MEETING: Governing Body AGENDA ITEM: 4 TITLE: COVID-19 ... · MEETING: Governing Body AGENDA ITEM:...

MEETING: Governing Body AGENDA ITEM: 14 DATE: 11 June 2020 TITLE: COVID-19 governance accountability and statutory duties AUTHOR: Russell Carpenter, Head of Governance/Board Secretary LEAD DIRECTOR: Robert Majilton, Deputy Accountable Officer LINK TO RISKS: Governing

Body Assurance Framework

No specific GBAF risk in relation to COVID-19 governance

Corporate Risk Register

COVID-19 risk register: Title: IF CCG is unable to demonstrate effective record keeping

Reason for presenting this paper: For Action For Approval For Decision For Assurance For Information For Ratification

Summary of Purpose and Scope of Report:

The Governing Body is asked to NOTE as ASSURANCE: a) COVID-19 Decision Log as at 4 June 2020b) submission of “reasonable costs” related to COVID-19 for the month of April 2020

Authority to make a decision – process and/or commissioning (if relevant)

n/a – assurance only

Conflicts of Interest: (please tick accordingly)

No conflict identified Conflict noted, conflicted party can participate in discussion and decision (see below) Conflict noted, conflicted party can participate in discussion but not decision (see below) Conflict noted, conflicted party can remain but not participate in discussion (see below) Conflicted party is excluded from discussion (see below) Governance assurance (see below) n/a – assurance only

Strategic aims supported by this paper (please tick) Better Health in Bucks – to commission high quality services that are safe, accessible to all and achieve good patient outcomes for all Better Care for Bucks – to commission personalised, high value integrated care in the right place at the right time

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Better Care for Bucks – to ensure local people and stakeholders have a greater influence on the services we commission Sustainability within Bucks – to contribute to the delivery of a financially sustainable health and care economy that achieves value for money and encourages innovation

Leadership across Bucks – to promote equity as an employer and as clinical commissioners

Governance requirements: (Please tick each box as is relevant to the paper)

Governance Element Y N N/A Comments/Summary Patient & Public Involvement

Equality/Equity Quality Privacy As described within Financial Risks As described within Statutory/Legal As described within Prior consideration Committees /Forums/Groups

SMT 05/05/2020, 12/05/2020

Membership Involvement

Member GPs as members of Governing Body

Supporting Papers: a) Decision Log report as at 4 June 2020

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COVID-19 governance accountability and statutory duties

a) Decision Log arrangements during coronavirus (paper a) Specialist lawyers say legal challenges against CCGs and providers are inevitable. Risks around deprivation of liberty, neglect, safeguarding, and potential gross negligence manslaughter. It is widely felt that, without doubt, there will be numerous investigations/inquiries and reports once the immediate crisis is contained. Legal experts urge CCGs, social care workers and NHS providers to ensure they are maintaining accurate records and to keep a clear audit trail that shows why and how decisions are being made. Clearly recorded information on what decisions were made and the reasons for them, will provide the best way for the NHS to answer any future questions on how they dealt with the pandemic.

Governance Risks – IF CCG is unable to demonstrate effective record keeping Mitigation: Process set in place – CCG function by function: Contracts, Corporate, Finance, Integrated Commissioning, Medicines, Planned and Right Care, Primary Care, Quality, Urgent Care. This is deemed to also incorporate any decisions where taken by more informal groups which sit outside the constituted governance structure. NHS BUCKINGHAMSHIRE CCGCOVID-19 DECISION LOGTEAM/FUNCTION Corporate

ID Date of Decision Category Sub-category Decision required Value/cost (if relevant) Decision rationale/impact Decision maker (individual)

Decision maker (committee/sub-committee/group)

Any conflicts of interest and mitigations preceding decision

Decision status Dated Added to Log

Email Trail/location of archived evidence

Select from options Freetext Clear and unambiguous Why? Initialsn/a if irrelevent

n/a if irrelevent Select from options

Paper 7a attached provides an assurance as to the decisions recorded by each function through this process. Amendments to the format of the report since the last report on 30/04/2020:

1. Each function tab now colour coded as suggested through feedback 2. Integrated Commissioning added as an additional function tab. 3. Additional column – “Any conflicts of interest and mitigations preceding decision” 4. Adjusted format so medicines log is printable/saveable to PDF and cells aligned

Follow up actions through Senior Management Team (SMT) meetings: • Function heads to check that there are no decisions that need to be added or

otherwise state a nil return. • Medicines Management asked to update their separate template to include costs

associated with their decisions.

Both actions have been acted upon and completed. The Primary Care tab will also be reporting through PCCC on 4 June (public).

• Contract • Finance • Procurement • Statutory duty • Legal/Regulation • Quality and Safety

• Primary Care • Corporate Governance • Human Resources • Clinical Governance • Individual delegated authority

• Approved • Declined

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https://www.hsj.co.uk/coronavirus/nhs-told-to-expect-huge-number-of-legal-challenges-after-pandemic/7027448.article?mkt_tok=eyJpIjoiWmpaa1pEQXdNVGN5WkRFMiIsInQiOiIwQkZLNFEyUjFTK25wVHpmZDVjYXo3amZwOFRFTGt4c2wrNlorb25ramlIRW1OVWQyZnUzczdRWjVCXC9NWlZSbHZvSlwvVGxcL0lJMSsrdHY4S1lhMThoU0crSEh3OUdEREpHODF6bDk4TUYzS1wvRFwvdXRualwvWGJmNTR0NFVud29YZSJ9

Guidance to inform function heads in completing the log: Does the log include every commissioning and process decision taken by the CCG during the pandemic? No. The following decisions are not required to be recorded on the log. Any decision taken which is within:

a) The boundary of the existing scheme of reservation and delegation b) The boundary of agreed diversions from the scheme of reservation and delegation

(specifically financial governance SOP and process for “reasonable costs”) c) Existing contractual terms d) Existing terms of reference for committees/sub-committees/groups where meetings

formally take place (with decisions evidenced in minutes or other meeting records).

• Example: request and signature of a single tender waiver in lieu of formal procurement, reported to Audit Committee

• Example: renewal of an existing contract as per its terms where there is no change to the level of expenditure and an annual renewal that would have been enacted as part of business as usual.

• Example: renewal of an existing contract as per its terms where there is a change to the level of expenditure, and which ordinarily would be taken to a committee for approval, but decision has been taken by an individual for expediency. This is not recordable on the log ONLY if it is captured through the “reasonable costs” process.

What does need to be recorded? The overriding principle is for this log to capture any decision where, for expediency, we have:

a) Taken decisions outside of existing agreed corporate governance frameworks. b) Taken decisions that temporarily changes the delivery terms of an existing contract,

but the agreed terms of the contract remain the same (for which there is not a formal variation). Example: renewal of an existing contract as per its terms e.g. extended access for an additional 12 months permitted within terms agreed in 2018. BUT delivery terms temporarily changed for contract capacity to be re-purposed as COVID-19 support for which there is no formal variation.

c) Any other decision where the decision making process needs to be recorded as well as the decision – this will support any future audit or information required to support inquiries or other actions, this is supports (a) above The principal is – “if in doubt record it”.

b) “Reasonable costs” return to NHS England April 2020 submission was undertaken Friday 15 May 2020.

• £1.7m cumulative requested for April, including £1m associated with hospital discharge

• £250,000 costs associated with primary care practices opening over the Easter bank holiday weekend.

The Governing Body is asked to NOTE as ASSURANCE:

a) COVID-19 Decision Log as at 4 June 2020. b) submission of “reasonable costs” related to COVID-19 for the month of April

2020

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NHS BUCKINGHAMSHIRE CCGCOVID-19 DECISION LOGTEAM/FUNCTION Corporate

ID Date of Decision Category Sub-category Decision required Value/cost (if relevant) Decision rationale/impact Decision maker

(individual)

Decision maker

(committee/sub-

committee/group)

Any conflicts of interest and mitigations

preceding decision

Decision status Dated Added to

Log

Email Trail/location of archived

evidence

Select from options Freetext Clear and unambiguous Why? Initials

n/a if irrelevent

n/a if irrelevent Select from

options

1 23/03/2020 Contract BHT confirmed they were stopping

their face to face diabetes Type 2

eduction

Increase in remote Diabetes education from Ovivia 80,000 500 additional sessions beyond

current agreement

RM n/a N/A Approved 20/04/2020 SGS to GH then GH to RM

2 23/03/2020 Finance COVID19 expenditure financial

governance arrangements

Process for making a request for expenditure at any value n/a Clear methodology for deviation

from existing scheme of delegation

and staff/primary care to reclaim

reasonable COVID-19 costs

RM n/a N/A Approved 20/04/2020 GH to RM

3 23/03/2020 Procurement MJOG STW Continuation of primary care messaging value £43372.80 £43,372.80 Annual contract renewal RM N/A Approved 20/04/2020 James Piggins to RM

4 24/03/2020 Contract TVS Data Processing Approve proposal for data linkage stage n/a N/A Approved 27/05/2020 RM to Ben Gattlin/Rod Marau

5 24/03/2020 Procurement 100 devices Approve Mobile devices to support GPs

7 30/04/2020 Contract MOU Personallised Care Approve/signed £50k

8 20/05/2020 Contract Continence Nurse contract Approve extension of contract to end March 2021 Approved 27/05/2020 GH to RM

9 17/04/2020 Procurement 1000 devices Approve Approved 27/05/2020 KH to RM

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NHS BUCKINGHAMSHIRE CCGCOVID-19 DECISION LOGTEAM/FUNCTION Finance

ID Date of Decision Category Sub-category Decision required Value/cost (if relevant) Decision rationale/impact Decision maker

(individual)

Decision maker

(committee/sub-

committee/group)


preceding decision


Log


evidence


n/a if irrelevent


options1 17/04/2020 Clinical Governance PPE Purchase of protective gloves for

hot hubs

£800 + VAT Known shortages of PPE equipment Gary Heneage n/a My wife has a friend working for Bolle (ski

wear, goggles, glasses etc).

Via my wife I was then introduced to the sales

team at Bolle.I was told that Bolle had only 200 pairs of

protective glasses and these would be suitable

for the hot hubs. I asked the 3 primary care

leads to get their independent view and they agreed that we should purchase them.

Given the urgent need for protective eyewear, I

then asked BHT to process this payment as it

would be much easier to set up and receipt the goods. The payment was 200 pairs @ £4 each =

£800. The cost of these will be claimed back as

part of the Covid return.

This is the only dealings I have had with Bolle.

Approved 05/05/2020 G:\AVCCG CCCG SCWCSU\COVID-

19\Conflicts of Interest

6

NHS BUCKINGHAMSHIRE CCGCOVID-19 DECISION LOGTEAM/FUNCTION Primary Care

ID Date of Decision

Category Sub-category Decision required Value/cost (if relevant) Decision rationale/impact Decision maker (individual)

Decision maker (committee/sub-

committee/group)

Any conflicts of interest and mitigations preceding decision

Decision status Dated Added to Log

Email Trail/location of archived evidence


n/a if irrelevent


options1 08/04/2020 Primary Care COVID frailty project The CCG Executive Committee was asked to

1. APPROVE procedure (a) which describes evidence and arrangements for primary care GPs to score frail patients, and

make clinical decisions on admission or management at

home on a case by case basis (for communication to member

practices by email and through Clarity TeamNet). This has been recommended for approval by the task and finish group

established to co-ordinate this work.

2. NOTE supporting letter (b) to notify care homes managers and staff and providers of domiciliary care as to application of said arrangements. At the time of writing this version is

subject to approval from Gill Quinton as Corporate Director

Adult Services and Health at Buckinghamshire Council.The CCG Executive Committee is asked to

1. APPROVE attached procedure (a) which describes evidence and arrangements for primary care GPs to score frail patients, and make clinical decisions on admission or management at

home on a case by case basis (for communication to member

practices by email and through Clarity TeamNet). This has been recommended for approval by the task and finish group

established to co-ordinate this work.

