Survey
* Your assessment is very important for improving the workof artificial intelligence, which forms the content of this project
* Your assessment is very important for improving the workof artificial intelligence, which forms the content of this project
Serious Incident Requiring Investigation Policy Serious Incident Requiring Investigation Policy Version: 2.0.0 Approved by: Clinical Risk and Quality Assurance Committee Date Approved: 24th October 2014 Ratified by: Policy Review Group Date ratified: 13 November 2014 Name of originator/author: Nina Barbosa (Risk Manager) Name of responsible committee/individual: Clinical Risk and Quality Assurance Committee Date issued: November 2014 Review date: October 2017 Target audience: All Staff Version 1.2.1 1/42 Serious Incident Requiring Investigation Policy Contents Section Page 1 Introduction 3 2 Purpose 3 3 Duties 3 3.1 Duties within the Organisation 3 3.2 Identification of Stakeholders 6 4 Method of development 6 4.1 Consultation and communication with stakeholders 6 5 Content 6 5.1 Definitions 6 5.2 Serious Incident Requiring Investigation process 8 5.2.1 Notification and basic fact finding 8 5.2.2 Initial enquiries 10 5.2.3 Agreeing the level and framework of the investigation 11 5.2.4 The main investigation 14 5.2.5 Closing the incident 16 6 Support for staff involved in SIRIs 17 7 Education/Training 17 8 Monitoring Compliance With and the Effectiveness of Procedural Documents 17 8.1 Process for Monitoring Compliance and Effectiveness 17 8.2 Standards/Key Performance Indicators 18 9 Links with other Trust Policies 18 10 References 18 Appendix 1 Quick Reference Flow Chart 19 Appendix 2 SIRI grading algorithm 20 Appendix 3 Specific Examples of Application 21 Appendix 4 Core List of Never Events 29 Appendix 5 Basic Principals of RCA 35 Appendix 6 Suggested Tools for RCA 37 Appendix 7 Incident Decision Tree 40 Appendices Version 1.2.1 2/42 Serious Incident Requiring Investigation Policy 1 Introduction Investigations are an important part of learning from our experiences and sharing lessons so that we improve where we could be better and continue what we do well. This in turn helps to improve the quality of care and service delivery we provide at BCH and helps to promote and develop its ‘open, just and fair’ environment. The NHS has made several commitments over the years to improving the safety and quality of care that we provide (Department of Health, 2000, 2008 & 2010). The Trust recognises that systematic review of incidents can be a significant driver for improvement. Staff are encouraged to use the principles of Root Cause Analysis (RCA) for all investigations and so that they achieve a systematic approach which ensures all aspects are reviewed and none are overlooked. This will enable more effective planning of any necessary change. 2 Purpose This Policy sets out the process and responsibilities for managing and investigating Serious Incidents Requiring Investigation (SIRIs), formerly referred to as Serious Untoward Incidents (SUIs). It defines the notifications to our commissioners and other external agencies, and timescales for completion so that our management of SIRIs meets local and national standards. It sets out the responsibilities of individual staff in being open with our patients and their families when a Serious Incident (SI) has occurred. 3 Duties 3.1 Duties within the Organisation 3.1.1 Trust board ● To review information provided on SIRIs. ● To ensure that lessons are learnt following SIRIs. ● If further assurance of learning from SIRIs is required, to make further recommendations. 3.1.2 Trust committees The following committees have involvement in the management of SIRIs: ● ● ● Clinical Risk and Quality Assurance Committee; Non-Clinical Risk Coordinating Committee; Regulatory Compliance Committee (for confidentiality breaches). They are required to review the outcome of SIRI investigations in their respective fields and to ensure that lessons learnt from those investigations are monitored and completed in a timely manner. Version 1.2.1 3/42 Serious Incident Requiring Investigation Policy 3.1.3 Chief Executive The Chief Executive is ultimately responsible for ensuring that robust investigations are carried out as required, and that these are completed in a fair and timely manner. 3.1.4 Chief Medical Officer To assess the information available and declare a clinical incident as a SIRI for notification to commissioners. Participate within the review of SIRIs and apply the principles of RCA. To promote an open, just and timely reporting culture as a key mechanism for enhancing safety. To provide updates to Trust Board on clinical SIRIs. 3.1.5 3.1.6 Chief Nursing Officer To assess the information available and confirm as SIRI in the case of significant safeguarding incidents, infection control incidents such as outbreaks and confidentiality breaches. Participate within the review of SIRIs and apply the principles of RCA. To promote an open, just and timely reporting culture as a key mechanism for enhancing safety. To provide updates to Trust Board on safeguarding SIRIs, infection control SIRIs and confidentiality breach SIRIs. Chief Operating Officer 3.1.7 Associate Chief Medical Officers for Safety On behalf of the Chief Medical Officer, to assess the information available and declare a clinical incident as a SIRI for notification to commissioners. Participate within the review of SIRIs and apply the principles of RCA. To promote an open, just and timely reporting culture as a key mechanism for enhancing patient safety. 3.1.8 Associate Chief Nursing Officer 3.1.9 Participate within the review of SIRIs and apply the principles of RCA. To promote an open, just and timely reporting culture as a key mechanism for enhancing patient safety Associate Director of Governance Version 1.2.1 To assess the information available and declare a non-clinical incident as a SIRI for notification to commissioners. Participate within the review of SIRIs and apply the principles of RCA. To promote an open, just and timely reporting culture as a key mechanism for enhancing safety. To provide updates to Trust Board on non-clinical SIRIs. Participate within the review of SIRIs and apply the principles of RCA. To promote an open, just and timely reporting culture as a key mechanism for enhancing patient safety. 4/42 Serious Incident Requiring Investigation Policy 3.1.10 The Executive On-call (Out of hours) Out of hours the on-call Executive is the person who must be immediately notified of the possible SI. They are also responsible for notifying the Risk Manager of the SI as soon as possible on the next working day. 3.1.11 Directorate Management Teams (including the Clinical Director, Head of Nursing and Associate Service Director) To promote an open, just and timely reporting culture as a key mechanism for enhancing patient safety. To ensure that lessons arising from SIRIs are cascaded within their Directorates 3.1.12 Risk Management Specialists The following members of staff are the designated Trust risk management specialists who will lead on SIRIs: The Head of Risk The Risk Manager – clinical risk The Health, Safety and Security Manager – health, safety and security risks The Information Governance Manager – information governance risks, including confidentiality breaches. Their key responsibilities are: To facilitate and lead on incident investigations within their areas of responsibility, using appropriate techniques. To report updates on investigations and learning outcomes to the appropriate Trust Board subcommittee. To liaise with external partners and other organisations in the reporting and investigation of serious incidents. 3.1.13 Lead Doctor & Lead Nurse for Child Protection They are responsible for leading or appropriately delegating investigations into safeguarding SIRIs. 3.1.14 Lead Doctor & Infection Control and Prevention Team They are responsible for leading or appropriately delegating investigations into Infection Control SIRIs, this includes outbreaks. 3.1.15 Managers Version 1.2.1 To ensure that any incident which meets the criteria for a SIRI is referred to the Risk Manager immediately upon becoming aware of it within normal office hours. Outside normal office hours the manager is responsible for contacting the On-call Executive. To support staff when reporting incidents and as a consequence of an incident having been reported, and enable them to participate in investigations, including the nomination of investigating officers with requisite skills and ensuring that their staff have time to prepare reports required for the investigation. 5/42 Serious Incident Requiring Investigation Policy To complete and follow up action plans as highlighted. To provide information and updates on action plan implementation in response to SIRI reviews. Provide staff with feedback on the outcomes of incident investigations and changes made as a result. 3.1.16 All staff To familiarise themselves with the definition of a serious incident and escalate any incident which meets that criteria to their manager or the Risk Manager immediately upon becoming aware of it. To participate as required in serious incident investigations, including the timely production of witness statements and reports required to inform the investigation. To ensure that the principles of being open with families and patients are met. To provide support for colleagues when involved in a SIRI 3.2 Identification of Stakeholders All staff are potential stakeholders in this policy as anyone may witness or be involved in a SIRI. Key staff who have specific responsibility for risk, either due to membership in a key risk committee or due to holding a senior managerial perspective were identified for consultation on this policy. 4.0 Method for development This policy was developed with reference to best practice guidance and our host commissioner’s policy. 4.1 Consultation and Communication with Stakeholders The Clinical Risk and Quality Assurance Committee were consulted with during the developments to this version of the policy. The Lead Doctor and Nurse for Safeguarding, Infection Control and Prevention Team and Lead Nurse for Tissue Viability were also consulted with during the development of this version of the policy. 5.0 Content 5.1 Definitions 5.1.1 What is a Serious Incident Requiring Investigation? 5.1.1.1 Harm The following definition of Serious Incident Requiring Investigation (SIRI), is taken from the West Midlands Strategic Health Authority SIRI policy 2010 and Heart of Birmingham’s SIRI policy (2010), and is adopted at the Trust: A Serious Incident Requiring Investigation is defined as an incident that occurred in relation to NHS funded services and care resulting in: Version 1.2.1 6/42 Serious Incident Requiring Investigation Policy ● ● ● ● ● the unexpected or potentially avoidable death of one or more patients, staff, visitors or members of the public, or permanent harm to one or more patients, staff, visitors or members of the public or where the outcome requires life-saving intervention or major surgical/medical intervention or will shorten life expectancy (this includes incidents graded under the NPSA definition of severe harm) a scenario that prevents or threatens to prevent a provider organisation’s ability to continue to deliver health care services, for example, actual or potential loss or damage to property, reputation or the environment a person suffering from abuse (e.g. neglect, of safeguarding concerns of a significant nature) adverse media coverage or public concern for the organisation or the wider NHS 5.1.1.2 Significant Trust-wide systems failure In addition to situations which result in significant harm to an individual or the organisation, BCH consider events which highlight potentially significant trustwide systems failures which have a reasonable potential to result in significant harm a SIRI. These events can be classed as a SIRI whether significant actual harm has been caused or not. Please see appendix 2 for details of how SIRIs are classified. 5.1.1.3 Significant Confidentiality Breach In addition the Department of Health (2013) has identified that a serious confidentiality breach is, any incident involving actual or potential failure to meet the requirements of the Data Protection Act 19981 • This includes unlawful disclosure or misuse of confidential data, recording or sharing of inaccurate data, information security breaches and inappropriate invasion of people’s privacy, and/or the Common Law of Confidentiality. • Such personal data breaches which could lead to identity fraud or have other significant impact on individuals. • This applies irrespective of the media involved and includes both electronic media and paper records. The Trust will also investigate any incident declared as an SIRI, by the Chief Medical Officer or Chief Operations Officer in line with this policy. If staff are in doubt about whether or not such an incident is an SIRI, they should contact the Risk Manager or Health, Safety and Security Manager for advice. 5.1.2 What is an Incident? An event or circumstance which represents a divergence from expected practice, a defined protocol, or accepted standard. These events could result in unnecessary damage, loss or harm to a patient, staff, visitors or members of the public, or may not actually result in harm, either due to staff action or the circumstances of the event. Please note that an event can be classed as an incident and be reported on the BCH incident reporting system (IR1 system) whether this represents a concern Version 1.2.1 7/42 Serious Incident Requiring Investigation Policy with BCH processes or care or not. If the event either affects or has the potential to affect a BCH patient or member of staff, then this should be reported on our system. Patient Safety Incidents (PSIs) Also called clinical incidents, these were defined by the National Patient Safety Agency (NPSA) as any unintended or unexpected incident which could have, or did, lead to harm to one or more patients receiving NHS-funded healthcare. Personal Accidents Unintended or unexpected incidents which could have, or did, lead to harm to staff or visitors on BCH premises. 5.2 Serious Incidents Requiring Investigation process This process is time bound as defined by the NPSA and our commissioners. The figure below provides an outline of the stages involved. Stage 1 Notifications and basic fact finding Day 1 Stage 2 Initial Enquiries Day 1-3 Stage 3 Agreeing the Investigation Day 3 Stage 4 Investigating Day 3-45 Stage 5 Closing the Incident Up to six months after the incident 5.2.1 Stage 1: Notifications and basic fact finding 5.2.1.1 When an SIRI is suspected When the member(s) of staff involved in or witnessing an incident suspects that a SIRI has occurred they must immediately notify their line manager and the Risk Manager. Likewise when an individual investigating an incident, not previously recognised by the reporter as a SIRI, suspects that the incident does in fact reach the threshold for a SIRI, they should inform their manager and the Risk Manager. If an individual suspects that an incident meeting the threshold for a SIRI has not been reported they should contact the Risk Manager immediately. When the incident occurs out of hours, it must be immediately reported to the Clinical Co-ordinator / Executive Director on call, who must inform the Risk Manager on the next working day. Version 1.2.1 8/42 Serious Incident Requiring Investigation Policy If Staff employed by other healthcare organisations witness a SIRI which occurs at BCH, or staff employed by BCH witness a SIRI at other healthcare organisations, they should report these incidents to the Risk Manager responsible for the organisation where the incident occurred for action, and to their own employer’s Risk Manager for information. Although notification of the Risk Manager should be done urgently following the discovery of the potential SIRI, and may best be achieved by telephone or face-to-face conversation, in all cases an IR1 form must be completed. All equipment and documentation related to the incident must be secured and consideration should also be given to quarantining the environment. 5.2.1.2 Notification of suspected incidents to the patient, their parents or carers. If a patient has suffered harm, what has happened must be explained fully and accurately to the patient and/or carers, including information on the likely long and short-term effects. This should be done as soon as the staff are aware an incident has occurred and in line with the Trust’s Being Open policy. The key principals, which must be adhered to include: (a) Ensure that the initial communication is prompt and that where significant harm has been caused there is agreement across the team about what the patient and their family will be advised. (b)Provide a sincere apology for the harm caused. This is not an admission of liability; it is a necessary expression of regret. (b) Avoid supposition and stick only to the known facts, as the investigation can sometimes highlight unexpected factors. (c) Advise the patient and the family how the incident will be investigated and when they can expect to receive feedback on the investigation. (d) Provide the patients, families and carers with contact details for further support, both in terms of the consequences of the harm caused and in terms of an update for the investigation. 5.2.1.3 Establishment of basic facts On notification of the incident, the Risk Manager or Health, Safety and Security Manager will carry out basic fact finding into the incident, obtaining information to provide to the relevant Chief Officer. Certain incidents will always be classed as SIRIs, these are detailed in appendix 3 and include MRSA bacteraemia, incidents subject to a Serious Case Review under child protection procedures, and incidents classed as Never Events in line with the current list of Never Events. The 2010/11 Never Event Framework is included at appendix 3. 5.2.1.4 Referral of suspected incidents to the relevant Chief Officer Upon notification of a potential SIRI the Risk Manager or Health, Safety and Security Manager will discuss the available details with either an Associate Chief Medical Officer (ACMO), Chief Nursing Officer (CNO) or Chief Version 1.2.1 9/42 Serious Incident Requiring Investigation Policy Operating Officer (COO). The ACMO, CNO or COO will declare the incident to be a SIRI or not based on these facts. In the absence of an ACMO, CNO or the COO, a discussion will be held with another Executive Director. The decision to declare a SIRI should be made as quickly as possible. Guidance in the National Framework for Serious Incident Reporting and Learning Framework (SIRL) (2010) and the Birmingham South Central Clinical Commissioning Group (2014) Serious Incident Reporting and Management Policy policies stipulates that this decision should be made within 48 hours of notification of the possible SIRI. 5.2.1.5 Referral of suspected incidents to commissioners The Risk Manager will notify the appropriate commissioner using the format agreed with that commissioner. Initial notification will be made within 48 hours of the Risk Manager becoming aware of the incident. Preferably initial notification will be made through a telephone conversation. If the commissioner is not available then initial notification will be made via e-mail. The time constraints on initial notification mean that the incident is unlikely to have been fully scoped. As much information as possible will be given at this stage. 5.2.1.6 Referral of suspected incidents to StEIS On notification of a SIRI the Risk Manager or Health, Safety and Security Manager is responsible for recording the incident on the Strategic Executive Information System (StEIS). The system must be updated regularly at key stages of the investigation. 5.2.1.7 Referral of suspected incidents to the National Reporting and Learning System (NRLS) The incident will be entered onto the Trust’s incident management system and notified to the NRLS within 48 hours of notification of the incident. Organisations such as the Care Quality Commission (CQC) will be notified by the NRLS report. 5.2.1.8 Referral of suspected incidents to the Police, HSE and other bodies If an incident requires referral to another organisation such as the Police and Health and Safety Executive (HSE) this will be done in accordance with the Memorandum of Understanding (2006). Depending on the nature of the incident it may also be necessary to notify other agencies such as the Medicines and Healthcare products Regulatory Agency (MHRA) or the Health Protection Agency (HPA). For full details of when to notify other agencies and who to notify please see appendix 3. If required, this will be done by the Risk Manager, following discussion with the appropriate Chief Officer. Version 1.2.1 10/42 Serious Incident Requiring Investigation Policy 5.2.2 Stage 2: Initial Enquiries - Scoping the Incident Scoping the incident will begin as soon as this is notified to the Risk Manager or Health, Safety and Security Manager. This will be started during the notification phase and will be used to inform the Chief Officer’s decision on whether to declare a SIRI. This process may take up to two days. Through this process the people, processes and equipment involved in the incident shall be identified. Terms of reference shall begin to be developed for any subsequent investigation. Sources of evidence will be identified which could include witness statements, monitor data, health records, equipment maintenance logs, procedural documents and photographs. Part of the scoping of the incident will include outlining a communication plan with the patient, family, carers and staff. This will allow the teams involved in the investigation, to support those affected by events and keep them updated. The purpose of the scoping phase of the investigation is to draw up a framework for the investigation following review of the initial facts. This concludes with the agreement of the Terms of Reference (TOR) for the investigation with the investigation chair and the assembly of the multi-disciplinary team who will carry out the review. 5.2.3 Stage 3: Agreeing the level of Investigation and specific framework for the investigation The full details of the incident shall be discussed with the appropriate commissioner. This conversation will agree the: ● ● Level of incident Investigation (see Section 5.2.3.2). The timescale for completion of the investigation (excluding completion of action plans). Terms of reference and review team composition as internally agreed. ● 5.2.3.1 Communication with patient, their parents or carers The patient and their families must be told if a decision to de-escalate the incident from an SIRI is made, giving the reasons for this decision and any alternative investigative process that will be applied. This communication should be led by the person who initially informed the family that the incident might be classified as a SIRI, and if they are not available, then the discussion must be held by a senior member of the clinical team, or other suitable member of staff such as Family Liaison Officer. Where an incident is investigated as an SIRI, families must be informed of what that process involves and the timescale agreed with the commissioners. Where families are unhappy with the suggested timescale, their concerns must be explored and where possible an alternative timescale agreed. If a revised timescale is agreed with the family, this must be reported to the commissioners. Families must be presented with the terms of reference of an investigation and given the opportunity to suggest areas which they want the investigation Version 1.2.1 11/42 Serious Incident Requiring Investigation Policy to look at. This role would typically be undertaken by the investigating officer, assisted by the responsible doctor or senior ward nurse for in-patients. Where it is not convenient for families to be party to these discussions within the short timeframe presented the investigation must proceed on agreed timescale and terms of reference. However, it may be necessary to revisit certain outcomes following discussion with families. 5.2.3.2 Level of Investigation The National Patient Safety Agency (2010) identified 3 grades of serious incident as detailed in the table below: Table 1 Grade Definition SIRI? Timescale for completion of investigation 0 Where an incident has occurred but it is unclear whether it meets the definition of a Serious Incident Requiring Investigation. No 45 days 1 Where an incident has occurred which meets the definition of a Serious Untoward Investigation and is to be investigated through an NPSA Level 2 Investigation. Yes 45 days 2 Where an incident which meets the definition of a Serious Untoward Investigation is considered to be of the most severe type and this investigation may be carried out by the Trust, but may also be subject to an Independent Investigation. Yes 60 days In line with national guidance (NPSA, 2010), the Trust investigates all SIRIs using Root Cause Analysis (RCA) techniques. RCA techniques include a range of tools which are designed to identify systemic failures and uncover root causes of incidents. It is recommended that RCA techniques are used for all grades of incident including level 0 as defined in the table above. There are a number of levels of investigation determined by the NPSA. The table below (table 2) details a few key features of each of level of investigation, including recommended RCA tools for the investigation. Version 1.2.1 12/42 Serious Incident Requiring Investigation Policy Table 3 Level Investigative techniques applicable Led by Approved by 1 Investigation carried out using concise format which reviews incident causation in a rapid manner. Is often carried out by an individual or two person team. Suitable RCA tools include: Local lead with support of person(s) experienced and/or trained in RCA. Directorate Governance forum with presentation of executive summary at Trust committee with responsibility for risk. Led by person(s) experienced and/or trained in RCA, human error and effective solutions development. Overseen by executive appointed chair or facilitator. ● ● ● ● ● 2 3 Chronology of events Timelines Brainstorming Cause & effect Time person grid Conducted with a high level of detail, including all elements of a thorough and credible investigation. Includes patient/relative/carer involvement and should include an offer to patient/relative/carer of links to independent representation or advocacy services. May require management of the media via the organisation’s communications department. Includes robust recommendations for shared learning, locally and/or nationally as appropriate. Suitable tools include those listed under level 1 and spider diagrams, and the Ishikawa (Fishbone) diagram. As with level 2, but must be commissioned and co-ordinated by the Commissioning PCT or SHA and independent to the organisations involved in the incident. Generally used for incidents, claims, complaints and concerns which would attract a high level of media or public interest. Should be used when Article 2 of the Human Rights Convention has been breached. Version 1.2.1 Results in full report with an executive summary and appendices. Conducted by a multidisciplinary team, or involves experts/expert opinion/independent Approved at advice or specialist Trust investigator(s). committee with responsibility Conducted by staff for risk. not involved in the incident, locality or directorate in which it occurred. Has commissioner representation. Investigation is Trust commissioned by the committee with PCT or SHA. responsibility for risk and the SHA Patient Safety Team 13/42 Serious Incident Requiring Investigation Policy The NPSA guidance also recommends that all actions that are proposed following completion of the SIRI investigation are closed within six months of the incident. The Trust acknowledges that in some rare occasions it will be necessary for the action plan to include some long-term actions, which may not be completed within six months. It is important that under such circumstances important milestones are recorded on the action plan. In all instances completion of actions must be monitored by the appropriate risk committee. Risks to the timely completion of actions must be risk assessed and recorded on an appropriate Risk Register. 5.2.4 Stage 4: The Main Investigation The main investigation will be carried out as agreed between the Chair of the investigation and the Investigating Officer. The Investigating Officer will be the member of staff with RCA expertise who has been assigned to facilitate the investigation. 5.2.4.1 Governance function Throughout the investigation the Investigating Officer must: ● ● ● ● ● ● ● Identify and collect evidence relevant to the circumstances of the incident and with reference to the initial terms of the investigation. In liaison with the Chair, review evidence collected, comparing it to the terms of reference of the investigation and identifying sources of new evidence. Identify additional terms of reference based on evidence collected and additional issues raised by it. Liaise with the person nominated to lead patient/carer/staff communication. Ensure that the multi-disciplinary review team receive the required information for the review meeting and subsequently meet to discuss the causation of the incident and develop an action plan for mitigating recurrence. Following analysis of the evidence by the review group the Investigating Officer must prepare the report of the analysis. This draft report must be shared for comment with the members of the review group and those members of staff directly involved with the incident. The Investigation Officer must review these comments and make any necessary changes to the report prior to presentation to the appropriate committee for ratification. Ensure any urgent risks are flagged to the appropriate people for action or information. 5.2.4.2 Composition of the Review Group The review group must include: ● Version 1.2.1 A senior clinical or managerial member of staff that has been trained by the Governance team to carry out this duty, and who is part of the RCA chair rota (Chair of the RCA) 14/42 Serious Incident Requiring Investigation Policy ● ● A facilitator competent in application of the Root Cause Analysis techniques (usually the Investigating Officer). Expert representatives from the disciplines involved in the incident. The review group must invite: ● ● ● A Non-Executive Director. A representative of the relevant commissioning team. A member of the education team. The review group must strongly consider inviting: ● Staff members directly involved in the incident. Traditional guidance has been that RCA investigations should not involve staff members directly involved in SIRI since this may affect the objectivity of the investigation. However, there is now significant evidence suggesting the benefits of those directly involved in the occurrence of the incident participating on the incident investigation. These benefits include: o The ability during the RCA meeting to clarify specific facts relating to the incident which may not have been included in witness statements o Contribution to the development of counter measures, to prevent recurrence of such an incident (those directly involved in the incident almost always have spent considerable time considering how the incident could have been prevented) o Reduction in the risk of ‘Second Victim’ phenomenon (staff members involved in such incidents are often traumatised by the event and may exhibit significant signs and symptoms such as insomnia, depression, anxiety and other stress-related symptoms. Allowing them to be a ‘part of the solution’ has been shown to reduce the risk of this occurring) There may be situations where even given these benefits, the attendance at the RCA meeting of those directly involved in the incident is not conducive to an effective investigation. The decision not to invite staff members directly involved in the incident should be made jointly by the investigation chair and the Investigation Officer, but there should be a good reason for not doing so. When a staff member involved in an incident a to be agrees to be a part of the RCA meeting, it is the responsibility of their line manager to ensure that they are provided with the appropriate support. 5.2.4.3 Key activities of the Review Group The review group meet at the end of the evidence collection process to analyse the evidence using techniques appropriate to the level of the investigation. Their key duties are to: ● ● Version 1.2.1 Represent their discipline during the course of the investigation. When presented with the investigation plan, highlight potential key evidence that has not already been identified. 15/42 Serious Incident Requiring Investigation Policy ● ● ● ● ● ● Meet to analyse the evidence within timeframes specified by the investigation. Ensure appropriate analytical techniques are applied to consideration of the evidence Identify system changes based on the analysis. Identify the contribution of Human Factors to the incident occurrence. Develop a time bound action plan for implementation of changes and give and agree responsibility for completion to named individuals. Respond to any draft report and propose changes for inclusion in any final report within timeframes specified by the investigation. 5.2.4.4 Ratifying Investigation Reports Investigation reports must be presented to the appropriate committee within timeframes specified by the investigation. It is the role of the committee to take assurance that the investigation has been completed using techniques in line with the level of the investigation. If the committee is not able to take such assurance, then direction for further action must be provided. 5.2.4.5 Monitoring Action Plans The committee must also agree the action plan presented within the final report. If the action plan does not provide adequate assurance that measures will be taken to mitigate identified risks, then the committee must direct further course of action. Action plans shall be included in Directorate Learning from Experience Reports and included in the analysis provided in the monthly Action Plan report. Both the Directorate Management Teams and relevant risk committee are responsible for ensuring that the action plans are monitored to completion in a timely manner. The Investigating Officer or relevant Service Line Manager must submit to the risk register any risks and actions highlighted by the investigation that cannot be immediately mitigated. 5.2.4.6 Communication with patient, their parents or carers The patient and their families must be kept informed of the progress of the investigation. This will include information on: ● ● ● ● The process of investigation and analysis being undertaken and to be undertaken by the Investigating Officer and the review group. The progress of the investigation Significant, relevant facts identified by the evidence collection and review process. Changes identified by the review group as a result of the analysis. The way in which information is shared should be agreed with the family at the outset of the investigation and should include: Version 1.2.1 16/42 Serious Incident Requiring Investigation Policy ● ● ● Format of any meeting or alternative format for feedback. Frequency of any meeting. Preferred attendance at any meeting. Additionally, once the report is ratified, the Chair of the Group, supported by a clinician caring for the child, should meet with the family and discuss the findings and changes to be made with them, in line with the Being Open Policy. 5.2.4.7 Communication with staff involved in the incident and sharing of lessons across the Trust It should be usual practice for all staff involved in the incident to be sent a draft copy of the report to give them the opportunity to comment on matters of fact (see 5.2.4.1 above). Once the report is ratified they must receive feedback based on the final report, its findings and recommendations. The format of the feedback will be dependent on the details of the incident and the type of staff involved, however, as a minimum, all staff involved in the incident will be provided with access to the final investigation report, and will be given an opportunity to discuss this further. 5.2.5 Closing the incident investigation There are three stages of in the closure of an incident investigation. The first is completion of the investigation, which is marked by the investigating team being satisfied that they have comprehensively investigated the incident and that the investigation report is an accurate reflection of their findings. The Trust will monitor compliance with the investigation completion target by this measure. The second is ratification, which is when the Trust’s appropriate risk committee has accepted the investigation report and its accompanying action plan. Once ratification has occurred the investigation outcome will be shared with Trust Board and other relevant organisations. The final stage is closure, which is when the action plan is complete. Current guidance from NPSA recommends that SIRI action plans should be completed no later than 6 months after the incident occurred. In situations where this is not believed to be possible the closure date must be agreed with the commissioners. The SIRI can be downgraded at any stage, if information comes to light which indicates that the incident was of a lower grade. If this is believed to be the case, then the Investigating Officer will discuss and agree the downgrading with the relevant commissioners. In many situations an incident that is downgraded from a SIRI will still require investigation at Directorate Level, using RCA. The Directorate Management Team will then be expected to appoint an Investigating Officer and ensure that RCA techniques are applied. Although communication with our commissioners may have ceased at this point, the need to maintain communication with the patient, their parents or carers remains, as does the need to feedback to staff involved. Version 1.2.1 17/42 Serious Incident Requiring Investigation Policy 6.0 Support for staff involved in SIRIs BCH recognises that involvement in a SIRI can result in significant distress for staff whether they had a pivotal role in the event on not. The occurrence of ‘Second Victim’ phenomenon in staff who were directly involved in the incident is now well recognised. A second victim is defined as: ‘A healthcare provider involved in an unanticipated adverse patient event, medical error and/or a patient-related injury who becomes traumatised by the event. Frequently, second victims feel personally responsible for the unexpected patient outcomes and feel as though they have failed their patient, and feel doubts about their skill and knowledge base.’ The second victim may experience symptoms of insomnia, nightmares, reliving the incident repeatedly, lack of self-confidence, anxiety (usually related to a fear of making a further error) and depression. Such symptoms are not dissimilate to those seen in posttraumatic stress disorder. Such symptoms often affect the individual’s ability to continue to work effectively. BCH is committed to providing support for all staff involved in SIRIs. The support required by individual members of staff may vary according to their level of involvement, the severity of the incident and the outcome, and their own perception of their level of contribution to the occurrence of the incident. Once a potential SIRI has occurred, local managers should hold a debriefing session with their teams as soon after the event as is practical. Consideration should be given to reallocating duties for the remainder of a shift if a member of staff has been involved in a SIRI. A period of supported practice may also be of benefit following a SIRI. It is however, important that any measures intended to support staff are handled in such a way that it is clear that the action is non-punitive. Staff should be provided with and encouraged to take up support offered by the Trust, this can include support by the chaplaincy and occupational health. As noted above (see 5.2.4.2), it should be standard practice to invite those significantly involved in a SIRI to be a part of the investigation process and the RCA meeting. Support should be provided during this process, whether or not these individuals attend the RCA meeting or not. As a minimum staff will be provided with information on the RCA process when asked to provide information to support the investigation and will be provided with feedback on the investigation findings. It is imperative that individuals involved in a SIRI be kept up to date with the progress of the investigation, whether or not they are part of the investigation process. 