, staff in post, and labour turnover rate (LTO) each month for the last 12 months. The figures are based on a cumulative number for the last 12 months. The latest LTO of 10.57% is based on the 26 leavers over the 12-month period of April 2020 to March 2021.

Table 14: staff turnover

Head-

count

FTE

Leavers’ head-count

Leavers’ FTE

Starters’ head-count

Starters’ FTE

Leavers (12m

)

Leavers FTE (12m

)

Turnover R

ate (12m

)

April 2020 244 207.38 3 2.8 19 15.4 37 22.71 15.29%May 2020 243 206.38 3 2.2 0 36 21.87 14.94%June 2020 241 204.54 1 0.67 0 35 20.53 14.61%July 2020 242 205.32 1 0.1 2 2 34 19.94 14.23%Aug 2020 243 205.66 4 3.05 4 2.2 34 19.53 14.26%Sept 2020 244 207.82 0 0 2 2 31 17.31 13.00%Oct 2020 245 209.56 4 3.59 3 3 34 19.89 14.17%Nov 2020 245 208.9 2 1.8 2 1 35 20.69 14.64%Dec 2020 248 209.66 4 3.2 5 2.96 36 21.87 14.94%Jan 2021 247 209.46 0 0 2 2 35 21.37 14.49%Feb 2021 248 210.86 1 1 1 1 35 21.89 14.34%Mar 2021 248 211.06 3 2 2 2 26 20.41 10.57%

2.5.6 Staff re-deployment during the pandemic

During the pandemic, no staff were formally re-deployed to partner organisations, although mutual aid to partners through the re-alignment of staff was provided to the following COVID-19 related services:

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

127

Marley COVID testing centre for staff – four staff were aligned to cover this seven day per week service from the start of the pandemic until December 2020 when the service reduced to six days. After a year of successful operation, the Marley site was closed during the first week of April 2021 and staff returned to their former duties.

COVID red-hubs in primary care/pillar one testing/test and trace – a total of 29 staff were realigned to these services from April 2020.

Bradford Teaching Hospitals NHS Foundation Trust – one staff member was realigned to work with the communications team at the Trust for a total of four weeks, covering staff sickness.

Continuing healthcare nursing/support staff – during March and April 2020,15 members of the team were re-aligned to Bradford District Care NHS Foundation Trust, five to the fast-track nursing team (to 31 August) and 10 to the out-of-hospital multi-disciplinary team (until 31 July). One staff member returned to provide additional support for a two-week period later in the year.

Whilst these staff were aligned to other organisations and/or projects for some or all of their working hours, many of them also continued to work in their CCG role.

2.5.7 Equality and diversity of our staff

Changes to staff composition of under-represented groups: There has been a slight decrease of under-represented groups due to the CCG merger when a number of clinical lead role contracts ended naturally. Organisation change policy was used for this process.

Comparison of staff composition of under-represented groups against diversity and inclusion targets: Whilst we have not agreed diversity and inclusion targets, we will bring together our system priorities to increase ethnic diversity across Bradford district and Craven.

Barriers to improving the diversity of the workforce: Two barriers have been identified, and the following actions have been put in place:

A diverse and inclusive leadership team (issues around recruitment practices).  Case studies of recent examples of unfairness have been collated by BAME staff network members showing that unfairness can occur before shortlisting and/or interview through the way that job descriptions and selection criteria are written, and through inequitable application of the recruitment and selection procedure.  Informed by lived experience of members of both the BAME and Wellbeing And Able staff networks, our recruitment, selection and promotion policy and procedure has been revised, which now include a mandatory checklist to ensure that the BAME staff network is engaged at the start of recruitment processes.  Engagement sessions have also been held with managers, with positive feedback, and further compulsory sessions are planned with discussions based around staff members’ lived experiences with the aim of promoting fair and consistent implementation of our policies and procedures.

Flexible working for work/life balance: following the experience of home-based working, which has significantly changed the overall perception of and approach

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

128

to flexible working, our policy has been revised to support staff, for example those with disabilities, to work in a more flexible way. An engagement session has been held with all of our staff to discuss future working arrangements.

2.5.8 Staff engagement percentages

Staff engagement scores are calculated for key questions from the staff survey, the maximum possible score is 10. In 2020 the CCG scored 7.2 overall, compared to 7.4 in 2019.

2.5.9 Raising concerns (whistleblowing)

Following an NHSEI review of the national whistleblowing and raising concerns policy, our local raising concern policy (whistleblowing) was reviewed and approved in March 2021.  This policy enables our staff to speak up about any concern they have at work. In accordance with our duty of candour, our SLT is committed to an open and honest culture and provides staff with access to the advice and support when they raise a concern.

2.5.10 Staff policiesOur HR policies and procedures are important functional elements to ensuring that staff do not experience discrimination, harassment and victimisation:

acceptable standards of behaviour policy and procedure equal opportunities and diversity employment policy flexible working procedures home-based working policy recruitment, selection and promotion policy maternity, adoption and parental leave (including shared parental leave) policy raising concerns policy retirement policy education, training and development policy study leave policy grievance policy alcohol, drugs and substance misuse policy secondment, acting up policy managing sickness absence policy annual and special leave policy pay progression policy organisational change policy working time regulation policy managing concerns with performance policy disciplinary policy

The implementation of these policies along with occupational health support ensures the continuation of employment and provision of appropriate training to any employee, who becomes disabled and ensures access for all of our employees, including disabled staff members to training, career development and promotion opportunities.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

129

All policies were due to be reviewed in May/June 2021 to incorporate any changes following the creation of the new CCG, but – due to the pandemic - these policies have been rolled over for a further 18 months.