2. NOTE supporting letter (b) to notify care homes managers

and staff and providers of domiciliary care as to application of said arrangements. At the time of writing this version is

subject to approval from Gill Quinton as Corporate Director Adult Services and Health at Buckinghamshire Council.

n/a NICE [NG159] and the Royal College of Physicians have

introduced the idea of risk stratifying patients based on the clinical evidence, according to the clinical frailty score, who

are unlikely to survive an ITU admission if they contract

COVID-19. The purpose of the NICE guideline is to optimise

the care of patients during the COVID-19 pandemic. This decision relates to local arrangements to implement this

NICE guidance.

Equality – older people are recognised as disproportionately frail compared to the wider population and a frailty score can

be subjective, however the purpose of implementation of

national guidance is to ensure sufficient equity in how they are clinically managed.

n/a Executive Committee Voting members of CCG Executive Committee

will likely apply said arrangements for their own frail patients, but immaterial to decision given

clinical nature to decision and no

financial/pecuniary benefit.

Approved 13/05/2020 G:\AVCCG CCCG SCWCSU\COVID-

19\Clinical Governance\Frailty - Executive Committee virtual decision

2 09/04/2020 Primary Care Agreed the 2 x sites for the Hot Hub Clinics will be SMH and High

Wycombe.

Approve N/A Correct infrastructure, Infection Control and Geography are factors in this decision

Primary Care Huddle

N/A N/A Approved 23/04/2020 G:\AVCCG CCCG SCWCSU\Primary Care\Covid-19\Issues Log\Action

Log\April 2020\22-04-2020.doc

3 20/04/2020 Primary Care Hot Hubs Hot Hubs: Agreed there is no pressing need to develop further sites than what it is at the moment at SMH and

Wycombe.

N/A Based on capacity currently going into the Hot Hubs Primary Care Huddle


Log\April 2020\22-04-2020.doc4 07/04/2020 Primary Care Easter OOH cover. It was agreed that FedBucks would be stood down for the

Good Friday and Easter Monday OOH cover.

N/A OOH to stand down. Home visiting service not possible to

deliver given current capacity. GPs open as normal

Primary Care

Huddle

N/A N/A Approved 23/04/2020 G:\AVCCG CCCG SCWCSU\Primary

Care\Covid-19\Issues Log\Action Log\April 2020\22-04-2020.doc

5 15/04/2020 Primary Care May Bank Holiday service. FedBucks to commission a May Bank Holiday service. N/A This is not a step down and asked FedBucks what they can look at in regard to the enhancement with the clinicians who

have indicated they would be able to work on the Bank

Holiday weekend

Primary Care Huddle


Log\April 2020\22-04-2020.doc

6 28/04/2020 Primary Care May Bank Holiday service. Stand down General Practice for 8th May Bank Holiday N/A Buckinghamshire CCG has agreed with Oxfordshire and Berkshire West that general practice should not be required

to open on the Friday 8 May bank holiday. This decision has

been made in light of current covid-19 trends and the limited demand for primary care services over the Easter weekend. The normal out of hours cover will be in place. The

requirement for the Spring Bank Holiday on 26 May will be reviewed in the next few weeks.

Primary Care Huddle

N/A N/A Approved 28/04/2020 file:///G:\AVCCG%20CCCG%20SCWCSU\Primary%20Care\Covid-

19\Issues%20Log\Action%20Log\Apri

l%202020\29-04-2020.doc

7 04/05/2020 Primary Care Locally Commissioned Services LCS Payments for 20/21; In the 20th March COVID-19 Daily Brief practices were

advised that they will receive fixed monthly LCS payments in

2020/21 calculated using their last year’s (2019/20) submitted LCS activity data. The process is automatic and

practices are therefore no longer required to complete and submit a Quarterly returns template.

1,976,018 • For GMS practices, payments will be included on the monthly GMS payment, code ZGPBPG, payment date 24th of

the month.

• For APMS and PMS practices, payments will be included on the monthly APMS/PMS payment, code ZGPBPA/ZGPBPP,

payment date 15th of the month.

N/A to be ratified by the PCCC

Dr Raj Bajwa and Dr Rashmi Sawhney are members of the Primary Care Huddle and hold a

conflict as their practices will be in receipt of this

income. This conflict will be managed when it is ratified by the PCCC

04/05/2020

8 06/05/2020 Primary Care May Bank Holiday service. Whitehill Surgery in Aylesbury have asked to open on BH Friday 8th May.

£571.90 Service level has been approved of 2 x GPs. DOS updated and the practice will claim as per the NHSE guidelines

Primary Care Huddle

N/A N/A Approved 06/05/2020 Agreed with Jessica Newman

9 06/05/2020 Primary Care SATS Monitors Agreed to continue with the local purchasing of SATS monitors

N/A Whilst there is a national scheme to procure SATS monitors, it has been agreed we will continue with our local purchasing decision of 100 items.

Primary Care Huddle

N/A N/A Approved 06/05/2020

7

../../../Primary Care/Covid-19/Issues Log/Action Log/April 2020/22-04-2020.doc
















NHS BUCKINGHAMSHIRE CCGCOVID-19 DECISION LOGTEAM/FUNCTION Quality

ID Date of Decision

Category Sub-category Decision required Value/cost (if relevant) Decision rationale/impact Decision maker

(individual)

Decision maker

(committee/sub-

committee/group)


preceding decision


Log


evidence


n/a if irrelevent


options

1 14/04/2020 Quality and Safety Learning Disability Mortality Review Programme

Access to GP clinical records through electronic means

Prevent physical access to GP surgeries

Asela Ali / Anna Lewis?

No conflicts of interest 14/04/2020 Asela Ali mailbox

2 13/05/2020 Quality and Safety Quality call with System Partners Reduction of meeting frequency N/A Weekly meetings undertaken

during the initial COVID-19 period.

Now moving into the next phase so reducing to fortnightly meetings.

Dr Karen West

David Williams

Bucks CCG: Quality

system call COVID-19

No conflicts of interest Approved 13/05/2020 Email correspondence by Julia

Simpkins - Quality Support

Assistant.

3 13/05/2020 Quality and Safety Clinical Harms Steering Group Cancel scheduled meeting on

14/5/20 to allow group to populate the clinical harms matrix

N/A Allow sufficient time for system

partners to complete harms document to support the next

meeting.

Dr Karen West

David Williams

N/A No conflicts of interest Approved 13/05/2020 Email correspondence by Julia

Simpkins - Quality Support Assistant.

8

NHS BUCKINGHAMSHIRE CCGCOVID-19 DECISION LOGTEAM/FUNCTION Integrated Commissioning

ID Date of Decision


(individual)

Decision maker

(committee/sub-

committee/group)


preceding decision


Log


evidence



1 16/03/2020 Finance Provider payments - for both COVID

claim costs and necessary

amendments or continuation of regular payment arrangements,

even if service not operating

Make provider payments for COVID

claims monthly and manage any

discrepancies retrospectively, continue provider payments for

commissioned placements or

services and provide flexibility

when required e.g. payment in

advance/payment on plan etc.

March and April COVID claims have

totalled c.£1.4m

To ensure we maintain cash flow

for care providers and avoid risk of

provider failure. To ensure that providers are able to promptly

reclaim against costs directly

associated with COVID. As part of a

Thames Valley approach to

managing claim types, some elements of claims (e.g. purchase of

iPads for a care home video conferencing) have been declined.

Cabinet Member AHH Board No Implemented 19th May BC N drive - N:\CHASC\Integrated

Commissioning\Business

Management\Business Continuity\COVID-19

Mailbox\Finance

https://buckinghamshire.moderngo

v.co.uk/ieDecisionDetails.aspx?ID=2

06

2 31/03/2020 Finance 2020/21 inflationary fee uplifts To approve a blanket 2% uplift for

all commissioned care providers without need for presentation of

business case

£3.05m To reduce time and resource

required for providers and commissioners in undertaking a

business case review and moderation process. To also

ensure uplifts are made swiftly to providers in order to help meet

their increased costs

Cabinet Member AHH Board No Implemented 19th May BC N drive - N:\CHASC\Integrated

Commissioning\Business Management\Business

Continuity\COVID-19 Mailbox\Finance

https://buckinghamshire.moderngov.co.uk/ieDecisionDetails.aspx?ID=2

04

3 10/05/2020 Finance High value Fremantle claim for April Further evidence required from

Fremantle to support high value claim.

£474k 95% of claim paid to provider in

order to not delay, but further interrogation and evidence

required to support outstanding

amount and the high value of the

claim

Service Director AHH Board No Implemented 19th May BC N drive - N:\CHASC\Integrated

Commissioning\Business Management\Business

Continuity\COVID-19

Mailbox\Finance

4 01/06/2020 Finance Infection Control Funding 75% of fund to be paid in 2 instalments to all 131 CQC

registered homes in Bucks. 25%

retained for payment to

commissioned Dom Care providers.

£6.25m Conditions stipulate how the grant must be paid. Bucks have asked

that all providers register and

complete national tracker and

submit up to date bank details in order to ensure that payment is not

delayed and that they understand

the purpose of the grant and their

responsibility in relation to the tracker.

Corporate Director/Chief

Executive

COMT No Implemented 03/06/2020

5 Various Contract delivery COVID-19 related changes to the delivery of services by

commissioned providers.

A number of changes have been made to the way many

commissioned services are delivered through the COVID-19

pandemic. These changes have not required contract variations These

are recorded in full on an accompanying spreadsheet.

£0 Service changes have been required to take account of changing

demand and need during the COVID-19 pandemic as well as in response

to social distancing requirements.

See accompanying

spreadsheet

See attached spreadsheet and

considering taking through ICET

No Implemented 04/06/2020 accompanying spreadsheet

6 Decision still to be

taken

Contract terms Contracts that require exemption

to allow them to continue until we are through the COVID-19 period

The Integrated Commissioning

Team are seeking exemptions on a number of contracts. This will allow

existing providers to continue to

deliver services until we are

through the COVID-19 period. These contracts require exemptions

because they are at the end of their

allowable contract term.

See accompanying spreadsheet

Services are currently under significant pressures due to COVID-

19 which means this is not an

appropriate time to ask them to

respond to a formal tender process.The need and demand for services

has changed during COVID-19 and

with ongoing uncertainty around

the duration of the pandemic, procurement processes at this time

will not be able to realise

opportunities for service

transformation.Capacity to continue

recommissioning has been reduced

due to the focus on supporting

providers to manage COVID-19.

There is no

formal decision making process

around

exemptions.

However there will be oversight

from the lead

Cabinet Member

and Executive director as well

as input from

legal,

procurement and finance.

There is no formal

decision making process around

exemptions. However

there will be oversight

from the lead Cabinet Member and Executive

director as well as

input from legal,

procurement and finance.

No Pending 04/06/2020 accompanying spreadsheet

9

NHS BUCKINGHAMSHIRE CCGCOVID-19 DECISION LOGTEAM/FUNCTION Integrated Commissioning

ID Date of Decision


(individual)

Decision maker

(committee/sub-

committee/group)


preceding decision


Log


evidence



7 Decision still to be

taken

Contract terms Contracts that require allowable

extensions to allow them to

continue until we are through the COVID-19 period

The Integrated Commissioning

Team are seeking allowable

extensions on a number of contracts. This will allow existing

providers to continue to deliver

services until we are through the

COVID-19 period. These contracts

require exemptions because they are at the end of their allowable

contract term.

See accompanying spreadsheet

Services are currently under

significant pressures due to COVID-19 which means this is not an

appropriate time to ask them to

respond to a formal tender process.