7.0 Education and Training All types of risk training are detailed in the Governance Training Needs Analysis. In relation to RCA and serious incident training, the previous training courses have been replaced with a one day ‘Advanced Investigations Training’. This course is aimed at all staff who are involved in the investigation of incidents, whether at the local level or through a commissioned RCA. The training includes investigations skills as well as background on how to support patients, families and members of staff who have been involved in an incident. Version 1.2.1 18/42 Serious Incident Requiring Investigation Policy Staff who have experience in investigating incidents through repeated exposure to the process and techniques of RCA may be identified as exempt from formal training through demonstration of their existing competence. GOVERNANCE TRAINING NEEDS ANALYSIS Foundation Governance Training Topic areas Incident reporting Advanced Governance Training Complaints Staff Incident management and investigation Claims and Inquest SIRI investigation Risk Management Statement writing Security Management Complaints Investigation Health and Safety Risk Register Management Policies Processes Responsibilities Risk Awareness All Staff Ward Managers Department Managers Specialty Managers Service Managers Directorate Managers DLR Investigators SIRI chairs Refresher Every 2 years frequency Delivery Need determined on individual basis through PDR Class-room learning sessions Blended delivery of class-room Moodle learning sessions supported by online resources. 8.0 Monitoring Compliance With and the Effectiveness of the policy 8.1 Process for Monitoring Compliance and Effectiveness Monitoring adherence with the SIRI process as defined in the policy will be carried out as follows: 8.1.1 Committee monitoring The Clinical Risk and Quality Assurance Committee will receive monthly reports, which provide an update on all ongoing SIRI investigations and all open action plans. When required the Regulatory Compliance Committee and Non-Clinical Risk Coordinating Committees will receive updates on relevant SIRIs and action plans. 8.1.2 Audit An annual audit of adherence to this policy will be presented to CRAQ and will include a consideration of: ● Timeliness of notifications Version 1.2.1 19/42 Serious Incident Requiring Investigation Policy ● Appropriateness of strategy agreed between the chair person and the facilitator, including whether the investigation was appropriate for the grade of incident. ● Timeliness of being open, including whether the family were given an opportunity to input into the investigation and whether they were provided with feedback on the outcome of the investigation in a timely manner. 8.2 Standards/Key Performance Indicators Monthly trust-wide performance indicators are developed and shall be included as part of performance review mechanisms: ● the timeliness of internal escalation of SIRIs and escalation to the commissioners. ● the completion of SIRIs within timeframes. In addition the proportion of action plans closed within allocated timescales are monitored on a monthly basis by the Clinical Risk and Quality Assurance Committee 9.0 Links with other Trust Policies and procedural documents ● ● ● ● ● ● ● ● ● ● ● ● Safety Strategy Incident Reporting policy Being Open policy Learning from Experience policy Health and Safety Policy Counter-Fraud Policy & Guidance Policy for the Management and Processing of Serious Case Reviews Procedure for responding to episodes of infection subject to mandatory Department of Health Surveillance. Policy for the Control of Methicillin-Resistant Staphylococcus Aureus (MRSA) Policy for the Control of Outbreaks of Infection in the Hospital (including major outbreak plan) Investigations Policy (HR) Governance Training Needs Analysis 10.0 References ● ● Birmingham South and Central CCG (2014) Policy on Serious Incidents Department of Health (2013) The Never Events Policy Framework – An update to the Never Events Policy ● National Patient Safety Agency (2010), National SIRL Framework ● Information Commissioner (2013) Checklist for Reporting, Managing and Investigating Information Governance Serious Untoward Incidents. ● Department of Health (2006), Memorandum of Understanding Version 1.2.1 20/42 Serious Incident Requiring Investigation Policy Appendix 1 Quick reference guidance to the SIRI process Incident Occurs or is identified Day of Process If required, the area is made safe/ remedial action is taken Evidence is Safeguarded Staff member notifies line manager and Risk Manager Day 1 Stage 1 Basic fact finding and briefing to appropriate Chief Officer. Decision regarding level of investigation made (SIRI/ DLR). Chair approached and investigation plan agreed. SIRI: No Day 1 – 3 Stages 2 and 3 Directorate Management Team, staff involved, patient and family/carers, commissioners, and Strategic Executive Information System all Notified along with other relevant agencies SIRI: Yes Chief Officer advises on next course of action e.g. DLR Information gathering and gap analysis Days 3 – 45 Stage 4 Multidisciplinary Team Root Cause Analysis Report produced and action plan confirmed Up to 6 Months Stage 5 Version 1.2.1 Share with all stakeholders Committee Review Monitor action plan 21/42 Serious Incident Requiring Investigation Policy Appendix 2 SIRI grading algorithm Was there an impact above moderate? Yes No Was an impact above moderate avoided by chance or exceptional action? No Does the incident appear to be preventable? Yes Is there a reasonable chance of repetition? Yes No No Consider discussion at an M&M meeting DLR Yes Yes Is the incident specific to one specialty or department? No SIRI Version 1.2.1 22/42 Serious Incident Requiring Investigation Policy Appendix 3 Specific examples of application Example of Application Specific Stage 1 Notifications to consider Blood transfusion. MRHA • Any serious adverse reaction following administration. European Blood Safety Directives/Re gulations • Any other serious event related to the storage, prescription, collection or administration. Safeguarding. • Any serious harm which required initiation of child protection procedures, including Serious Case Reviews. Local Safeguarding Board Stage2 Stage 4 Stage 5 In line with the main policy Fact finding carried out by the Lead Social Services Doctor or Lead Nurse for Child Protection Local Authority Initial enquiries carried out by the Lead Doctor and lead Nurse for Child Protection in conjunction with Governance CEMACH Version 1.2.1 Stage 3 23/42 Automatic SIRI As with Stage 2 The report should be The Chief reported to Nursing Officer the has executive Safeguarding responsibility for Committee for child protection, initial approval therefore must before being be urgently presented to advised of a the Clinical safeguarding Risk and concern. Quality Serious Incident Requiring Investigation Policy Example of Application Specific Stage 1 Notifications to consider Stage2 Stage 3 Stage 4 Stage 5 Assurance Committee. Emergency Plan Evoked / Major Incident. Police Automatic SIRI • Including terrorism, biological, chemical or nuclear incidents. NHS Security Management Service In line with the main policy. Local Transport Local Ambulance Armed Forces Outbreaks of communicable diseases. HPA • Any episode of two people having HSE developed and infection following contact, or use of the same space or equipment, the episode must be treated as an outbreak until confirmed otherwise. Version 1.2.1 Fact finding As with Stage 1 carried out by a Consultant Microbiologis t, or the Infection Prevention and Control Team 24/42 Automatic SIRI The CNO is the executive lead for infection prevention and control, therefore must be urgently advised of a possible As with Stage 1 The report should be approved at the Infection Prevention and Control Committee before presentation to the Clinical Serious Incident Requiring Investigation Policy Example of Application Specific Stage 1 Notifications to consider Information Governance. • Major confidentiality breaches. • An incident that could lead to actual or potential identify fraud or have a serious impact on individuals. Information Technology. • Any form of systems loss leading to serious outcomes. Media Issues. • Matters which are likely to attract significant media attention, including apparently trivial ones which may become more serious. Version 1.2.1 Information commissioner Police Stage2 Fact finding As with Stage 1 carried out by the Information Governance Manager. Connecting for Health In line with the main policy SHA's media centre In line with main policy HSE NHS Counter Fraud Service or 25/42 Stage 3 Stage 4 Stage 5 outbreak. Risk and Quality Assurance Committee. The Chief Office As with Stage 1 for Governance is the Trust's Caldicott Guardian, therefore must be advised of the incident urgently. The report should be approved at the Information Governance Steering Group. Serious Incident Requiring Investigation Policy Example of Application Specific Stage 1 Notifications to consider • Security Management Service Any Health Improvement Notices. Medical Devices. MHRA Stage2 In line with main policy • Any serious harm or potential serious The harm, arising from the use of a medical manufacturer device. Medico-legal incidents. NHSLA • Suspicion of large scale theft which may require police involvement. Police • Potential legal claims against the hospital due to a serious incident. In line with main policy NHS Security Management Service • Potential legal claims that may affect national policy. Mental Health, Substance Misuse, Learning Difficulties related incidents. • Serious offences including homicide committed by a person in receipt of mental Version 1.2.1 CQC Automatic SIRI Police In line with main policy Probation Staff 26/42 Stage 3 Stage 4 Stage 5 Serious Incident Requiring Investigation Policy Example of Application Specific Stage 1 Notifications to consider Stage2 healthcare. • Absence with out leave of a person detained under the Mental Health Act (1983) who are a danger to themselves or others. • A patient who is receiving inpatient mental health care in a secure unit going missing. Mortality/Morbidity Care Incidents. Coroner • Clusters of unexpected or unusual deaths. HSE • Deaths resulting in adverse comments fro the coroner. In line with main policy. Police Professional bodies. • Suicide of any one in receipt of heath care or having been discharged within the last 12 months. Premises and Equipment Incidents. MHRA • Incidents causing serious damage to healthcare premises. HSE • In line with main policy. NHS Security Incidents resulting in serious harm to Management Version 1.2.1 27/42 Stage 3 Stage 4 Stage 5 Serious Incident Requiring Investigation Policy Example of Application Specific Stage 1 Notifications to consider individuals or serious disruption of services. Service Stage2 Stage 3 Stage 4 Stage 5 Automatic SIRI As with Stage 1 The report should be approved at the Infection Prevention and Control Committee before presentation to the Clinical Risk and Quality Assurance Committee. • Failure of equipment which could endanger life, even if this does not occur. • Malicious damage to equipment or property . MRSA bacteraemia (each case) Version 1.2.1 Fact finding As with Stage 1 carried out by a Consultant Microbiologis t or the Infection Prevention and Control Team 28/42 The CNO is the executive lead for infection prevention and control, therefore must be urgently advised. Serious Incident Requiring Investigation Policy Example of Application Specific Stage 1 Notifications to consider Radiology. MHRA • Severe equipment failure leading to harm or death. Royal College of Radiologists Screening Programme. SHA screening lead • Loss of test results. • Failure to detect cancer. • Incorrect notification of results to patients or carers. Staff Related. • Serious complaints about members of staff. • staff. Serious criminal acts by members of • Serious drug errors. Professional bodies Stage 4 Stage 5 In line with main policy. In line with main policy. In line with main policy. Any investigations into serious fraud will be led by the Trust Counter Fraud National Clinical Specialist. Assessment Service Police NHS Counter Fraud Service • Occupational Health Version 1.2.1 Stage 3 Relevant Screening Programme Centre • Issue of competence (See Incident Decision Tree, Appendix 7). Serious fraud. Stage2 29/42 Serious Incident Requiring Investigation Policy Example of Application Specific Stage 1 Notifications to consider Unexpected death, serious harm or injury. HSE • Including clusters of some lower harm incidents. Police Violence towards healthcare staff. Security Management Service Version 1.2.1 Stage2 In line with main policy. Coroner In line with main policy. 30/42 Stage 3 Stage 4 Stage 5 Serious Incident Requiring Investigation Policy Appendix 4 Core list of Never Events A Never Event is a specific type of incident that has previously caused significant harm, and has specific guidance which if fully implemented would prevent the incident from happening. Never Events will always automatically be SIRIs. Our Commissioners can impose financial penalties if we have a Never Event. Surgical Never Events 1. Wrong site surgery A surgical intervention performed on the wrong site (for example wrong knee, wrong eye, wrong patient, wrong limb, or wrong organ); the incident is detected at any time after the start of the operation and the patient requires further surgery, on the correct site, and/or may have complications following the wrong surgery. Includes biopsy, radiological procedures and drain insertion, where the intervention is considered surgical. • Excludes wrong site anaesthetic block. • Excludes interventions where the wrong site is selected because of unknown/unexpected abnormalities in the patient’s anatomy. This should be documented in the patient’s notes. Please note that a severe patient outcome is not required for a wrong site surgery to be classed as a Never Event. 2. Wrong implant/prosthesis Surgical placement of the wrong implant or prosthesis where the implant/prosthesis placed in the patient is other than that specified in the operating plan either prior to or during the procedure. The incident is detected at any time after the implant/prosthesis is placed in the patient and the patient requires further surgery to replace the incorrect implant/prosthesis and/or suffers complications following the surgery. • Excludes where the implant/prosthesis placed in the patient is intentionally different from the operating plan, where this is based on clinical judgement at the time of the operation. • Excludes where the implant/prosthesis placed in the patient is intentionally planned and placed but later found to be suboptimal. Please note that a severe patient outcome is not required for a wrong implant/prosthesis to be classed as a Never Event. 3. Retained instrument post-operation Unintended retention of a foreign object in a patient after surgical intervention, including interventional radiology, cardiology and vaginal birth. • Includes swabs, needles, implants, fragments of screws, instruments and guidewires. SIRI draft Policy version 0.3 31/42 Serious Incident Requiring Investigation Policy • Excludes where any relevant objects are found to be missing prior to the completion of the surgical intervention and may be within the patient, but where further action to locate and/or retrieve would be more damaging than retention, or impossible. This must be documented in the patient’s notes and the patient informed. Please note that a severe patient outcome is not required for a retained instrument postoperation to be classed as a Never Event. Medication Never Events 4. Wrongly prepared high-risk injectable medication Death or severe harm as a result of a wrongly prepared high-risk injectable medication. • High-risk injectable medicines are identified using the NPSA’s risk assessment tool. A list of high-risk medicines has been prepared by the NHS Aseptic Pharmacy Services Group using this tool. Organisations should have their own list of high-risk medications for the purposes of the never events policy, which may vary from the NHS Aseptic Pharmacy Services Group list, depending on local circumstances. • The patient receives a wrongly prepared high risk injectable medication if it was not; prepared in accordance with the manufacturer's Specification of Product Characteristics; prepared in accordance with a protocol formally agreed by the local organisation (for example for off-label or unlicensed product use); prepared in accordance with patient specific directions of a prescriber in an urgent or emergency situation and supported by evidence or expert advice. • This event excludes any incidents that are covered by other never events. • Where death or severe harm cannot be attributed to incorrect preparation, treat as a Serious Untoward Incident. 5. Maladministration of a potassium-containing solution Death or severe harm as a result of maladministration of a potassium-containing solution. Maladministration refers to; • selection of strong potassium solution instead of intended other medication, • wrong route administration, for example a solution intended for central venous catheter administration given peripherally, • infusion at a rate greater than intended. 6. Wrong route administration of chemotherapy Intravenous or other chemotherapy (for example, vincristine) that is correctly prescribed but administered via the wrong route (usually into the intrathecal space). 7. Wrong route administration of oral/enteral treatment Death or severe harm as a result of oral/enteral medication, feed or flush administered by any parenteral route. 8. Intravenous administration of epidural medication SIRI draft Policy version 0.3 32/42 Serious Incident Requiring Investigation Policy Death or severe harm as a result of intravenous administration of epidural medication. • A broader never event covering intravenous administration of intrathecal medication or intrathecal administration of intravenous medication is intended once the deadlines for both parts A (updated) and B of the Safer spinal (intrathecal), epidural and regional devices patient safety alert have passed. 9. Maladministration of Insulin Death or severe harm as a result of maladministration of insulin by a health professional. Maladministration in this instance refers to when a health professional • uses any abbreviation for the words ‘unit’ or ‘units’ when prescribing insulin in writing, • issues an unclear or misinterpreted verbal instruction to a colleague, • fails to use a specific insulin administration device e.g. an insulin syringe or insulin pen to draw up or administer insulin, or • fails to give insulin when correctly prescribed. 10. Overdose of midazolam during conscious sedation Death or severe harm as a result of overdose of midazolam injection following use of high strength midazolam (5mg/ml or 2mg/ml) for conscious sedation. • Excludes areas where use of high strength midazolam is appropriate. These are specifically only in general anaesthesia, intensive care, palliative care, or where its use has been formally risk assessed. • Excludes paediatric care. 11. Opioid overdose of an opioid-naïve patient Death or severe harm as a result of an overdose of an opioid given to a patient who was opioid naïve. Specifically this means: • Where a dose is used that is not consistent with the dosing protocol agreed by the healthcare organisation, or the manufacturer’s recommended dosage for opioid-naïve patients*. • Where the prescriber fails to ensure they were familiar with the therapeutic characteristics of the opioid prescribed. • Excluded are cases where the patient was already receiving opioid medication. 12. Inappropriate administration of daily oral methotrexate Prescription, supply or administration of daily oral methotrexate to a patient for non-cancer treatment including supply to the patient with the instruction to take daily. • Excludes cancer treatment with daily oral methotrexate • Excludes where the error is intercepted before the patient is supplied with the medication. SIRI draft Policy version 0.3 33/42 Serious Incident Requiring Investigation Policy Mental Health 13. Suicide using non collapsible rails Death or severe harm to a mental health inpatient as a result of a suicide attempt using non collapsible curtain or shower rails. 14. Escape of a transferred prisoner A patient who is a transferred prisoner escaping from medium or high secure mental health services where they have been placed for treatment subject to Ministry of Justice restriction directions. General Healthcare 15. Falls from unrestricted windows Death or severe harm as a result of a patient falling from an unrestricted window. • Applies to windows “within reach” of patients. This means windows (including the window sill) that are within reach of someone standing at floor level and that can be exited/fallen from without needing to move furniture or use tools to assist in climbing out of the window. • Includes windows located in facilities/areas where healthcare is provided and where patients can and do access. • Includes where patients deliberately or accidentally fall from a window where a restrictor has been fitted but previously damaged or disabled, but does not include events where a patient deliberately disables a restrictor or breaks the window immediately before the fall. 16. Entrapment in beds rails Death or severe harm as a result of entrapment of an adult in bedrails that do not comply with Medicines and Healthcare products Regulatory Agency (MHRA) dimensional guidance. 17. Transfusion of ABO-incompatible blood components Death or severe harm as a result of the inadvertent transfusion of ABO-incompatible blood components. 18. Transplantation of ABO incompatible organs as a result of error Death or severe harm arising from inadvertent ABO mismatched solid organ transplantation. • Excluded are scenarios in which clinically appropriate ABO incompatible solid organs are transplanted deliberately • In this context, ‘incompatible’ antibodies must be clinically significant. If the recipient has donor specific anti-ABO antibodies and is therefore, likely to have an immune reaction to a specific ABO compatible organ then it would be a never event to transplant that organ inadvertently and without appropriate management. 19. Misplaced naso- or oro-gastric tubes Death or severe harm due to a misplaced naso- or oro-gastric tube being used where the misplacement of the tube is not detected prior to commencement of feeding, flush or medication administration. SIRI draft Policy version 0.3 34/42 Serious Incident Requiring Investigation Policy • Where appropriate checks are conducted and documented and demonstrate that the tube is in the correct place, but the tube is subsequently found to have become misplaced, for example after becoming dislodged, provided there has been regular checking of tube placement, this is not a never event. 20. Wrong gas administered Death or severe harm as a result of the administration of the wrong gas, or failure to administer any gas, through a line designated for Medical Gas Pipeline Systems (MGPS) or through a line connected directly to a portable gas cylinder. 21. Failure to monitor and respond to oxygen saturation Death or severe harm as a result of failure to monitor or respond to oxygen saturation levels in a patient undergoing general or regional anaesthesia, or conscious sedation for a healthcare procedure (e.g. endoscopy). • Includes failure to physically have monitoring in place, and failure to act on relevant information from monitoring oxygen saturation. • Excludes where action is taken in response to recorded adverse oxygen saturation levels, but this fails to prevent death or severe harm for other reasons (e.g. pre-existing problems with oxygenation that cannot be resolved). • Excludes incidents where the accepted limitations of monitoring equipment mean that adverse readings may be artefactual (e.g. shock/vasoconstriction). 22. Air embolism Death or severe harm as a result of intravascular air embolism introduced during intravascular infusion/bolus administration or through a haemodialysis circuit. • Excludes the introduction of air emboli through other routes. This therefore excludes introduction via surgical intervention (particularly Ear, Nose and Throat surgery and neurosurgery), during foam scleropathy and during the insertion of a central venous catheter. • Introduction of an air embolism after the insertion of a central venous catheter, through the line, and during its removal, is included. • Excludes where the introduction of the air embolism was caused by the actions of the patient. 23. Misidentification of patients Death or severe harm as a result of administration of the wrong treatment following inpatient misidentification due to a failure to use standard wristband (or identity band) identification processes. Failure to use standard wristband identification processes means; • failure to use patient wristbands that meet the NPSA’s design requirements, • failure to include the four core patient identifiers on wristbands – last name, first name, date of birth and NHS number, • failure to follow clear and consistent processes for producing, applying and checking patient wristbands, SIRI draft Policy version 0.3 35/42 Serious Incident Requiring Investigation Policy • printing several labels with patient details at one time. This event does not apply to those units where wristbands are not used, for example some mental health inpatient units (this requires local agreement). This event excludes where the patient refuses to wear a wristband despite a clear explanation of the risks of not doing so, or where it has been documented that the patient cannot wear a wristband due to their clinical condition or treatment, or in emergency care environments where high patient turnover, insufficient patient identity information, or the need for rapid treatment can delay wristband use. 24. Severe scalding of patients Death or severe harm as a result of a patient being scalded by water used for washing/bathing • Excludes scalds from water being used for purposes other than washing/bathing (e.g. from kettles) 25. Maternal death due to post partum haemorrhage after elective caesarean section In-hospital death of a mother as a result of haemorrhage following elective caesarean section. • Excludes cases where placenta accreta is found, or where there is a pre-existing bleeding disorder, or the mother refuses blood components for any reason. • Excludes emergency caesarean section and where a scheduled elective caesarean section is brought forward. SIRI draft Policy version 0.3 36/42 Serious Incident Requiring Investigation Policy Appendix 5 Basic principles of Root Cause Analysis 1. What is a root cause and root cause analysis? A root cause is a fundamental cause which must be addressed in order eliminate or reduce the highlighted risk or problem. For example, a root cause may illustrate a need for clearer communication lines. Root causes have the following properties: Underlying causes – the ones that if addressed would stop this type of incident. Can reasonably be identified Are those for which effective recommendations must be generated to prevent recurrence of the incident. There are many academic definitions of what root cause analysis is, but in essence it is a process that enables the root causes to be identified and then used to reduce future risks. The following is one examples of RCA definitions: “RCA “is a retrospective review of an event undertaken in order to identify what, how and why it happened. The analysis is then used to identify areas for change, recommendations and sustainable solutions, to help minimise the re-occurrence of the incident type in the future.” (RCA training and tool kit section from the NPSA website.) It can therefore by concluded that RCA is asking the following questions: What happened? Why did it happen? How did it happen? What can we learn from it? These questions form the core element of investigations at BCH, and should be reflected in any investigation undertaken. 2. When can I do a RCA review? This Policy outlines the process for investigating Serious Untoward Incidents and gives responsibility to the Chief Medical Officer, supported by Risk Specialists at the Trust for agreeing the level of investigation of SUI’s with our commissioners and families. Incidents of other grades may be investigated using RCA in a process managed at local level. Those investigations may draw on RCA as a technique and may be prompted by: Review of an IR1 form or other report of an incident. Complaints Claims Operational / Business review SIRI draft Policy version 0.3 37/42 Serious Incident Requiring Investigation Policy Finance review Participation review Investigations may take the form of a general review undertaken by any member of staff, or be more formal, requiring an RCA meeting. SIRI draft Policy version 0.3 38/42 Serious Incident Requiring Investigation Policy Appendix 6 Suggested tools for RCA reviews There are many tools and techniques for RCA sessions. It is strongly recommended that staff attend the RCA training that is provided as part of Level 2 or Level 3 risk training. Please contact the Education Department to book a slot. The following are brief introductions and suggestions: 1. chronology of events 2. brainstorming 3. timelines 4. contributory factors checklists 5. cause and effect diagrams 6. fishbone diagram 7. time person grid 8. summary of the above Staff are referred to the NPSA website which has a tool kit for staff to gain more knowledge on RCA and the tools available. 1. Chronology of events: A descriptive account of the risk / problem. This may be taken from the case notes, statements and alike. A chronology of events given to participants at the start / before the session is useful; however, the session may be concerned with seeking others opinions on the chronology of events so may be done during the session. A chronology of events is sometimes a good way to start a RCA report. 2. Brainstorming Brainstorming is a group of people highlighting their suggestions or concerns. It is designed to obtain the maximum number of ideas relating to a specific area of interest. The aim is to end up with a list of raw ideas to use later on in the session, so ideally should be undertake towards the start of the meeting. 3. Timelines An essential tool for any investigation, a timeline is a visual representation of the chronology and allows the investigator to discover points in the process where problems may have occurred or where gaps in our understanding of the events may exist. Especially useful if it tracks to point in time before the incident, for instance, the point of admission, the point of referral etc. 4. Contributory Factors checklists The NPSA has produced a checklist of possible contributory factors, reference to the checklist when carrying out an analysis of the sequence of events can help ensure SIRI draft Policy version 0.3 39/42 Serious Incident Requiring Investigation Policy that we do not miss any possible causes of the incident. This is the most common tool for carrying out RCA in our Trust. 5. Cause and effect A cause and effect diagram is a tool that helps identify, sort and display possible causes of a specific problem. It graphically illustrates the relationship between a given outcome and all the factors that influence the outcome. Constructing a cause and effect diagram can help your team when you need to: • identify the possible root causes • Understand the interactions among the factors affecting a particular process of effect. • Analyse existing problems so that corrective action can be taken. 6. Fishbone diagrams This type of diagram is sometimes called an “Ishikawa diagram” because it was invented by Kaoru Ishikawa, or a ‘fishbone diagram’ because of the way it looks. This is a very useful tool when the incident is complex and there are many possible contributory factors. The tool is used for drilling down into the contributory factors to identify root causes. 7. Time person grid This allows you to graphically put together what happened during a short time period and is good for highlighting in a report specific items and timings and the actions taken by individuals at those times. The basic layout is available on the Governance intranet site. The basic layout of a cause and effect diagram and the NPSA fishbone are available on the Governance intranet site, alongside the contributory factor framework used in the NPSA methodology 8. Characteristics of some RCA tools The following are a few of the pros and cons for each of the above tools: Chronology of events Tells the story of what happened in a logical format. Key points may get lost Timelines Can view the event in one diagram Difficult to use for long time period Brainstorming Quick Can be unstructured and strong characters dominate Cause & effect Good if problem areas are known Specific and may limit the review SIRI draft Policy version 0.3 40/42 Serious Incident Requiring Investigation Policy Time person grid Can see where people are Person focused Fishbone 9 contributory factors in one tool Can use headings as topics for discussion General and time consuming. SIRI draft Policy version 0.3 41/42 Serious Incident Requiring Investigation Policy Appendix 7 Incident Decision Tree START HERE Were the actions as intended? ILL HEALTH NO Does there appear NO to be evidence of ill health or substance misuse? YES YES Were adverse consequences intended? YES NO Did the individual YES know they have a medical condition? NO FORESIGHT TEST Did the individual knowingly depart from agreed protocols or safe procedures? SUBSTITUTION TEST NO YES NO Were the protocols and safe procedures available, workable, intelligible, correct and in routine use? Were there any deficiencies in training and selection or experience? YES Is there evidence of reckless behaviour? NO Guidance on appropriate management action required, please refer to Human Resources. RCA may be required. YES SYSTEM INDUCED ERROR YES NO YES Guidance on appropriate Guidance on appropriate management action management action required, please refer to required, please refer to Human Resources. RCA may Human Resources. RCA may SIRI draft Policy version 0.3 be required. be required. Would another individual coming from the same professional group, possessing comparable qualifications and experience behave in the same way? RCA required Were there mitigating YES circumstances, e.g. root causes promoting protocol violations? NO Guidance on appropriate management action required, please refer to Human Resources. RCA may be required. 42/42 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Risk Management Manual Version: 1.0.1 Ratified by: Clinical Risk & Quality Assurance Date ratified: April 2008 Name of originator/author: Michelle Errington Name of responsible committee/individual: Risk Manager Date issued: April 2008 Review date: April 2011 Target audience: All Trust Staff 1 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 1.0 Contents Page – Risk Management Manual 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 9.0 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 9.0 10.0 11.0 12.0 13.0 14.0 Ap 1 Ap 2 Ap 3 Ap 4 Ap 5 Introductory Section Contents page Policy Statement Introduction to Risk Management Manual Purpose Definitions used in risk Manual Implementation and Dissemination plan for this Manual Monitoring of this Manual References for Introductory Section PART A – Risk Strategy Forward Introduction Trust risk management vision Roles and responsibilities for delivery of this strategy and risk management agenda Training for senior management, board members and executives Process for Board review of the risk register Performance review of risk management by the board Process for the management of risk at local level, including authority of line managers Monitoring of part A – risk strategy Part B – Incident Reporting, including Serious Untoward Incidents and Being Open. Introduction Purpose Objectives Definitions Duties Communication and notification Completion of IR1 forms and linking to the complaints and claims process Incident investigation Serious Untoward Incidents Incident and causal factor analysis Hotline arrangements Being Open Monitoring part B References Appendix one – incident form procedural guidelines Appendix two – statement writing guidance Appendix three – flowchart for triggering an SUI Appendix four – Hotline forms Appendix five – Quick reference guide for being open Page 2 Page 12 Page 21 2 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 9.0 10.0 11.0 12.0 Ap 1 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 9.0 10.0 Ap1 Ap 2 Part C – Investigation / Root Cause Analysis Guidance Forward Introduction Why are investigations necessary and what is RCA? When do I do a RCA review? Ir1 forms and RCA reviews Trust RCA reviews RCA reviews and complaints RCA reviews and claims Suggested tools for RCA reviews Staff responsibilities Monitoring of Part C References Appendix one – Contributory factors classification framework Part D – Risk Assessment and Risk Register Introduction Defining risk Procedures and process for undertaking a risk assessment Risk register Staff responsibilities and review at trust level Staff training and information Trust review of risk assessment / risk register Extreme risks Monitoring of part D References Appendix one – Risk scoring system 2008 Appendix two – Proforma for risk assessments Page 51 Page 69 3 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 2.0 Policy Statement The Birmingham Children’s Hospital (BCH) NHS Foundation Trust is committed to the active management of risk and is dedicated to establishing an organisational culture that ensures that risk management is an integral part of everything it does. Risk management will be a key part of all management systems and corporate planning as well as the setting of strategy and objectives. The Trust takes the view that it is unacceptable to reach other objectives at the expense of safety. The objective of the Trust is to provide a responsive, high quality service to patients. This is achieved by promoting a policy of openness and accountability and by effective communication with the local community. The continued delivery of such quality requires BCH to identify, manage and reduce the effect of events or activities, which could result in a risk to patients, staff and the community. The management of such risks is a key organisational responsibility across the Trust, and at all levels. All managers and clinicians accept the management of risks as one of their fundamental duties. Additionally every member of staff must be committed to identifying and reducing risks. This is best achieved through an environment of honesty and openness, where mistakes and untoward incidents are identified quickly and dealt with in a positive and responsive way. 4 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 3.0 Introduction to Risk Management Manual This risk management Manual has been written to assist staff in using the principles and tools of risk management in their day to day roles as well at strategic and operational level. The Manual is divided into four parts, with part A focused on the risk management strategy, and parts B, C and D focused on risk management in practice. Although each part of the Manual focuses on one aspect of risk, staff are reminded that each part links in with the others and therefore must be considered as a whole. PART A Risk Management Strategy PART B Incident Reporting, including Serious Untoward Incidents and Being Open PART C Investigation / Root Cause Analysis Guidance. PART D Risk Assessment and Risk Register Guidance Each part of the Manual includes the duties for staff, and how monitoring is to be undertaken. The dissemination and implementation of the Manual is outlined in this introductory section. The Manual focuses on risks, claims, and complaints, which are collectively called INCIDENTS within this Manual. Staff are referred to the following personnel if they require specific detail relating to a claim, complaint or risk: Chief Medical Officer Ext 8077 Director of Healthcare Governance & Education Ext 8433 Head of Legal and Corporate Affairs Ext 8423 Health, Safety and Security Manager Ext 8431 Risk Manager Ext 8959 Patient Interface Manager Ext 8419 Moving and Handling Advisor Ext 8953 Claims, complaints and risks are discussed further in the Learning from Experience Policy. 