2.5.11 Trade union facility time

We have one steward from a recognised union, but otherwise our staff access those from Bradford District Care NHS Foundation Trust (our HR provider). Individuals can join and be a member of a recognised union. A policy on trade union and recognition and facilities and time off for trade union representatives is in place to support.

Our HR partner, Bradford District Care NHS Foundation Trust, has trade union stewards from recognised unions and our staff can join and be a member of a trade union. A policy on trade union recognition and facilities and time off for trade union representatives is in place to support.

Within the context of this agreement and the exclusion of others, currently we recognise the following trade unions/societies:

UNISON Managers in Partnership UNITE - AMICUS Royal College of Nursing British Medical Association GMB

An employee who chooses not to join will not be the subject of any discrimination bythe CCG or a trade union.

When consulting on organisation change matters, we engage with Bradford District Care NHS Foundation Trust staff side representatives.

Table 15: relevant union officialsNumber of employees who were relevant union officials during the relevant period

Full-time equivalent employee number

1 1

Table 16: percentage of time spent on facility timePercentage of time Number of employees0% 01-50% 151%-99% 0100% 0

Table 17: percentage of pay bill spent on facility timeFigures

Provide the total cost of facility time £1,842.00Provide the total pay bill £13,095,632.37Provide the percentage of the total pay bill spent on facility time, calculated as:

0.01%

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

130

(total cost of facility time ÷ total pay bill) x 100

 Table 18: paid trade union activitiesTime spent on paid trade union activities as a percentage of total paid facility time hours calculated as:(total hours spent on paid trade union activities by relevant union officials during the relevant period ÷ total paid facility time hours) x 100

0.03%

 2.5.12 Other employee matters

We have recently formed two staff networks: the Black, Asian and Minority Ethnic (BAME) staff network and the WellbeingAndAble (WAA) staff network. WAA is a network of colleagues who have long-term physical and/or mental health conditions and/or are disabled. 2.5.13 Health and safety of our staff

Bradford District Care NHS Foundation Trust became our provider of health and safety competency advice from 1 March 2016. We have an agreed work plan in place and provision for regular meetings during the year. However, due to the pandemic, these review meetings have been limited. Monitoring of this service includes:

risk assessments: first aid, security, premises and fire; review and development of relevant policies; monitoring and (where appropriate) investigation of reported incidents; health and safety and fire training; circulation of relevant health and safety information via the staff bulletin.

Reports were presented to audit and governance committee meetings giving an overview of the operational health and safety activity during each quarter and to provide assurance that any health and safety risks have been identified and are being managed.  Reports included any Health and Safety Executive national priorities/new guidance issued during this timeframe.

The committee noted the following assessments (which identified a low level of risk) and action plans arising at our Scorex House premises:

health, safety and security assessment; fire safety assessment.

The standard for mandatory training attendance is 90% of staff. Our figures for staff mandatory training as at March 2021 are detailed below:

fire safety (yearly – alternating between on-line and classroom training) – 89%; health and safety (three yearly – on-line) – 93%; moving and handling (three yearly – on-line) – 93%.

We did not report any health and safety incidents or near misses during 2020/21.

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

131

2.5.14 Expenditure on consultancy

We spent £69,902 on external consultancy in 2020/21.

2.5.15 Off-payroll engagements

Following the review of the tax arrangements of public sector appointees published by the Chief Secretary to the Treasury on 23 May 2012, we must publish information on off-payroll engagements.

Table 19: Off-payroll engagements as at 31 March 2021, for more than £245 per day that last longer than six months

Number of existing engagements as of 31 March 2021

Number

0of which, the number that have existed:

for less than one year at the time of reporting

for between one and two years at the time of reporting

for between two and three years at the time of reporting

for between three and four years at the time of reporting

for four or more years at the time of reporting

All existing off-payroll engagements have at some point been subject to a risk based assessment.

Table 20: New off-payroll engagements between 1 April 2020 and 31 March 2021, for more than £245 per day and that last longer than six months

Number

Number of new engagements, or those that reached six months in duration, between 1 April 2020 and 31 March 2021 0

of which:

Number assessed as IR35 being applicable

Number assessed as IR35 being not applicable

Number engaged directly (via PSC contracted to department) and are on the departmental payroll 0

Number of engagements reassessed for consistency/assurance purposes during the year 0

Number of engagements that saw a change to IR35 status following the consistency review 0

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

132

Table 21: Off-payroll engagements of board members and/or senior officials with significant financial responsibility, between 1 April 2020 and 31 March 2021Number of off-payroll engagements of board members, and/or senior officers with significant financial responsibility, during the financial year.

0

Total number of individuals on payroll and off-payroll that have been deemed “board members, and/or, senior officials with significant financial responsibility”, during the financial year. This figure should include both on payroll and off-payroll engagements.

19

Table 19: Off-payroll engagements of board members and/or senior officials with significant financial responsibility, between 1 April 2020 and 31 March 2021

Helen HirstHelen Hirst Accountable officerNHS Bradford District and Craven CCG

15 June 2021

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

133

Parliamentary accountability and audit report

Bradford District and Craven CCG is not required to produce a parliamentary accountability and audit report. Disclosures on contingent liabilities, losses and special payments, gifts and fees and charges are included as notes in the financial statements of this report at pages 165 and 170. An audit certificate and report is also included in this annual report at page 137.

Helen HirstHelen Hirst Accountable officerNHS Bradford District and Craven CCG

15 June 2021

NHS Bradford District and Craven CCGAnnual Report and Accounts 2020/21

134

Chapter 3: Annual Accounts

This page is intentionally blank