The need and demand for services

has changed during COVID-19 and with ongoing uncertainty around

the duration of the pandemic, procurement processes at this time

will not be able to realise opportunities for service

transformation.Capacity to continue

recommissioning has been reduced due to the focus on supporting

providers to manage COVID-19.

Relevant cabinet

member and

Executive Director

ICET No Pending 04/06/2020 accompanying spreadsheet

10

CCG Governing Body 11/06/2020, agenda item 14a2Covid-19 Medicines Management – Decisions Log

Item No. Date raised Decision Owner Description Decision outcome Costs if relevantDate approved/ not

approvedConflicts of interest and

mitigations

1 01/04/2020 CCG Commissioning of EoL drugs list (with amendments) for community pharmacy -covers of buccal diazpem off license

Approved £12,000 + additional stock in 2 places (to be costed)

20/04/2020 None

2 07/04/2020 ICP Warfarin switches to DOAC: commisioning of service and clinical guidelines

Approved None 20/04/2020 None

3 07/04/2020 ICP 28 day prescriptions for Olympic Lodge on discharge from BHT Approved None 07/04/2020 None

4 14/04/2020 BHT Section 10 exemption approval Approved None 20/04/2020 None

5 17/04/2020 ICP Change to Olazapine injection post monitroing for COVID 19 Approved None 20/04/2020 None

6 17/04/2020 ICP COVID 19 lithium monitoring guidance Approved None 20/04/2020 None

7 17/04/2020 ICP COVID 19 clozapine montioring guidance Approved None 20/04/2020 None

8 20/04/2020 ICP VTE guidance Not approved None 20/0402020 None

9 20/042020 BHT Updated procedure for oxygen shortages at BHT Approved None 20/04/2020 None

10 17/04/2020 ICP Can SPS guidance re: montitoring intervals for high risk drugs be communicated to primary care?


11 20/04/2020 ICP System for redeployment of returner staff. Approved None 20/04/2020 None

12 17/04/2020 CCG Approval of CCG band 7 post for safety and AMR Approved None 20/04/2020 None

13 31/03/2020 ICP Approval of an extra Mims licence for MRC Approved £261.69 in VAT None

14 31/03/2020 CCG Approval for support for practices with eRD Approved None 20/04/2020 None

15 22/04/2020 CCG Notification of purchase of prescQiPP e-learning to support medication switches as a result of COVID 19

Approved £1,200 in VAT 22/04/2020 None

16 24/04/2020 BHT Ratification of Medicines Policy Annexe 12 Clinical Trials Approved None 27/04/2020 None

17 24/04/2020 BHT Ratification of Medicines Policy Amendments due to COVID-19 pandemic


18 24/04/2020 OH Ratification of Remote outpatient guidance OH Approved None 27/04/2020 None

19 24/04/2020 OH Ratification of Olanzapaine prescribing guidance Approved None 27/04/2020 None

20 24/04/2020 OH Ratification of hand fact sheet for clozapine Approved None 27/04/2020 None

21 24/04/2020 OH Ratification of clozapine information for HCP during COVID 19 Approved None 27/04/2020 None

22 24/04/2020 OH Ratification LAI administration dosing intervals during COVID 19


23 24/04/2020 OH Ratification of lithium monitoring during COVID 19 Approved None 27/04/2020 None

24 17/04/2020 ICP Approval of Drugs requiring monitoring intervals guidance during COVID 19

Approved None 27/04/202011/05/2020

None

25 27/04/2020 ICP Approval of content for ramadan TeamNet page for medicines Approved None 27/04/2020 None

26 27/04/2020 CCG Retention and quarantine of anticipatory medicines Approved None 27/04/2020 None

27 01/05/2020 CCG Ratification of Access to COVID 19 testing for community pharmacy


28 01/05/2020 CCG Discussion on Hyrdoxycholoroquine monitoring n/a None Feed back to next governance meeting.

None

29 04/05/2020 CCG Approval of Band 7 safety/AMR job description (to follow) Approved None 04/05/2020 None

30 04/05/2020 CCG Discussion on Reuse of medicines policy (attached) Approved None 11/05/2020 None

31 04/05/2020 BHT Outpatient prescribing during COVID 19 for ratification Ratified None 04/05/2020 None

32 04/05/20202 CCG Delivery service for Palliative Care drugs in Community Pharmacies

Not approved Y- to be costed None

33 04/05/2020 ICP SGLT2 prescribing in COVID 19 Approved None None

ICP MOB decisions

11

Covid-19 Medicines Management – Decisions Log

Item No. Date raised Decision Owner Description Decision outcome Costs if relevantDate approved/ not

approvedConflicts of interest and

mitigations

34 11/05/2020 CCG Prescription quantities for patients discharged to care homes from BHT


35 11/05/2020 CCG Staff support from BHT for structured medication reviews in care Homes


36 11/05/2020 CCG Use of SPS safety of use of medicines posters re: change in look of medicines due to shortages posters.


37 08/05/2020 Comm pharm To ratify the decision for Bucks community pharmacy to use the NHSE medicines waste arrangements for community policy guidance.


37 18/05/2020 CCG Update on care homesIncluding:-Reuse of medicines policy- Process for medication referral

n/a

38 18/05/2020 CCG Fast tracked delivery of EoL medicines Not approved None n/a None

39 18/05/2020 CCG When to restart the usual governance structure Not approved None n/a None

40 18/05/2020 CCG Updating the formulary n/a None n/a None

41 18/05/2020 ccg Warfarin to DOAC switching Approved None 18/05/2020 None

42 18/05/2020 ccg CGS action notes Approved None n/a None

43 18/05/2020 CCG PGD for administration of salbutamol in acute asthma Approved None 18/05/2020 None

44 18/05/2020 CCG Use of transdermal patches in care homes Approved None 18/05/2020 None

45 18/05/2020 CCG Patient/carer information: top tips on keeping hydrated during COVID 19


46 18/05/2020 BHT Updated medicines policy amendments Approved None 18/05/2020 None

47 18/05/2020 BHT DMARDs for use in Rheumatology, Gastroenterology, Dermatology, Respiratory patients during COVID 19


48 Jun-20 CCG Expression to be part of working group for SBS wound care framework

Approved None n/a None

49 01/06/2020 CCG Fast tracked delivery of EoL medicines Approved Up to £5,000 01/06/2020 None

50 01/06/2020 CCG Patient information leaflet governance and strategy for the digital platform

Approved None None

51 01/06/2020 CCG Care Homes medication review process including prioritisation for SMR

Outstanding None

52 01/06/2020 CCG Staff recruitment for MOCH team Outstanding None

53 01/06/2020 CCG New form for medicines administration for ACHT Outstanding None None

54 01/06/2020 CCG Availability of retinal screening for patients taking hydroxychloroqine

Outstanding £40,000 None

55 01/06/2020 BHT EAMS for Remdesivir - formulary approval ask for e-approval None

56 01/06/2020 BHT Approval of Occular lubricants guideline Not approved None

08/06/2020 Action UO: to bring process for who reviews medication in what circustmnces to next meeting.08/06/2020 Action UO: to prepare a draft of an Annex for care homes to adopt in their medicines policy.08/06/2020 Action UO: to send out a comms about the service as part of a piece about the whole of the care homes offer.

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Governing Body 11/06/2020, agenda item 15a

Safeguarding Annual Report 2018/19

1. Introduction This report covers the financial year April 2018 to March 2019. Buckinghamshire Clinical Commissioning Group (CCG) is a National Health Service (NHS) employer of staff and is also a commissioner of health services for Buckinghamshire children. It is required to comply with the safeguarding requirements as set out in section 11 of the Children Act 2004, and the Care Act 2014. This report provides Buckinghamshire CCG Governing Body with an overview of safeguarding across health services in Buckinghamshire during 2018/19. The CCG is a statutory NHS body with a range of statutory duties, including safeguarding children, young people and adults. The CCG regards its statutory responsibilities to safeguard children, young people and adults at risk of harm as a priority for the organisation and for our work with local partners. We continue to maintain strong partnership working in order to achieve a collaborative approach to addressing the identified needs, whilst supporting and safeguarding the vulnerable including those children and young people looked after by the local authority. The report reviews the work across the year, giving assurance that the CCG has discharged its statutory responsibility to safeguard the welfare of children and adults across the health services it commissions. Additionally, information is included about national changes, influences, local developments and activity. Safeguarding of children, young people, and adults with care and support needs (referred to as ‘adults’ throughout this report), is embedded within the wider duties of all organisations across the health system. CCGs have safeguarding roles, duties and responsibilities as defined through legislation and the NHS Accountability and Assurance Framework (2015) and can be divided across 5 key areas

• Governance arrangements • Commissioning cycle • Assurance of provider arrangements • Securing expertise • Partnership working

The purpose of the safeguarding annual report is to assure the Governing Body and members of the public that Buckinghamshire Clinical Commissioning Group is fulfilling its’ statutory duties in relation to safeguarding. It outlines the responsibilities of the CCG, in respect of safeguarding, the actions taken to meet these responsibilities over the previous year and priorities for the coming year.

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2. Influences on the safeguarding agenda in 2018/19

2.1 National

• October saw the release of the first Intercollegiate Adult Safeguarding Guidance. This is a huge step towards ensuring that the health workforce, now and in the future, is equipped with the knowledge and skills they need to work in partnership to safeguard vulnerable adults. The guidance was commissioned by NHS England and involved 30 other Royal Colleges and professional healthcare organisations. The Adult Safeguarding: Roles and Competencies for Health Care Staff outlines the professional standards that all staff at healthcare organisations will need to meet if they are to be involved in adult safeguarding.

• March saw the publication of the draft Bill from the Law Commission proposing to replace Deprivation of Liberty Safeguards (DoLS) with Liberty Protection Safeguards. The Bill has significant implications for health services including CCGs and NHS Trusts scrutinising and authorising deprivations of liberty occurring where they are responsible for the care. The new Bill has had initial discussions at the Safeguarding Steering Group provider meeting. It was agreed that MCA Leads will prepare briefs for their organisations to begin considering responses to the Bill.

• In April, the Coroners and Justice Act 2009 was amended so that people subject to authorisations under the Deprivation of Liberty Safeguards (known as DoLS) will no longer be considered to be ‘otherwise in state detention’ for the purposes of Section 1 of the Coroners and Justice Act 2009. This means, from April 2017 natural deaths occurring where a person is deprived under DoLS, the Court of Protection authorisations, or whilst applications are being made, are no longer reported to the Coroner. Reports to the Coroner should still be made if the cause of death is unknown or where there are concerns that the cause of death was unnatural or violent, including where there is any concern about the care given having contributed to the person’s death. This information was shared with member practice safeguarding leads and practice managers and disseminated to safeguarding leads across provider services.

• In March 2018 the revised and updated statutory guidance Working Together to Safeguard Children was published. It incorporates legislation and statutory guidance. It includes clarification on referring allegations of abuse against those who work with children and the definition of serious harm for the purpose of serious case reviews (SCRs).

• The Wood Report made recommendations for changing the manner in which child deaths are reviewed by the multi-agency partnership.

• Revised Prevent Duty guidance in the Counter-Terrorism and Security Act 2015 requiring specified organisations to have due regard to the need to prevent people from being drawn into terrorism. As part of this duty the Government require providers to report compliance figures quarterly to NHSE as part of the London Prevent Region. The CCG is no longer required to submit Prevent returns but remain responsible for overseeing providers to do so.

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2.2 Local • Implementation of the Buckinghamshire local authority improvement plan,

following the second consecutive OfSTED judgement of children’s’ services being inadequate.

• Learning from multi-agency reviews including SCRs and Safeguarding Adult Reviews (SARs)

• Impact of police operations in relation to child sexual exploitation • Support for safeguarding and serious incident investigations within provider

trusts and care home.