4.0 Purpose The Trust has a statutory responsibility to patients, parents, public and commissioners to ensure that it has effective processes, policies and people in place to deliver its objectives and to control any risk that it may face in achieving these objectives. The Trust will take all steps (reasonably practicable), in the management of risk with the overall objective of protecting patients, staff, members of the public and its assets. The Trust’s primary concern is the provision of safe, minimal 5 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 risk environments and services, achieved through a structured approach to risk assessment and minimisation across the organisation. The aim of this Manual is to ensure that the Trust has a risk management approach that: ensures the safe delivery of health care within the available financial resources and other resource limits; ensures compliance with national statutory requirements; ensures there is a standardised, systematic mechanism to identify, assess, control and minimise risks across the organisation, principally through the further development and maintenance of a Trust risk register; enables staff to undertake risk management as part of their every-day activities; ensures staff use the principles and practice of risk management, including root cause analysis and risk assessment; supports the organisation with continually improving services through the principles of risk management. ensures that the principles of being open are utilised. 5.0 Definitions used in risk Manual A list of definitions is found at the start of Part B, C and D of the Manual and outlines definitions relevant to that part. The following is a list of all key definitions used within all of the Manual. Risk Management Is the assessment, analysis and management of risks. It is simply a way of recognising which events (hazards) may lead to harm in the future, and minimising their likelihood of occurrence (how often?) and consequence(s) (how bad?). NPSA (January 2008) A risk matrix for risk managers Integrated Risk Management NPSA (July 2004) Seven steps to patient safety. The full reference guide. Patient Incident Is the process of identification, assessment, analysis and management of all risks and incidents for every level of an organisation, and aggregation of the results at a corporate level. This facilitates prioritysetting and improved decision making to reach an optimal balance of risk, benefit and cost. Safety A patient safety incident is any unintended or unexpected incident which could have or did lead to harm for one or more patients receiving NHS care. It is a specific type of adverse event. NPSA website. Hazards Are situations with the potential to cause harm NPSA (March 2007) Healthcare risk assessment made easy Likelihood The likelihood score is a reflection of how likely it is that the adverse consequence described will occur. NPSA (January 2008) A risk matrix for risk managers Consequence The outcome or the potential outcome of an event. NPSA (January 6 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 There may be more than one consequence of a single event. 2008) A risk matrix for risk managers Adverse incident Is any event or circumstance leading to unintentional harm or suffering. NPSA (January 2008) A risk matrix for risk managers Near Miss Incidents that have been prevented (also known as near misses). NPSA Seven Steps to Patient Safety April 2004 Control measures Risks are usually analysed by combining estimates of consequence and likelihood in the context of existing controls measures. (e.g. policies, guidelines and so on). Action plan treatment Guidelines for managing risks in healthcare. (2000) Standards Australia International Sydney / Risk Treatment is the process of selecting and implementing of measures to modify risk. Risk treatment measures can include avoiding, optimizing, transferring or retaining risk. Treatment is more commonly known as action plans. Safety Culture The safety culture of an organisation is the product of individual and group values, attitudes, perceptions, competencies and patterns of behaviour that determine the commitment to, and the style and proficiency of, an organisation's integrated risk management system. Harm The severity of a loss which has occurred to people, property or the organisation. Investigation The collection of information to enable a review to be undertaken and to determine learning outcomes and what we did well. Causal Factors The factors which contribute to the incident, and are sometimes known as contributory factors. Risk Reduction The process of reducing the likelihood that harm will occur to the lowest possible level. Inherent Risk This is a permanent or currently unavoidable risk that is associated with a particular event / task / practice. The risk that should be targeted when an inherent risk is noted, is the risk that is added to the inherent risk, e.g. poor communication or teamwork. NPSA (March 2007) Healthcare risk assessment made easy Risk Assessment A risk assessment is simply a careful examination of Health and Safety Health and Safety Executive HSE65 (2003) 7 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 what, in your work, could cause harm to people, so that you can weigh up whether you have taken enough precautions or should do more to prevent harm Executive – Risk management part of website. www.hse.gov.uk Risk Score Is the combination of likelihood and consequence. The risk scores are not intended to be precise mathematical measures of risk but they are useful for prioritising control measures. NPSA (March 2007) Healthcare risk assessment made easy Residual risk Residual risk is a risk that remains after Risk Management options have been identified and action plans have been implemented. It also includes all initially unidentified risks as well as all risks previously identified and evaluated but not designated for treatment at that time. Low Risk Scores Quick, easy measure implemented immediately and between 1 and 10 further action planned for when resources permit. and is the green colour on the risk matrix. NPSA (March 2007) Healthcare risk assessment made easy Moderate Risk Actions implemented as soon as possible, but no scores between 11 later than a year. and 16 and is the yellow colour on the risk matrix. NPSA (March 2007) Healthcare risk assessment made easy High Risk scores Actions implemented as soon as possible, but no between 17 and 19 later than 6 months. and is the orange colour on the risk matrix. NPSA (March 2007) Healthcare risk assessment made easy Extreme Risk Requires urgent action. The Trust board is made scores between 20 aware and actions are undertaken as soon as and 25 and is the possible. red colour on the risk matrix. NPSA (March 2007) Healthcare risk assessment made easy Root Cause Analysis RCA “is a retrospective review of a patient safety incident undertaken in order to identify what, how and why it happened. The analysis is then used to identify areas for change, recommendations and sustainable solutions, to help minimise the reoccurrence of the incident type in the future.” RCA training and tool kit section from the NPSA website 8 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 6.0 Implementation and Dissemination plan for this Manual Action Launch of Risk Management Manual: Timescale October 2008 Risk Manager / Health, Safety and Security Manager April 2008 onwards Via Trust Intranet Trust P Drive Governance Bulletin Copy sent to Executive Team, Directorate Management Teams and Heads of Departments Staff information: Lead Risk Manager Risk Awareness in Governance Support Training Key facts from Manual in staff risk management leaflet (included in new staff induction program) 7.0 Monitoring of this Manual The overall responsibility for the monitoring of this Manual belongs to the Risk Manager. 8.0 References NPSA (2004) Seven Steps to Patient Safety 9 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Risk Management Strategy PART A of the Risk Management Manual 1.0 Forward This strategy outlines the principles of risk management and the Trust’s collective responsibilities and risk management structure. This will enable the Trust to deliver its objectives and meet its statutory requirements. It also forms a key component of the Trust’s overall approach to Governance. This strategy is supported by Part B, C and D of the risk management Manual which outlines guidance for staff on the procedural aspects of risk management. That is, B – incident reporting including serious untoward incidents and being open C – investigations and root cause analysis D – risk assessment and risk register 2.0 Introduction For the purposes of this strategy, risk is defined as “anything which prevents an organisation from achieving its declared aims and objective” and Risk Management can be considered as the systematic processes and procedures that an organisation puts in place to ensure that it identifies, assesses, prioritizes and takes action to manage these risks to ensure it continues to deliver its objectives. The Trust has a statutory responsibility to patients, parents, the public and commissioners to ensure that it has effective processes, policies and people in place to deliver its objectives and to control any risks that it may face in achieving these objectives. The need for the organisation to have effective risk management systems and processes in place is governed by the following key requirements: Statutory Controls Assurance Statement of Internal Control - One of the principle approaches that the Department of Health requires organisations to use as an assurance of this, is to produce an annual Statement of Internal Control, signed by the Chief Executive. This statement is produced as part of the Trust’s annual report and must be signed by the Chief Executive. It aims to demonstrate that the organisation is doing its “reasonable best” to manage its affairs efficiently and effectively through the implementation of internal controls to manage risk, (HSC 2001/005. Governance in the new NHS: Controls Assurance Statements 2000/2001). 1999 Health Act – Following the introduction of the Health Act 1999 (and the preceding publication A First Class Service 1998), a statutory duty for the quality of care was imposed on all Chief Executives and Trust Boards throughout the NHS. For the first time since the creation of the NHS, an equal emphasis of statutory duty was placed on quality and finance. 10 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 This duty explicitly described the need for organisation to have effective risk management systems in place to maintain a safe system of care for patients and public. 3.0 Trust risk management vision statement The Trust’s strategy aims to deliver pragmatic and effective multi-disciplinary approach to Risk Management, which is underpinned by a clear accountability structure from Board to Practitioner level. It recognises the need for robust systems and processes to support continuous programmes of Risk Management, enabling staff to integrate Risk Management into their daily activities, where possible. Delivery of the strategy will support the development of continuous improvements in care and practice, recognising that these may only be incremental changes over a period of time. It will produce clear outcomes, which can be measured against targets and performance indicators to ensure national and local standards are achieved. The Trust will continue to work towards an integrated governance agenda. This risk management strategy will contribute to supporting this. It will enable the Trust to achieve and maintain high levels of accreditation against the NHSLA standards for clinical and non-clinical claims, risk management and complaints management. The Trust will endeavour to proactively involve patient, parents and the public to create a ‘real’ user involvement where appropriate. Other key partners and stakeholders will be encouraged to participate in initiatives that foster a multi-professional, multidisciplinary and multi-agency approach. Staff will be encouraged and supported to share learning and best practice in a way that creates a culture of open supportive learning with accountability, even when mistakes have been made. Knowledge will be seen as a cornerstone of building safer care in the future and the Trust will work to adopt and provide a proactive knowledge management infrastructure. 4.0 Roles and responsibilities for delivery of this strategy and the risk management agenda This section of the strategy identifies the roles and responsibilities of key individuals and committees, highlighting accountability levels at each stage. It provides a brief synopsis of key role and key committees. Further details on staff and committee responsibility can be found in parts B, C and D of the risk management Manual. 4.1 Role responsibilities The Trust Board, managers and staff are responsible for establishing, maintaining and supporting a holistic approach to risk management, in all areas of their responsibility. They should comply with the Trust Risk Management policy and procedures and ensure effective risk management mechanisms are implemented in accordance with these. Some members of staff and Committees have particular specialist functions in relation to risk management as described below. 4.1.1 Chief Executive The Chief Executive has overall responsibility for the Trust’s risk management programme and ensuring that this operates effectively. As Accountable Officer, he is responsible for signing the Statutory Statement of Internal Control. Although operational responsibility for 11 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 risk management is delegated to all Executive Directors, the Chief Medical Officer and Director of Governance and Education have lead responsibilities in these areas. 4.1.2 Chief Medical Officer The Chief Medical Officer is responsible to the Trust Board and Chief Executive in relation to clinical risk management and provides quarterly reports to the Integrated Governance Committee and in turn the Trust Board in this regard. The Director of Healthcare Governance and Education assists with the performance of his/her duties. The Chief Medical Officer has a particular role in overseeing the provision of internal clinical advice in relation to risk management. 4.1.3 Director of Healthcare Governance and Education The Director of Healthcare Governance and Education is responsible for the risk management strategy within the Trust, and for the direction of the Risk Management Department generally. He/she will regularly report to the Chief Medical Officer, to the Integrated Governance committee and to the Trust Board in relation to risk management activities (in particular adverse incident report and risk register status), and will liaise with other senior members of the Trust as required. In addition the Director of Healthcare Governance and Education has responsibility for developing the assurance framework. Utilising the assistance of other senior managers within the Trust as appropriate, the Director of Healthcare Governance and Education will oversee the work of the Trust Risk Manager. 4.1.4 Executive Directors All Executive Directors are responsible for overseeing a programme of risk management activities, in accordance with the Trust’s risk management policies and procedures and advising the Chief Medical Officer and Director of Healthcare Governance and Education on risk issues in areas of their responsibility. By working closely together these individuals will ensure an integrated and holistic approach to the Trust’s risk management activities. All Directors are members of the Integrated Governance Committee. 4.1.5 Non-executive Directors All Non-executive Directors are responsible for assuring themselves that the systems of internal control, including Clinical Governance and financial management, are properly established and that appropriate systems of risk management are in place. 4.1.6 All Staff All staff across the Trust have a responsibility to ensure they comply with local risk management strategies, policies and procedures. 4.2. Committee responsibilities 4.2.1 Trust Board The Trust Board is responsible for assuring that appropriate risk management systems are in place to enable the organisation to deliver its objectives. It will delegate operational 12 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 responsibility for the delivery of risk management to the Integrated Governance Committee and Clinical Risk and Quality Assurance Committee. 4.2.2 Integrated Governance Committee The Integrated Governance Committee, which is chaired by the Chief Executive, is responsible for ensuring that individual Directorates, through the Integrated Governance Executive Committee structure, undertake a full programme of risk management activities, maintain up-to-date risk registers and take action to control these risks. It is responsible for reviewing these risks on a quarterly basis. It has a particular role in overseeing the management of risks that have significant funding implications and/or are Corporate/Trustwide in nature. 4.2.3 Integrated Governance Executive Committees The Executive Committees consist of: Clinical Risk and Quality Committee Staff and Environment Committee Asset Management Committee Research and Development Committee Information Governance Committee Information Management & Technology Committee Patient, Parents and Public involvement Committee These Committees are responsible for risk management in relation to their individual areas of specialism and are responsible for advising the Integrated Governance Committee Board on risks in these particular areas. 4.2.5 Audit Committee The Audit Committee, through the Internal Audit Department is responsible for monitoring and reviewing the adequacy the Trust’s internal control systems for risk management and, ensuring that these are effective and comply with the national standards. 4.2.6 Clinical Risk and Quality Assurance Committee This committee is responsible for ensuring that all clinical risks are reviewed and actioned in an appropriate manner. The committee is chaired by the Chief Medical Officer and the vice chair is the Director of Healthcare Governance and Education. Information from this meeting is cascaded to the executive management committee and Trust Board. The committee is attended by the directorate clinical directors who are responsible for cascading information back to the directorates. 4.2.7 Non Clinical Risk Co-ordinating Committee This committee is responsible for ensuring that all non clinical risks are reviewed and actioned in an appropriate manner. The committee is chaired by the Director of Healthcare Governance and Education. Information from this meeting is cascaded to the integrated governance meeting, executive management committee and Trust Board. 13 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 4.2.8 Drugs and Therapeutic Committee This committee’s responsibilities include ensuring that all appropriate risks and incidents are reviewed in an appropriate manner. The Information from this meeting is cascaded to the clinical risk and quality assurance committee via a subcommittee report. The Chief Pharmacist is responsible for producing and maintaining the Trust Medicine’s Policy. This is reviewed by the Drug and Therapeutics Committee which reports to the CRQAC. The Policy will include the following topics: Prescribing, Storage and dispensing and Administration of Medicinal Products. It will be compliant with Statutory Regulations and Policies, Guidelines and Advice published by the Department of Health, National Institute for Clinical Excellence, Medicines’ Healthcare Regulatory Agency, National Patient Safety Agency and other relevant bodies. The policy is approved by the Drug and Therapeutics Committee 5.0 Training for senior management - Board members and Executives Full details for risk management training are outlined in the risk management training needs analysis. All staff are required to attend mandatory Governance Training or otherwise meet the learning outcomes of that session. Alternatives methods to meet these learning outcomes for Senior Managers (Executive Team and Board) will be defined by the Director of Governance and Education. Examples of existing types of alternative training are outlined below. Method of delivery Annual update of risk management policies at Trust Board and Executive Management Team meetings Aim To provide an awareness of the policy contents and developments: Annual Risk Register updates and developments at Trust Board and Executive Management Team meetings To provide an awareness of the risk assessment and risk register process and concept. By whom Director of Healthcare Governance and Education Risk Strategy Risk Reporting Risk Assessment Serious Untoward Incidents Integrated Risk Management And other related topics Director of Healthcare Governance and Education Follow up of non compliance against the defined learning outcomes is undertaken on an annual basis by the Director of Governance & Education. Follow up of non attendance is via a letter from the Director of Governance & Education. Information from this meeting is passed to the Education Department and attendance is entered onto the Trust database for staff training. 14 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 6.0 Process for Board review of the Risk Register The risk register can be described as a ‘log of all risks that may threaten the success of the Trust in achieving its declared aims and objectives.” The risk register is populated by reviews undertaken at Department, Directorate and Trust level. The information entered at department level is entered into the assurance framework and Trust risk register, via two ways. Firstly, those which are scored 20 or 25 on the department risk registers and secondly via information provided by the monthly risk register review meeting led by the Chief Medical Officer. Trust board information is presented by the Director of Governance and Education, who is responsible for ensuring that the Trust Board receives its information in a timely and effective manner. The board is responsible for reviewing, actioning and validating these risks and for cascading information to the subcommittees/ directorates for follow up. 7.0 Performance review of Risk Management by the Board The Trust will utilise the following tools to support performance review: NHSLA Risk Management Standards NHS high-level performance indicators Benchmarking activity Internal standards Use of risk management tools by departments Compliance with mandatory induction and training standards Incident investigations and complaints Patient and staff attitude surveys Standards for Better Health The Trust Board may develop and use additional indicators to monitor risk management performance, as considered necessary. 8.0 Process for the management of risk at local level, including authority of managers Full details on the following processes can be found in the remainder of this Manual and the Learning from Experience Policy. 8.1 Learning from experience The concept of learning from experience plays a key role within risk management and is one which is echoed throughout this Manual. All risk management activity at both local and corporate level must endeavour to incorporate this philosophy to ensure that the hospital maximises the benefits of the risk management and governance systems. This in turn will aid the Trust in meeting its corporate objectives and aims. At local level the key activity for staff is to share lessons learnt and to incorporate incidents, claims, complaints and PALS information in their action plans. Staff are aided with a quarterly directorate patient experience report and monthly risk management reports which are sent to each directorate. 15 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 It is the responsibility of the directorate management teams and heads of departments to ensure that staff adopt this approach in their day to day activities. 8.2 Being open The being open process is outlined in Part B of the risk management Manual. This process is aimed at improving communication between healthcare professionals with other staff, external agencies and patients and their relatives, with the ultimate aim an improvement in patient safety. All staff are encouraged to be open and say sorry for any incidents or near misses and explain what happened. Local managers are encouraged to support staff in this process. This is complimented by the staff support policy following incidents. The principles which staff are provided with follow the national patient safety agency (NPSA) guidance and are fully supported by the royal colleges and professional organisations. 8.3 Risk Assessment / Risk Register The risk assessment process and risk register is outlined in Part D of the risk management Manual. All staff are responsible for completing risk assessments appropriate to their area. Risks are registered onto the department risk register and actioned appropriately to reduce the residual risk score. Risks which are noted as high risk or extreme risk (20 and 25 scores) are notified to the appropriate line manager and the directorate management team. The Risk Manager is informed within 24 hours or the next working day, who informs the appropriate Director for action / review at the appropriate Trust subcommittee and / or Trust board. This cascade of information applies to action points which are to be taken at Trust level and those which departments and directorates are unable to complete or require advice. Trust board is informed of Directorate risks via reports to the clinical risk and quality assurance committee and the non clinical risk committee. These reports are presented quarterly and enable discussion, review and validation of risks. 8.4 Incidents, external stakeholders and communication Information for incident reporting and serious untoward incidents is found in part B and C of the risk management Manual. All staff are responsible for completing incident report forms for incidents and near misses in their area and day to day work. These forms are reviewed at local level and actioned appropriately. Those which are potential claims or complaints are forwarded to the appropriate manager in the Governance department. The principles of being open are followed as required. All investigations follow the principles of root cause analysis, to ensure that all lessons to be learnt are identified and that good practice is acknowledged. This information forms the basis of the action plans and recommendations. Incidents and near misses which are serious untoward incidents are notified to the Risk Manager within 24 hours or the next working day. The process is commenced immediately and external stakeholders informed as outlined in the Manual. 16 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Lessons learnt from serious untoward incidents and significant risks highlighted at local level are shared with the rest of the Trusts staff via the risk mail and risk alert system which is coordinated by the Risk Manager. 8.5 Authority of line managers All line managers are responsible for ensuring that their staff remain risk aware and that they apply the general principles of risk management to their day to day roles. Managers are therefore responsible for: Sifting incidents to ensure that only appropriate incidents and near misses are reviewed in detail and for ensuring that serious untoward incidents are reported immediately. Complaints and claims processes highlighted in the appropriate policy are included within their risk management processes Relevant risk assessments are undertaken and entered onto the department risk register and escalated to the appropriate personnel for information, review or action. Principles of root cause analysis are used for investigations Lessons learnt are shared with staff and others department / Trust which have been identified in any risk management process Ensuring that staff are supported for the being open process 9.0 Monitoring the effectiveness of Part A. Item for monitoring Structure of committees responsible for the co-ordination of risk. Process for the board review of the organisation wide risk register Purpose of monitoring Ensure that the committees are meeting the requirements of the Terms of Reference. To ensure escalation of appropriate risks to Board. Process for monitoring Audit performance against terms of reference and action plan accordingly. Monitoring by whom and when? Governance team Annual Minutes of trust boards meetings confirming review of the Assurance Framework and confirming receipt of reports from these committees with responsibility for coordinating risk. Board Ongoing Process for management of risk locally To ensure that there effective local risk management. 100 IR1 audit to demonstrate that all areas are reporting incidents Risk Manager Annual Risk Register Review to ensure that all areas are registering risks Risk Manager Annual Directorate Risk Reports in accordance with the reporting Directorate management Teams 17 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 committee framework outlined within the Learning from Experience Policy Duties of key staff Authority of all managers regarding risk management To ensure that key staff meet their obligations as defined in this Manual. To ensure that managers participate within the risk management systems and enable staff to incorporate these systems within their daily activities. Quarterly Audit performance against terms of reference and action plan accordingly. Governance team Annual 100 IR1 audit to demonstrate that all areas are reporting incidents Risk Manager Annual Risk Register Review to ensure that all areas are registering risks Risk Manager Annual Directorate Risk Reports in accordance with the reporting committee framework outlined within the Learning from Experience Policy Directorate management Teams Annual Review of Serious Untoward Incident Investigations Risk Manager 100 IR1 audit to demonstrate that all areas are reporting incidents Risk Manager Annual Risk Register Review to ensure that all areas are registering risks Risk Manager Annual Directorate Risk Reports in accordance with the reporting committee framework outlined within the Learning from Experience Policy Directorate management Teams Quarterly Annual Quarterly 18 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Incident Reporting, including Serious Untoward Incidents & Being Open PART B of the Risk Management Manual 1.0 Introduction The Birmingham Children’s Hospital NHS Foundation Trust (BCH) is committed to providing high quality patient care within a safe environment, with one aspect of this commitment: learning from our experiences which are highlighted via the incident reporting system, claims and complaints which is collectively called INCIDENT in this Manual. BCH has recognised the value of incident reporting, and stresses the importance of consistent monitoring and review of incidents which resulted, or had the potential to result in injury, damage or other loss. BCH therefore aims to develop its current systems and facilitate a wider organisational learning process and to be open. BCH believes that risk management is the responsibility of all staff, from the board to the practitioner. The board is committed to developing an open and honest environment and learning from the hospitals lessons. This policy is part of the risk management Manual and should be read in conjunction with the other parts. 2.0Purpose It is the policy of BCH to record all incidents, claims and complaints (known as incidents in this policy) which have resulted in injury or loss or have the potential to do so. With these reported to an appropriate person in a timely manner to ensure that they are reviewed at local level. This applies to incidents affecting patients, directly employed staff and others including visitors, contractors and volunteers. This will enable lessons to be identified and action points to be noted and implemented. Incidents which fit the serious untoward incident (SUI) criterion must be notified within 24 hours or the next working day. “An Organisation with a Memory” (Department of Health 2000) has firmly established the need for better reporting systems across the health service and demonstrated the impact of such systems on safety in other industries. The analysis and investigation of incidents form an integral part of the strategy for risk management and is therefore fully supported by the board and executive team. In line with the National Patient Safety Agency (NPSA) safer practice notice BCH will be open when patients are harmed and ensure that the organisation and individuals try to make amends to the injured party for any hurt caused. In addition it will report all appropriate incidents to it host PCT (Heart of Birmingham) and the NPSA database, along with other appropriate regulatory bodies. 19 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 3.0Objectives The following are the objectives of incident reporting for BCH: BCH has a statutory duty to report certain kinds of accidents, violent incidents, dangerous occurrences and occupational ill health under the Health and Safety at Work Act 1974 and more specifically in accord with the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) 1995. It is also required to report certain incidents to a national body, e.g. Medicine and Healthcare products Regulatory Agency (MHRA), NHS estates, National Patient Safety Agency (NPSA) and the Counter Fraud and Security Management Service (CFSMS) within a specific timeframe. BCH seeks to promote a positive and non-punitive culture for incident reporting so that individuals and BCH can learn from incidents, so long as there has been no flagrant disregard to the Trust Policies, repetitious incidents, fraud or gross misconduct, or knowingly been involved in an incident but failed to report it or cooperate with the investigation. It is the duty of all staff to be aware of and understand the basic concepts of this and other risk management policies. BCH seeks to ensure that when patients, carers or the public are harmed by the actions of the Trust they will make every effort to be open in explaining what has occurred, and what action can be taken to prevent it happening again. The risk management team within governance services is responsible for ensuring that the incident reporting system is maintained and for producing monthly Directorate summary reports for their review and action. This is complemented with a quarterly Trust report for both Clinical Risk and Quality Assurance Committee and Non Clinical Risk Committee for review and action, which are part of the patient experience reports (incidents, claims, complaints, PALS and participation). Information is passed to the Trust board via the Director of Healthcare Governance & Education and the Chief Medical and Nursing Officers to enable a Trust wide overview of risk management with regards to the wider business of the Trust. 4.0 Duties 4.1 4.2 Trust board To review information provided within the patient experience and exception report To follow up high risks and action appropriately To make recommendations following review of the information provided Trust sub committees Clinical risk and quality assurance committee is responsible for reviewing information provided by the Risk Manager o SUI reports o SUI updates on action plans o Annual audit on all SUI’s Non clinical risk meeting is responsible for reviewing information provided by the Health, Safety and Security Manager o SUI reports o SUI updates on action plans o Annual audit on all SUI’s 20 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 5.3 Chief Executive The chief executive is ultimately responsible for investigations, and ensuring that they are dealt with effectively and appropriately. 5.4 Chief Medical Officer To participate within the review of SUI’s and apply the principles of RCA To encourage all medical staff to report incidents using the BCH system Overall Clinical Risk responsibility 5.5 Director of Healthcare Governance and Education To support the governance team and ensure that the incident reporting system is robust To present to the board any developments within the reporting system To participate within the review of SUI’s and apply the principles of RCA To present the patient experience report to the board To provide the board and executives with updates and developments in appropriate meetings. 5.6 Risk Manager / Health, Safety and Security Manager / Patient Interface Manager / Head of Legal and Corporate Affairs / Moving and Handling Advisor To develop and maintain current reporting systems at BCH To support staff when reporting any type of incident To report to the subcommittees updates on investigations and learning outcomes To provide relevant meetings with area specific reports To provide relevant meetings with a patient experience report To support staff who are undertaking investigations 5.7 Directorate Management Team To support staff when reporting incidents, and enable them to participate in investigations To undertake and follow up action plans as highlighted To report any risks with scores of 20 or 25 within 24 hours or the next following day To include updates on reviews within the appropriate quarterly directorate risk reports. Provide staff with feedback 5.8 All staff To report incidents using the BCH systems To report incidents in a timely manner To escalate high risks within 24 hours or the next working day To undertake training and updates and remain risk aware To undertake and follow up action plans as highlighted To report incidents to the appropriate person, which may require an investigation 6.0Communication and Notification 6.1Patient / Relative / Visitor / Contractors Communication and Support This communication and support process links in with the Trust’s being open philosophy, the PALS and complaints process. Further details can be found in 12.0, the complaints policy and the policy for the delivery of PALS. 21 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 6.2Process by which to raise concerns Staff are referred to: Human Resources Policies including the Whistle blowing Policy. Policy for the delivery of PALS Staff support policy 6.3Internal communication All staff are responsible for ensuring that appropriate information about incidents are communicated to Line Managers, Directorate Management Team and the Risk Manager or Health, Safety and Security Manager in a timely manner. This information will include details of incidents, complaints and claims with action plans. The governance team is responsible for sharing information about complaints, claims and incidents with the Directorates, who in turn share the information with the staff within their area. Further information can be found in the Learning from Experience Strategy. 6.4External stakeholder notification Staff are referred to 9.7. 6.5Media involvement If appropriate, the Executive Director on-call or the Chief Executive will inform the press office and a press statement will be prepared. The press statement will be updated on a regular basis as appropriate. In exceptional circumstances, the Chief Executive may convene a special group to co-ordinate the Trust’s media response. Under no circumstances should any member of staff discuss an incident with the media, without receiving express permission from the Chief Executive or Executive Director on Call. Staff are reminded that they need to inform patient/staff/relatives and other persons (i.e. contractors involved in or affected by the event) before the media as outlined above. 7.0 Completion of incident forms (IR1’s) and linking to the claims and complaints process. Appendix One outlines the process for completing incident forms in detail. The following are the key points: 7.1 Procedural requirements for completing the reporting section of the incident form All incidents, whether they impact on a person, service, property, reputation or finance must be reported using the incident reporting form. Events which are part of a management plan or are expected to occur, that have no adverse effect / near miss do not need to be reported. 22 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 The incident form must be accurate, complete and factual. Include the outcome for the patient or member of staff in terms of harm, or in rare cases, death. Do not give opinions, draw conclusions or make subjective statements. The report must be completed by a member of staff who was involved in or witnessed the event, or by the person to whom the incident is reported to. All forms should be completed within 48 hours. Incidents must not be left in the reporting pad if they require immediate review. Potential SUI’s must be reported within 24 hours or the next working day. Non SUI’s must be reported to line management as indicated. If a potential compliant is highlighted on the incident form, discuss with the parents / patient and inform them of the PALS and complaints process. Inform the Patient Interface Manager if appropriate (refer to the Complaints Policy). If a potential claim is highlighted on the incident form information should be passed to the relevant line manager who will inform the Head of Legal and Corporate Affairs as required. Potential claims which are SUI’s must follow the SUI process. Being Open with patients / parents and staff is vital to ensure effective communications. Support can be obtained from your line manager, or Risk Manager Health, Safety and Security Manager Moving and Handling Advisor Patient Interface Manager Head of Legal and Corporate Affairs. 8.0 Incident investigation Staff are referred to: PART C of the risk management Manual (Investigation / Root Cause Analysis Guidance) which outlines the processes and information needed to undertake an investigation using the principles of root cause analysis. The following is information to compliment PART C of the risk management Manual. A statement writing advice sheet for staff can be found in appendix two. 8.1 Action planning 8.1.1 Action plans and monitoring These can be outlined on the back of the IR1 forms as appropriate, or within a report. Actions should clearly state its aim, by whom and by when it will be completed. The author of the report or IR1 form reviewer is responsible for ensuring that all relevant people are aware of their action points within a timely manner. This person is responsible for following up action points but the lead for the action point is responsible for completing the action and for feedback to the author. Where a concern or issue arises within the action points the author of the action plan should discuss with their line manager or Directorate Management Team in the first instance and if required with the Risk Manager or Health, Safety and Security Manager. The latter will forward the concern to the relevant Trust meeting for discussion. 23 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 8.2.2 SUI action plans These are to be included in the SUI report, with a copy sent to the Risk Manager for inclusion on the central action point database and the CR&QA agenda. The action plan update is presented quarterly with risks discussed and forwarded to the Executive Management Team as required. The database is forwarded to the host PCT (HOB) following this meeting, to ensure that they are kept up to date with actions. The PCT discuss the action plan in their integrated governance meeting and provide feedback to the BCH Risk Manager via the PCT Risk Manager. The action plan should outline all of the actions and recommendations made within the report. It is important to highlight by whom and when the actions will be completed. It is the responsibility of both the SUI chair and the individuals allocated to each action point to ensure that actions are completed within the specified timescale. The Risk Manager is to be kept informed of progress and completion of actions. Appropriate information and concerns are highlighted at the CR&QA committee. SUI chairs are responsible for ensuring that the appropriate personnel are informed of the action and timescale outlined in the SUI action plan. A further action plan in the SUI report should highlight how feedback will be provided to the Trust. If assistance is required with formatting the action plan please contact the Risk Manager. 8.2.3 Process of ensuring continual risk reduction following the implementation of action plans The Risk Manager is responsible for presenting to CR&QA an annual audit of the trends and themes within the SUI action plans. This will highlight any risks which have not effectively been reduced and may require further action to be taken. This audit will also outline repetitious action points in the different SUI’s. Investigation action plans are followed up by the author of the action plan. Where actions taken have not reduced the risk to an acceptable level, information is to be passed in the first instance to their line manager or Directorate Management Team and as appropriate to either the Risk Manager or Health, Safety and Security Manager who will forward the action point to the relevant Trust meeting for discussion. 8.3 Involvement of relevant stakeholders including the process for updating lessons learnt and action taken. BCH has a responsibility to inform external agencies about certain incidents and SUI’s. Some of these incidents may be notified by a specific area or lead practitioner. For example the Coroner, MESH, IRMER, SHOT, Child Protection and so on. It is the responsibility of the person notifying the agency to inform the Risk Manager that this has been completed. For those agencies which have not been notified, it is the responsibility of the Risk Manager and Health, Safety and Security Manager to notify them. It is therefore important that they are informed of the details within 24 hours of the incident or at the start of the following working day. Notification is via a telephone call, with details supplied in an email to the Governance Support Team. On receipt of the information the Risk Manager will inform the host PCT of the SUI and other agencies as highlighted by the SUI. 24 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 The following is a list of agencies which may need to be notified of certain incidents or SUI’s. Other NHS Organisations Health & Safety Executive Healthcare Commission NHS Directorate of Health and Social Care NHS Litigation Authority The Police HM Coroner Social Services Medicines and Healthcare Products Regulatory Agency (MHRA) Health Protection Agencies Head of Corporate Affairs and Legal Services National Patient Safety Agency Other During the SUI process, the host PCT is updated on a quarterly basis, with the SUI action plan update sent to their integrated governance meeting. Following completion of the SUI, all external agencies / stakeholders are sent copies of the final report, following review at the relevant Trust meeting, as indicated by the incident. The reports outline lessons learnt, and action plans to reduce or eliminate future risks. Other information is sent to external stakeholders as highlighted by the individual incident. All staff are responsible for timely reviews and notification of incidents, to ensure that BCH is effective in its communication with its external stakeholders. 8.4 Sharing of lessons learnt The following are some of the methods for sharing lessons learnt at BCH: Method Information Aim By whom Patient experience report Aggregated information on risk, claims, complaints, PALS and patient experience. To provide reports to each Directorate and the Trust to review / encourage learning from an integrated risk management viewpoint. Governance team SUI reports Significant SUI’s are reviewed at either the trust clinical or non clinical risk meetings. To ensure that the process for SUI’s involves the Trust. Risk Manager or Health, Safety and Security Manager Risk Mail Newsletter sent to all departments following completion of SUI’s To share key information and learning points from SUI’s with staff. Risk Manager with support from chair of SUI or appropriate personnel. Risk Alert Newsletter sent to all departments with To share urgent information with staff. Risk Manager with support from 25 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 urgent information highlighted from another part of the risk management process. appropriate senior personnel. Meetings and handovers Line manager or nominated personnel updates on completed investigations to their team and Directorate. To provide feedback to staff and updates on internal reviews and other information cascaded from Directorate meetings. Line Managers and Directorate Management Team, with support from senior personnel in their Directorates. Monthly Directorate risk reports Aggregated risk management information on incidents. To provide feedback to directorate management for action and review. Risk Manager sends reports monthly to DMT. To provide staff information of incidents in their area. DMT cascade information to their staff. Report available on risk management intranet page. Participation from all staff is essential to ensure an effective system for providing feedback to staff and sharing lessons learnt by our experiences at BCH. Staff suggestions for improving these methods are welcome and should be sent to the Risk Manager / Health, Safety and Security Manager on the governance support team email. 9.0 Serious Untoward Incidents (SUI) 9.1 Definition of SUI A serious untoward incident, is described by the Strategic Health Authority ((West Midlands) (SUI policy 2007 – 2008) as: A serious untoward incident (SUI) is an accident or incident when a patient, member of staff (including those working in the community), or member of the public suffers serious injury, major permanent harm or unexpected death (or the risk of death or serious injury) on either premises where health care is provided, or whilst in receipt of health care or, Any event where actions of health service staff are likely to cause significant public concern. Any event that might seriously impact upon the delivery of services and / or which is likely to produce significant legal, media or other interest and which, if not properly managed, may result in loss of the Trust’s reputation or assets. The following are examples of SUI’s and are taken from our host PCT (HOB) incident reporting policy (2007 – 2009) and should be considered as SUI’s at BCH: 26 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Where there is suspicion that a patient was potentially at risk of serious harm as a result of possible negligence or error by a member of directly employed staff or service. Where there is suspicion that a patient may have suffered injury as the result of a deliberate act by a member of directly employed staff, another patient or a member of the public. Where there is suspicion that a patient may have suffered serious harm as a result of faulty procedures, a lack of proper procedures or failure to follow proper procedures. Where there is suspicion of serious harm to a patient, member of directly employed staff, or member of the public, resulting from faulty equipment, drugs or unsafe environment. Where a patient or member of directly employed staff attempts serious harm to themselves on BCH premises. A fire, where damage has occurred and where patients and directly employed staff have been put at risk and / or circumstances are suspicious. Any other serious untoward incident which would not be included within any of the above categories, is to be discussed with the Chief Medical Officer and / or Chief Nursing Officer and / or Director of Healthcare Governance & Education in conjunction with the Risk Manager or Health, Safety and Security Manager. In addition to this list, as highlighted by the Department of Health 2008: Any incident involving the actual or potential loss of personal information that could lead to identity fraud or have other significant impact on individuals. If staff are in doubt about whether or not an incident is an SUI, they should contact the Risk Manager or Health, Safety and Security manager for advice. The process for undertaking an SUI is outlined in part C. Staff have access to a progress report on SUI’s and Trust RCA’s on the Risk Management intranet page. 9.2 The process for reporting / triggering a SUI When a SUI occurs it is important to take action at the time to ensure that the risk is eliminated or reduced as much as possible with this action depending on the individual incident. Appendix three highlights the steps to take to trigger the SUI process which MUST start within 24 hours or the next working day. This includes informing the appropriate regulatory bodies, host PCT and alike within 24 hours or the next working day. Staff are reminded that the following types of incidents MUST also be reported to the relevant lead professionals and their policies followed. Incident types which are not highlighted must be referred as appropriate. Incident type Lead professional Child Protection Infection IRMER Assault / violence Transfusion Lead for child protection Lead consultant for infection control Radiology Manager Health, Safety and Security Manager Blood Bank Manager 27 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Medication Unexpected Death Information Security Chief Pharmacist Lead consultant Head of IM&T 9.3 Information at the start of the SUI process To enable an effective start to the SUI process, brief information MUST be passed to the on call executive and risk manager within 24 hours or the next working day. All Incidents must include relevant information in the following areas: Patient / staff / visitor details Equipment details Service Delivery details Day / date / time of incident Location of incident Description of incident What action was taken at the time of the incident? What follow up action is planned? Whether a) the individuals concerned have been informed, b) a decision has been taken no to inform, c) this has not yet been decided Whether the SUI is in the public domain and the extent of any media interest and / or publication. Who was the incident initially reported to? Incidents which involve information security must also include the following information: Details of how the information was held: paper, memory stick, disc, laptop etc Details of any safeguards such as encryption that would mitigate risk Details of the number of individuals whose information is at risk. Details of the type of information: demographic, clinical, bank details etc Whether a) the information commissioner has been informed, b) a decision has been taken not to inform or c) this has not yet been decided 9.4 SUI Training Training for chairs of SUI’s and incident leads is bespoke and is arranged through the Risk Manager on ext 8959. A basic introduction to SUI’s is included in the new management training programme which is led via the education department. Further information is available in the risk management training needs analysis. 10.0 Incident & Causal Factor Analysis Please also refer to the Learning from Experience policy. 10.1 Responsibility for incident analysis and trend analysis Incident and trend analysis is divided into four levels at BCH. Level one: IR1 reviews at local level, as indicated by the IR1 forms. With the line manager responsible for the risks reported within their area. This type of review is qualitative in nature and forms part of local level discussions and passed to the Directorate Management Team if there are any trends which need inclusion on the Directorate quarterly risk reports for Trust meetings. 28 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Level two: Monthly Directorate risk reports produced by the Risk Manager, with information included from the Health, Safety and Security Manager and Moving and Handling Advisor. These reports are both quantitative and qualitative in nature. They include a rolling monthly statistic review and trend analysis on themes. With these themes further explored and actioned at Directorate level. Information from the Directorate reviews is forwarded to the Risk Manager for inclusion in the appropriate Trust risk management reports. The monthly risk reports are considered at performance reviews. Level three: Quarterly risk management reports produced by the Risk Manager, Health Safety and Security Manager, Moving & Handling Advisor and Patient Interface Manager. These reports are both quantitative and qualitative in nature and discuss any trends which have been identified. These reports form part of level four reviews. Level four: The patient experience report brings together the reports in level three and includes claims, complaints, PALS and patient experience information. The report is complied by the Governance Team on a quarterly basis and is both quantitative and qualitative. This report is discussed further in the Learning from experience strategy. 11.0 Hotline Arrangements In the event of a serious untoward incident involving multiple individuals a “Help line/hotline” service may need to be established. The decision to set up a ‘hotline’ will be made by the Chief Executive Officer, or in their absence, another Executive Director. As per the Major Incident Plan, there are designated telephone lines that can also be used should the need arise. These lines are included on the Hospital backup system and will therefore be available for use in the event of a major switchboard failure. 11.1. Setting up the ‘hotline’ Once the decision has been made that a hotline needs to be set up to deal with enquiries from the public, the Press and Communications Officer, the Risk Manager and the appropriate Director will take responsibility for activating the ‘hotline’. They will also be responsible for identifying a named person to set up the ‘hotline’ room. The control centre for a serious untoward incident will be the A&E seminar room, as per the Major Incident Plan. Out of hours will be arranged via the on call executive with support from the clinical co-ordinators or as otherwise indicated. 11.2. Staffing the ‘hotline’ The Director responsible must ensure that the appropriate staff for the incident manage the telephones, e.g. microbiologist or infection control nurse for enquiries regarding an outbreak of infection query. All staff will be briefed and provided with sufficient information to deal with the queries. Consideration must be given to recruiting adequate staff to manage the queries over the time that telephone calls may be received. This will depend on the type of incident, but the ‘hotline’ may need to be open over several days or weeks. 11.3. Informing the public of the contact number The Communications Officer will be responsible for arranging for the publicising of the ‘hotline’ number to both patients / families and staff. During ‘out of hours’ this responsibility will fall to the Executive Director on call. 11.4. Record keeping and Documentation 29 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Printed forms for recording telephone conversations are detailed in Appendix four and will be utilised to note all calls received and made. Facilities must be in place for collecting and responding to other modes of communication such as e-mails and letters and queries through other modes of communication must be recorded on the forms 11.5. Review of ‘hotline’ arrangements In discussion with the person designated to manage the incident, the Director responsible for the service/Head of service and the Chief Executive, the Risk Manager will decide whether or not to continue to run the ‘hotline’ from the ED seminar room. If another site is considered to be more appropriate, the Communications Officer will take responsibility to ensure that the resources and arrangements are adequate. This will include postal and IT arrangements as indicated. 11.6. Media Contact If appropriate, the Executive Director on-call or the Chief Executive will inform the press office and a press statement will be prepared. The press statement will be updated on a regular basis as appropriate. In exceptional circumstances, the Chief Executive may convene a special group to co-ordinate the Trust’s media response. Under no circumstances should any member of staff discuss an incident with the media, without receiving express permission from the Chief Executive or Executive Director on Call. 12.0 Being Open Central to the Trust’s strategy to improve patient safety is its commitment to improving communication between healthcare professionals / teams and patients and/or carers when a patient is harmed as a result of a patient safety incident. This communication is known as being open (NPSA 2005). Being open involves apologising and explaining what happened. It ensures communication is open, honest and occurs as soon as possible following an incident. Being open about what happened and discussing incidents promptly, fully and compassionately can help patients cope better with the after-effects. Incident refers to: incidents, concerns, complaints and claims. Being open will help to: Establish an environment where healthcare professionals, or patient and/or their carers receive the information they need to enable them to understand what happened and the reassurance that everything possible will be done to ensure that a similar type of incident does not recur; Create an environment where patients and/or carers, healthcare professionals and managers all feel supported when things go wrong. 30 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 The principles of being open are fully supported by the Royal Colleges and professional organisations. If a patient has suffered serious harm, immediate action should be taken to provide prompt and appropriate clinical care and prevention of further harm, if that is possible. When appropriate, an apology should be offered. What has happened should be explained fully and accurately to the patient and/or carers, including information on the likely long and short-term effects. A verbal apology allows face-to-face contact between the patient and their carers and the healthcare team. This should be given as soon as the staff are aware an incident has occurred. It must be recognised that information on an incident that has resulted in serious harm may cause added stress to the patient and/or their carers and potential loss of confidence in the standard of care. Continued and open discussion with the patient and carers is essential. Communication should be timely: patients and/or their carers should be provided with information that is based solely on the facts known at the time. It should be explained that new information may emerge as an incident investigation is undertaken and they should be kept up-to-date with the progress of an investigation. Patients and/or their carers should receive clear, unambiguous information and be given a single point of contact for any questions or requests they may have. They should not receive conflicting information from different members of staff. The use of medical jargon should be avoided at all times. In undertaking such open discussions with the patient and carers, it is important that the criteria detailed in Appendix five are met. Sometimes, despite the best efforts of staff or others, the relationship between the patient, their carers and the healthcare professional may breakdown as a result of the incident. The patient and family may not accept the information provided and may not wish to participate in the process of being open. Consideration should be given to utilising PALS as a mechanism to support the patient/relatives during this process. Information provided should be clear, concise and consistent. Consideration should also be given to the need to use an interpreting service for families’ whose first language is not English. Ensure the patient and/or their carers are aware of the formal complaints procedure. Advice can be obtained from the Patient Interface Manager. A good way to be open and learn from lessons is to use the principles of root cause analysis. Staff are referred to PART C of the risk management Manual. 13.0 Process for monitoring the effectiveness of part B Item for monitoring Being Open Purpose of monitoring Ensure process for encouraging open communication is followed Process for monitoring 100 IR1 Audit. Monitoring by whom and when? Risk Manager. Quarterly. Complaints / Claims – Patient Interface Audit. Manager. Quarterly Ensure that being 100 IR1 Audit. open process is Risk Manager. Monthly. 6 31 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 documented appropriately Incidents Complaints / Claims – Patient Interface ongoing audit. Manager. To ensure incidents Minutes of clinical risk Risk Manager are reported to and quality assurance 6 Monthly. external agencies committee, which demonstrate that papers were sent to Host PCT Risk Manager. SUI audit which demonstrates that all SUIs were reported to the appropriate external agencies (e.g., Host PCT, Monitor etc.) 100 IR1 audit To ensure that the 100 IR1 audit process for reporting is followed To ensure that staff 100 IR1 audit meet their duties to report Risk Manger 6 Monthly. Risk Manager 6 monthly 14.0 References National Patient Safety Agency website: www.npsa.nhs.uk General Medical Council website: Organisation with a memory: Department of Health 2000 32 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 APPENDIX One INCIDENT REPORT FORM PROCEDURAL GUIDELINES 1. Incident Reporting forms All incidents are reported on an IR1 form, contained within the Incident Reporting books. The incident reporting books are held in each Ward/department or Service area. Replacement books can be obtained from the Governance Support Team on ext 8541. 2. Who reports? Any person who is directly employed by the Trust or who is working for the Trust on a temporary, locum, or agency basis, as a contractor or volunteer, including placement students, may complete an incident form. Ideally the person who was directly involved in the incident should report the incident as soon as possible after the event. Where this is not possible a witness or supervisor may complete the incident report. If the incident is reportable under RIDDOR it is the responsibility of the individual’s line manager/supervisor and/or the Head of Service to ensure this incident has been reported. 3. Where do you report? Ideally an incident should be reported on the IR1 form held at the ward/department where the incident occurred or at the nearest locality possible. If an incident reporting book is not available at the time of the incident, please use another department’s and order another book as soon as is practical. 4. Estates Incidents Incidents involving the Estate should be completed by the Estates staff where they are present. If they are not in attendance it is the duty of the individual who first identified the incident to complete the form. 5. Legal Issues Completion of the form does not constitute any admission of liability of any kind on any person. However, completed forms may be requested as part of a freedom of information request, coroner request, complaint, claim or trend analysis. It is therefore essential that they are completed accurately and factually. THE INCIDENT REPORT SHOULD IDENTIFY FACTS NOT OPINIONS AND SHOULD GIVE AN OBJECTIVE AND CLEAR ACCOUNT OF WHAT HAPPENED. Any clinical opinion or professional judgement noted on the form should be clearly separated and identified from the factual evidence. 6. What should be reported? It is the policy of BCH to record all incidents which have resulted in injury or loss or have the potential to do so. However, when interpreting this statement the following must be applied: Common sense – is it an incident? Is it reasonably expected? For example if the event is part of a management plan then it may not be an incident, but if the event results in injury to a person or impacts on patient care or the environment, then it may be an incident. Healthcare acquired infections are incidents and must be reported to infection control and risk management as soon as is practical. 33 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Is it an unexpected outcome and not included in any risk assessment or management plan? It may be an incident. Does the incident come under any regulatory bodies? For example, IRMER, MESH and HSE? These are incidents. Unexpected Death is an incident. Cardiac arrest is an incident. A series of similar events which are graded high or extreme are reportable, until an action plan is put into place and monitored. Environmental contamination is an incident. If in doubt please contact your line manager, or the risk manager on ext 8959 or the health, safety and security manager on ext 8541. 7. Where more than one person is involved In the case of incidents involving more than one person, when reporting via the IR1 form, a form should be completed for each person. For example if there was an incident where 4 people were injured then 4 forms should be completed. 8. Complaints Reference is to be made to the Trust policy on complaints. 9. Defective Equipment The following basic principles are taken from the guidance given by the Medical Devices Directorate at the Department of Health (RIDDOR, 1995). Ensure the patient is safe. Quarantine the device involved in the Incident, including packaging and instructions, where appropriate, and secure safely. If it is a machine, try to leave all switches and controls as they were at the time of the Incident, unless they have to be changed to make them safe. Complete an incident report/IR1 form, giving details and the number of the device. Ensure the device is labelled with a red warning sticker, giving the database ID/IR1 form reference number before reporting and sending to the Medical Devices (engineering) department Do not return the device to the manufacturer before an appropriate person, i.e. medical engineer, examines it. If the item is part of a batch, check the remaining stock and ask if the defect has arisen due to faulty storage. The batch may need to be withdrawn. The Medications and Healthcare Products Regulatory Agency (MHRA) will be notified of adverse Incidents involving devices, equipment or related procedures. The Health and Safety Advisor will normally undertake this action. If a serious incident occurs involving defective equipment/products, any witness to the incident should make a written report and submit to the Health and Safety Advisor. Any device involved in an incident will only be released back into use following a full examination by the medical engineering team and written authorisation by a member of the Governance Support Unit. 10. DELAYED REPORTING THE OUTCOMES OF MANY INCIDENTS ARE IDENTIFIED IMMEDIATELY E.G. BROKEN BONE, DAMAGED EQUIPMENT, FIRE. HOWEVER IT IS JUST AS IMPORTANT TO REPORT INCIDENTS WHERE THE OUTCOMES ARE IDENTIFIED AT A LATER STAGE. 34 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 FOR EXAMPLE A BACK SPRAIN RESULTING FROM MANUAL HANDLING MAY NOT BE APPARENT FOR A FEW DAYS, SIMILARLY A PATIENT WHO DEVELOPS UNEXPECTED PRESSURE TISSUE DAMAGE OR COMPLICATION WHILST IN THE CARE OF BCH. All staff should report delayed incidents as soon as possible and inform the risk manager or health, safety and security manager on the governance support team email as soon as is practical. 11. When should it be reported? The person who first becomes aware of the incident should report the incident on the IR1 form within 24 hours. The IR1 form should then be forwarded to the line manager within 2 working days to enable a local review to take place. The completed IR1 form (including information about the line managers review) is then sent within 2 weeks to the governance support team for review by the risk manager / health, safety and security manager before entry onto the risk management database. Forms which are expected to take longer than 2 weeks to complete, information is to be sent to the risk management team on the governance support team email. Incidents which are major or serious ones, should be immediately reported to the line manager who should IMMEDIATELY inform the Head of Service/Clinical Director (or to the Clinical Coordinator / Executive Director on call during out of hours) and is to be complimented with an IR1 form at the time of the incident. The risk manager, or health, safety and security manager are to be informed as soon as practical. Incidents which require reporting to an external agency MUST be reported to the risk manager or health, safety and security manager as soon as practical to enable statutory requirements to be met. 12. Information to record Detailed instructions on completing the IR1 forms are given on the inside cover of the Incident Reporting form book held in each area. The following sections are included: Section A The type of incident; Section B The individual affected by the incident; Section C Attention offered to the person if appropriate e.g. first aid. The details recorded in this section of the form for patients are in addition to clear and accurate documentation in patient records; Section D Physical Injury - body part affected, nature of incident, apparent cause; Section E Details of the location where the incident occurred and date and time of the incident; Section F An outline of the circumstances of the incident; Section G Any immediate or remedial action that was taken following the incident. This may include removing equipment from use, liasing with patients, relatives or phoning the police; Section H Details of witnesses where appropriate; Admin. Details Name of person reporting the incident; 35 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 13. Where do the forms go? Following completion of an IR1 form, the blue and pink copies should then be removed from the book. Both copies should be sent to the ward/department Line manger within 2 working days, for review on content, grading according to severity and likely hood of reoccurrence. Grading the incident will assist the manager to determine the level of investigation required. Details on the investigation should be detailed on the back of the IR1 form. The Blue copy should be sent to the Governance Support Unit within 2 weeks. The line manager stores the pink copy. The IR1 form is a confidential document and should be treated accordingly, ensuring that it is secured and stored correctly in order to maintain confidentiality. Note: previous IR1s and IR1 books should be treated as confidential and secured and only accessed for legitimate reasons. Alternatively the incident forms and books should be destroyed in accordance with the confidential waste policy. The grey copy should be retained in the IR1 book and secured as confidential information. All IR1 forms received by the Governance Support Unit will be stored as confidential information and retained for 10 years unless the incident relates to: 1. Legal action in which case advice should be sought from the Trust solicitors 2. Exposure to hazardous substances or biological agents which may lead to disease (e.g. asbestos, latex and other respiratory sanitizers, noise) in which case they should be kept for 40 years from the date of entry. It is important that any records retained are properly controlled, readily accessible and available for use to authorised persons, and eventually archived or otherwise disposed of in accordance with best practice guidance and the Data Protection Act. 14. Options for reporting All directly employed staff are encouraged to report ‘near miss’ Incidents using the above system with completion of the incident forms. In circumstances where an individual feels awkward about reporting a sensitive incident or near miss (for example in cases of whistle blowing), telephone contact can be made direct to the Risk Manager or Health, Safety and Security Manager to highlight the incident. Directly employed staff must be aware that if the issue is serious the Risk Manager may be required to discuss the situation with other Trust managers to ensure that prompt action was taken. Reporting in this way may be applicable where the situation is sensitive and a member of directly employed staff requires advice on how to manage the incident. However situations where anonymous reporting would be appropriate are very rare. 15. Losses The form can be used to record losses of property that may also result in payment of compensation subject to the Trust’s Standing Financial Instructions. In addition to completing sections A, B, E, F, and G on the IR1 form, it is also necessary to include the owner of the property i.e. Trust or named individual, a full description of the item stolen with its purchase price and current value and any steps that have been taken to repair/replace items. Completion of an incident report form in no way guarantees that a payment will be made to a claimant. Each report will be thoroughly investigated to determine whether or not the Trust was liable for the property, whether the Trust acted negligently and whether there was an actual loss. 36 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 16. Fire Incidents In the case of fire incidents the information given on the form must include the following: False alarms or actual fire Method used to raise the alarm Whether evacuation occurred and to what extent Any method used to fight the fire e.g. extinguisher, hose reel Whether the Fire Service attended The materials that first ignited The cause and spread of the fire if known This reporting system does NOT affect the need to involve the Fire Safety Advisor. This must continue in line with the Trust’s Fire Policy. 37 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Appendix 2 GUIDELINES FOR PREPARING AND WRITING STATEMENTS It is hoped that these guidelines may be helpful to staff who are asked to provide written statements which relate to: legal claims complaints adverse incidents General o o o At all times statements must be factual and exclude personal opinions, unless these have been specifically requested, and emotional statements They should follow the order in which the events occurred Always check your statement before you hand it in. Help may be obtained from a variety of sources, for example your line manager, colleague, union representative or other of your choice. Remember to send your statement in by the requested time. This helps to ensure that reviews are completed as quickly as possible. If you are unable to complete the statement by the stated time, please inform the requestor, and provide a new date for submission (exceptional circumstances). It is good practice to refer to case notes or other documentation when writing statements. If you are writing something from memory, please state this in your statement. Recommended format 1. state your present:: 2. if different from the above, give the following information as it applied when the incident / events that are under investigation occurred: 3. name address [if not still employed by the Trust] position relevant qualifications at the time how long you had occupied that post relationship to patient: e.g. named nurse, ward manager, Consultant/doctor on take, Consultant in charge of patient, radiographer, physiotherapist etc. provide a narrative of the events - this does not need to be elaborate, just keep to the facts and in date and time order state: 4. name address or location in the hospital position relevant qualifications how long you have been in the post how you can be contacted most easily when and what you did and why where relevant, identify your contributions to nursing or medical notes - add an explanation if you feel there is any doubt as to what you meant by the entries Sign, date and time of writing statement Remember: STATEMENTS ARE NOT ABOUT ATTRIBUTING BLAME : THEY ARE ABOUT ESTABLISHING WHAT HAPPENED 38 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Appendix 3 Flowchart for triggering a Serious Untoward Incident (SUI) Potential SUI occurs as described in the policy Information about a potential SUI is highlighted post incident Take immediate action as highlighted by the incident or information Inform Line Manager ASAP Inform DMT or Clinical Co-ordinator ASAP Information passed to executive risk team for consideration and to determine type of review Department review Trust RCA review Inform Risk Manager (x8959) within 24 hours or the next working day Regulatory bodies and Host PCT informed of incident. SUI 39 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 APPENDIX 4 FORM A Incident ‘Hotline’ documentation form (Patient/Relative) Call No: ……. Date: ………. Time: …………. Recipient:: …………………. CALLER DETAILS Caller's Name: .......................................................................……....................……… Caller's Address: ......................................................….............................………………………………… ………………………………………………………………………………………………… ...................................……............................................................................………… ....................................……............................................................................………. ……………………………………………………………………………………………….. Caller's Telephone Number Home: ...........……...........................................……. Work: …….....................................................….….. Is caller a patient (P) or relative(R): .......……...................................................………... If relative name and address of person they are calling on behalf of: ..........................................................…….......................................................…… ...................................................…….............................................................……. ....................................……............................................................................…… ....................................……............................................................................…… ....................................……............................................................................……… DETAILS OF ENQUIRY Nature of query: ..................…….....................................................................……… ....................................……............................................................................……… ....................................……............................................................................……… ....................................……............................................................................