3. CCG statutory responsibilities 3.1 Internal governance arrangements Following the publication in July 2015 of the updated Safeguarding Vulnerable People in the NHS – Accountability and Assurance Framework the CCG has reviewed compliance with safeguarding roles, duties and responsibilities, and strengthened safeguarding arrangements, updating our safeguarding policy and providing clarity on the mechanism of CCG delivery on statutory duties and priorities. The Safeguarding Steering Group is an operational sub-group of the CCG, reporting to the Quality and Performance Committee and provides assurance to the CCG Governing Body and Exec. It is responsible for the coordination of CCG safeguarding arrangements and ensures that statutory functions are effectively discharged. The diagram below illustrates how the steering group links to safeguarding arrangements in place for Buckinghamshire for this reporting period.

Safeguarding Steering Group Governance & Membership

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The Safeguarding Steering Group is chaired by the governing body clinical director with responsibility for safeguarding and meets monthly. Twice a year, senior representatives from provider health organisations are invited to attend. There is quarterly reporting to the Quality and Performance Committee with additional highlight /exception reporting as appropriate.

Quality and Performance Committee

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Commissioning Cycle Safeguarding is included as part of the NHS standard contract. The safeguarding team provide support and advice to commissioners in the procurement of services and monitoring of NHS contracts. The CCG is committed to commissioning services that will improve outcomes and life chances for the most vulnerable and that can identify and respond to children and adults who are at risk. All commissioned services must be able to demonstrate compliance with safeguarding duties and have mechanisms in place to ensure continuous improvement. A more comprehensive, structured approach to obtaining CCG assurance on this was introduced in 2015 – see section 3.3

A priority for 2018/19 is to look at innovative ways to ensure that there is engagement from children, young people and adults in service development. There is also a need to work across the health economy to ensure that the voice of the child and adult is listened to and influences practice. This can be demonstrated by service user engagement, audit, and response to service user feedback.

3.2 Assurance of provider arrangements In order to meet our responsibilities to seek assurance on safe and effective safeguarding arrangements, the safeguarding team developed and introduced a safeguarding assurance framework and requirement for quarterly reporting through the safeguarding dashboard into contracts with key commissioned services from April 2018. Reporting on the dashboard is now quarterly and is reviewed at the safeguarding steering group with exception reporting to the Quality and Performance committee. A service specific version will be introduced to newly commissioned services through commissioning and procurement arrangements. We have strengthened our mechanisms to not only gain assurance that providers are discharging their statutory safeguarding requirements, but can also demonstrate continuous improvement through the development of the safeguarding dashboard. Further work will continue over the coming year.

The safeguarding team work closely with safeguarding leads in provider organisations and the local safeguarding arrangements to identify any emerging themes and trends and to review safeguarding practice either within a single provider or across the health economy. The CCG offers support, and acts as a critical friend, to providers including GP practices, where complaints, serious incidents and/or inspection reports identify weaknesses in their safeguarding arrangements. The team have completed assurance visits to support this work.

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3.3 Securing expertise The safeguarding team works across Buckinghamshire to provide professional leadership and expertise to the health economy and to both the adult and children safeguarding boards. The CCG continue to work collaboratively with Designated Doctor for Safeguarding Children, the named GP for safeguarding children and the named GP for adults.

3.4 Partnership working

The CCG has senior representation on both the Buckinghamshire Safeguarding Adults Board (BSAB) and the Buckinghamshire Safeguarding Children Board (BSCB). Following the implementation of the Care Act 2014, Clinical Commissioning Groups have become statutory core partners on the Safeguarding Adult Board. The CCG employs a Safeguarding Adults Lead Nurse for the whole health economy and supports the CCG to fulfil their obligations to the safeguarding Adults Board. This ensures CCG strategic oversight of safeguarding arrangements across health providers and the wider multiagency partnerships. The CCG safeguarding team have supported the work of the BSAB and BSCB through active participation in many of the sub-committees and reviews. The Safeguarding Adults Lead is chair of the BSAB policies and procedures subcommittee and has driven forward the development of new BSAB policies to reflect the changes following implementation of the Care Act.

We have ensured that there has been appropriate challenge and oversight of the health contributions to Safeguarding Adult Reviews and Serious Case Reviews for children through panel membership and support of learning regarding the role of the GP. All overview reports are available to read on the safeguarding board websites. A brief synopsis is given in the table below.

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Multi-agency reviews

Date commenced

Type of review Key issue Date published, Outcome or action points

July 2018 SAR Adult Z Adult Z received an emergency callout overnight were the advice was to call GP if felt unwell, Adult Z did not engage with services and died the following day.

To produce a multi-agency flowchart on how to raise concerns when the person that is being visited does not engage or is not at home.

August 2018 SCR Family T Young parents, mum is a looked after child, exploitation, mental health.

Review ongoing.

September 2018 SCR SYV Some small of youths involved in serious stabbing incident.

To be determined

September 2018 Safeguarding Adult Review (SAR). Adult BB

Elderly resident of a care home made a disclosure of abuse that was not escalated in line with protocol.

To be determined

October 2018 Domestic Homicide Review (DHR)

Evidence of Domestic Abuse, Aylesbury

Review ongoing

October 2018 Domestic Homicide Review (DHR)

Person found deceased in their home. Threats to kill from a member of the family.

Review ongoing

January 2019 SCR Baby N Neglect, cross border communication and lone working.

Review ongoing.

January 2019 SCR Child V Neglect and mental health.

Review ongoing.

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The CCG has continued to work in partnership with the Local Authority and statutory agencies to implement the Buckinghamshire Safeguarding Children Improvement Plan. Key areas of focus for on-going work within health have been:

• Continued commitment to partnership working and developing a whole system approach to safeguarding children

• Continued improvement of internal governance and coordination of the safeguarding system across health through the safeguarding steering group and countywide safeguarding professionals network

• Embedding the Early Help Strategy and understanding of the Thresholds Document

• Monitoring the appropriateness and quality of referrals to children’s social care

• On-going development of MASH (multi-agency safeguarding hub) and reporting on key performance indicators.

In response to a Bucks County Council proposal, Buckinghamshire NHS commissioners and health providers agreed to create a specialised unit, initially through the co-location of staff from children’s social care, the police, Barnardo’s and health to coordinate the multi-agency response to victims and potential victims of child sexual exploitation. The unit was known as the Swan Unit and is renamed as the Exploitation hub. In the context of both national and local high profile child sexual exploitation (CSE) cases, the development of a dedicated unit was an opportunity to work more effectively with partners to address exploitation as a whole. The CCG agreed initial investment to second a 0.5wte specialist nurse to the Exploitation hub hosted by Buckinghamshire Healthcare Trust; this has increased to 0.6 WTE.

4. CCG safeguarding priorities 2018/19 and key achievements

The safeguarding team have agreed priorities for inclusion in the 2018/19 CCG operating plan. Work has already begun on delivery against these priorities and progress will be reported on throughout this paper and subsequent quarterly reports.

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Priority Key Action Priority Key Action

Priority 1: Embed safeguarding standards in the commissioning process

• Safeguarding standards included in new service specifications

• Develop & monitor provider assurance process to include increased focus on outcomes for vulnerable service users

• Use patient and carer stories to illustrate service improvement

Priority 2: Promote the identification and support of those at risk of all forms of exploitation including radicalisation

• Quality assure delivery of Prevent training

• Review and promote referral pathways

• Ensure training is pointed to promote key themes.

Priority 3: Lead an effective health economy response to the system wide safeguarding agenda

• Audit GP involvement in child protection conferences

• Deliver a plan to promote Making Safeguarding Personal (MSP) and mental capacity act principles

• Evidence that views of children, young people and adults with care and support needs are included in safeguarding referrals and assessments

Priority 4: Work with partners to deliver measurable outcomes for children and adults with the best use of resources

• Maintain contributions to Safeguarding board

• Gain assurance that the Mental Capacity Act is embedded throughout the System

• Work with BCC to support delivery of Ofsted Improvement Plan for children’s services

Priority 1: Embed safeguarding standards in the commissioning process Provider assurance continues to be held where evidence of patient input in to service improvement and review has been shared.

Priority 2: Promote the identification and support of those at risk of all forms of exploitation including radicalisation Through a re-design within the Police and Crime Commissioner (PCC) office to support services for victims, The Willow Project as of July 2018 became the Thames Valley-wide service to support adult victims of all forms of Exploitation and/or with other Complex Needs. Priority 3: Lead an effective health economy response to the system wide safeguarding agenda The Child Protection Information System has been implemented in BHT. This system sends an electronic alert to an allocated whenever a child or young person, subject to a child protection plan, or is Looked After, attends an unscheduled care setting. It is also being implemented in maternity. The system allows social care to identify when and where a child/young person has attended an out of hours health care setting, which allows for professional discussion and early identification of professional concerns.

Priority 4: Work with partners to deliver measurable outcomes for children and adults with the best use of resources In 2017 the Buckinghamshire Safeguarding Adults Board (BSAB) received a request from the Buckinghamshire Safeguarding Children Board (BSCB) to look at the local transition arrangements for young people in light of a Serious Case Review into Child

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Sexual Exploitation in Buckinghamshire 1998-2016. A multi-agency audit was completed in 2018, this is informing future plans for transition.

4.1 Training

Each GP Practice has an identified safeguarding lead and twice a year the CCG safeguarding team facilitate training for the practice safeguarding leads network (PSLN). These sessions are always very well attended with good evaluations. During 2018/19, the CCGs provided 7 training sessions with a total of 234 attendees. The chart below shows representation of attendees at PSLN sessions and other safeguarding training events hosted by the CCG.

The PSLN update which focussed on the adult safeguarding agenda focussed on Persons in Position of Trust (PIPOT) following the introduction of a multi-agency policy together with Professional Curiosity training. These themes were aligned against the outcomes of two published Safeguarding Adult Reviews (SAR).

The PSLN update on children’s safeguarding included learning from SCRs and national priorities.

This year the safeguarding adult lead facilitated bespoke safeguarding training to support care homes where safeguarding concerns were raised. These sessions focussed on reporting and escalation of safeguarding and professional accountability.

The safeguarding team also provide training for local trainee GP’s arranged through the Buckinghamshire VTS programme.

The safeguarding adult lead organised Prevent training specifically targeted to GP’s, this was facilitated by NHSE Prevent leads with a view as to increasing awareness and the levels of referrals from the primary care sector. The session was well attended by over 40 GP’s from various practices across the county.

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5. Priorities for 2018/19

The safeguarding priorities for 2019/20 link with key CCG strategic aims

CCG strategic aim Safeguarding Action Commission high quality services that are safe, accessible to all and achieve good patient outcomes

• Programmed timetable for Quality assurance visits to gain assurance for the CCG.

Commission personalised, high value integrated care in the right place at the right time

• Commitment to support integrated care partnership working by ensuring open communication across the footprint between safeguarding professionals.

Ensure local people and stakeholders have a greater influence on the services commissioned

• Engagement with system partners including we do care, to ascertain their views and feedback. This is incorporated into future planning.

Contribute to the delivery of a financially sustainable health and care economy that achieves value for money and encourages innovation

• Reviewed contract arrangement for effectiveness in safeguarding, which has led to reviews of financial arrangements to inform future planning.

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MEETING: Governing Body AGENDA ITEM: 15b DATE: 11 June 2020 TITLE: Data Security and Protection / Information Governance annual

report. Incorporating reports from the Caldicott Guardian, Data Protection Officer and Senior Information Risk Owner (SIRO)

AUTHOR: Dr Karen West, Caldicott Guardian Russell Carpenter, Data Protection Officer

LEAD DIRECTOR: Dr Karen West, Caldicott Guardian Robert Majilton, Senior Information Risk Owner

LINK TO RISKS: Governing Body Assurance Framework

No direct links


A series of CCG relate to information governance, though none currently meet the escalation threshold

Reason for presenting this paper: For Action For Approval For Decision For Assurance For Information For Ratification Summary of Purpose and Scope of Report: The Governing Body is asked to

• ACCEPT this annual report and the assurance it offers • Continue to SUPPORT the role of Data Security and Protection / Information

Governance and appointments of Caldicott Guardian, Data Protection Officer and Senior Information Risk Owner (SIRO)

Authority to make a decision – process and/or commissioning (if relevant) N/A as no decision required – for assurance only. Conflicts of Interest: (please tick accordingly) No conflict identified Conflict noted, conflicted party can participate in discussion and decision (see below)

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Conflict noted, conflicted party can participate in discussion but not decision (see below) Conflict noted, conflicted party can remain but not participate in discussion (see below) Conflicted party is excluded from discussion (see below) Governance assurance (see below) N/A as no decision required – for assurance only. Strategic aims supported by this paper (please tick) Better Health in Bucks – to commission high quality services that are safe, accessible to all and achieve good patient outcomes for all

Better Care for Bucks – to commission personalised, high value integrated care in the right place at the right time

Better Care for Bucks – to ensure local people and stakeholders have a greater influence on the services we commission

Sustainability within Bucks – to contribute to the delivery of a financially sustainable health and care economy that achieves value for money and encourages innovation


Governance requirements: (Please tick each box as is relevant to the paper) Governance Element Y N N/A Comments/Summary Patient & Public Involvement

Equality Quality Privacy One or more issues described within the report

may relate to privacy and outcomes of Data Protection Impact Assessments (DPIAs) as are required under the General Data Protection regulation (GDPR)

Financial Risks As described within Statutory/Legal Appointment to the role of Caldicott Guardian is a

statutory obligation Prior consideration Committees /Forums/Groups


Supporting Papers: Report inserted below

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Data Security and Protection / Information Governance Annual Report 1.0 Overview and governance framework 1.1 Purpose of report This report provides Governing Body with an annual overview of local Data Security and Protection / Information Governance activities, responding to national legislation and guidance and managing risks in respect of our information and to protect the interests of the population served. It incorporates annual reports for the statutory roles of the Caldicott Guardian, Data Protection Officer and Senior Information Risk Owner (SIRO). Its aim is to demonstrate the openness, maturity and accountability of the CCG with specific regard to data security and protection and protecting patient identifiable information. 1.2 Statutory Role appointees during 2019/2020 Role Appointee Term Caldicott Guardian

Dr Karen West, Clinical Director for Quality and Integrated Care and Chair of Quality and Performance Committee

From July 2016 for both NHS Aylesbury Vale CCG and Chiltern CCG when operating in Federation, and for NHS Buckinghamshire CCG following the former CCCG’s merger from 1 April 2018.

Data Protection Officer

Russell Carpenter, Head of Governance/Board Secretary

From May 2018 when statutory role came into effect

Senior Information Risk Owner

Robert Majilton, Deputy Accountable Officer

Same as the Caldicott Guardian

1.2 Supporting Governance / Assurance Framework The statutory roles are members of the CCG’s Information Governance Steering Group, which is held jointly with the equivalent for NHS Oxfordshire CCG and meets quarterly. It is chaired by either a Senior Information Risk Officer (SIRO) or Caldicott or Director of Governance from Buckinghamshire or Oxfordshire CCG, with information governance specialists from South Central and West Commissioning Support Unit as standing invitees. The CCG’s Information Governance Steering Group

• Is shown within the CCG Constitution as accountable to the Audit Committee, which is in turn accountable to the Governing Body.

• Provides assurances to Audit Committee on matters relating to information governance best practice and information mechanisms in place.

Its standing items during 2019/2020 have included:

1. Risk Register – to assess risks to security and integrity of information and management of confidential information.

2. Records Management and review/approval of other function policies and procedures 3. Data Protection Impact Assessments (DPIA’s) – approvals and escalations as required. 4. Legislation Update and certification/registration issues and escalations 5. Data Security and Protection Toolkit – progress reports 6. Reviews of registers of data flows (record of data processing activities) and information

assets. 7. Reports from the Data Protection Officer 8. Information Governance Incident Reports. 9. Freedom of Information Request and Subject Access Requests – quarterly & annual reports 10. Confidentiality and spot check audit reports. 11. Data Security Awareness training compliance.

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Table 1 describes briefly describes its activity separate to standing items and not otherwise referred to within embedded reports from the Caldicott Guardian, Data Protection Officer and Senior Information Risk Owner (SIRO). TABLE 1: SHORT SUMMARY OF THE ACTIVITY OF THE CCG INFORMATION GOVERNANCE STEERING GROUP 2019-2020 Quarter 1

1. Reviewed and updated terms of reference aligned to meeting jointly with Oxfordshire CCG, together with the annual work plan

2. GDPR compliance audit debrief 3. Distinctions between Toolkit requirements for smaller and larger organisations 4. Review of Information Commissioners Office guidance on leaving the EU (six steps to

take) Quarter 2

1. Data Security and Protection arrangements specific to “My Care Record” shared care records in Buckinghamshire, including “on boarding” arrangements for data processors.

2. Review and approval of specific policies – risk stratification and acceptable use. Quarter 3

1. Review of “on boarding” arrangements for My Care Record and comparison with data security and protection checklist requirements any new data processor engaged by the CCG, or processing patient identifiable data in primary care

Quarter 4

1. Governance arrangements and terms of reference for Buckinghamshire Integrated Care Partnership Information Governance Steering Group, with a lead data controller (proposed to be supported by the BHT team),

2.0 Definitions and purposes of statutory roles 2.1 Caldicott Guardian The Caldicott Guardian:

• Is a senior person as the 'conscience' within the organisation who is responsible for protecting the confidentiality of patient and service user information

• Responsible for procedures governing access to, the use of, patient identifiable data (PID) and, where appropriate, the transfer of that information to other bodies.

• Represents and champions risks and issues through Governing Body, at all other levels within the organisation, and with partner organisations outside the NHS.

• Organisational lead for data protection, human rights, freedom of information, and code of practice on confidentiality.

Each NHS organisation is required to have a Caldicott Guardian, which for the CCG is also a member of Governing Body. The job description states that the holder of the role shall, on an annual basis, formally report to the Governing Body the CCG’s performance against the whole information governance agenda, making recommendations for further improvement where appropriate. This may include such matters as, but is not limited to:

• The number and type of Caldicott issues that have been logged, satisfactorily resolved and remain pending (with reasons they have not been resolved)

• Any issues that have been escalated due to an unsatisfactory response from the organisation, or because the issue has become more pressing and requires a more immediate response.

• Clear indications of any necessary improvements, addressing issues such as the implementation of a new policy or procedure, the need for staff training and awareness, etc. In addition, required operational resources for implementation (human, financial or time allocated to the role) should also be included.

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2.2 Data Protection Officer The Data Protection Officer:

• Is a designated person with responsibility for protection of personal identifiable data reporting to the Senior Information Risk Owner (SIRO)

• Holds the role of in-house Information Governance Lead, coordinating its work programme and is accountable for ensuring effective management, compliance and assurance for all aspects of information governance/data security and protection.

• Monitors CCG compliance with GDPR and other data protection legislation • Monitors CCG compliance with data security and protection policies. • Ensure compliances with the annual Data Security and Protection Toolkit published by NHS

Digital. • Leads on annual audit in relation to the Toolkit. • Lead as secretary to the joint CCG Information Governance Steering Group with NHS

Oxfordshire CCG. • Is the CCG point of contact with the Information Commissioner’s Office (ICO), employees

and the public in relation to data security and protection in order to: 1. Inform and advise the organisation and its employees about their obligations to

comply with applicable data protection legislation; 2. Support and monitor compliance with applicable data protection legislation; 3. Be the first point of contact for individuals whose data is being processed.

The Data Protection Officer (DPO) is a mandatory appointment, introduced in 2018 as part of the General Data Protection regulation GDPR). It is also:

• Separate to the Caldicott Guardian to avoid a conflict of interest as described within EU guidelines, where the Caldicott Guardian role leads to the determination of purposes and means of processing. For NHS Buckinghamshire CCG the Caldicott Guardian role holder is also a GP Clinical Director for Integrated Care.

• NOT the Data Protection Officer for primary care practices. As with the role of Caldicott Guardian (above), practices are expected to have their own appointment. A CCG appointment could not cover primary care given practices independent contractor status, and the substantial limitations placed on CCGs by Caldicott 2 in terms of patient confidential information it is authorised to receive which do not apply to member practices.

2.3 Senior Information Risk Owner (SIRO) The Senior Information Risk Owner (SIRO):

• Is a nominated person and Executive Director taking ownership of the organisation’s information risk policy at Board level, reporting on statements of internal control.

• Shall receive regular training as necessary to ensure they remain effective in their role. • Liaises and works with staff at all levels to promote Caldicott principles alongside the

Caldicott Guardian. • Initiate and oversee a comprehensive programme of work that identifies, prioritises and

addresses NHS IG risk and systems’ accreditation for all parts of the organisation, with particular regard to information assets that hold and/or process personal data.

• Delegates as is necessary to the CCG Data Protection Officer.

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3.0 Caldicott Guardian Annual Report 3.1 Training

• The Caldicott Guardian completed advanced Caldicott Guardian Training in January 2019 as part of the annual Data Security and Protection Toolkit submission for 2018/2019.

• No other advanced training has taken place this year other than completion of annual standard Data Security Awareness training as is completed by 31 March each year by all CCG staff.

3.2 Issues report TABLE 2: CALDICOTT GUARDIAN ANNUAL REPORT 2019/2020

• TO FOLLOW . 4.0 Data Protection Officer Annual Report This section compiles into a single report all the information and assurance provided in-year by the Data Protection Officer to the CCG Audit Committee. Throughout the year the Committee was assured that the CCG continues to sustain its statutory duty to appointment to this role. 4.1 Data Security and Protection Toolkit compliance Although the deadline for submission of Data Security and Protection Toolkits was extended from 31 March 2020 to 30 September 2020 as a result of the COVID-19 pandemic, the CCG has already completed its submission before 31 March 2020. https://www.dsptoolkit.nhs.uk/OrganisationSearch/14Y In 2019/2020, standards were exceeded. As regards internal audit outcomes in 2019/2020, this had one low risk action related to ensuring assertions that are in progress are to have evidence required for completion recorded within the DSP Toolkit action plan. This has happened by default in order to complete the Toolkit submission. 4.2 Policy compliance During 2019-2020 the following policies have been reviewed and approved:

Ref Number Title Version IGPOL005 Information Governance Staff Handbook V2.3

All other relevant policies were reviewed, and where appropriate updated, in 2018/2019 with bi-annual review dates. They will all be due for further review before the end of 2020/2021. 4.3 Data Security and Protection arrangements during coronavirus (COVID-19)

a. Information Commissioner’s Office (ICO) and NHSX guidance The Information Commissioner’s Office (ICO) and NHSX have issued advice and guidance on how to manage and share information appropriately during the Coronavirus (COVID-19) pandemic. Both

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https://www.dsptoolkit.nhs.uk/OrganisationSearch/14Y

organisations acknowledge the significant pressures that are being put on health and social care systems. The advice focuses on some of the tools that can be used to support individual care, share information and communicate with colleagues during this time: • https://www.nhsx.nhs.uk/key-information-and-tools/information-governance-guidance • https://ico.org.uk/about-the-ico/news-and-events/news-and-blogs/2020/03/data-protection-and-

coronavirus/ In light of these circumstances, NHSX and NHS Digital have also decided to extend the compliance deadline for the national data opt-out and the final date for submission of the Data Security and Protection Toolkit (DSPT) to 30/09/2020.

b. Health Service Control of Patient Information Regulations (COPI) 2002 NHS England and NHS Improvement have been given legal notice to support the processing and sharing of information to help the COVID-19 response. Individual healthcare organisations, Arm’s Length Bodies (except NHS Digital and NHS England and NHS Improvement which have been separately notified) and Local Authorities have now also been given legal notice under the same regulations to support the processing and sharing of information to help the COVID-19 response. This is to ensure that confidential patient information can be used and shared appropriately and lawfully for purposes related to the COVID-19 response. Please see link to the COPI Notice here. This notice is deemed to apply to all providers of healthcare, all GP practices, all Department of Health and Social Care's Arm's Length Bodies and Local Authorities. However this notice does not refer specifically to CCGs and their involvement in this process, likewise the original 2002 regulations. NHSX Information Governance Policy team has deemed the COPI notice to apply to CCGs (as at 30 March 2020) who are permitted to process patient identifiable information for COVID-19 related purposes, subject to all usual GDPR/DPA2018 considerations that the CCG has in place. However once COPI expires (currently 30th September 2020, but could be lifted sooner) so do all uses of the data for COVID-19 purposes and the CCG must go back to business as usual. There have already been examples in Buckinghamshire where the Data Protection Officer and/or Caldicott Guardian have deemed the above notice to apply to avoid delay in protecting the safety of patients and anticipated increase in cases:

1. Additional data sharing through director on call process to speed up delayed discharge of current admissions to release bed capacity.