……… 40 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 ....................................……............................................................................……… ....................................……............................................................................……… ....................................……............................................................................……… ....................................……............................................................................……… Information given: ….....................................................................................………….. ................................................................................................................…………… ................................................................................................................…………… ………………………………………………………………………………………………… ....................................……............................................................................…… ....................................……............................................................................……… Any other relevant information e.g. questions asked that you could not answer: ………............................................................................................................………… .....................................................................................................………..................… ................................................................................................................……….......… Does patient need appointment? Yes/No Would patient like to speak to someone else? Yes/No Would patient like copy of information sheet? Yes/No Information (if appropriate) about how the Trust will handle the enquiry and feedback mechanisms ……………………………………………………………………………………….………………………… ……………………………………………………………….………………………………………………… ……………………………………….………………………………………………………………………… ………………………………………… How would you like to be contacted in future? Telephone: Yes / No Letter: Yes / No Meeting: Yes / No Nil: Yes / No 41 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Trusts Direct Telephone Number is (0121) 333 9999 Any other comments to note: ………………………………………………………………………………………………………………… ………………………………………………………………………………………………………………… ………………………………………………………………………………………………………………… ………………………………………………………………………………………………………………… ………………………………………………………………………………………………………………… ………………………………………………………………………………………………………………… ………………………………………………………………………………………………………………… ………………………………………………… Signature: ____________________ Name (in block capitals): ____________________ Designation: ____________________ 42 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 FORM B Incident ‘Hotline’ documentation form (G.P’S) Call No: ……. Date: ………. Time: …………. Recipient: …………………… Name of GP:........................................................…………..................................…… Address of surgery: .........................................................................……….......…… ………………………………………………………………………………………………… ………………………………………………………………………………………………… ………………………………………………………………………………………………… Contact tel. No: ……..................................................................................……… Fax No.: ……..................................................................................……… Information required: ……................................................................................………........................... ................................................................................................................………… ................................................................................................................………… ................................................................................................................………… If information about individual patients required please take details Name: .................................................................... Date of Birth: ............…………… Address:...................................................................................................…….……… .................................................................................................................…….……… .................................................................................................................…….……… NHS No if known: ......................................................................................…….……. Consultant if known: ..................................................................................…….……. Signature: Name (in block capitals): Designation: ____________________ _______________________________ ____________________ 43 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 FORM C Incident ‘Hotline’ documentation form (Media feedback) Call No: ……. Date: ………. Time: …………. Recipient: ………………….….. Name of Caller: ..................................................................................…………............. Who does caller work for?:.............................................................................……… News organisation: .........................................................................................……. Fax: .........................................................................................…… Nature of query? ............................................................................................................................................................. ............................................................................................................................................................. ....................................................................................................................................................…..… …………………………………………… Information given: ............................................................................................................................................................. ............................................................................................................................................................. ............................................................................................................................................................. ............................................................. Broadcast/story filing requirements: ............................................................................................................................................................. ............................................................................................................................................................. ............................................…..…..……............................................................................................... ...............…........................................................................................................................................... .................................... Signature: Name (in block capitals:) Designation: ____________________ _______________________________ ____________________ 44 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 FORM D Incident ‘Hotline’ documentation form (Other Organisations) Call No: ……. Date: ………. Time: …………. Recipient:: ……………….….. Name of caller: ....................................................…………......................................... Organisation: .....................................................................…………........................... Contact No. Tel: ..........................................................................……….................... Fax: ....................................................................................………......... Nature of query: ............................................................................................................................................................. ............................................................................................................................................................. ............................................................................................................................................................. .................….….................................................................................................................................... ............................................................................................................................................................. ............. Information given: ............................................................................................................................................................. .............................................................................….…........................................................................ ............................................................................................................................................................. ..........….…........................................................................................................................................... ....................................................................................................….…................................................. ..............................................................................…………………………………………..…………… ……………………………..….………...…………………………………………… Signature: Name (in block capitals): Designation: ____________________ ____________________ ____________________ 45 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Appendix 5 Quick reference guide to Being Open Apologising and explaining when patients have been harmed can be very difficult. You may have already considered some or all of the recommendations below, but this guide will help ensure that you follow best practice. Patients and/or their carers should receive an apology as soon as possible after a patient safety incident has occurred and staff should feel able to apologise on the spot. Saying sorry is not an admission of liability and it is the right thing to do. Patients have a right to expect openness in their healthcare. The key points to remember are: Truthfulness Clarity of communication Timeliness. Documentation of communication Stage 1: preliminary meeting with the patient and/or their carer Who should attend? A lead staff member who is normally the most senior person responsible for the patient’s care and/or someone with experience and expertise in the type of incident that has occurred. Ensure that those members of staff who do attend the meetings can continue to do so; continuity is very important in building relationships. The person taking the lead should be supported by at least one other member of staff, such as the risk manager, nursing or medical director, or member of the healthcare team treating the patient. Ask the patient and/or their carers who they would like to be present. Consider each team member’s communication skills; they need to be able to communicate clearly, sympathetically and effectively. Hold a pre-meeting amongst healthcare professionals so that everyone knows the facts and understands the aims of the meeting. When should it be held? As soon after the incident as possible. Consider the patient’s and/or their carer’s home and social circumstances. Check that they are happy with the timing. Offer them a choice of times and confirm the chosen date in writing. Do not cancel the meeting unless absolutely necessary. Where should it be held? Use a quiet room where you will not be distracted by work or interrupted. Do not host the meeting near to the place where the incident occurred if this may be difficult for the patient and/or their carers. 46 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Stage 2: Discussion How should you approach the patient and/or their carers? Speak to the patient and/or their carers as you would want someone in the same situation to communicate with a member of your own family. Do not use jargon or acronyms: use clear, straightforward language. Consider the needs of patients with special circumstances, for example, linguistic or cultural needs, and those with learning disabilities. What should be discussed? Introduce and explain the role of everyone present to the patient and/or their carers and ask them if they are happy with those present. Acknowledge what happened and apologise on behalf of the team and the organisation. Expressing regret is not an admission of liability. Stick to the facts that are known at the time and assure them that if more information becomes available, it will be shared with them. Do not speculate or attribute blame. Suggest sources of support and counselling. Check they have understood what you have told them and offer to answer any questions. Provide a named contact who they can speak to again. Stage 3: follow-up and documentation Clarify in writing the information given, reiterate key points, record action points and assign responsibilities and deadlines. In respect of IR1 incidents, the patient’s notes should contain a complete, accurate record of the discussion(s) including the date and time of each entry, what the patient and/or their carers have been told, and a summary of agreed action points. For complaints / claims information will be documented within the specific file. Maintain a dialogue by addressing any new concerns, share new information once available and provide information on counselling, as appropriate. Indicate on the IR1 form when the being open process has been commenced. If appropriate inform the Patient Interface Manager, Legal and Corporate Affairs Manager, or Risk Manager that the being open process has been commenced. 47 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Investigations Root Cause Analysis PART C 1.0 Forward This guidance policy has been produced to support staff undertaking an investigation using root cause analysis (RCA) principles and is a part of the Risk Management Manual. It is acknowledged that each investigation will be individual, but the basic concept of the RCA framework must be applied. Staff are referred to Part B of the risk management Manual which includes information to compliment RCA and the process for following up action plans. The aim of this guidance policy (part C) is therefore: To outline the concept of RCA To outline the process for investigations of incidents, complaints and claims Provide an outline of the possible tools staff may use for an investigation The Trust makes reference to the NPSA website which provides staff with RCA information and a teaching package to explain the tools. Full details of staff training can be found in the risk management training needs analysis. WWW.NPSA.NHS.UK 2.0 Introduction / Why are investigations necessary? Investigations are an important part of learning from our experiences and sharing lessons learnt. That is, they provide valuable information on lessons learnt and what we do well. This in turn helps to improve the quality of care and service delivery we provide at BCH and help to promote and develop its ‘open, just and fair blame’ environment. BCH encourages staff to use the principles of RCA for all investigations and reviews because using RCA principles provides staff with a systematic methodology to ensure that all aspects of the incident / claim / complaint are reviewed and that important aspects are not ignored. To utilise the benefits of RCA, the BCH promotes its use in all types of incidents, claims and complaints. This includes; clinical, non clinical, finance, strategic, reputation and operational risks. This approach will enable the Trust to comply with its terms of authority, its objectives and targets. Investigations and RCA is therefore a key component for ensuring that the hospital provides high quality care and service delivery. 3.0 What is a root cause and root cause analysis? 48 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 A root cause is a fundamental cause, if resolved will eliminate or reduce the highlighted risk or problem. For example, a root cause may illustrate a need for clearer communication lines. Root causes can be summarised into the following sections: Root causes are Underlying causes Those that can reasonably be identified Those over which management has control Those for which effective recommendations can be generated. There are many academic definitions of what root cause analysis is, but in essence it is a process that enables the root causes to be identified and then used to reduce future risks. The following is one examples of RCA definitions: “RCA “is a retrospective review of a patient safety incident undertaken in order to identify what, how and why it happened. The analysis is then used to identify areas for change, recommendations and sustainable solutions, to help minimise the re-occurrence of the incident type in the future.” (RCA training and tool kit section from the NPSA website.) It can therefore by concluded that RCA is asking the following questions: What happened? Why did it happen? How did it happen? What can we learn from it? The above therefore forms the core element of investigations at BCH, and should be reflected in any investigation undertaken. This will enable BCH to learn from its lessons and help to avoid similar events in the future. This is in conjunction with governmental developments and the National Patient Safety Agency (NPSA) recommendations. 4.0 When do I do a RCA review? All investigations/reviews should apply the principles of RCA, with these investigations originating from one of the following (this is not an exhaustive list). Review for an IR1 form Serious Untoward Incident review Complaints Claims Operational / Business review Finance review Participation review Investigations may take the form of a general review undertaken by any member of staff, or be more formal, requiring an RCA meeting. The following sections outline how the principles may be used for an IR1 investigation, SUI or complaint. Claims are outlined in the Claims Handling Policy and Procedure, with support provided by the Head of Legal and Corporate Affairs. 49 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 5.0 IR1 forms and RCA reviews The ward / area or specialty manager is responsible for ensuring that IR1 incidents are ‘sifted’ appropriately and that detailed reviews are limited to those which require them. The following matrix demonstrates what type of review should be considered when an incident occurs. Please refer to the PART B and D of the risk management Manual for further information on the matrix and definitions. Likelihood x Severity Rare – Not in next 5 years Unlikely – Once in every 3 to 5 years Possible – once or twice a year Likely – once or twice a month Almost Certain – more than once a week. Insignificant 1 Minor 2 Moderate 3 Major 4 Catastrophic 5 2 4 6 8 10 3 6 9 12 15 4 8 12 16 20 5 10 15 20 25 SEVERITY GREEN TYPE OF REVIEW General review using RCA principles LEVEL OF STAFF AS REVIEW LEAD Any appropriate member of staff who has attended governance or other relevant training YELLOW RCA report ORANGE RCA report or RCA meeting with report Line managers who have attended governance or other relevant training Area / ward / specialty managers senior medical staff RED SUI process, including RCA review / report Governance Team Reviews and reports may be delegated to another member of staff, but ultimate responsibility remains with the highlighted staff type in the table above. If you are unsure and require support, please contact: Risk Manager Health, Safety and Security Manager Moving & Handling Advisor Patient Interface Manager Head of Legal and Corporate Affairs Staff are referred to the supporting staff policy for information on staff/patient and relatives support. 50 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 5.1 The process for undertaking an RCA review / investigation at Directorate and Department level The process for undertaking an investigation using RCA principles has been divided into two to aid the flow of the information in this guidance. Please note, that some investigations may require a combination of both. Please remember to complete the RCA within a timely manner, to ensure that actions are completed and risks for future incidents are reduced as quickly as possible. This will require effective communications which will enable the lessons learnt to be shared and the principles of Being Open to be followed. Reference is made to the investigation part (PART B) of the risk management Manual. 5.2 Using RCA principles to write a report or to complete the IR1 form investigation part (with NO formal RCA meeting required) (LOW SEVERITY incidents) 1. Identification of the event which requires an investigation. IR1’s which are significant MUST be notified to your line manager and Risk Manager within 24 hours, or the next working day. A serious untoward incident may be commenced. Please refer to part (B) 2. Identification of person to complete the investigation, write the report and follow up action plans. 3. Data collection a. Statements (Part B, appendix 2 for statement writing advice sheet for staff) b. Policies / Procedures c. Case notes d. Other documents e. Discussions with relevant staff or external agencies/stakeholders When requesting information from staff, consider sending the RCA staff information leaflet (different versions of this leaflet can be found on the risk management intranet page). 4. Use the tools outlined in section 6.0, which are applicable to your investigation. Remember to keep any relevant documents. 5. The format for your findings will depend on the type of investigation which you are carrying out. A basic IR1 review may only require a few sentences or paragraphs on the back of the IR1 form. A more general review will require a report to be written, with the detail depending on the incident (Don’t forget to acknowledge good practice in your report). 6. Investigations require actions and recommendations to be made, which will need a lead person and time scale for completion identified. Actions should be sustainable, realistic and cost effective. The author of the report is responsible for ensuring that all risks are followed up, but the identified lead for each action point is responsible for completing the action. Actions which have a significant risk attached to them must be passed to the Risk Manager for inclusion on the agenda of either Clinical Risk and Quality 51 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Assurance or Non Clinical Risk Committee. Line Managers must be kept informed of key action points and their progress. 7. It is good practice to discuss your report or findings at staff handovers, meetings and alike. Minutes of meetings will need to reflect any discussions and action points. This will enable the staff to feel part of the process and learn from others experiences. Consider one to one feedback of lessons learnt with staff involved in the incident, this may be in person or a summary letter. Key points which have lessons to share with the rest of the Trust should be forwarded to the Risk Manager. These will be included within a risk alert and sent to all areas within the Trust. 8. Enter any highlighted risks onto the appropriate risk register. Risks with scores of 20 or 25 must be forwarded to the Directorate Management Team and Risk Manager within 24 hours or the next working day. These high risks are forwarded to the appropriate Trust meeting for discussion and / or review by the Risk Manager, which will compliment the work undertaken at local level. Items on the risk register must follow the process outlined in Part D. 9. Following completion of the action plan, a review of the original risks is required to determine if the action taken was effective and that the residual risk score is acceptable. Additional action plans are to be used where required. 5.3 Investigations which require a RCA meeting and formal report: 1. Identification of an event which requires a RCA meeting. Reference is made to the investigation policy (Part B) within the Risk Management Manual, which outlines what an incident is, and when it may be a serious untoward incident. Do any external agencies need to be informed of the incident and RCA review? If yes, inform the Risk Manager as soon as possible. 2. Identification of lead personnel a. Identify a person to co-ordinate the RCA meeting and write up the report. b. Identify who the chair of the meeting is, and involve them in the pre meeting preparations. It is good practice to consider a chair from a different area / specialty. 3. Data collection to prepare the pre – meeting reading and for the meeting a. Statements b. Policies / Procedures c. Case notes d. Other documents e. Discussions with relevant staff or external agencies/stakeholders 4. Identify staff to attend the meeting a. It is good practice to have a representatives from each area / speciality involved b. A member of staff from a different area / speciality should be considered. 5. Consider inviting the patients and / or relatives. This links in with the Trust’s being open policy and complaints policy. 52 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 6. Consider the involvement of external agencies within the investigation process. 7. Send pre – meeting information to attendees. 8. RCA session a. Consider which tools may be applicable for the meeting / review b. Identify the key contributory factors and actions / recommendations required (see appendix 1) 9. Write up the RCA report a. Identify the contributory factors (this may include using some of the RCA tools in your report) b. Identify action points and recommendations (with leads and timescale for completion). Actions should be sustainable, cost effective and realistic. c. Consider writing a summary sheet for the report, to circulate to staff and / or patients for an update on the investigation. (This links in with Part B and Being Open). 10. Follow up action plans and report updates to appropriate meetings. The author of the report is responsible for ensuring that all risks are followed up, but the identified lead for each action point is responsible for completing the action. Actions which have a significant risk attached to them must be passed to the Risk Manager for inclusion on the agenda of either Clinical Risk and Quality Assurance or Non Clinical Risk Committee. 11 It is good practice to discuss your report or findings at staff handovers, meetings and alike. Minutes of meetings will need to reflect any discussions and action points. This will enable the staff to feel part of the process and learn from others experiences. Consider one to one feedback of lessons learnt with staff involved in the incident. Key points which have lessons to share with the rest of the Trust should be forwarded to the Risk Manager. These will be included within a risk alert and sent to all areas within the Trust. 12 Enter highlighted risks onto the Risk Register. Risks with scores of 20 or 25 must be forwarded to the Risk Manager and Directorate Management Team within 24 hours or the next working day. 13 Following completion of the action plan, a review of the original risks is required to determine if the action taken was effective. Additional action plans are to be used where required. 14. Support for RCA meetings can be obtained from: Risk Manager Health, Safety and Security Manager Patient Interface Manager Moving and Handling Advisor Head of Legal and Corporate Affairs 53 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 6.0 TRUST RCA REVIEWS by Risk Manager and Health, Safety and Security Manager. Trust RCA reviews form part of the serious untoward incident review process. They follow the same format as above (point 5.0). Completed reports are forwarded to Clinical Risk and Quality Assurance, or Non Clinical Risk Co-ordinating Committee every quarter for discussion and review. These reports are followed up every quarter until completion of all action points. The action up date information is presented in an excel sheet format, and uses a colour coding system to highlight actions within or outside of the time scale for completion. This is complemented by an annual audit of all significant reviews, to determine trends and themes, and is completed by the Risk Manager and presented to Clinical Risk and Quality Assurance Agenda, or Non Clinical Risk Co-ordinating Committee. The board is informed of the above information via the minutes of the relevant meetings and via an exception report which highlights the key points from SUI’s. Key points are highlighted in the board meetings by the relevant Director or Chief Officer. This information, along with completed reports is forwarded to BCH’s host PCT and is discussed at the PCT integrated governance meeting. Highlighted risks are entered onto the risk register and follow the procedure outlined in PART D. 6.1 SUI / RCA reviews and information security This type of RCA review must include the following information as highlighted by the Department of Health. This information MUST be forwarded to the appropriate on call Executive (out of hours) and the Risk Manager (in office hours) within 24 hours or the next working day. A short description of what happened, including the actions taken and whether the incident has been resolved. Details of how the information was held: paper, memory stick, disc, laptop etc Details of any safeguards such as encryption that would mitigate risk Details of the number of individuals whose information is at risk. Details of the type of information: demographic, clinical, bank details etc Whether a) the information commissioner has been informed, b) a decision has been taken not to inform or c) this has not yet been decided Whether a) the individuals concerned have been informed, b) a decision has been taken no to inform, c) this has not yet been decided Whether the SUI is in the public domain and the extent of any media interest and / or publication. 7.0 RCA reviews and complaints The investigations conducted in line with the NHS Complaints Procedure should follow the RCA guidance contained within this document and should use the standard investigation report format as detailed in the Complaints Policy. The investigation can take the form of a report and/or a meeting with the family. The main points to consider during this type of investigation are: Underlying causes, i.e. what happened? When? Where and why? What can we learn from it and what recommendations can be generated? Clearly identify what (if anything) went wrong in line with ‘Being open’; Clearly identify good practice; Clarify any points with the complainant; 54 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Complete the investigation in a timely manner; Ensure accuracy in the content of the report; Utilise any documents to ensure a comprehensive investigation e.g. o Statements from the staff involved o Medical notes o Policies and Procedures o Other documents Use the tools outlined in section 8.0, which are applicable to your investigation. Remember to keep any relevant documents. Consider whether the issues identified require escalation and consider whether any risks have been highlighted that require registration. Request for investigations are sent the relevant Directorate Management Team or Head of Department. This person will then determine the appropriate member of staff to undertake the review, depending on the severity of the complaint. The matrix in 5.0 is to be used as a guide. Should you require any assistance with the investigation, help and guidance can be sought from the Patient Interface Manager. 8.0 RCA reviews and claims Staff are referred to the Policy and Procedures for Claims Management. 9.0 Suggested tools for RCA reviews There are many tools and techniques for RCA sessions. The following are brief introductions and suggestions: 1. 2. 3. 4. 5. 6. 7. chronology of events brainstorming cause and effect diagrams fishbone diagram timelines time person grid summary of the above Staff are referred to the NPSA website which has a tool kit for staff to gain more knowledge on RCA and the tools available. 9.1. Chronology of events: A descriptive account of the risk / problem. This may be taken from the case notes, statements and alike. A chronology of events given to participants at the start / before the session is useful; however, the session may be concerned with seeking others opinions on the chronology of events so may be done during the session. A chronology of events is sometimes a good way to start a RCA report. 9.2 Brainstorming Brainstorming is a group of people highlighting their suggestions or concerns / a process designed to obtain the maximum number of ideas relating to a specific area of interest. The aim is to end up with a list of raw ideas to use later on in the session. 55 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Ideally a brainstorming activity (if appropriate) should be undertake towards the start of the meeting. 9.3. Cause and effect & fishbone diagrams A cause and effect diagram is a tool that helps identify, sort and display possible causes of a specific problem. It graphically illustrates the relationship between a given outcome and all the factors that influence the outcome. This type of diagram is sometimes called an “Ishikawa diagram” because it was invented by Kaoru Ishikawa, or a ‘fishbone diagram’ because of the way it looks. Constructing a cause and effect diagram can help your team when you need to: identify the possible root causes, the basic reasons, for a specific effect, problem or condition. Sort out and relate some of the interactions among the factors affecting a particular process of effect. Analyze existing problems so that corrective action can be taken. The following is the basic layout of a cause and effect diagram: CAUSE A CAUSE B EFFECT CAUSE C CAUSE D Some risks / problems may benefit from using the NPSA fishbone diagram, as below: 56 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Help with categories for the fishbone diagram can be found in appendix one. If the diagram is not appropriate to your review or meeting, consider using the headings to divide the meeting review or report into sections. 9.4.Timelines A timeline tracks the incident and allows the investigator to discover any parts of the process where problems may have occurred or there are gaps in the events. An example may include: Prepare drugs Prepared Medications 12 noon disrupted 12.45pm Patient dies 1.45pm Wrong medication given 1.15pm Respiratory arrest 1.30pm 9.5 Time person grid This allows you to graphically put together what happened during a short time period and is good for highlighting in a report specific items and timings. 57 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Mary John 12.00 12.15 12.30 12.45 Admitted patient Buzzer …… ….. Answers buzzer 9.6 Summary of key points for RCA tools The following are a few of the pros and cons for each of the above tools: Chronology of events Tells the story of what happened in a logical format. Key points may get lost. Brainstorming Quick Can be unstructured and strong characters dominate Timelines Can view the event in one diagram Difficult to use for long time period Time person grid Can see where people are Person focused Cause & effect Good if problem areas are known Specific and may limit the review Fishbone 9 contributory factors in one tool Can use headings as topics for discussion General and time consuming. 58 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 10.0 STAFF RESPONSIBILITIES 10.1 Trust board To review information provided within the patient experience and exception report To follow up high risks and action appropriately To make recommendations following review of the information provided 10.2 Trust sub committees Clinical risk and quality assurance committee is responsible for reviewing information provided by the Risk Manager o SUI reports o SUI updates on action plans o Annual audit on all SUI’s Non clinical risk meeting is responsible for reviewing information provided by the Health, Safety and Security Manager o SUI reports o SUI updates on action plans o Annual audit on all SUI’s 10.3 Chief Executive The chief executive is ultimately responsible for investigations, and ensuring that they are dealt with effectively and appropriately. 10.4 Chief Medical Officer To participate within the review of SUI’s and apply the principles of RCA To chair RCA reviews as appropriate Overall Clinical Risk responsibility 10.5 Director of Healthcare Governance and Education To support the governance team and ensure that investigations are carried out appropriately To present the exception report to the board. To present the patient experience report to the board To provide the board and executives with updates and developments in appropriate meetings. To chair RCA reviews as appropriate 10.6 Risk Manager / Health, Safety and Security Manager / Patient Interface Manager / Head of Legal and Corporate Affairs / Moving and Handling Advisor To undertake Trust investigations as required To report to the subcommittees updates on investigations and learning outcomes To provide relevant meetings with area specific reports To provide relevant meetings with a patient experience report To support staff who are undertaking investigations 10.7 Directorate Management Team To support staff, and enable them to participate in investigations To undertake and follow up action plans as highlighted To report any risks with scores of 20 or 25 within 24 hours or the next following day To include updates on reviews within the appropriate quarterly directorate risk reports. Provide staff with feedback 59 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 10.8 Role of co-ordinators and chairs To participate within investigations as highlighted, to ensure that reports and meetings are undertaken with action plans followed up To forward any risks or action plan points to the Risk Manager and their line manager as appropriate To report any risks with scores of 20 or 25 within 24 hours or the next following day. To undertake training and updates on investigations 10.9 All staff To participate in investigations as required To undertake training and updates on investigations To undertake and follow up action plans as highlighted To report incidents to the appropriate person, which may require an investigation Incidents, complaints and claims are jointly reviewed within the patient experience report. 