2. Escalating to other CCGs the fast track temporary discharge of spinal patients from Stoke Mandeville Hospital specialist unit to resident counties, also to release bed capacity.

3. Receipt of list from NHS Digital of people at “high risk” of complications from COVID-19, who should be shielded for at least 12 weeks (Shielded Patient List, national cohort circa 1.5m), to liaise with member practices and for which a lawful basis is required. https://digital.nhs.uk/coronavirus/shielded-patient-list/shielded-patient-list-methodology

4.4 Continuity of Data Protection Impact Assessments during COVID-19 It is expected that appropriate due diligence on data security and protection is to continue during the outbreak, in line with Data Protection legislation, so as to capture and manage any immediate Data Protection concerns. That involves completing Data Protection Impact Assessments for additional solutions or initiatives introduced during the pandemic, especially in support clinical interventions. The CCG Data Protection Officer has deemed to keep this simple with conclusions:

1. Although SCWCSU (as IG advice and support service) has provided a short form DPIA, there is a risk that the accompanying process (which includes review and recommendation

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https://www.nhsx.nhs.uk/key-information-and-tools/information-governance-guidance

https://ico.org.uk/about-the-ico/news-and-events/news-and-blogs/2020/03/data-protection-and-coronavirus/

https://ico.org.uk/about-the-ico/news-and-events/news-and-blogs/2020/03/data-protection-and-coronavirus/

https://digital.nhs.uk/services/national-data-opt-out

https://www.dsptoolkit.nhs.uk/News/71

https://www.dsptoolkit.nhs.uk/News/71

https://elinkeu.clickdimensions.com/c/6/?T=NTgyNTUzNzk%3AcDEtYjIwMDg2LTVjOWI1OTY0MGJmMTRkM2VhNDgxNzAxYjM4MGM1Yzli%3AcnVzc2VsbC5jYXJwZW50ZXJAbmhzLm5ldA%3AbGVhZC0xZGFmZTFhNDU2NmZlYTExYTgxMTAwMGQzYTg2YjhkNS0wNmI1MWEyYjZiM2M0YmE4YTc1NjNiMmI1ZTc1OWRmZQ%3AZmFsc2U%3AMw%3A%3AaHR0cDovL2ZpbGVzLWV1LmNsaWNrZGltZW5zaW9ucy5jb20vaHNjaWNnb3Z1ay1hbW5qZS9maWxlcy8yMDIwLjAzLjIwLWZpbmFsZ2VuZXJhbGNvcGlub3RpY2Utc2lnbmVkLnBkZj8xNTg0OTYxOTcyMTYwJl9jbGRlZT1jblZ6YzJWc2JDNWpZWEp3Wlc1MFpYSkFibWh6TG01bGRBJTNkJTNkJnJlY2lwaWVudGlkPWxlYWQtMWRhZmUxYTQ1NjZmZWExMWE4MTEwMDBkM2E4NmI4ZDUtMDZiNTFhMmI2YjNjNGJhOGE3NTYzYjJiNWU3NTlkZmUmZXNpZD1kYTI4M2I1Yy01MjZmLWVhMTEtYTgxMS0wMDBkM2E4NmI0MTA&K=ZqSd7SWES_s051IDIXtxeg

https://digital.nhs.uk/coronavirus/shielded-patient-list/shielded-patient-list-methodology

by SCWCSU to CCG) would be too time consuming to implement solutions quickly during the current pandemic.

2. Initiatives already in train are following a fast track process (details available upon request). 3. For other initiatives where there is a COVID-19 need identified, suppliers may also provide

pre-populated templates that the CCG Data Protection Officer can review and sign (or escalate to the Caldicott Guardian on as need basis) rather than duplicating effort by completing a different SCWCSU template.

4.5 Freedom of Information, Subject Access Requests and the coronavirus: a measured approach There is the possibility, that at some point during or immediately after the current pandemic, there could be a significant increase in Freedom of Information Act enquires and media / press enquires which requires additional resources to respond within required statutory time limits (20 working days for freedom on information). The Information Commissioner’s Office (ICO) also recognises the unprecedented challenges all are facing during the coronavirus (COVID-19) pandemic. Their advice is that “Whilst we can’t extend statutory timescales, we will not be penalising public authorities for prioritising other areas or adapting their usual approach during this extraordinary period”. On that basis, the CCG has agreed the following arrangements:

1. Follow our existing process as normal for compliance within 20 working days (FOI) and 40 days (SAR).

2. FOI: Robert Majilton Deputy Accountable Officer to sign off in first instance, delegated to Gary Heneage Chief Finance Officer where able/unavailable. Additional contingency for COVID-19, delegated to Russell Carpenter Head of Governance if neither available due to system resilience/response.

3. SAR: Dr Karen West 4. Any responses likely to breach will be signed off by Robert Majilton (FOI) and Dr Karen

West (SAR) to ensure a clear audit trail if later challenged. The CCG website has been updated to advise patients and the public that, whilst the normal channel is still to be followed and the CCG shall endeavour to respond within the specified timescales, there may be occasions where we may be unable to do so. This takes into account the time limit for response at 18 hours (£450 maximum staff cost to respond) for the CCG as a public authority. A reasoned judgement would be needed (by CCG responder and SCWCSU FOI Team) as to compliance both above and below this time limit on a case by case basis whilst the pandemic continues. 4.6 Data Flow Mapping and EU Exit The UK previously voted to leave the European Union and left on 31 January 2020. Catherine Mountford (Director of Governance, Oxfordshire CCG) continued as the named Senior Responsible Officer (SRO) for EU Exit. A risk assessment was previously undertaken by the CCG Data Protection Officer in anticipation of a previously expected EU Exit departure at 29 March 2019. This identified only one CCG flow with links to EEA based servers – relating to staff data to ASC Corporate eye care for follow up intervention for CCG staff following VDU assessment. Re-assurance at the time was sought, and confirmed, that data management would revert to UK based servers in the event of any issues. A further assessment will be undertaken as part of data flow mapping for the 2019/20 data security and protection toolkit submission to NHS Digital. Additional assurances were sought specifically in relation to data flows where the CCG is data controller, and where third party organisations are contracted/sub-contracted as data processors on behalf of the CCG.

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Data Flow Contract Sub-

contract Assurances

Continuing Healthcare

Oxford Health NHS Foundation Trust (assessment service)

CHS Healthcare

Data held at the following UK based data centre: Xicon Ltd, Bank House, 1 Bank Street, Warrington Data centre hosting

Individual Funding Requests

NHS South Central and West Commissioning Support Unit (SCWCSU)

Blueteq (software user interface for processing applications)

Blueteq has assessed its risk in the following areas and these are their findings: 1. Staff – no staff would be affected. 2. Location of data – systems and data are located in the UK (Six Degrees Data Centre, Birmingham Central, Westley Street, Birmingham, B9 4ER

Assurances were also sought from some providers in relation their own assurances from their suppliers. Frimley Health has reported that they had not identified any significant risks with EU Exit and data flows. They have documented the flows of data outside of England and have agreements in place to cover these arrangements. Buckinghamshire Healthcare NHS Trust has provided equivalent assurances. The Audit Committee was also informed that the Cabinet Office and Department for Digital, Culture, Media & Sport (DCMS) had liaised with 18 of the major storage suppliers who have provided an assurance that all the data stored remains within the UK and not the EEA. Although these suppliers have supplied reassurance to government, NHS England had advised it is up to each individual organisation to determine whether they wish to seek their own assurances, as they have to manage their own risks. The CCG sought no further assurances, which also became a moot point. 4.7 My Care Record (Buckinghamshire Shared Care Record) and risk sharing Work has continued throughout the year to connect information from various organisations to create a full Shared Care Record. Developments specifically relate to data matching Buckinghamshire’s My Care Record with equivalent data held by Frimley/Berks. The COVID-19 pandemic has made this even more vital in order to minimise safeguarding and patient safety risk. The Information Commissioners Office published guidance indicating that they would not pursue an organisation for sharing data in the circumstances of a breach from another organisation. However, given the arrangements in place for shared care records, a risk sharing agreement has been implemented between the CCG and its member practices. This provides for reasonable legal costs in defending claims arising out of sharing information for agreed system activities (e.g. linked to the development of a Shared Care Record). 4.8 Primary Care engagement/workshop A combined digital transformation and Data Protection workshop took place on Tuesday 11 February as part of Protected Learning Time, to cover a range of areas with practices including DPO support. Specific learning and opportunity to emerge related to member practices published privacy notices following an audit. A template CCG Privacy Notice which practices can signpost to was also subject to some further amendments, with practices in the process of updating their websites to achieve this rather than publish their own. 4.9 Primary Care Data Protection Officer Support function A new 5 year GP contract was issued in January 2019 which included the following statement: CCGs will be responsible for offering a Data Protection Officer (DPO) function to practices in addition to their existing DPO support services, whether by the CCG directly or through its commissioning support service. Appointing a DPO remains a practice’s legal responsibility, but this arrangement will be more efficient for the NHS as a whole.

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https://xiconcloud.com/about-us/uk-data-centre-hosting/

Funding was said by NHS England to have been made as been made available in CCGs’ baseline to support this requirement to be implemented as of April 2019. The CCG DPO has provided support where possible. An updated Primary Care GP Digital Services Operating Model 2019-2021 was also published, confirming responsibility for CCGs to provide member practices with a DPO function. This also describes the scope for such a function. The CCG considered a number of options:

1. Internal recruitment, with considerable potential to share resource with Oxfordshire 2. Variation to existing Service Level Agreement (SLA) with South Central and West

Commissioning Support Unit (following which they would assess and address recruitment needs)

3. Mini-procurement if, on the basis of procurement advice, this is deemed as necessary. Where companies made approaches with offers, active dialogue was curtailed to avoid procurement prejudice.

When scoping options including cost and route to provide, feedback from Procurement suggested the CCG is not obliged to procure and could vary the existing SLA. Available frameworks could also facilitate a mini-competition and avoid running a full OJEU process. An offer from South Central and West Commissioning Support Unit (SCWCSU) has since been agreed and into effect from 1 June 2020. 5.0 Senior Information Risk Owner (SIRO) annual report This section covers any remaining matters not covered elsewhere. 5.1 Training

• The Senior Information Risk Owner completed advanced Caldicott Guardian Training in January 2019 as part of the annual Data Security and Protection Toolkit submission for 2018/2019.

• No other advanced training has taken place this year other than completion of annual standard Data Security Awareness training as is completed by 31 March each year by all CCG staff.

5.1 Subject Access Requests Subject Access Requests are responded to by the data controller for the record. For the CCG this relates only to provision of continuing healthcare and funded nursing care which it commissions, the assessment and brokerage of which is administered on its behalf by Oxford Health NHS Foundation Trust. Requests related to primary care are directed to member practices where patients are registered, and those relating to other commissioned services are directed to the providers of those services. This function is provided on behalf of the CCG by South Central and West Commissioning Support Unit (SCWCSU). At the time of writing, the CCG processed and responded to a total of 1 subject access request under article 15 of the General Data Protection Regulation (GDPR), EU 2016/679. These must be responded to within one calendar month starting the day after the request was received. Nil requests exceeded timescale. 5.2 Freedom of Information (FOI) Requests Public authorities are obliged to reply to FOI requests within 20 working days.

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This function is provided on behalf of the CCG by South Central and West Commissioning Support Unit (SCWCSU). During 2018/19 to date, the CCG processed a total of FOI requests. Quarter 2018/19 Number of requests responded to 1 70 2 66 3 80 4 71 Total 287 5.3 Data Flow Mapping/Asset Register - Summary Risk Report As part of the annual Data Security and Protection Toolkit (previously known as Information Governance Toolkit) submission, it is a requirement for all organisations that handle health data, which includes CCGs, to identify and do a risk assessment on all its information flows and information assets. In addition to this, there is also a requirement from the new General Data Protection Regulation (GDPR)/Data Protection Act 2018 (DPA 2018), for the CCG to conduct a comprehensive Information Governance Audit to identify and record the types of data it processes and how/where it is held. The SIRO has received and confirmed acceptance of these analyses, further details of which are available separately as part of the CCG’s comprehensive Toolkit evidence.

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MEETING: Governing Body AGENDA ITEM: 16 DATE: 11 June 2020 TITLE: Communications and Engagement Report – January – March 2020 AUTHOR: Kim Parfitt, Head of Communications LEAD DIRECTOR: Robert Majilton, Deputy Accountable Officer LINK TO RISKS: Governing

Body Assurance Framework

GBAF 1 relates to commitments within the ICP memorandum of understanding and related operating plan


The Corporate Risk Register includes a risk in relation to ICP Service design and engagement framework

Reason for presenting this paper: For Action For Approval For Decision For Assurance For Information For Ratification Summary of Purpose and Scope of Report: This report in for information and assurance to the Governing Body. It outlines public engagement and involvement work that has been undertaken for the Buckinghamshire NHS Clinical Commissioning Group and the Integrated Care Partnership. It also includes an outline of all media related activity and communications and campaigns that have taken place. We have endeavoured to outline the impact our work has had. A considerable amount of activity has been impacted by Coronavirus and put on hold to focus on communications relating to this for both the public, primary care and the voluntary sector. Section 7 introduced Patient Stories – this quarter we have foscussed on stories from Buckinghamshire Healthcare NHS Trust Authority to make a decision – process and/or commissioning (if relevant) N/A Conflicts of Interest: (please tick accordingly) No conflict identified Conflict noted, conflicted party can participate in discussion and decision (see below) Conflict noted, conflicted party can participate in discussion but not decision (see below) Conflict noted, conflicted party can remain but not participate in discussion (see below) Conflicted party is excluded from discussion (see below) Governance assurance (see below) N/A

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Strategic aims supported by this paper (please tick) Better Health in Bucks – to commission high quality services that are safe, accessible to all and achieve good patient outcomes for all






Please refer to report for details

Equality/Equity Quality Privacy Financial Risks Statutory/Legal Prior consideration Committees /Forums/Groups


Supporting Papers: See report below

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1.0 Introduction This report covers Quarter four – January to March 2020. There was considerable work planned for the period for both the Clinical Commissioning Group and for the Integrated Care Partnership focussing on planned communications and engagement work with engagement activities around future commissioning arrangements and aligning with the communications work for Buckinghamshire, Oxfordshire and Berkshire West (BOB) Integrated Care System.

However, this period was dominated with coronavirus – communications were involved from as early as January liaising with Public Health England, NHS England and the Council.

The report outlines the public and patient involvement that has taken place, alongside staff engagement. It provides details on the campaigns that have taken place, wherever possibly displaying metrics and evaluation data. Also included is the media (both traditional and social) that has taken place during this period.

2.0 Our Objectives The Communications and Engagement service provides strategic and operational support for Buckinghamshire CCG to enable it to work with stakeholders, partners, patients and the public to deliver their commissioning intentions both for the CCG but also as part of the Buckinghamshire Integrated Care Partnership.

The service assists the CCG to ensure that it meets its statutory duties to engage and consult and works to ensure that equality and diversity issues are taken into account throughout delivery of the service.

Alongside this, the service provides support for the wider integrated care partnership alongside the communications teams at partner organisations.

3.0 Public and Patient Involvement There have been a number of areas of work where residents in Buckinghamshire have been able to get involved with various aspects of the CCGs work.

3.1 Getting Buckinghamshire Involved Steering Group

The Getting Bucks Involved Steering Group was set up to look at plans to involve local people in changes to health and care services in Buckinghamshire. The group helps us make sure we are talking to the right people at the right time and in the right way, so these people can give us their views on the possible changes. This group is identified as a key group in the governance for the ICP in its role of scrutinising communications and engagement work. In the last quarter, we have merged representatives from the Social Prescribing working group as well as welcoming members of Patient Participation Groups.

In January, with 23 attendances, the agenda covered: 37

• Public and patient participation in strategic direction of Buckinghamshire mental health services

• Community nurses team for children with learning disabilities, • social prescribing, • Winter Communications plan

In February, 17 people attended from Buckinghamshire Healthcare NHS Trust, Carers Bucks, Healthwatch Bucks, Talk Back, Citizen Advice, Fremantle Trust, Fact Bucks, patient participation groups and representatives of patients. The meeting covered:

• Reviewing the proposed changes to the Terms of Reference • Social prescribing communications plan, • Collecting feedback from the group for the ICP Shared Exec group • Updates on winter plan • Preparing of adulthood

The meeting in March had to be cancelled due to coronavirus.

3.2 Other engagement and involvement activities, including impact

3.2.1 Residents Panel – Winter Survey

A winter survey was shared with the resident panel in January. The survey came to a close at the end of February. 1437 received the survey. Of those that received the survey, around 20% (280) opened it and around 90% (256) responded.

Top headline results:

- Flu - 57% had seen information about the free flu jab this year. 60% had the jab this year. 17% who said they didn’t get the jab, said they were not eligible for it

- Advice on vomiting and diarrhoea bugs - Majority of people said they would stay at home, keep warm and drink lots of fluid and wash hands if they got the vomiting and diarrhoea bug. 13% would call NHS 111 & 8% would go to the pharmacy.

- NHS 111 service - 95% have heard of the service. The majority would use this service to get information on how to look after their condition, if they had an urgent medical problem or get an out of hours GP appointment.

- GP practices open for longer – 54% have not benefited from this service yet and 30% didn’t know they were open longer. Around 10% said they were able to get appointments more easily.

- Repeat prescriptions – 46% would go to their GP practice, 29% would use an app or website and 19% through their pharmacy.

- Using local pharmacy – 27% pick up a prescription, 21% advice on medication, 17% advice on colds and coughs and 16% for advice on minor tummy upsets.

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- Helping an elderly or frail person – 23% would go to a relevant charity, 19% would use Google, 17% would use their Council.

- Safe travel in winter – 28% would use travel websites such as AA, RAC. 19% would go to Google. 15% would use local media. 9% would go to their council website.

The data from this survey will be used to help with planning for winter 20/21.

3.2.2 Care and Support Planning Survey – Type 2 Diabetes

A care and support survey was set up to find out how useful patients find their Care and Support Planning appointments to help them manage type 2 diabetes.

The survey was set up on the new digital engagement platform, Your Voice Bucks with information and promotional copy to support.

Unfortunately this work has been interrupted by COVID-19 outbreak.

3.2.3 Improved Access

Working in partnership with FedBucks and GP practices, a patient survey was set up on the Your Voice Bucks platform.

The survey is designed to measure patient understanding and usage of Improved Access appointments. The Interim report shared and presented at February Improved Access GP workshop.


3.2.4 Consultation on prescribing gluten free foods

Following on from the previous quarters report, where we outlined the work involved in this consultation, in this period the end of consultation report was prepared and submitted.

On 12 March, the CCGs Governing Body approved that gluten free bread, bread mixes and flour mixes will only be available to prescribe for patients that meet the exception criteria.

On 19 March, the decision was taken to defer the implementation of the consultation outcomes, and subsequent decision. This was due to the COVID-19 pandemic in particular pressure on primary care and potential food supply issues.

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https://yourvoicebucks.citizenspace.com/

Communications planning for implementation is now in progress. However, no date has been scheduled; we do expect an update by August 2020. A statement outlining the decision and plans to hold implementation was issued to the press and stakeholders on 13 May 2020.

4.0 Staff Engagement 4.1 CCG member bulletin

This continues to be produced on a weekly basis and shared among 768 subscribers.

4.2 Shared Records and LHCRE

A large steering group was held, comprising of stakeholders and patients to discuss the new shared record, how it could be accessed, and how this would be communicated to patients.

Together, we discussed the difficulties around this and the methods to simplify the language around data protection. The outcome of this workshop is a simpler version of the FAQ document being written with simpler/consistent messages on the website and privacy statement.

4.3 Teamnet

The Communcations Team have been creating and maintaining new areas on Teamnet to support Primary Care communications and encourage more use of the Teamnet resource.

Alongside this we were developing and producing a weekly newsletter for Clinical Directors/ PCNs. This commenced mid February 2020 but was suspended after 3 weeks due to Covid19. However in three weeks the newsletter and PCN support page was viewed 400 times during.

To meet the needs for quickly sharing information with GP Practices, we created and are maintaining Covid19 pages and information on Teamnet. This launched on 3 March.

The Main Covid19 page was viewed 3,000 times from 3-31March 2020.

4.4 Primary Care Covid19 Briefing

With the impact of Covid19, regular briefings have been essential to GP Practices. As a result we have compiled, edited, published and supported distribution of a daily briefing to primary care colleagues.

The aim was to reduce email traffic to GPs at this unprecedented time, while ensuring they received essential information quickly and easily without the need to log in to Teamnet each time ( ie ensure all linked documents and other information was easily accessible.

Outcomes: 40

• Consistently positive feedback from CCG senior management team and from practices

• Increased use of Teamnet • Mailing list increased to include all GPs, locums, practice managers, CCG

staff • Publication achieved on a daily basis

5.0 Communications 5.1 Traditional Media 5.1.1 Media

From January – March 2020, we handled 12 media requests directly relating to the CCG including enquiries and interview requests. We have drafted 11 press releases, including 4 ‘if asked’ statements (two of these were to support potential issues faced by specific GP practices). These included:

- Numerous COVID-19 issues (GP closure, handwashing, information and advice) - Winter pressures (including advice to pharmacies, 111, good neighbours, hospital

A&E pressure, support to hospitals, funding) - Healthwatch contract - Sue Ryder Nettlebed - Freemantle Trust Integrated Service - Mental Health Crisis team

Media enquiries included:

- Several enquiries about COVID-19 (GP practice closures) - GP capacity at Poplar Grove - IVF issues - Transforming care (LD and autism) - BOB shared AO - PCN funding - PCN clinical directors

5.2 Social Media

Social media remains critical for engaging with the patients and the public. It allows us to target and inform relevant residents either using demographics or by geography. It provides us with a cost effective solution for reaching residents either with no cost attached or on occasion using a small budget to specifically target segments of the population. The table below outlines the key channels, Twitter and Facebook, and the relevant key data.