11.0 Monitoring of the effectiveness of Part C. Item for monitoring Staff duties Purpose of monitoring To ensure that investigations use RCA principles. Process for monitoring Annual review of SUIs. Monitoring by whom and when? Governance team Annual Different levels of investigations To ensure investigations are appropriate to the severity of the incident Other incidents are reviewed in the 100 IR1 audit and SUI annual review. Governance team Process for following up relevant action plans To ensure closure of action points and that they are followed up appropriately. SUI action update taken to CR&QA Risk Manager Quarterly. Sharing safety lessons with stakeholders To ensure that they are communicated internally and externally. Trust Risk Reports, will outline key lessons learnt and with whom Risk Manager Quarterly. Review of 100 IR1 forms Annual Review of SUIs. 12.0 References Tool kit for RCA training: National Patient Safety Agency Website: www.npsa.nhs.uk 60 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Appendix 1: RCA contributory factor classification framework Individual Factors Individual Factors Physical issues Components General Health (e.g. nutrition, diet, exercise, fitness) Physical disability (e.g. eyesight problems, dyslexia) Fatigue Stress (e.g. distraction/preoccupation) Specific mental health illness (e.g. Depression) Mental impairment (e.g. illness, drugs, alcohol, pain) Motivation (e.g. boredom, complacency, low job satisfaction) Cognitive factors (e.g. attention deficit, distraction, preoccupation, overload and boredom) Domestic/lifestyle problems Low self confidence/over confidence Gregarious/interactive, reclusive Risk averse/risk taker Psychological Issues Social Domestic Personality Issues Team and Social Factors Team Factors Role Congruence Leadership Support and cultural factors Components Is there parity of understanding Are role definitions correctly understood Are roles clearly defined Is there effective leadership – clinically Is there effective leadership – managerially Can the leader lead Are leadership responsibilities clear and understood Is the leader respected Are there support networks for staff Team reaction to adverse events Team reaction to conflict Team reaction to newcomers Team openness Communication Factors Communication Factors Verbal communication Components Written communication Non verbal communication Verbal commands / directions unambiguous Tone of voice and style of delivery appropriate to situation Correct use of language Made to appropriate person(s) Recognised communication channels used (e.g. head of service) Are records easy to read Are all relevant records stored together and accessible when required Are the records complete and contemporaneous (e.g. availability of patient management plans, patient risk assessments, etc) Are memo’s circulated to all members of team Are communications directed to the right people Body Language issues (closed, open, aggressive, relaxed, stern faced) 61 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Task Factors Task Factors Guidelines Procedures and Policies Decision making aids Procedural or Task Design Components Up-to-date Available at appropriate location (e.g. accessible when needed) Understandable / useable Relevant; Clear; Unambiguous; Correct Content; Simple Outdated; Unavailable/missing; Unrealistic Adhered to / followed Appropriately targeted ( e.g. aimed at right audience) Availability of such aids e.g. CTG machine, risk assessment tool, fax machine to enable remote assessment of results Access to senior / specialist advice Easy access flow charts and diagrams Complete information - test results, informant history Do the guidelines enable one to carry out the task in a timely manner Do staff agree with the ‘task/procedure design’ Are the stages of the task such that each step can realistically be carried out Education and Training Factors Education and Training Competence Components Supervision Availability / accessibility Appropriateness Adequacy of knowledge Adequacy of skills Length of experience Quality of experience Task familiarity Testing and Assessment Adequacy of supervision Availability of mentorship Adequacy of mentorship On the job training Emergency Training Team training Core skills Training Refresher courses Content Target audience Style of delivery Time of day provided 62 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Equipment and Resources Factors Equipment Displays Integrity Positioning Usability Components Correct information Consistent and clear information Legible information Appropriate feedback No interference Good working order Appropriate size Trustworthy Effective safety features Good maintenance programme Correctly placed for use Correctly stored Clear controls User manual Familiar equipment New equipment Standardisation Working Conditions Work Environment Factor Administrative factors Component Design of physical environment Environment Staffing Work load and hours of work Time The general efficiency of administrative systems e.g. reliability Systems for requesting medical records Systems for ordering drugs Reliability of administrative support Office design: computer chairs, height of tables, anti-glare screens, security screens, panic buttons, placing of filing cabinets, storage facilities, etc. Area design: length, shape, visibility, cramped, spacious Housekeeping issues – cleanliness Temperature Lighting Noise levels Skill mix Staff to patient ratio Workload / dependency assessment Leadership Use Temporary staff Retention of staff / staff turnover Shift related fatigue Breaks during work hours Staff to patient ratio Extraneous tasks Social relaxation, rest and recuperation Delays caused by system failure or design Time pressure 63 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Organisational and Strategic Factors Organisational Factor Organisational structure Priorities Externally imported risks Safety culture Patient Factors Clinical condition Social factors Physical factors Mental/ psychological factors Interpersonal relationships Components Hierarchical structure, not conducive to discussion, problem sharing, etc. Tight boundaries for accountability and responsibility Clinical versus the managerial model Safety driven External assessment driven e.g. Star Ratings Financial balance focused Locum / Agency policy and usage Contractors Equipment loan PFI Safety / efficiency balance Rule compliance Terms and Conditions of Contracts Leadership example (e.g. visible evidence of commitment to safety) Open culture Components Pre-existing co-morbidity Complexity of condition Seriousness of condition Treatability Culture / religious beliefs Life style (smoking/ drinking/ drugs/diet) Language Living accommodation (e.g. dilapidated) Support networks Physical state – malnourished, poor sleep pattern, etc. Motivation (agenda, incentive) Stress (family pressures, financial pressures) Existing mental health disorder Trauma Staff to patient and patient to staff Patient to patient Inter family – siblings, parents, children 64 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Risk Assessment & Risk Register Guidance PART D of Risk Management Manual 1.0 Introduction A risk assessment is a careful examination of an actual or potential risk, with these risks including clinical, non clinical and corporate risks. Risk assessments highlight whether adequate precautions are being taken or if further measures are needed to reduce or eliminate them, with the process of risk assessment seeking to answer four simple, related questions: Reference for table: National Patient Safety Agency This guidance is an outline of how to undertake a risk assessment, the role of the risk register and responsibilities of staff. It shows Birmingham Children’s Hospital (BCH) commitment to improving care and services and ultimately a safe environment and excellent patient experience. This guidance forms part of the Risk Management Manual and is intended to be read in conjunction with the other parts. Staff who wish to raise a concern which does not fit into the risk assessment process, are referred to the whistle blowing policy, which is located on the intranet. Full advice on raising a concern and the process to do so, can be obtained from the Human Resources department. 65 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 2.0 Procedure and process for undertaking a risk assessment From the Source of risk Identify the risk Equality impact assessment Identify the associated risks What are the controls in place? What is the original risk score? What action is required? Discussion at appropriate meetings / inclusion in reports as required. Extreme risks MUST be notified to senior management / Trust board. What is the residual risk score? Completion of risk assessment or review of action plan. 66 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 2.1 Source of the risk A risk can be identified from a variety of sources, they are not just related to risks identified by staff self assessment. The following are examples of where risks for risk assessment can be sourced: Audit / benchmarking / gap analysis NHSLA Risk Management standards Media External reports / National enquiry Trend analysis Complaints / PALS Coroners reports Corporate issues New legislation IR1 forms Moving & Handling Team meeting Self assessment Financial / business concern Health & Safety Executive Safety alerts / bulletins Healthcare Commission Professional bodies Service user group Service process or procedures Risk review process Business risks The source of the risk is to be included in the description of the risk on both the risk assessment proforma and on the risk register. 2.2 Identification of the associated risks Once a risk has been identified it needs to be reviewed in detail to determine what risks are associated with it. For example, if an identified risk is a cable lying across the floor, it’s associated risks would include: potential for staff / visitor / patient accident, damage to equipment if cable pulled and so on. A clinical example is a lack of guideline for a new procedure, with the associated risks lack of clarity for staff to undertake procedures, no continuity of care for patient, potential for errors or miscommunication and so on. A finance example may include lack of resources for services or a decision between two. The process for determining the associated risks may come from a variety of methods, for example: Pre determined in a report Brain storming Meeting Incident / complaint or claim trends It is important to consider: 67 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 A multi disciplinary approach in determining the associated risks because most risks are not isolated to one area or to one staff type. Not to exclusively narrow the assessment to one type, for example a clinical risk assessment may have finance risks, non clinical risks and operational risks. 2.3 Equality Impact Assessment When undertaking your risk assessment, it is important to consider the impact on equality and disability. Please indicate on the risk assessment proforma and the risk register if you have undertaken an assessment for equality and disability. Any appropriate actions should be included on the risk assessment action plan. For further information please refer to the guidance on Equality Impact Assessment . 2.4 Review of the risk controls & risk scoring Appendix One: Staff risk scoring information leaflet. The next part of the process is to review the risk and identify the score. This will include looking at the controls / actions in place at that moment which are aimed at reducing the risk. This follows the advice outlined in the January 2008 NPSA document, risk matrix for risk managers. For example: A control may be a checklist to ensure that staff check a piece of equipment at a specified time to ensure that it is in working order when required. The purpose of giving risks scores is to give the risk a priority / severity rating that enables BCH to review it’s risks in a more objective and systematic way. At BCH the following newly developed risk matrix scoring system is used. Likelihood 1 2 3 4 5 1 1 2 3 4 5 2 2 4 6 8 10 Consequence 3 4 3 4 6 8 9 12 12 16 15 20 5 5 10 15 20 25 The matrix explained: The likelihood is the frequency that the risk will occur, with the scoring column located in the left column. 1 is a low likelihood and 5 is high. The consequence is the adverse outcome associated with the risk that has occurred. The scoring row is located in the top row of the matrix. 1 is a low impact and 5 is high. After the likelihood and consequence have been decided they are multiplied together and equal the risk score. The overall risk score CANNOT exceed 25. Likelihood x Consequence = Risk Score The following outlines the priority / severity rating for the above matrix in more detail: 68 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Risk type Low risk Moderate risk High risk Extreme risk Risk Colour Green Yellow Orange Red Risk Score 1 to 6 7 to 10 11 to 19 20 to 25 Choosing risk scores is very subjective and may mean different things to different people, for example driving without a seat belt on may be considered by some as low risk and others as high risk. To ensure that the risks assessed at BCH are risk scored using the same thought process, the following is used. 2.4.1 To determine the Likelihood score If possible score the likelihood by assigning a predicted frequency of the adverse outcome occurring. If this is not possible then assign a probability to the adverse outcome occurring within a given time frame, such as the lifetime of the project or the patient care episode. If it is not possible to determine a numerical probability then use the probability descriptions to determine the most appropriate score. The likelihood score is at the top of the column with the most relevant description. Likelihood Scoring Matrix: 1 Rare Descriptor Frequency Probability Not expected to occur for years < 1% Will only occur in exceptional circumstances 2 Unlikely 3 Possible 4 Likely Expected to occur at least annually 1-5% Expected to occur at least monthly 6-20% Reasonable chance of occurring Expected to occur at least weekly 21-50% 5 Almost Certain Expected to occur at least daily >50% Likely to occur More likely to occur than not Unlikely to occur 3.4.2 To determine the Consequence score Use the table below and choose the relevant descriptor(s) and work across the columns until the most relevant description is found. The Consequence score is at the top of this column. Descriptor Objectives/ Projects 1 Insignificant Insignificant cost increase/ schedule slippage. Barely noticeable reduction in scope or quality 2 Minor 3 Moderate <5% over budget/ schedule slippage. Minor reduction in quality/ scope 5-10% over budget/ schedule slippage. Reduction in scope or quality. Injuries Minor Injury not requiring first aid Minor injury or illness, first aid treatment needed RIDDOR/ Agency reportable. Moderate injury. Patient Care Acceptable management Unacceptable management but no adverse outcome Moderate Mismanagement of patient care with 4 Major 10-25% over budget/ schedule slippage. Doesn’t meet secondary objectives Major injuries, or long term incapacity/ disability (loss of limb) 5 Catastrophic >25% over budget/ schedule slippage. Doesn’t meet primary objectives Serious Mismanagement of Death Death or major permanent incapacity 69 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 adverse outcome patient care with an adverse outcome Complaints/ Claims Locally resolved complaint Justified complaint peripheral to clinical care Below excess claim. Justified complaint involving lack of appropriate care Claim above excess level. Multiple justified complaints Service/ Business Interruption Loss/ interruption > 1 hour Loss/ interruption > 8 hours Loss/ interruption > 1 day Loss/ interruption > 1 week Staffing and Competence Short term low staffing level temporarily reduces service quality (<1 day) Ongoing low staffing level reduces service quality Late delivery of key objective/ service due to lack of staff. Minor error due to poor training. Ongoing unsafe staffing Uncertain delivery of key objective/ service due to lack of staff. Serious error due to poor training Financial Small loss Loss > 0.1% of budget Loss >0.25% of budget Inspection/ Audit Minor recommendations Minor noncompliance with standards Recommendations given. Noncompliance with standards Reduced rating. Challenging recommendations. Non-compliance with core standards Loss of >0.5% of budget Enforcement Action. Low rating. Critical report. Major noncompliance with core standards Rumours Local Media – short term. Minor effect on staff morale Local Media – long term. Significant effect on staff morale Adverse Publicity/ Reputation National Media < 3 Days Multiple claims or single major claim Permanent loss of service or facility Non delivery of key objective/ service due to lack of staff. Loss of key staff. Critical error due to insufficient training Loss of >1% of budget Prosecution. Zero Rating. Severely critical report National Media > 3 Days. MP Concern (Questions in House) 3.4.3 Consequence Modifiers Modifiers may be necessary for certain consequences involving the probability (not frequency) of a risk affecting more than one person or involving a risk to minor or very important services, projects or objectives. Modifiers should only be used when scoring consequences with descriptors highlighted in the same colours as in the modifier table. Staff are reminded that when modifying the score for the consequence, the score can not be higher than 5 and the minimum is 1. For example: if the consequence score is 4, only 1 can be added and not 2. If the consequence score is 1, nothing can be taken away. C = -1 (Minimum 1) Number of people Affected Importance of service, project or object at risk Minor service/ project/ objective C = +1 (Maximum 5) More than a single ward or department Service/ project/ objective important to the whole Trust C = +2 (Maximum 5) More than the whole Trust (Local Health Economy) Service/ project/ objective critical to the whole Trust 2.5 Risk treatment / action plans / Monitoring Following the identification of the risks and their appropriate risk scores, relevant actions / treatment need to be identified to reduce or eliminate the risk from (re)occurring. These actions / treatment need to have a lead person identified and a time scale. If actions/ treatment are required in another department or directorate who are not part of the original assessment process above; the risk assessment lead is responsible for ensuring that the relevant person / department is informed in a timely manner with their comments added to the risk assessment process. 70 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Actions that are required by or are to be accepted at Directorate / Trust level must be notified within a timely manner to the relevant Head of Nursing / Directorate General Manager / Clinical Director. Trust actions are to be taken to either the Clinical Risk and Quality Assurance Committee or Non Clinical Risk Committee, as appropriate. This links in with section 5.0. Monitoring of action plans is the responsibility of the risk assessment lead, with the residual risk score updated on the relevant risk register to reflect actions taken. Overdue actions / treatments must be notified to the relevant line manager, with the relevant Head of Nursing / Directorate General Manager / Clinical Director informed if appropriate. 2.6 Residual risk The residual risk score is the risk rating when actions taken are partly or wholly completed and is determined by the same method as the original risk score in section 3.3. This score is either entered onto the risk register, to complete or update the assessment or is used to re decide the actions / treatment required to reduce or eliminate the risk. The original risk score WILL NOT alter, the residual risk score is the reflection of actions taken. If the residual risk is not acceptable on completion of the actions / treatment, the risk assessment is referred to the appropriate line manager and if applicable to the relevant Head of Nursing / Directorate General Manager / Clinical Director. Information is passed to either the Clinical Risk and Quality Assurance Committee or Non Clinical Risk Committee if the residual risk is above 16 (orange) or as appropriate. 2.7 Templates / proforma for risk assessment process Appendix two has an example of the Trust’s risk assessment proforma. A ‘Word’ copy of this can be found on the risk management webpage and can be made a longer or short document. The proforma can be used for all types of risks, including non clinical, clinical and corporate. Annual risk reviews can also follow the same format. 3.0 Risk register The aim of the risk register is to populate all risks at BCH in one place to enable an effective and systematic review of the risks and ultimately improve care and service delivery. When a risk is entered onto a risk register it will automatically be entered onto all of the appropriate registers if the score is too high for the original register. For example: If a risk is entered onto the department risk register and scores 18 it will automatically be entered onto the Department register, Directorate register and also the Trust register. If a risk is entered onto department risk register and scores 8 it will not cascade upwards to the Directorate risk register. It will only be entered onto the Department risk register. The scoring system for which register the risk is located is outlined below: Risk Score 1 – 10 11 – 16 17 – 25 Department Directorate Trust Assurance Framework Yes Yes Yes No Yes Yes No No Yes No No Yes (only score 20 and 25) 71 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Access to the risk register is not just limited to one person per area, a wide range of staff can be nominated following a brief training outline from the Risk Manager or Health, Safety and Security Manager. Do not attempt to use the register without training. A staff Manual for how to enter and update risks on the risk register is available on the hospital intranet site, or can be obtained from the Trust Risk Manager or the Trust Health, Safety and Security Manager. The risk register at BCH can be found on the V drive. 4.0 Staff responsibilities and review at Trust level The following table shows the responsibilities for action, decision to accept a risk and which risk register this is related to. A more detailed outline of staff responsibilities is highlighted below. Risk Colour Green Yellow Orange Red Decision to accept Remedial Action risk Department Manager Department Manager Department Manager DGM / CD DGM / CD DGM / CD CR&Q Board of Directors Risk register level Department Department Directorate / Trust ALL registers All risks of 20 and 25 scores or those which have been passed to the Risk Manager which require Trust review, are reviewed monthly by the following staff: Chief Medical Officer Chief Operations Officer Director of Governance and Education Risk Manager Information from this monthly review is passed to the Trust board and the relevant sub committee for review and action as appropriate. 4.1 ALL STAFF: Are responsible for contributing to the risk assessment process, for example: o Highlighting risks and concerns o Participation in risk reviews / including all risks severities o Undertaking actions and monitoring these actions 4.2 Link workers: To provide representation for their clinical area within the network by attending meetings and acting as a resource. Establish efficient communication strategies between department, manager and network group to enable sharing of relevant information in a timely manner. Be committed to active implementation of group objectives within department. Participate in relevant audit, teaching or development of practice as appropriate. Negotiate with department manager appropriate time out of their normal clinical duties to enable them to fully undertake the role. 4.3 Department / speciality leads: Ensure that the department / speciality risk registers are regularly reviewed and updated. Update staff with the successes of the risk register and how practice has developed. 72 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Monitoring action plans and taking the appropriate action. 4.4 Directorate General Manager / Clinical Director / Head of Nursing: Ensure that the Directorate risk register is regularly reviewed and updated. Update staff within their Directorate with the risk register developments, and changes in practice and it’s successes. Provide information on the Directorate risk register in their quarterly governance report which is submitted to the Clinical Risk and Quality Assurance Committee. Specific attention is to be given to their top 5 clinical risks, actions or risks for other Directorates and actions for Trust attention. Provide information on the Directorate risk register in their quarterly report which is submitted to the Non Clinical Risk Committee. Specific attention is to be given to their significant non clinical risks, actions or risks for other Directorates and actions for Trust attention. Monitoring action plans and taking the appropriate action. Cascade risks for review at Trust level to the Risk Manager. 4.5 Moving and Handling Advisor / Facilitator: To support staff when undertaking moving and handling risk assessments Participate in risk assessment training 4.6 Health, Safety and Security Manager: Support staff when undertaking risk assessments in the area of health & safety and security Work in conjunction with the risk manager to deliver risk assessment training Assist the risk manager in conducting an annual risk register audit. Share information and safety risks with the directorates Maintain / review the health & safety and security risk register Provide non clinical risk committee with information on risk assessments / risk register Support the Trust in ensuring departments can meet their statutory duties for risk assessment. 4.7 Risk Manager Support staff when undertaking risk assessments in the area of corporate and clinical risks Work in conjunction with the health & safety and security manager to deliver risk assessment training Conduct an annual risk register audit, with assistance from the health & safety and security manager Share information and risks with the directorates Ensure that the risk register database is reviewed and developed Provide clinical risk and quality assurance committee with information on risk assessments / risk register Participate in the monthly Trust risk review 4.8 Director of Healthcare Governance & Education To support the Board and executives when undertaking risk assessments or review the current highlighted risks. To provide the Board with information on risks with scores of 20 and 25. To provide the Board and executives with updates and developments within the risk assessment system. To support the Risk Manager with the yearly risk register audit. 73 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 To assess strategic risks. Participate in the monthly Trust risk review Responsibility for the Assurance Framework 4.9 Medical and Nursing Chief Officers To assess strategic risks in conjunction with the Director of Healthcare Governance and Education. To support the Board and executives when undertaking risk assessments or review the current highlighted risks. Responsibilities for clinical risks 4.10 Trust Board Review the information provided by the monthly trust review meeting. That is risks with scores of 20 or 25 or those which are lower scores but significant. To ensure that risk assessment and risk register review is included within their agenda. That actions and decisions are passed to the appropriate meeting / person. Validate risks and amend / action as required. 5.0 Staff training and information Full details on risk assessment training and the risk register is outlined in the risk management training needs analysis. Basic information for staff is found on the risk management intranet page. 6.0 Trust review of risk assessment / risk register 6.1 Annual audit An annual review of the risk register system is undertaken by the Risk Manager with a report produced. The report will outline: Review of risks entered onto the risk register Trend analysis Outline of outstanding actions Review of the risk register success’s This report is circulated to the Board and the Directorates for information and action as appropriate. 6.2 Trust board review of risks The Board is responsible for ensuring that it reviews and actions appropriately, any risk which is presented by the Director of Healthcare Governance and Education, as highlighted in the monthly Trust risk register meetings. These risks will mainly include those with a risk score of 20 or 25. 6.3 Risk Register The database which contains all of the risk assessments is reviewed annually by the Risk Manager with updates and developments added. These updates are announced on the risk management intranet page. 74 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 6.4 Assurance Framework This is aligned to the 5 Corporate Objectives and is populated by the Director of Governance and Education. Information is taken from the Trust Risk Register and reflects the Trust’s extreme risks. The framework is discussed at the Executive Management Team (EMT) meeting and the Trust board. Action points resulting from these meetings is cascaded to the relevant sub committee meeting. Staff are able to indicate which of the corporate objectives their risk is related to, via the type of risk section on their department risk registers. 7.0 Extreme risks Significant risks are classified as extreme risks (red risks) and MUST be actioned in a timely manner. Risks with scores of 20 or 25 must be notified within 24 hours or the next working day. These must be escalated to the relevant Directorate General Manager / Clinical Director / Head of Nursing, with information passed to the Trust via the Risk Manager, Health, Safety and Security Manager, Director of Healthcare Governance and Education or the Chief Medical or Nursing Officer. 9.0 Monitoring of this policy. Issue Purpose Monitoring process By Whom and by when? Staff duties To ensure that different staff groups with key responsibilities for risk management undertake risk assessment Directorates review their risk register Annual risk review process report. Risk Manager Annually Staff duties Staff duties Trust review of risks at Trust board Audit of Risk Register Quarterly Directorate Governance reports to committees with responsibility for coordinating risk, in accordance with the Learning from Experience Policy. Minutes of Trust Board meetings confirming review of the Assurance Framework and confirming receipt of reports from those committees with responsibility for co- Directorate Management Teams Quarterly Board Ongoing 75 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 ordinating risk. Risk register has minimum requirements captured Risks are populated from a variety of sources Risk assessment identified actions are completed Strategic risks are reviewed Annual review of risk register database system Annual review of risk register data. Risk Register Review Risk Manager Annually Risk Register Review Risk Manager Annually. Directorate and Department reviews Quarterly Directorate Governance reports. Directorate staff Ongoing Risk Register Review Risk Manager Annually. Trust board and performance meetings Minutes of meetings Director of Governance and Education & Director of Performance Ongoing High and extreme risks are considered by a multidisciplinary Trust team Monthly risk register review Risk Manager, Director of Governance and Education, Chief Medical Officer, Chief Operations Officer Monthly Process for assessing all types of risks Assurance framework – high / extreme risks are linked to the corporate objectives. To ensure that all types of risks are reported Minutes of EMT and the framework Director of Healthcare Governance and Education Risk Register Review Risk Manager Annual 10.0 References National Patient Safety Agency website: www.npsa.nhs.uk 76 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Appendix One - Risk Register Scoring System 2008 Instructions for use: 1. Define the risk(s) explicitly in terms of the adverse consequence(s) that might arise from the risk. 2. Use table 1 (see over) to determine the consequence score(s) C, for the potential adverse outcome(s) relevant to the risk being evaluated. 3. Use table 2 (see over) to determine the likelihood score(s) L, for those adverse outcomes. If possible score the likelihood by assigning a predicted frequency of the adverse outcome occurring. If this is not possible then assign a probability to the adverse outcome occurring within a given time frame, such as the lifetime of the project or the patient care episode. If it is not possible to determine a numerical probability then use the probability descriptions to determine the most appropriate score. 4. Modifiers may be used to increase or decrease the consequence score in certain circumstances. If the consequence involves injury, adverse patient experience, complaint or claim (shown as light blue) a modifier of +1 or +2 (to a maximum of 5), may be applied to the consequence score if large numbers of people are affected by the risk as shown in table 3 (see over). This type of modifier should only be used when the likelihood score is calculated based on the probability of the adverse outcome occurring to a single individual. If the consequence involves partial or complete failure to meet an objective, problems with a project or temporary loss of a service, a modifier of –1, +1 or +2 (minimum score 1, maximum score 5) may be applied to the consequence score depending upon the importance of the objective, project or service to the organisation as shown in table 3 (see over). 5. Multiply the Consequence Score (C) (after any relevant modifiers have been applied) with the likelihood score (L) to obtain the risk rating which should be between 1 and 25. RISK = Consequence score x Likelihood score. 6. Use the risk matrix below to determine the colour banding for the risk. Consequence Likelihood 1 2 3 4 1 1 2 3 4 5 5 2 2 4 6 8 10 3 3 6 9 12 15 4 4 8 12 16 20 5 5 10 15 20 25 7. Identify the level at which the risk will be managed in the organisation, assign priorities for remedial action, and determine whether risks are to be accepted or not on the basis of the colour bandings and risk ratings. 77 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 Risk Colour Remedial Action Decision to accept risk Risk register level Green Department Manager Department Manager Department Yellow Department Manager DGM / CD Department Orange DGM / CD DGM / CD Directorate / Trust Red CR&QA EMT Directorate / Trust / Corporate Scores of 1 – 10 = Department Risk Register Scores of 11 – 16 = Directorate Risk Register Scores of 17 – 25 = Trust Risk Register Controls Assurance Register = Scores of 20 and 25. Table 1 – Consequence Score (C) Descriptor Objectives/ Projects Injuries Patient Care 1 Insignificant 2 Minor 3 Moderate 4 Major Insignificant cost increase/ schedule slippage. Barely noticeable reduction in scope or quality <5% over budget/ schedule slippage. Minor reduction in quality/ scope 5-10% over budget/ schedule slippage. Reduction in scope or quality. 10-25% over budget/ schedule slippage. Doesn’t meet secondary objectives Minor Injury not requiring first aid Minor injury or illness, first aid treatment needed RIDDOR/ Agency reportable. Moderate injury. Major injuries, or long term incapacity/ disability (loss of limb) Acceptable management Unacceptable management but no adverse outcome Moderate Mismanagement of patient care with adverse outcome Serious Mismanagement of patient care with an adverse outcome Locally resolved complaint Justified complaint peripheral to clinical care Below excess claim. Justified complaint involving lack of appropriate care Claim above excess level. Multiple justified complaints Service/ Business Interruption Loss/ interruption > 1 hour Loss/ interruption > 8 hours Loss/ interruption > 1 day Loss/ interruption > 1 week Staffing and Competence Short term low staffing level temporarily reduces service quality (<1 day) Ongoing low staffing level reduces service quality Late delivery of key objective/ service due to lack of staff. Minor error due to poor training. Ongoing unsafe staffing Uncertain delivery of key objective/ service due to lack of staff. Serious error due to poor training Financial Small loss Loss > 0.1% of budget Loss >0.25% of budget Inspection/ Audit Minor recommendations Minor noncompliance with standards Recommendations given. Noncompliance with standards Reduced rating. Challenging recommendations. Non-compliance with core standards Loss of >0.5% of budget Enforcement Action. Low rating. Critical report. Major non-compliance with core standards Adverse Publicity/ Reputation Rumours Local Media – short term. Minor effect on staff morale Local Media – long term. Significant effect on staff morale Complaints/ Claims National Media < 3 Days 5 Catastrophic >25% over budget/ schedule slippage. Doesn’t meet primary objectives Death or major permanent incapacity Death Multiple claims or single major claim Permanent loss of service or facility Non delivery of key objective/ service due to lack of staff. Loss of key staff. Critical error due to insufficient training Loss of >1% of budget Prosecution. Zero Rating. Severely critical report National Media > 3 Days. MP Concern (Questions in 78 Birmingham Children’s Hospital NHS Foundation Trust – Risk Management Manual 2008/2009 House) Table 2 – Likelihood Score (L) 1 Rare Descriptor Frequency Not expected to occur for years Probability < 1% Will only occur in exceptional circumstances 2 Unlikely Expected to occur at least annually 1-5% Unlikely to occur 3 Possible Expected to occur at least monthly 6-20% Reasonable chance of occurring 4 Likely Expected to occur at least weekly 21-50% Likely to occur 5 Almost Certain Expected to occur at least daily >50% More likely to occur than not Table 3 – Consequence Modifiers Modifiers may be necessary for certain consequences involving the probability (not frequency) of a risk affecting more than one person or involving a risk to minor or very important services, projects or objectives. Modifiers should only be used when scoring consequences with descriptors highlighted in the same colours as in the modifier table. C = -1 (Minimum 1) Number of people Affected Importance of service, project or object at risk Minor service/ project/ objective C = +1 (Maximum 5) More than a single ward or department Service/ project/ objective important to the whole Trust C = +2 (Maximum 5) More than the whole Trust (Local Health Economy) Service/ project/ objective critical to the whole Trust A modified score CAN NOT go above 25. 79 Birmingham Children’s Hospital NHS Trust - Risk Management Manual. Appendix 2 - Risk Assessment Proforma Risk Assessors Name: Date of Assessment: Overall Risk Assessment Score (highest original risk score): Area / Speciality (completing proforma): Location of Risk: Equality / Disability assessment completed? Type of risk (e.g., clinical, non clinical, finance) Y/N Description of Risk Assessment (include here: Main Risk, Source of risk, & Reason for assessment): RESIDUAL RISK SCORE C C L L = = C C L L = = C C L L = = 80 Complete? ACTIONS / TREATMENT REQUIRED to reduce / eliminate the effects (inc. costs) Timescale ORIGINAL RISK SCORE LEAD Trust Other CONTROL MEASURES IN PLACE to prevent risk & hazards occurring. Staff EFFECTS OF THE RISKS & HAZARDS Patient RISKS & HAZARDS (associated with the description) Incident reporting Policy Version: 2.0.0 Approved by: Clinical Risk And Quality Committee Date Approved: 24 October 2014 Ratified by: Policy Review Group Date ratified: 13 November 2014 Name of originator/author: Bryan Healy, Head of Risk Name of responsible committee/individual: Clinical Risk And Quality Committee Date issued: November 2014 Review date: October 2017 Target audience: All Staff 1 Contents Section Page 1 Introduction 3 2 Purpose 3 3 Duties 3 3.1 Duties within the Organisation 3 3.2 Identification of Stakeholders 5 4 Method of development 5 4.1 Consultation and communication with stakeholders 5 5 Contents 6 5.1 Definitions 6 5.2 Incidents Reporting Process 7 5.3 Managing Reported Incidents 8 5.4 Notifying stakeholders and external agencies 9 5.5 Sharing of lessons learnt 10 5.6 Additional Reporting Arrangements 10 5.7 Staff training 12 6 Process for monitoring the effectiveness of this Policy 12 7 Links with other Trust Policies and procedural documents 12 Appendices App. I Quick reference guide to Being Open 13 App. 2 Information required by the on-line IR1 and how it compares to the old blue paper form 15 2 1.0 INTRODUCTION The Birmingham Children’s Hospital NHS Foundation Trust (BCH) is committed to providing high quality patient care within a safe environment. Where errors or defects are identified they must be analysed so that we can learn from experience and avoid further repetition. BCH recognises the value of incident reporting, and the importance of consistent investigation of incidents which resulted, or had the potential to result in injury, damage or other loss. BCH therefore aims to use its reporting systems to ensure that learning is captured and improvements are made at a local and organisational level. The Trust is committed to developing an open and honest environment where concerns can be raised and improvements made without fear of criticism or reprisal. It is the policy of BCH to record all incidents, claims and complaints (known as incidents in this policy) which have resulted in injury or loss or have the potential to do so. With these reported to an appropriate person in a timely manner to ensure that they are reviewed at local level. This applies to incidents affecting patients, directly employed staff and others including visitors, contractors and volunteers. This will enable lessons to be identified and action points to be noted and implemented. Incidents which fit the criteria of a serious incident requiring investigation (SIRI) must be notified within 24 hours or the next working day. 2.0 PURPOSE This Policy sets out the responsibilities and process for individual staff to report incidents and of mangers to investigate incidents and to feed back outcomes at a local level. It defines the corporate response to incidents reported, including their use in trend analysis and the feedback of this information at a corporate level. It sets out the responsibilities of individual staff in being open with our patients and their families when an incident has occurred. It defines serious incidents requiring investigation (SIRI’s) and highlights responsibilities to report them, but does not define the management of them which is included in the investigations policy 3.0 DUTIES 3.1 DUTIES WITHIN THE ORGANISATION a. TRUST BOARD To review information provided within the quality report. To note high risks identified by this information. To make recommendations following review of the information provided. b. TRUST COMMITTEES WITH RESPONSIBILITY FOR RISK The Clinical Risk and Quality Assurance committee is responsible for reviewing information provided by the Risk Manager in the following areas: Clinical Incident Trend analysis SIRI reports 3 SIRI updates on action plans A programme of annual audit covering the Incidnet Reporting and SIRI policies. Non clinical risk co-ordinating committee is responsible for reviewing information provided by the Health, Safety and Security Manager in the following areas: Non-Clinical Incident Trend analysis SIRI reports c. CHIEF EXECUTIVE The chief executive is ultimately responsible for investigations, and ensuring that they are dealt with effectively and appropriately. d. CHIEF MEDICAL OFFICER To encourage all medical staff to report incidents using the BCH system Overall Clinical Risk responsibility To support the governance team and ensure that the incident reporting system is robust To present to the board any developments within the reporting system To participate within the review of SIRI’s and apply the principles of RCA To present the quality report to the board To provide the board and executives with updates and developments in appropriate meetings. To participate within the management of SIRI investigations which apply the principles of RCA. e. RISK MANAGEMENT SPECIALISTS The Associate Director of Governance, the Head of Risk, the Risk Manager, the Health, Safety and Security Manager and the Moving and Handling Advisor are key individuals identified as competent people within the risk management structure at the Trust. Their key responsibilities are: To develop and maintain current reporting systems at BCH. To support staff when reporting any type of incident. To report to the subcommittees updates on investigations and learning outcomes. To provide relevant meetings with area specific reports. To provide relevant meetings with a patient experience report. To support staff who are undertaking investigations. To liase with external partners in the reporting and investigation of serious untoward incidents and any other for which there is a statutory duty to report. f. DIRECTORATE, SPECIALITY AND DEPARTMENTAL MANAGERS To support staff when reporting incidents, and enable them to participate in investigations. To undertake and follow up action plans as highlighted. 4 To ensure that any incident which meets the criteria for a serious incident is referred to the risk manager immediately upon becoming aware of it. To provide information and updates on action plan implementation in response to SIRI reviews and the Quality report. Provide staff with feedback on the outcomes of incident investigations and changes made as a result. g. ALL STAFF To report incidents using the BCH systems To report incidents in a timely manner To familiarise themselves with the definition of a serious incident and escalate any incident which meets that criteria to the risk manager immediately upon becoming aware of it. To undertake training and updates and remain risk aware To undertake and follow up action plans as highlighted 3.2 IDENTIFICATION OF STAKEHOLDERS All staff are given duties within their contract of employment for the management of risk. As such, in addition to those with defined responsibilities in managing risk, all staff are considered to be stakeholders. 4.0 METHOD FOR DEVELOPMENT This policy version renews existing arrangements for risk assessment as defined in the Risk Manual ratified in April 2008 that forms version 1.01 of this policy. The introduction of a web-accessed incident reporting system introduced new processes for the recording of incidents and their escalation. The rules which govern escalation and reporting of incidents through the organisation were adjusted in the previous Policy version. This updated policy version strives to improve the process based on further experience of working in the system and lessons from audit of that system. 4.1 CONSULTATIONS AND COMMUNICATION WITH STAKEHOLDERS Clinical Risk and Quality Committee and Non-clinical Risk Coordinating Committee are identified as the sub- committees with responsibility for risk. The membership of these committees is identified as primary stakeholders for consultation. 5 5.0 DEFINITIONS a. WHAT IS AN INCIDENT? NHS England defines any unintended or unexpected incident which could have, or did, lead to harm as being reportable. It is the policy of BCH to record incidents in line with this definition whether they affect patient, staff, visitor, equipment or the services we provide. In addition staff shoud be aware that: Healthcare acquired infections are incidents and must be reported to infection control and risk management as soon as is practical. Some incidents need additional reporting to regulatory bodies. For example, IRMER, MESH and HSE. Unexpected Death is an incident. Cardiac arrest is an incident. Environmental contamination is an incident. If in doubt please contact your line manager, or the risk manager on ext 8959 or the health, safety and security manager on ext 8541. b. WHAT IS A SERIOUS INCIDENT REQUIRING INVESTIGATION (SIRI)? A SIRI is one of the most serious types of incident we experience and may involve: death of, or permanent harm to, patients, staff, visitors or members of the public an outcome which requires life-saving intervention or major surgical/medical intervention or will shorten life expectancy a scenario that prevents or threatens to prevent our ability to continue to deliver health care services, a person suffering from abuse adverse media coverage or public concern for the organisation or the wider NHS a serious confidentiality breach is Staff should ensure they are familiar with the fuller definition and management process described in the Serious Incident Requiring Investigation Policy, If staff are in doubt about whether or not an incident is a SIRI, they should contact the Risk Manager or Health, Safety and Security manager for advice. c. CLINICAL INCIDENTS Also called Patient Safety Incidents, they are defined by NHS England as any unintended or unexpected incident which could have, or did, lead to harm for one or more patients receiving NHS-funded healthcare. d. PERSONAL ACCIDENTS 6 Unintended or unexpected incidents which could have, or did, lead to harm for staff or visitors on BCH premises. e. SECURITY INCIDENTS Incidents involving physical or non-physical assault (including verbal abuse, attempted assaults and harassment), theft of or criminal damage (including burglary, arson, and vandalism) to Trust property or to staff or patient personal property. f. INCIDENTS RELATING TO PERSONAL INFORMATION (INFORMATION GOVERNANCE) Involving actual or potential breaches of confidentiality including data loss. g. INCIDENT REPORTING FORMS Incidents may be reported online at http://safeguard/safeguard/. Remote workers can report incidents via laptop or tablet using the link on the BCH internet home page . 6.0 THE INCIDENT REPORTING AND MANAGEMENT PROCESS 6.1 REPORTED BY Any person who is directly employed by the Trust or who is working for the Trust on a temporary, locum, or agency basis, as a contractor or volunteer, including placement students, may complete an incident form. Ideally the person who was directly involved in the incident should report the incident as soon as possible after the event. Where this is not possible a witness or supervisor may complete the incident report. 6.2 REPORTED TO Incidents should be reported to the senior person in charge where the incident occurred. The designated manager of that location is responsible for investigating the incident and implementing remedial measures. Where the cause of the incident and mitigating actions are outside of the authority of the local manger the incident must be identified to a manager with the authority to implement the necessary change. 6.3 DEFINITIONS OF HARM Since definitions of harm were originally described by the NPSA in their Publication, ‘7 Steps to Patient Safety’ there have been a number of definitions introduced to reflect that an outcome might not always involve personal injury. Hence diffiernet 7 terms are encontered. The Incident reporting system replicates these grades under the field Actual Impact and the manager’s form adopts them for grading of incident Severity on the risk mmatrix. BCH adopts the NPSA definitions and for clarity, equivalent terms and scores used across risk management systems are given below. Score 5 4 3 2 1 Term in Safeguard Severity (risk) Actual Impact Catastrophic Catastrophic, Death 4 - Severe, Severe Major Permanent Harm 3 - Moderate, Semi Moderate Permanent Harm (Upto 1 M) 2 - Minor, Non Permanent Minor Harm (Upto 1 M) Insignificant 1 - No Harm NPSA term Death: Significant: Moderate: Low: NPSA definition Death Severe Moderate Low No harm Definition of term Any patient safety incident that directly resulted in the death z of one or more persons receiving NHS funded care. Any patient safety incident that appears to have resulted in permanent harm y to one or more persons receiving NHSfunded care. Explanation of harm casued The death must relate to the incident rather than to the natural course of the patient’s illness or underlying condition. Permanent harm directly related to the incident and not related to the natural course of the patient’s illness or underlying condition is defined as permanent lessening of bodily functions, sensory, motor, physiologic or intellectual, including removal of the wrong limb or organ, or brain damage. Any patient safety incident that x Moderate increase in treatment is resulted in a moderate increase defined as a return to surgery, an in treatment x and which caused unplanned re-admission, a significant but not permanent prolonged episode of care,extra harm, to one or more persons time in hospital or as an receiving NHS-funded care. outpatientor transfer to another area such as intensive care as aresult of the incident. Any patient safety incident that Minor treatment is defined as first required extra observation or aid, additional therapy, or minor treatmentw and caused additional medication. It does not minimal harm, to one or more include any extra stay inhospital or persons receiving NHS-funded any extra time as an outpatient, or care. continued treatment over and above the treatment already 8 planned. Nordoes it include a return to surgery or re-admission. No harm: • Impact prevented Any patient safety incident that had the potential to cause harm but was prevented, resulting in no harm to people receiving NHS-funded care. Any patient safety incident that ran to completion but no harm occurred to people receiving NHSfunded care • Impact not prevented 6.4 BEING OPEN & DUTY OF CANDOUR BCH is committed to being open and honest about incidents which have happened and the reasons for them. Staff are encouraged to discuss incidents with families and carers and provide an apology where we have made a mistake. For all incidents where a patient has suffered more than moderate harm the duty of candour requires us to: Provide an initial verbal apology and explanation Offer a written explanation Record the details of that conversation in the patient record Staff should record this conversation in the ‘Being Open’ section of the incident report form. 6.5 MANAGING REPORTED INCIDENTS 6.5.1 GRADING INCIDENTS Upon receiving incidents managers should undertake an initial grading of the incident. This will allow them to identify the level of investigation required in relation to the incident and help them prioritise action toward higher risk incidents. The table below indicates the escalation rules and timeframes which would be applied to closing incidents at different levels of severity and the authority that local managers have to undertake the investigation. Using Trust 5x5 matrix Using matrix on IR1 form 1-6 Delegate investigation to Low harm, unlikely to member of staff who has recur attended governance or other relevant training 1 month 8-10 Moderate harm, Investigate unlikely to recur 1 week Managers authority Timescale 9 12-15 16+ Significant harm, likely to recur Escalate to Risk Manager Immediate Severe harm, likely to for consideration as SUI. recur 6.5.2 INVESTIGATING INCIDENTS Responsibility for investigating incidents or escalating them to a manager with the appropriate authority is given to local ward and departmental managers. The process of investigating may be given to other senior staff members within the department but outcomes and recommendations must be validated by the departmental manager. The findings of investigations should be detailed on the incident reporting form. Actions arising to mitigate risk should also be described here. 6.5.3 WHEN A SIRI IS SUSPECTED When an investigating manager has concern that a SIRI has occurred they must immediately notify the Governance department. Initial scoping of the incident and discussion with the commissioners of that service will identify the level of investigation which is required. The investigation process described in the Serious Incident Requiring Investigations Policy will be adopted. 6.5.4 DEVELOPING ACTIONS Responsibility for developing actions is given to local ward and departmental managers. Actions should have a clearly stated aim, responsible person and date for completion. The author of the report or investigator is responsible for ensuring that all relevant people are aware of their action points within a timely manner. This person is responsible for following up action points but the lead for the action point is responsible for completing the action and for feedback to the author. Where a concern or issue arises within the action points the author of the action plan should discuss with their line manager or Directorate Management Team in the first instance and if required with the Risk Manager or Health, Safety and Security Manager. 6.6 NOTIFYING STAKEHOLDERS AND EXTERNAL AGENCIES BCH has a statutory duty to report certain kinds of work place accidents, occupational ill health, violent incidents and dangerous occurrences in accordance with the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) 1995. We are also required to report certain incidents to a national body, e.g. Medicine and Healthcare products Regulatory Agency (MHRA), NHS estates, National Patient Safety Agency (NPSA) and the Counter Fraud and Security Management Service (CFSMS) within a specific timeframe. 10 Some incidents may be notified by a specific area or lead practitioner. Staff are reminded that the following types of incidents MUST also be reported to the relevant lead professionals and their policies followed. Incident types which are not highlighted must be referred as Appropriate. Patient Safety Incidents to NHS England (National Reporting and Learning System). Medical Device Incidents to the MHRA (Medicines and Healthcare products Regulatory Agency). Non-medical equipment failures and unsafe or dangerous practices to NHS Estates. Adverse Medication Reactions to MHRA. Serious Adverse Blood Reactions and Transfusion Hazards to SABRE/SHOT Physical Assault against staff to NHS Protect (SIRS). Prescribed Health and Safety Incidents to the HSE (The Health and Safety Executive). Incidents involving Ionising Radiation to the CQC, HSE, Environment Agency and /or Police The process and responsibilities for this reporting is detailed in the ‘Reporting Incidents to External Agencies Protocol.’ 11 6.7 SHARING OF LESSONS LEARNT 6.7.1 LOCAL FEEDBACK Managers should ensure that they have robust feedback mechanisms implemented locally so that all staff are aware of the hazards in their environment and the steps they are expected to take to mitigate them. 6.7.2 ORGANISATIONAL FEEDBACK The Safety Dashboard provides aggregated information on risk, claims, complaints, PALS and patient feedback. It is produced on a quartelry basis. It informs the Quality report which is produced monthly. Both reports identify trends and give recommended actions to the Directorates and departments within. SIRI reviews are reported to the trust clinical or non clinical risk meetings and onward to Trust Board. They are also shared with the staff members involved in the incident. 6.8 ADDITIONAL REPORTING ARRANGEMENTS 6.8.1 NOTIFYING SIRI’S OUT-OF-HOURS Major or serious incidents should be immediately reported to the Clinical Coordinator / Executive Director on call during out of hours. The risk manager, or health, safety and security manager are to be informed as soon as practical. 6.8.2 STAFF NOT EMPLOYED AT BCH Should staff employed at other healthcare organisations be involved in or witness incidents which occurred at BCH they must be reported on BCH incident forms and are subject to investigation at BCH. 6.8.3 INCIDENTS OCCURRING OUTSIDE BCH Should staff employed at BCH be involved in or witness incidents which occurred at other healthcare organisations they must be reported on incident forms and are subject to investigation at that host organisation. Incidents which are referred to managers at BCH regarding other healthcare organisations shall be referred to the Governance Team at those organisations. 6.8.4 ESTATES INCIDENTS Incidents involving the Estate should be completed by the Estates staff where they are present. If they are not in attendance it is the duty of the individual who first identified the incident to complete the form. 6.8.5 WHERE MORE THAN ONE PERSON IS INVOLVED In the case of incidents involving more than one perso (for example an outbreak incident involves at least 2 people) only one form needs to be completed. The online reporting form has capability to report multiple individuals involved in an incident. 6.8.6 COMPLAINTS Reference is to be made to the Trust policy on complaints. 12 6.8.7 DELAYED REPORTING The outcomes of many incidents are identified immediately e.g. broken bone, damaged equipment, fire. However it is just as important to report incidents where the outcomes are identified at a later stage. For example a back sprain resulting from manual handling may not be apparent for a few days, similarly a patient who develops unexpected pressure tissue damage or complication whilst in the care of BCH. All staff should report delayed incidents as soon as they become aware that an incident has occurred 6.8.8 OPTIONS FOR REPORTING All directly employed staff are encouraged to report incidents using the web-based incident reporting system. In circumstances where an individual feels unable to report an incident locally they may report the incident direct to the Governance Team who shall assist in the completion of the form. However, staff must be aware that where risks are identified the investigation must be referred to either departmental or service manager and the maintenance of anonymity cannot be assured. Alternatively, staff may refer to the Trust whistle blowing policy. 6.8.9 FIRE INCIDENTS In the case of fire incidents the information given on the form must include the following: False alarms or actual fire. Method used to raise the alarm. Whether evacuation occurred and to what extent. Any method used to fight the fire e.g. extinguisher, hose reel. Whether the Fire Service attended. The materials that first ignited. The cause and spread of the fire if known. This reporting system does NOT affect the need to involve the Fire Safety Advisor. This must continue in line with the Trust’s Fire Policy. 6.9 TRAINING AND EDUCATION Incdent reporting forms part of Governance Training which is a mandatory requirement for all staff. The Education & Learning (E & L) department will be proactive in the consultation of E & L delivered at BCH NHS FT in response to workforce and service needs. For all Statutory and Mandatory Training E & L will design and facilitate the events. In order to demonstrate compliance; the following statements apply: Attendance at all Statutory and Mandatory learning/training events will be recorded onto the Oracle Learning Management (OLM) system. Any non-attendance, for booked places, will be escalated to the relevant individual and their line manager and department. 13 Statutory and Mandatory Training attendance % be reported for line managers and departments to monitor compliance % on a Trust Dashboard; against defined Key Performance Indicators (KPIs). Each department and Directorate will be able to use this information for robust reporting (to the relevant committees, meetings and forums within the current Governance framework), monitoring and to produce action plans to assure that compliance is met. E & L will undertake quarterly audits of policies that they originate/develop to assure monitoring and compliance is met. Incdent mangement and investigation forms part of Advanced Governance Training which is a necessary requirement for all staff with a responsibility for the management of incidents 7.0 PROCESS FOR MONITORING THE EFFECTIVENESS OF THIS POLICY The chairs of the Clinical risk and Quality Assurance Committee and Non-clinical risk coordinating committee will receive reports from the Directorates in line with the reporting frameworks for those committees. Those reports will detail: progress against the actions given within the Quality Report and Safety Dashboard in response to incident trends arising; Progress against actions arising from SIRI investigations. In addition the Chair of the Clinical risk and Quality Assurance Committee shall receive annual audits of: Use of the incident reporting process across all staff types; and SIRI investigations undertaken. 8.0 LINKS WITH OTHER TRUST POLICIES AND PROCEDURAL DOCUMENTS Patient Safety Strategy SIRI Policy Being Open policy Health and Safety Policy Counter-Fraud Policy & Guidance Policy for the Management and Processing of Serious Case Reviews Procedure for responding to episodes of infection subject to mandatory Department of Health Surveillance. Policy for the Control of Methicillin-Resistant Staphylococcus Aureus (MRSA) Policy for the Control of Outbreaks of Infection in the Hospital (including major outbreak plan) Investigations Policy (HR) 14 APPENDIX 1 QUICK REFERENCE GUIDE TO BEING OPEN Stage 1: preliminary meeting with the patient and/or their carer Who should attend? A lead staff member who is normally the most senior person responsible for the patient’s care and/or someone with experience and expertise in the type of incident that has occurred. Ensure that those members of staff who do attend the meetings can continue to do so; continuity is very important in building relationships. The person taking the lead should be supported by at least one other member of staff, such as the risk manager, nursing or medical director, or member of the healthcare team treating the patient. Ask the patient and/or their carers who they would like to be present. Consider each team member’s communication skills; they need to be able to communicate clearly, sympathetically and effectively. Hold a pre-meeting amongst healthcare professionals so that everyone knows the facts and understands the aims of the meeting. When should it be held? As soon after the incident as possible. Consider the patient’s and/or their carer’s home and social circumstances. Check that they are happy with the timing. Offer them a choice of times and confirm the chosen date in writing. Do not cancel the meeting unless absolutely necessary. Where should it be held? Use a quiet room where you will not be distracted by work or interrupted. Do not host the meeting near to the place where the incident occurred if this may be difficult for the patient and/or their carers. Stage 2: Discussion How should you approach the patient and/or their carers? Speak to the patient and/or their carers as you would want someone in the same situation to communicate with a member of your own family. Do not use jargon or acronyms: use clear, straightforward language. Consider the needs of patients with special circumstances, for example, linguistic or cultural needs, and those with learning disabilities. 15 What should be discussed? Introduce and explain the role of everyone present to the patient and/or their carers and ask them if they are happy with those present. Acknowledge what happened and apologise on behalf of the team and the organisation. Expressing regret is not an admission of liability. Stick to the facts that are known at the time and assure them that if more information becomes available, it will be shared with them. Do not speculate or attribute blame. Suggest sources of support and counselling. Check they have understood what you have told them and offer to answer any questions. Provide a named contact who they can speak to again. Stage 3: follow-up and documentation Clarify in writing the information given, reiterate key points, record action points and assign responsibilities and deadlines. In respect of IR1 incidents, the patient’s notes should contain a complete, accurate record of the discussion(s) including the date and time of each entry, what the patient and/or their carers have been told, and a summary of agreed action points. For complaints / claims information will be documented within the specific file. Maintain a dialogue by addressing any new concerns, share new information once available and provide information on counselling, as appropriate. Indicate on the IR1 form when the being open process has been commenced. If appropriate inform the Patient Interface Manager, Legal and Corporate Affairs Manager, or Risk Manager that the being open process has been commenced. 16 APPENDIX 2 GOVERNANCE TRAINING NEEDS ANALYSIS Foundation Governance Training Topic areas Incident reporting Complaints Claims and Inquest Risk Management Security Management Health and Safety Policies Processes Responsibilities Risk Awareness Staff All Staff Refesher frequency Delivery Every 2 years Class-room learning sessions Moodle Advanced Governance Training Incident management and investigation SIRI investigation Statement writing Complaints Investigation Risk Register Management Ward Managers Department Managers Speciality Managers Service Managers Directorate Managers DLR Investigators SIRI chairs Need determined on individual basis through PDR Blended delivery of class-room learning sessions supported by online resources. 17 Risk Assessment Policy Version: 1.1.1 Approved by: Clinical Risk And Quality Committee Date Approved: 31st Jan 2011 Ratified by: Policy Review Group Date ratified: 24th February 2011 Name of originator/author: Bryan Healy, Head of Risk and Counter Fraud Name of responsible committee/individual: Clinical Risk And Quality Committee Date issued: 1st March 2011 Review date: 31st January 2014 Target audience: All Staff Contents Section Page 1 Introduction 3 2 Purpose 3 3 Duties 3 3.1 Duties within the Organisation 3 3.2 Identification of Stakeholders 5 Method of development 5 Consultation and communication with stakeholders 5 Contents 6 5.1 Definitions 6 5.2 The Risk Assessment Process 6 5.3 The Risk Register 13 5.4 The assurance framework 13 5.5 Staff training 14 6 Monitoring of this policy 14 7 Links with other Trust Policies and procedural documents 15 Appendix I Risk Matrix 16 Appendix 2 Risk Assessment Proforma 20 Appendix 3 Risk Assessment Options Appraisal 21 4 4.1 5 Appendices 1.0 Introduction Birmingham Children’s Hospital NHS Foundation Trust (BCH) is committed to providing high quality patient care within a safe environment. Legislation places a duty upon us to identify foreseeable risks and take reasonably practicable steps to minimise them. Through this requirement, legislation recognises that staff, patient and visitor safety is best delivered through a proactive approach to identifying and controlling risk. The Trust adopts this vision but realises that if it is to provide quality services, it must also identify and control risks to clinical effectiveness and patient satisfaction. Risk Assessment is adopted as the tool which is used Trust wide to identify and control risks to the quality and, by extension, the safety of our services. 2.0 Purpose This Policy sets out the responsibilities for assessment of risks within the organisation alongside the process for doing so. It provides guidance on how to undertake a risk assessment, scoring and prioritisation of risk and the role of the risk register. It defines the escalation routes from local risk assessments to consideration at a Directorate and corporate level. 3.0 3.1 DUTIES Duties within the organisation a. Trust board Trust Board will: review information provided within reports arising from the risk register; review action plans developed in respect of high risks; make recommendations following review of the information provided. b. Trust committees with responsibility for risk Clinical risk and quality assurance committee and the Non clinical risk co-ordinating committee are responsible for reviewing information provided in the following areas: High Risk Reports Significant risks escalated by the Clinical Directorates and Corporate support departments 3 c. Chief Executive The CEO is ultimately accountable for risk management, which includes ensuring that those with delegated responsibility for the identification, management and review of risks meet their duties within a timescale and with a priority commensurate with the severity of the risk identified. d. Chief Medical Officer The CMO has overall responsibility for the management of Clinical Risk, which includes participation in the review of risks and action plans arising and the encouragement of all medical staff to escalate risk through the BCH risk register and reporting systems e. Director of Governance and Education The Director of Governance and Education has overall responsibility for the management of Non-Clinical Risk, which includes participation in the review of risks and action plans arising and the encouragement of all staff to escalate risk through the BCH risk register and reporting systems. f. Director of Healthcare Governance and Education The Director of Healthcare Governance and Education will: support the governance team and ensure that the incident reporting system is robust present to the board any developments within the reporting system participate within the review of risk assessments present the risk register summary reports to the board g. Risk Management Specialists The Associate Director of Governance, the Head of Risk and Counter-Fraud, the Risk Manager, the Health, Safety and Security Manager and the Moving and Handling Advisor are key individuals identified as competent people within the risk management structure at the Trust. Their key responsibilities are: To develop and maintain the risk register and reporting systems at BCH. To support staff when assessing risk. To provide relevant meetings with area specific reports. To provide relevant meetings with a patient experience report. 4 To review the risk registers at the Trust, providing speciality and directorate managers with reports of trends which arise. h. Directorate, speciality and departmental managers Directorate, speciality and departmental managers will: Maintain a programme of risk identification and review within the Directorate, speciality and wards for which they have responsibility. Support staff undertaking risk assessment, including the identification of training needs and provision of time and other resources to enable the process of review and assessment Undertake and follow up action plans arising from risk assessment; Validate risks within their authority and escalate those outside of their authority i. All staff All stuff must: Familiarise themselves with the definition of hazard and risk; Maintain an awareness of risks within their working environment, highlighting concerns to their departmental, speciality or directorate managers as necessary; Participate in the implementation of action plans arising from risk assessments where necessary; Undertake risk management training and updates. 3.2 Identification of Stakeholders All staff are given duties within their contract of employment for the management of risk. As such, in addition to those with defined responsibilities in managing risk, all staff are considered to be stakeholders. 4.0 Method for development This policy version renews existing arrangements for risk assessment as defined in the Risk Manual ratified in April 2008 that forms version 1.01 of this policy. The introduction of a new risk register to the organisation, which is accessed through an online interface, has introduced new processes in the recording of risk, notification and escalation. Accordingly the rules which govern notification, escalation and 5 reporting of risks through the organisation have been adjusted. This policy version reflects those changes. 4.1 Consultations and communication with stakeholders Clinical Risk and Quality Committee and Non-clinical Risk Coordinating Committee are identified as the high level committees with responsibility for risk. The membership of these committees are identified as primary stakeholders for consultation. . The Policy will be launched to coincide with a month long series of activities and training sessions held to promote an on-line incident reporting system linked to the risk register. 5.0 Content 5.1 Definitions A risk assessment is a careful examination of an actual or potential risk. Risk assessments identify the existing precautions which are being taken and what further measures are needed to reduce the risk to an acceptable level. The process of risk assessment seeking to answer four simple, related questions: Within this process one considers potential hazards and their outcomes, controls which mitigate these outcomes and the likelihood of an adverse event occurring given the controls in place. Hazard is the potential to cause harm. A hazard is a situation that poses a level of threat to life, health, property, environment or the services which we provide. Most hazards are dormant or potential, with only a theoretical risk of harm. The term consequence is used to refer to the actual type of outcome which may occur. Controls are anything which reduces the likelihood of that potential harm actually occurring; or the consequences of it. They may be physical, such as an item of protective clothing; or they may be procedural such as a protocol or a management process. 6 Risk is the likelihood of that potential hazard actually occurring. The Risk score is calculated by multiplying the hazard and the likelihood scores. 5.2 The Risk Assessment Process 5.2.1 Identifying risk A risk can be identified from a variety of sources, they are not just related to risks identified by staff self assessment. The following are examples of where risks for risk assessment can be sourced: Audit / Corporate issues Healthcare benchmarking / New legislation Commission gap analysis IR1 forms Professional NHSLA Risk Moving & bodies Management Handling Service user standards Team meeting group Media Self assessment Service process External reports Financial / or procedures / National business Risk review enquiry concern process Trend analysis Health & Safety Business risks Complaints / Executive PALS Safety alerts / Coroners bulletins reports 7 5.2.2 Documenting Risk Assessments The organisation has a duty to record the findings of risk assessments. That may be achieved by using the Risk Assessment proforma at Appendix B or by direct entry to the risk register. 5.2.3 The Risk Assessment proforma The proforma at Appendix A is particularly suited to describing complex risks. A problem may present different risks to different groups. Some risks may be greater and in need of more urgent action than other risks highlighted by the problem. This proforma is offered as a structured document to help describe the risk. A summary of the risks must be subsequently transcribed on the risk register. 5.2.4 The Risk register The risk assessment proforma does not need to be used in every case; risks may be entered directly to the risk register. This may be appropriate for risks which are more simply described. 5.2.5 Specialist risk assessments Requirements for specialist risk assessments exist in other policies, e.g. Moving and Handling, Display Screen Equipment, COSHH, Work at Heights, Lone Worker, First Aid needs. These policies typically describe risks within a discrete activity or pertaining to the needs of an individual patient. They exist as a description of how risks are controlled in the undertaking of an activity and should not be entered on the risk register. However, they may used to identify where risks exist. For example: A patient handling assessment may say use a hoist but the department does not possess a hoist. The department should then assess the risks of not having a hoist to assist with the handling of any patient on the ward and enter that risk on the risk register. 8 Fig 1. The Risk assessment Process Risk assessment should follow the process outlined in the flow chart below: Describe the situation, giving background to a problem where hazards may exist List those hazards and the expected typical outcome of them Detail the existing controls that reduce the likelihood of an accident and severity of harm caused. Significant risks and action plans must be reported through clinical and non-clinical committee reporting frameworks. Calculate a risk score and escalate the risk for validation Detail the outstanding controls needed to reduce the likelihood and harm. High risks must be notified Chief Operating Officer and Governance Team for validation. Develop and monitor an action plan which puts outstanding controls in place. Update progress on actions. Review the risk score in light of changes. Close the risk. 9 5.2.6 Authority to accept risks Risks must be scored according to severity and likelihood of outcome using the risk matrix at Appendix A and defined as minor, moderate, significant and high risks. Table 1 identifies the authority of managers to accept risks at each level of harm. Table1 Escalating risks Risk Colour Remedial Decision to Action accept risk Authority of the Manager The department manager can: Green Department Department • Enter the risk as validated. (minor) Manager Manager • Close the risk when they are satisfied it is controlled The department manager must: • Yellow Department (moderate) Manager Validate the risk after discussion with the DGM / CD Directorate Team. • Close the risk after discussion with the Directorate Team. The Directorate management Team must: Orange (significant) • Directorate Directorate management management discussion with the Team Team department. • Validate the risk after Close the risk after discussion with the department. The Directorate Team must: Red (high) CR&Q Board of • Escalate the risk for validation. Directors • Closely manage reduction of the risk. 5.2.7 Validation of risks Where a manager does not have the authority to accept a risk it is recorded on the risk register as ‘Not yet Validated.’ The validation process should agree the severity and outcome of a risk in light of the existing controls. When validated, that risk is described 10 as ‘Partially Controlled’ to both reflect the presence of existing controls and need for additional controls. 5.2.8 Development of outstanding controls Where a risk is not controlled as far as is reasonably practicable, actions to reduce the risk must be developed. The term, as far as is reasonably practicable, reflects our legal duties to reduce risk. This standard is best met through a balancing of the inputs required to manage a risk against the reduction in risk which we expect to achieve. That judgement must be made by or in consultation with a manager with authority to accept risk. Balancing risk The options appraisal proforma at Appendix C is offered as a structured document to help undertake a detailed justification for the selection of the most appropriate control and from which an action plan may be developed. 11 5.2.9 Reviewing risks Table 2 identifies the expected frequency of risk review at each level of harm. Table 2 Expected review frequency Risk Colour Green Yellow Reviewer Department Manager Department Manager Review frequency Following changes to risk or implementation of controls Following changes to risk or implementation of controls Orange DMT As required but at least quarterly Red CRAQ Monthly 5.2.10 Closing Risks Closed risks may be described as: Risk Removed o Where the hazard has been removed and there is no further exposure to risk. Risk Controlled o Where the hazard remains present but the physical and management controls are sufficient to ensure that both the severity of outcome and the likelihood of an incident are reduced as far as is reasonably practicable. Closure of a risk will involve reduction of the risk score and that reduction must be validated by a manager with the authority to accept the original risk score. 5.2.11 Equality Impact Assessment When undertaking your risk assessment, it is important to consider the impact on equality and disability. Please indicate on the risk assessment proforma and the risk register if you have undertaken an assessment for equality and disability. Any appropriate actions should be included on the risk assessment action plan. For further information please refer to the guidance on Equality Impact Assessment . 