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Twitter Facebook Tweets Visits to

Profile New Followers Post/Shares Reach

January 2019 91 1012 36 71 11193 February 86 863 35 56 16282 March 61 925 27 44 6954 April 58 1206 19 36 2137 May 55 540 20 41 2475 June 67 803 28 44 6283 July 40 743 14 41 6518 August 10 96 8 23 2393 September 14 215 11 23 1896 October 30 237 20 51 4316 November 47 244 24 49 8616 December 46 179 11 42 8445

Twitter Facebook Tweets Visits to

Profile Impressions New Followers

Post/ Shares Reach New

Followers January 2020 47 299 80.6K 31 50 11396 7 February 44 133 58.5K 25 45 10863 7 March 29 454 73.2K 49 46 6778 10

Please note: Reach is the total number of people who see your content. Impressions are the number of times your content is displayed, no matter if it was clicked or not.

6.0 Campaigns 6.1 Winter – January to March 2020

The winter campaign continued to promote key themes in line with the national campaign with the following results:

6.1.1 Social media

The best results were achieved by sharing or re-tweeting post on the Buckinghamshire County Council social media accounts. There were several strands.

Use the right service

This was in direct response to OPEL4 pressures on urgent care services, particularly A&E in first week of January. Seven Facebook posts were seen over 14,500 times, and six tweet reached over 22,000 during this time, in addition to being shared on social media by local radio.

•

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NHS111 and 111 Online:

33 tweets seen over 33,000 times

The top two tweets with the same message featured both a video and static image and were seen a total of 17,700 times on Twitter.

Ask NHS app

Top tweet: 20,000 impressions and an engagement rate of 31%

Cold weather and good neighbours

Top tweet 8 January 7,800 impressions

Pharmacies (#HUHY)

Pharmacy advice messages in February reinforced those used in November’s Ask Your Pharmacist week, but stopped being posted in early March due to Coronavirus being a priority.

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Top post on Twitter on 3 January had over 15,000 impressions, while the top post on Facebook on 25 February reached almost 1,000.

Infection control: Norovirus and hand hygiene

The CCG Facebook post about Norovirus on 11 January was seen by around 1,000 people.

Messages were revised in March to promote hand hygiene due to Coronavirus and reached 4,952 people on 4 March.

6.1.2 Press and community magazine coverage

Four press releases were issued:

• be a good neighbour;

• pharmacies

• use the right service

• handwashing

All were published by local press and community magazines including BOPAG, My Bucks and Hiya Bucks.

Be a good neighbour was most widely published - featured on Mix96 (50,000 weekly news listeners) and 480 online views, plus Bucks Herald and Bucks Free Press .

6.1.3 Paid advertising and promotions

A budget was approved in late December for paid advertising to support the winter campaign. This was used as follows:

• Commissioned and scripted 30 second advert on Mix96 for 8 weeks advising where to get help from NHS for winter illness. It was broadcast 450 times to reach over 66,000 people. Cost £4,000.

• Full page advert in Primary Times (45,000 copies to all primary schools, plus 60,000 online views costing £500 (negotiated half usual price). Promoted stay

44

well messages, where to get medical help and a reminder to use the right service.

• Leaflet aimed at families of children in Key Stage 1 with winter health advice and where to get medical help. 20,000 copies cost £500. Distribution included:

- Libraries - Family Support centres

- Nurseries - Leisure facilities - Schools - GP practices.

• Promoted on Mumsnet for two adverts over 8 weeks: cost £1,000

6.2 Integrated Care in Action Week (9-15 March)

During this week, we supported BOB ICS in promoting the week with direct posts and retweets and shares from other organisations.

Integrated Care in Action Week campaign (9 - 15 March 2020) Buckinghamshire CCG organic social media posts - summary of outcomes

Twitter Facebook Total no. of posts: 3 Total no. of posts: 4 Overall impressions: 9,202 Overall reach: 362

Overall engagements: 61 Overall engagements: 17 Overall average engagement rate 0.8%

Overall average engagement rate: 4%

Most popular post impressions and engagement: 5,471

Most popular post reach/engagement: 141

Engagement rate: 0.4% Engagement rate: 6%

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6.3 Social Prescribing

Communications was prepared to promote role of Social Prescribing among GPs and healthcare professionals and patients, as required.

This was informed by speaking to social prescribers to understand issues and challenges faced by them, and how to address these.


6.4 Children’s Hubs

September saw the launch of this pilot scheme to improve the way healthcare is delivered to children across the BMW and Maple Primary Care Networks in Aylesbury (Berryfields Surgery, Meadowcroft Surgery, Whitehill Surgery; and The Mandeville Practice, Oakfield Surgery, Poplar Grove Surgery).

Communications were circulated to GPs during January - March, updating on both the progress of the project and future plans for wider roll out.


6.5 MMR Immunisation

During this period, families were encouraged regarding the uptake of MMR with the growing cases of measles of particular concern. Messages were shared on social media and through local press release.

6.6 Coronavirus

From February we started to work closely with Public Health on Coronavirus. The first messages started to been seen in February although they did not directly mention coronavirus, with the focus on washing hands, followed by:

In addition, a sction was created on the CCG’s website with related information for the public. This also linked to the information on both BHT’s website and the Council Coronavirus Support and information pages, which included public health messages.

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https://www.buckinghamshireccg.nhs.uk/wash-your-hands-to-stop-the-spread-of-infections/?fbclid=IwAR0SggAneNCoFnTMrqW84GjTLm0mCCONuM1PhD_1sP9icp2TRgvj_9YEg70

https://www.buckinghamshireccg.nhs.uk/16447-2/

https://www.buckshealthcare.nhs.uk/coronavirus/public-information-covid_19.htm

https://www.buckinghamshire.gov.uk/coronavirus/community-hub/keeping-you-safe/

https://www.buckinghamshire.gov.uk/coronavirus/community-hub/keeping-you-safe/

On the 4 March, the CCGs Facebook account started to see the black imagery for Stay home, protect the NHS and save lives.

From 17 March, the messages changed to

From 23 March, the message then changed at the start of lock down.

6.6.1 Integrated working with Buckinghamshire Councils Adult Social Care Cell

The Council’s Adult Social Care Cell has worked closely with the CCG as part of its response to the pandemic.

Activities include the establishment and promotion of Olympic Lodge a 240 bed facility for vulnerable adults, promotion of joint webinars to care home providers, and online information – in particular around infection control, PPE and testing. This included ensuring joint branding on communications.

In the report for Quarter 1, 20/21 we will aim to provide a significant evaluation of the initial communications carried out from March through to June for the pandemic.

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https://www.buckinghamshire.gov.uk/news/innovative-social-care-centre-opens-its-doors/

https://www.buckinghamshire.gov.uk/news/innovative-social-care-centre-opens-its-doors/

https://www.buckinghamshire.gov.uk/coronavirus/social-care-providers-hub/workforce/covid-19-adult-social-care-training/

https://www.buckinghamshire.gov.uk/coronavirus/social-care-providers-hub/workforce/covid-19-adult-social-care-training/

7.0 Patient Stories

Joan, 89, tells of her experience of the acute medical ward featuring use of the Red Bag scheme: https://youtu.be/YSqEjenEUYM (February 2020)

Therapy & Nursing Led Unit: https://youtu.be/Ao87b9qb5ro (filmed November 2019)

A Therapy & Nursing Led Unit (TNLU) was developed up December 2018 on Ward 8 at Stoke Mandeville in line with National Guidance. The aim was to improve rehabilitation and outcomes for patients including safe and effective discharge and to provide a focus for rehabilitative care in a non-medical environment.

Patients requiring Rehabilitation were scattered over a number of different ward areas with other acutely unwell patient which led to a lack of focus on the right care and environment. Therapists often have to find these patients across a number of different ward areas including escalation areas.

The TNLU gave the opportunity develop a focus on rehabilitation and build Nursing and Therapy joint work to maximise the patients input, experience and outcomes as well as to support a safe & timely discharge.

Continuity of Carer: https://youtu.be/Diy3mVj9WfY (filmed July 2019)

Continuity of carer begun to be implemented in the Trust in specific low risk pregnancies from autumn 2019. This video seeks to convey the importance of this innovation from a mother’s perspective and also from a midwife’s perspective.

Tissue viability: https://youtu.be/DF9Mvbubvzw (filmed May 2019)

How specialist care in a wound clinic run by tissue viability nurses helped heal a patient’s leg whose wound had not improved over many months.

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MEETING: Governing Body AGENDA ITEM: 17 DATE: 11 June 2020 TITLE: Proposed changes to the CCG Constitution (from 1 June 2020) AUTHOR: Russell Carpenter, Head of Governance/Board Secretary LEAD DIRECTOR: Robert Majilton, Deputy Accountable Officer LINK TO RISKS: Governing Body

Assurance Framework No direct link to risks


No direct link to risks

Reason for presenting this paper: For Action For Approval For Decision For Assurance For Information For Ratification Summary of Purpose and Scope of Report: The Constitution is the legal document sets out the way in which the CCG will fulfil its statutory responsibilities as set out in the 2012 Act. The Governing Body is informed of: asked to:

1. Editorial changes version 1.29 2. At present the CCG Constitution is not wholly aligned to the national template, but that

this is not a mandated requirement. The Constitution is otherwise deemed to be legally compliant resulting from NHS England approval. Through collaborative working with Oxfordshire and Berkshire West CCGs there is expected to be further Constitution review and alignment over coming months.

Editorial changes version 1.29

• Foreword: number of member practices changed from 51 to 50. • Appendix I: Audit Committee) terms of reference are unchanged after annual review. • Appendix J Remuneration Committee terms of reference updated after annual review.

Both sets of terms of reference shall remain in place until such as time there is a separate decision on collaboration with other CCGs and migration to meeting “in common” arrangements across BOB (Buckinghamshire, Oxfordshire and Berkshire West) which may occur during 2020/21. This has already begun for Remuneration Committee as of April 2020. Authority to make a decision – process and/or commissioning (if relevant) Consideration and approval of applications to NHS England on any matter concerning changes to the CCG's Constitution is reserved to the Membership. Source: CCG Constitution – Appendix F1 – Scheme of Reservation and Delegation. However all changes to be approved relate to matters:

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• Already delegated to the CCG Governing Body (e.g. its sub-committee arrangements) • Roles which no longer exist and which do not affect the composition and quorum of the

Governing Body and therefore have no material impact. • All of which fall within a definition of “immaterial” changes approved by the Governing

Body at its meeting in public on 13/06/2019. It is on this basis therefore no membership approval is deemed necessary or sought. This is different to member approved version 1.20 (April 2019) where there were explicit changes to the composition and quorum of the Governing Body which had a material impact. Conflicts of Interest: (please tick accordingly) No conflict identified Conflict noted, conflicted party can participate in discussion and decision (see below) Conflict noted, conflicted party can participate in discussion but not decision (see below) Conflict noted, conflicted party can remain but not participate in discussion (see below) Conflicted party is excluded from discussion (see below) Governance assurance (see below) Any voting of member of Governing Body would be directly conflicted where changes to the Constitution which affects their role. Whereas there some changes to roles specified, these relate to roles (e.g. Locality Clinical Directors) which no longer exist and therefore individuals cannot be conflicted in relation to approval of changes for this. Strategic aims supported by this paper (please tick) Better Health in Bucks – to commission high quality services that are safe, accessible to all and achieve good patient outcomes for all






Equality Quality Privacy Financial Risks All proposed changes are within existing delegated

authority; therefore no request to CCG membership to adopt is required. However, there is some risk in relation to delegated authority to Remuneration Committee for pay decisions. However this risk is felt to be low.

Statutory/Legal The CCG is required to have a legally compliant Constitution

Prior consideration Audit Committee (01/04/2020) and Remuneration

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Committees /Forums/Groups

Committee have reviewed and agreed terms of reference. Ratified Governing Body 11/06/2020 and 21/05/2020 respectively.


Through Member GPs with voting rights on Governing Body

Supporting Papers: None

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