12 5.3 The Risk Register The web-based risk register is accessible at http://safeguard/safeguard/ Access to the risk register is given to department, speciality and directorate managers with access rights given to reflect the authority of the manager, so: department managers can see all the risks in their department, speciality managers can see the aggregated risks of departments in that speciality and, Directorate management teams can see aggregated risks from all specialities and departments under their control. The organisational risk register comprises the aggregated risks from all clinical directorates and non-clinical departments and is accessible by the Executive Management Team and those specialists managing risk at the Trust, with filters allowing a focus on high and significant risks. The committee reporting framework facilitates reporting escalation and monitoring of high and significant risks from the organisational risk register with the frequency given at table 2 above. 5.3.1 High Risks on the risk register High risks are those scoring above 16 and must be escalated to the relevant Directorate Management Team and to the Risk Manager, Health, Safety and Security Manager, Director of Healthcare Governance and Education or the Chief Medical or Nursing Officer. 5.4 The assurance framework Strategic or Corporate risks are those that transcend the department, speciality or directorate that have identified and escalated them and are expected to affect the strategy and direction of the Trust with an impact on numerous people within or outside of the Trust. Corporate objectives which are recognised by the Trust Board as priorities to the organisation are defined within 5 themes. Known risks to meeting these objectives are aligned to these themes. Actions to mitigate those risks are monitored through the assurance framework. The assurance framework is also populated with those high risks escalated through the risk register. 13 5.5 Staff training Training in risk awareness and use of the risk register is delivered to staff in accordance with the Training Needs Analysis developed by the Governance Support Unit and implemented at departmental level. Additional training documentation and support is found within the Governance Support Unit intranet pages. Access to the risk register is not just limited to one person per area, a wide range of staff can be nominated following a brief training outline from the Risk Manager or Health, Safety and Security Manager. Do not attempt to use the register without training. 6.0 Monitoring of this policy 6.1 Risk Register Review An annual review of the risk register system is undertaken by the Risk Manager and submitted to the Clinical Risk and Quality Assurance Committee. That report shall consider: Type of risks entered onto the risk register; Source of risks entered onto the risk register Severity of risks entered onto the risk register; Departments populating the risk register; Outstanding actions within significant risks entered on the risk register. 6.2 Review of High Risks High Risk Reports are received by the Clinical Risk and Quality Committee on a monthly basis. High Risks are reported to Non-clinical risk co-ordinating committee through Directorate Reports. 6.3 Review of Significant Risks Directorates are expected to report significant clinical risks and work toward controlling them as part of the reporting framework to the Clinical Risk and Quality Committee. Directorates are expected to report significant non-clinical risks and work toward controlling them as part of the reporting framework to the Non-Clinical Risk Coordinating Committee. 14 6.4 Assurance Framework Review Progress in action plans developed to mitigate risks appearing on the assurance framework is reported to Trust Board on a quarterly basis. 7.0 Links with other Trust Policies and procedural documents Safety Strategy SIRI Policy Incident Reporting Policy Being Open policy Learning from Experience policy Health and Safety Policy Counter-Fraud Policy & Guidance Governance Training Needs Analysis 15 Appendix 1 Risk Matrix 1 The matrix explained The purpose of giving risks scores is to give the risk a priority / severity rating that enables BCH to review it’s risks in a more objective and systematic way. At BCH the following risk matrix scoring system is used. Consequence Likelihood 1 2 3 4 5 1 1 2 3 4 5 2 2 4 6 8 10 3 3 6 9 12 15 4 4 8 12 16 20 5 5 10 15 20 25 The likelihood is the frequency that the risk will occur, with the scoring column located in the left column. 1 is a low likelihood and 5 is high. The consequence is the adverse outcome associated with the risk that has occurred. The scoring row is located in the top row of the matrix. 1 is a low impact and 5 is high. Likelihood x Consequence = Risk Score After the likelihood and consequence have been decided they are multiplied together and equal the risk score. The overall risk score CANNOT exceed 25. The following outlines the priority / severity rating for the above matrix in more detail: Risk type Risk Colour Risk Score Low risk Green 1 to 6 Moderate risk Yellow 7 to 10 High risk Orange 11 to 19 Extreme risk Red 20 to 25 16 Choosing risk scores is very subjective and may mean different things to different people, for example driving without a seat belt on may be considered by some as low risk and others as high risk. To ensure that the risks assessed at BCH are risk scored consistently, the following descriptors of consequence and likelihood are used. 2 To determine the Consequence score Consequence may be scored on a number of scales depending on the nature of the risk being assesses. These are listed I Table A1 below. Different risk types defined in the first column should be used to determine on which row the risk is being scored. Read across subsequent columns unto identify the descriptor which best mirrors the typical outcome from this hazard and use the numerical score at the top of that column as the consequence score. 2.1 Consequence Modifiers Some hazards may affect only one person or a small number of people within a ward or department at BCH. Larger groups may be affected as hazards stretch across multiple wards or departments at BCH; or even to our patients and families outside of BCH. Harm to these larger groups which is minor in nature can be missed as we prioritise more severe harm. But where there is a cumulative affect of lots of minor harm across a large number of people we want to reflect that in our scoring. The consequence modifiers in Table A2 are used to raise the consequence scores and better reflect the severity of these risks. 2 rules apply to using modifiers: They should only be used when scoring consequences with descriptors highlighted in the same colours as in the modifier table. The final outcome score can not be higher than 5 and the minimum is 1. 3 To determine the Likelihood score Score the likelihood by assigning a predicted frequency of the adverse outcome occurring. That may be the simple descriptor; the more quantitative description given under frequency; or the more accurate probability, which may be derived from a measurement of an actual incident rate. 17 Table A1 Consequence scores Descriptor 1 2 3 4 5 Insignificant Minor Moderate Major Catastrophic Insignificant cost Objectives/ Projects increase/ schedule slippage. Barely noticeable reduction in scope or quality Injuries Patient Care <5% over budget/ 5-10% over budget/ schedule slippage. schedule slippage. Minor reduction in Reduction in scope or quality/ scope quality. Minor injury or RIDDOR/ Agency illness, first aid reportable. Moderate treatment needed injury. Unacceptable Moderate Acceptable management but no Mismanagement of management adverse outcome patient care with Minor Injury not requiring first aid adverse outcome Complaints/ Locally resolved Claims complaint Service/ Business Interruption Justified complaint peripheral to clinical care Below excess claim. Justified complaint involving lack of appropriate care 10-25% over budget/ schedule slippage. Doesn’t meet secondary objectives Major injuries, or long term incapacity/ disability (loss of limb) >25% over budget/ schedule slippage. Doesn’t meet primary objectives Death or major permanent incapacity Serious Mismanagement of Death patient care with an adverse outcome Claim above excess Multiple claims level. Multiple or single major justified complaints claim Loss/ interruption > 1 Loss/ interruption > Loss/ interruption > 1 Loss/ interruption > hour 8 hours day 1 week Permanent loss of service or facility Non delivery of Short term low Staffing and Competence staffing level Ongoing low staffing temporarily reduces level reduces service service quality (<1 quality day) Late delivery of key Uncertain delivery key objective/ objective/ service due of key objective/ service due to to lack of staff. Minor service due to lack lack of staff. Loss error due to poor of staff. Serious of key staff. training. Ongoing error due to poor Critical error due unsafe staffing training to insufficient training Financial Small loss Minor Inspection/ Audit recommendations Minor noncompliance with standards Adverse Publicity/ Reputation Rumours Loss > 0.1% of budget Recommendations given. Noncompliance with standards Loss >0.25% of budget Loss of >0.5% of Loss of >1% of budget budget Reduced rating. Enforcement Action. Challenging Low rating. Critical recommendations. report. Major non- Non-compliance with compliance with core standards core standards Local Media – short Local Media – long term. Minor effect term. Significant effect on staff morale on staff morale National Media < 3 Days Prosecution. Zero Rating. Severely critical report National Media > 3 Days. MP Concern 18 (Questions in House) Table A2 Consequence Modifiers C = -1 (Minimum 1) C = +1 (Maximum 5) C = +2 (Maximum 5) Number of people More than a single ward or More than the whole Trust Affected department (Local Health Economy) Importance of service, Minor service/ project/ Service/ project/ objective Service/ project/ objective project or object at risk objective important to the whole Trust critical to the whole Trust Table A3 Likelihood Score Descriptor Frequency Probability 1 2 3 4 5 Rare Unlikely Possible Likely Almost Certain Not expected to occur for Expected to occur Expected to occur at Expected to occur Expected to occur years at least annually least monthly at least weekly at least daily < 1% 1-5% 6-20% 21-50% >50% Will only occur in exceptional circumstances Unlikely to occur Reasonable chance of occurring Likely to occur More likely to occur than not 19 Appendix 2 - Risk Assessment Proforma Risk Assessors Name: Date of Assessment: Overall Risk Assessment Score (highest original risk score): Area / Speciality (completing Location of Risk: Type of risk (e.g., clinical, non clinical, finance) proforma): Description of Risk Assessment (include here: Main Risk, Source of risk, & Reason for assessment): Through a description of the background to the problem being considered, hazards may be identified. Descriptions of the backg round would answer the questions: What are we risk assessing? Some answers are given in the tables at Appendix B What are the drivers? Some answers are given at Section 5 above What is the problem? This is the heart of the description and may refer to a piece of equipment, may describe a work area; it may describe the findings of an incident investigation; it may summarise e the findings of an external or internal audit report or review. hazards occurring. REQUIRED to reduce / eliminate the effects (inc. Responsibility PLACE to prevent risk & ACTIONS / TREATMENT Time scale with the description) HAZARDS CONTROL MEASURES IN RISK SCORE RISKS & HAZARDS (associated EFFECTS OF THE RISKS & costs) 20 Appendix 3 Risk Assessment Options Appraisal Location of risk: Risk Assessment Ref.: Author of submission: Date: Essential Background Information: (maximum of 500 words – an outline of background information to support this submission) Results of Risk Assessments: (e.g. general risk assessment or specialist assessments such as COSHH, handling (patient and non-patient, display screen, personal protective equipment, violence and aggression, latex etc.) Options for Discussion: Implications for the Trust: (including financial and other resource implications) Recommendation: Outcome: (to be completed by the chair of the group to which the submission has been made) Signature: ……………………………………………. Date: ……………………………. Title: ………………………………..………………… 21 Appendix Ci Risk Assessment Options Appraisal on the risk register An appraisal of the benefits of identified controls may be undertaken directly on the risk register. Click on the pencil to open a larger window with the boxes to fill out 22 Risk Assessment Policy Version: 2.0.0 Approved by: Clinical Risk And Quality Committee Date Approved: 24 October 2014 Ratified by: Policy Review Group Date ratified: 13 November 2014 Name of originator/author: Head of Risk Name of responsible committee/individual: Bryan Healy, Head of Risk Date issued: November 2014 Review date: October 2017 Target audience: All Staff Contents Section Page 1 Introduction 3 2 Purpose 3 3 Duties 3 3.1 Duties within the Organisation 3 3.2 Identification of Stakeholders 5 Method of development 5 Consultation and communication with stakeholders 5 Contents 6 5.1 Definitions 6 5.2 The Risk Assessment Process 6 5.3 The Risk Register 13 5.4 The assurance framework 13 5.5 Staff training 14 6 Monitoring of this policy 14 7 Links with other Trust Policies and procedural documents 15 Appendix I Risk Matrix 16 Appendix 2 Risk Assessment Proforma 20 Appendix 3 Risk Assessment Options Appraisal 21 4 4.1 5 Appendices 1.0 Introduction Birmingham Children’s Hospital NHS Foundation Trust (BCH) is committed to providing high quality patient care within a safe environment. Legislation places a duty upon us to identify foreseeable risks and take reasonably practicable steps to minimise them. Through this requirement, legislation recognises that staff, patient and visitor safety is best delivered through a proactive approach to identifying and controlling risk. The Trust adopts this vision but realises that if it is to provide quality services, it must also identify and control risks to clinical effectiveness and patient satisfaction. Risk Assessment is adopted as the tool which is used Trust wide to identify and control risks to the quality and, by extension, the safety of our services. 2.0 Purpose This Policy sets out the responsibilities for assessment of risks within the organisation alongside the process for doing so. It provides guidance on how to undertake a risk assessment, scoring and prioritisation of risk and the role of the risk register. It defines the escalation routes from local risk assessments to consideration at a Directorate and corporate level. 3.0 DUTIES 3.1 Duties within the organisation a. Trust board Trust Board will: review information provided within reports arising from the risk register; review activity taken to mitigate high risks; Make recommendations following review of the information provided. b. Trust committees with responsibility for risk Clinical risk and quality assurance committee and the Non clinical risk co-ordinating committee are responsible for reviewing information provided in the following areas: High Risk Reports Significant risks escalated by the Clinical Directorates and Corporate support departments 3 c. Chief Executive The CEO is ultimately accountable for risk management, which includes ensuring that those with delegated responsibility for the identification, management and review of risks meet their duties within a timescale and with a priority commensurate with the severity of the risk identified. d. Chief Medical Officer The CMO has overall responsibility for the management of Clinical Risk, which includes participation in the review of risks and action plans arising and the encouragement of all medical staff to escalate risk through the BCH risk register and reporting systems e. Chief Operating Officer The Chief Operating Officer has overall responsibility for the management of NonClinical Risk, which includes participation in the review of risks and action plans arising and the encouragement of all staff to escalate risk through the BCH risk register and reporting systems. f. Associate Director of Governance The Associate Director of Governance, through the Governance team, will: ensure that the organisation maintains a robust, dynamic risk register participate within the review of risk assessments g. Risk Management Specialists The Head of Risk, the Risk Manager, the Health, Safety and Security Manager and the Moving and Handling Advisor are key individuals identified as competent people within the risk management structure at the Trust. Their key responsibilities are: To develop and maintain the risk register and reporting systems at BCH. To support staff when assessing risk. To provide Directorate, Speciality and Department meetings and subcommittees with area specific reports. To review the risk registers at the Trust, providing speciality and directorate managers with reports of trends which arise. h. Directorate, speciality and departmental managers The Directorate, speciality and departmental management Teams will: 4 Maintain a programme of risk identification and review within the Directorate, speciality and wards for which they have responsibility. Support staff undertaking risk assessment, including the identification of training needs and provision of time and other resources to enable the process of review and assessment Undertake and follow up action plans arising from risk assessment; Validate risks within their authority and escalate those outside of their authority i. All staff All staff must: Familiarise themselves with the definition of hazard and risk; Maintain an awareness of risks within their working environment, highlighting concerns to their departmental, speciality or directorate managers as necessary; Participate in the implementation of action plans arising from risk assessments where necessary; 3.2 Undertake risk management training and updates. Identification of Stakeholders All staff are given duties within their contract of employment for the management of risk. As such, in addition to those with defined responsibilities in managing risk, all staff are considered to be stakeholders. 4.0 Method for development This policy version renews existing arrangements for risk assessment as defined in the Risk Assessment Policy ratified in 2011 that forms version 1.1.1 of this policy. 4.1 Consultations and communication with stakeholders Clinical Risk and Quality Committee and Non-clinical Risk Coordinating Committee are identified as the high level committees with responsibility for risk. The membership of these committees is identified as primary stakeholders for consultation. Additionally, Directorate Management Teams were consulted. 5 5.0 Content 5.1 Definitions A risk assessment is a careful examination of an actual or potential risk. Risk assessments identify the existing precautions which are being taken and what further measures are needed to reduce the risk to an acceptable level. The process of risk assessment seeking to answer four simple, related questions: Within this process one considers potential hazards and their outcomes, controls which mitigate these outcomes and the likelihood of an adverse event occurring given the controls in place. Hazard is the potential to cause harm. A hazard is a situation that poses a level of threat to life, health, property, environment or the services which we provide. Most hazards are dormant or potential, with only a theoretical risk of harm. The term consequence is used to refer to the actual type of outcome which may occur. Controls are anything which reduces the likelihood of that potential harm actually occurring; or the consequences of it. They may be physical, such as an item of protective clothing; or they may be procedural such as a protocol or a management process. The term Directorate refers to the Clinical Directorates and non-clinical units (Workforce, Estates and Facilities and the Corporate Directorate comprising Governance, Finance and IT). 5.2 The Risk Assessment Process 5.2.1 Identifying risk A risk can be identified from a variety of sources; they are not just related to risks identified by staff self-assessment. The following are examples of where risks for risk assessment can be sourced: 6 Audit / benchmarking / gap Moving & Handling analysis Team meeting NHSLA Risk Management Self-assessment recommendations Financial / business concern Media Health & Safety Executive External reports / National Safety alerts / bulletins enquiry Healthcare Commission Trend analysis Professional bodies Complaints / PALS Service user group Coroners reports Service process or procedures Corporate issues Risk review process New legislation Business IR1 forms 5.2.2 Describing risky situations The situation where the risk sits should be described. The mnemonic INSIDE is a useful tool for structuring that description: Introduction: who/where are we assessing? Scene setting: describe the activity or the problem or the general situation where the risk resides Individuals: Who are the people, processes, equipment or places that might be affected by this risk? Dangers: describe the hazards or the dangers we see here. Effect: And describe the outcome should the hazard affect those people. 5.2.3 Describing Controls The controls which are currently in place and stop people in the situation being affected by the hazard should be identified. 5.2.4 Assessing risks The information collected so far can now be analysed to see how likely the hazard is to occur and how severely people may be affected by it. That will be strongly influenced by the controls currently in place and how effective they are at protecting people. It will be informed by individual experiences and opinions. 7 It is important at all stages to include a number of stakeholders in the assessment process to ensure that a holistic view of the problem is established, rather than an individual opinion. 5.2.5 Scoring risks The assessment should ask if this risk is realised: What is the severity of the outcome expected to be? Scored on a scale of 1 to 5, this provides the hazard score (also referred to as the severity or consequence score). A hazard score of 1 indicates that the anticipated outcome is minor; a hazard score of 5 indicates a more serious outcome How likely is it that outcome to occur? Scored on a scale of 1 to 5, this provides the likelihood score (also referred to as the frequency score). A likelihood score of 1 indicates that the anticipated outcome occurs rarely; a likelihood score of 5 indicates the outcome is almost imminent. The Risk score is calculated by multiplying the hazard and the likelihood scores. Hazard scores related to safety, quality and patient experience (full table of hazard scores is in Appendix 1) 1 Descriptor Injuries Patient Care Insignificant Minor Injury not requiring first aid Acceptable management Complaints/ Locally resolved Claims complaint 2 3 Minor Moderate Minor injury or RIDDOR/ Agency illness, first aid reportable. treatment needed Moderate injury. Unacceptable management but no adverse outcome Justified complaint peripheral to clinical care 4 Major Catastrophic Major injuries, or long term incapacity/ disability (loss of limb) Moderate Serious Mismanagement of Mismanagement of patient care with patient care with an adverse outcome adverse outcome Below excess claim. Justified complaint involving lack of appropriate care 5 Claim above excess level. Multiple justified complaints Death or major permanent incapacity Death Multiple claims or single major claim Likelihood Score 1 Descriptor Frequency Probability 2 3 4 5 Rare Unlikely Possible Likely Almost Certain Not expected to Expected to occur at Expected to occur at Expected to occur at Expected to occur at occur for years least annually least monthly least weekly least daily < 1% 1-5% 6-20% 21-50% >50% 8 Will only occur in exceptional circumstances Unlikely to occur Reasonable chance of occurring Likely to occur More likely to occur than not 9 5.3 Documenting Risk Assessments The organisation has a duty to record the findings of risk assessments. That may be achieved by using the Risk Assessment Proforma at Appendix B or by direct entry to the risk register. 5.3.1 The Risk Assessment Proforma The Proforma at Appendix A is particularly suited to describing complex risks. A problem may present different risks to different groups. Some risks may be greater and in need of more urgent action than other risks highlighted by the problem. This Proforma is offered as a structured document to help describe the risk. A summary of the risks must be subsequently transcribed on the risk register. 5.3.2 The Risk register The risk assessment Proforma does not need to be used in every case; risks may be entered directly to the risk register. This may be appropriate for risks which are more simply described. 5.3.3 Specialist risk assessments Requirements for specialist risk assessments exist in other policies, e.g. Moving and Handling, Display Screen Equipment, COSHH, Work at Heights, Lone Worker, First Aid needs. These policies typically describe risks within a discrete activity or pertaining to the needs of an individual patient. They exist as a description of how risks are controlled in the undertaking of an activity and should not be entered on the risk register. However, they may be used to identify where risks exist. For example: A patient handling assessment may say use a hoist but the department does not possess a hoist. The department should then assess the risks of not having a hoist to assist with the handling of any patient on the ward and enter that risk on the risk register. 10 Fig 1. The Risk assessment Process Risk assessment should follow the process outlined in the flow chart below: Describe the situation, giving background to a problem where hazards may exist List those hazards and the expected typical outcome of them Detail the existing controls that reduce the likelihood of an accident and severity of harm caused. Significant risks and action plans must be reported through clinical and non-clinical committee reporting frameworks. Calculate a risk score and escalate the risk for validation Detail the outstanding controls needed to reduce the likelihood and harm. High risks must be notified Chief Operating Officer and Governance Team for validation. Develop and monitor an action plan which puts outstanding controls in place. Update progress on actions. Review the risk score in light of changes. Close the risk. 11 5.3.4 Authority to accept risks Risks must be scored according to severity and likelihood of outcome using the risk matrix at Appendix A and defined as minor, moderate, significant and high risks. Table 1 identifies the authority of managers to accept risks at each level of harm. Table1 Escalating risks Risk Colour Remedial Decision to Action accept risk Authority of the Manager The department manager can: Green Department Department • Enter the risk as validated. (minor) Manager Manager • Close the risk when they are satisfied it is controlled The department manager must: • Yellow Department (moderate) Manager Validate the risk after discussion with the DGM / CD Directorate Team. • Close the risk after discussion with the Directorate Team. The Directorate management Team must: Orange (significant) • Directorate Directorate management management discussion with the Team Team department. • Validate the risk after Close the risk after discussion with the department. The Directorate Team must: Red (high) CR&Q Board of • Escalate the risk for validation. Directors • Closely manage reduction of the risk. 5.3.5 Validation of risks Where a manager does not have the authority to accept a risk it is recorded on the risk register as ‘Not yet Validated.’ The validation process should agree the severity and outcome of a risk in light of the existing controls. When validated, that risk is described 12 as ‘Partially Controlled’ to both reflect the presence of existing controls and need for additional controls. 5.3.6 Development of outstanding control strategies Where a risk is not controlled as far as is reasonably practicable, actions to reduce the risk must be developed. The term, as far as is reasonably practicable, reflects our legal duties to reduce risk. This standard is best met through a balancing of the inputs required to manage a risk against the reduction in risk which we expect to achieve. That judgement must be made by or in consultation with a manager with authority to accept risk. Balancing risk On Balance Control B ? Risk A 4x4 = 16 ? Control C Time Cost Resources Practicability Proportionate response Acceptance of risks Competing prioritises Risk A 4x3 = 12 Risk A 3x3 = 9 ? Control D Risk A 3x2 = 6 The options appraisal Proforma at Appendix C is offered as a structured document to help undertake a detailed justification for the selection of the most appropriate control and from which an action plan may be developed. Responses to risk might attempt to reduce the severity of the risk should it happen of risks; or they might attempt to reduce the likelihood of the risk occurring; or they might target both. 5.3.7 Principles of prevention in controls 13 There is a hierarchy of control measures at the top of which is, ‘Avoid the risk all together’. If possible do the work in a different way, taking care not to introduce new hazards; this is not always possible in healthcare, we expose the patient and are exposed to risk as part of treatments which are necessary and cannot be avoided. In such cases we should use risk assessment to identify the controls we will use to reduce risk: Control at source: if we can remove the risk altogether, we should do so. o A good example of this is the use of ‘safer sharps’ where needles are replaced with devices which have a cover to stop users suffering an accidental needle stick injury Use controls which protect the largest number of people from risk. o In rooms where X-rays or, lasers are used, we have interlocks on doors so that people who do not need to enter dangerous areas cannot enter them. o Our wards and departments have controlled access, only allowing entry to people who need to be there. Where it is not possible to use mechanical controls we develop procedures to restrict the number of people who have access to the hazardous area or are exposed to the hazard. Standard procedures e.g. the preparation and administration of medicines will define the safest way of performing a task. These are probably our most frequent type of control; but they also rely on users adhering to these procedures. When developing procedures: o They are supported by induction and training. o It is important that procedures are developed in consultation with the teams who will perform them so that they are sensible and achievable by the team, so that team members see value in them and own them. o And they should be monitored to make sure they continue to work: that could be formal monitoring of the process (e.g. PEWS monitoring and NCQI’s); it could be monitoring outcomes (e.g. M&M review, audit, feedback, complaints, incidents); or it could be an on-going discussion with users to make sure the procedures are the right ones. o Monitoring will most likely be a mixture of all three types. The results of monitoring should be fed into review of the risk assessment. 14 5.3.8 Reviewing risks Table 2 identifies the expected frequency of risk review at each level of harm. Table 2 Expected review frequency Risk Colour Green Yellow Reviewer Department Manager Department Manager Review frequency Following changes to risk or implementation of controls Following changes to risk or implementation of controls Orange DMT As required but at least quarterly Red CRAQ Monthly 5.3.9 Closing Risks Closed risks may be described as: Risk Removed o Where the hazard has been removed and there is no further exposure to risk. Risk Controlled o Where the hazard remains present but the physical and management controls are sufficient to ensure that both the severity of outcome and the likelihood of an incident are reduced as far as is reasonably practicable. Closure of a risk will involve reduction of the risk score and that reduction must be validated by a manager with the authority to accept the original risk score. 5.3.10 Equality Impact Assessment When undertaking your risk assessment, it is important to consider the impact on equality and disability. Please indicate on the risk assessment Proforma and the risk register if you have undertaken an assessment for equality and disability. Any appropriate actions should be included on the risk assessment action plan. For further information please refer to the guidance on Equality Impact Assessment. 15 5.4 The Risk Register The web-based risk register is accessible at http://safeguard/safeguard/ Access to the risk register is given to department, speciality and directorate managers with access rights given to reflect the authority of the manager, so: department managers can see all the risks in their department, speciality managers can see the aggregated risks of departments in that speciality and, Directorate management teams can see aggregated risks from all specialities and departments under their control. The organisational risk register comprises the aggregated risks from all clinical directorates and non-clinical departments and is accessible by the Executive Management Team and those specialists managing risk at the Trust, with filters allowing a focus on high and significant risks. The committee reporting framework facilitates reporting escalation and monitoring of high and significant risks from the organisational risk register with the frequency given at table 2 above. 5.4.1 High Risks on the risk register High risks are those scoring above 15 and must be escalated to the relevant Directorate Management Team and to the Risk Manager, Health, Safety and Security Manager, Director of Healthcare Governance and Education or the Chief Medical or Nursing Officer. 5.5 The assurance framework Strategic or Corporate risks are those that transcend the department, speciality or directorate that have identified and escalated them and are expected to affect the strategy and direction of the Trust with an impact on numerous people within or outside of the Trust. Corporate objectives which are recognised by the Trust Board as priorities to the organisation are defined within 5 themes. Known risks to meeting these objectives are aligned to these themes. Actions to mitigate those risks are monitored through the assurance framework. The assurance framework is also populated with those high risks escalated through the risk register. 16 5.6 Training and Education Training in risk awareness and use of the risk register is delivered to staff in accordance with the Training Needs Analysis developed by the Governance Support Unit and implemented at departmental level. Additional training documentation and support is found within the Governance Support Unit intranet pages. Access to the risk register is not just limited to one person per area, a wide range of staff can be nominated following a brief training outline from the Risk Manager or Health, Safety and Security Manager. Do not attempt to use the register without training. The Education & Learning (E & L) department will be proactive in the consultation of E & L delivered at BCH NHS FT in response to workforce and service needs. For all Statutory and Mandatory Training E & L will design and facilitate the events. In order to demonstrate compliance; the following statements apply: Attendance at all Statutory and Mandatory learning/training events will be recorded onto the Oracle Learning Management (OLM) system. Any non-attendance, for booked places, will be escalated to the relevant individual and their line manager and department. Statutory and Mandatory Training attendance % be reported for line managers and departments to monitor compliance % on a Trust Dashboard; against defined Key Performance Indicators (KPIs). Each department and Directorate will be able to use this information for robust reporting (to the relevant committees, meetings and forums within the current Governance framework), monitoring and to produce action plans to assure that compliance is met. E & L will undertake quarterly audits of policies that they originate/develop to assure monitoring and compliance is met. 6.0 Monitoring of this policy 6.1 Risk Register Review An annual review of the risk register system is undertaken by the Risk Manager and submitted to the Clinical Risk and Quality Committee. That report shall consider: The location of risks and use of the risk register Risk scoring and validation; Controls in place; 17 Actions to put additional controls in place; Review and closure of risks. 6.2 Review of High Risks Risk Reports are presented to the Clinical Risk and Quality Committee and Non-Clinical Risk Coordinating Committee on a monthly basis. These reports include all high risks and other risks which those committees have asked to receive information about. Reports are received in order to discuss progress toward implementing actions which will reduce risk. High risks are subsequently highlighted to the Quality Committee of the Board: By CRAQ through the monthly Quality Report. From NCRCC through its’ monthly report to that committee. 6.3 Review of Significant Risks Directorates are expected to report significant clinical risks and work toward controlling them as part of the reporting framework to the Clinical Risk and Quality Committee. Directorates are expected to report significant non-clinical risks and work toward controlling them as part of the reporting framework to the Non-Clinical Risk Coordinating Committee. 7.0 Links with other Trust Policies and procedural documents Safety Strategy SIRI Policy Incident Reporting Policy Being Open policy Learning from Experience policy Health and Safety Policy Counter-Fraud Policy & Guidance Governance Training Needs Analysis 18 Appendix 1 Risk Matrix 1 The matrix explained The purpose of giving risks scores is to give the risk a priority / severity rating that enables BCH to review its risks in a more objective and systematic way. At BCH the following risk matrix scoring system is used. Consequence Likelihood 1 2 3 4 5 1 1 2 3 4 5 2 2 4 6 8 10 3 3 6 9 12 15 4 4 8 12 16 20 5 5 10 15 20 25 The likelihood is the frequency that the risk will occur, with the scoring column located in the left column. 1 is a low likelihood and 5 is high. The consequence is the adverse outcome associated with the risk that has occurred. The scoring row is located in the top row of the matrix. 1 is a low impact and 5 is high. Likelihood x Consequence = Risk Score After the likelihood and consequence have been decided they are multiplied together and equal the risk score. The overall risk score CANNOT exceed 25. The following outlines the priority / severity rating for the above matrix in more detail: Risk type Risk Colour Risk Score Low risk Green 1 to 6 Moderate risk Yellow 8&9 Significant risk Orange 10 & 12 High risk Red 15 to 25 19 Choosing risk scores is very subjective and may mean different things to different people, for example driving without a seat belt on may be considered by some as low risk and others as high risk. To ensure that the risks assessed at BCH are risk scored consistently, the following descriptors of consequence and likelihood are used. 2 To determine the Consequence score Consequence may be scored on a number of scales depending on the nature of the risk being assesses. These are listed I Table A1 below. Different risk types defined in the first column should be used to determine on which row the risk is being scored. Read across subsequent columns unto identify the descriptor which best mirrors the typical outcome from this hazard and use the numerical score at the top of that column as the consequence score. 2.1 Consequence Modifiers Some hazards may affect only one person or a small number of people within a ward or department at BCH. Larger groups may be affected as hazards stretch across multiple wards or departments at BCH; or even to our patients and families outside of BCH. Harm to these larger groups which is minor in nature can be missed as we prioritise more severe harm. But where there is a cumulative effect of lots of minor harm across a large number of people we want to reflect that in our scoring. The consequence modifiers in Table A2 are used to raise the consequence scores and better reflect the severity of these risks. 2 rules apply to using modifiers: They should only be used when scoring consequences with descriptors highlighted in the same colours as in the modifier table. 3 The final outcome score cannot be higher than 5 and the minimum is 1. To determine the Likelihood score Score the likelihood by assigning a predicted frequency of the adverse outcome occurring. That may be the simple descriptor; the more quantitative description given under frequency; or the more accurate probability, which may be derived from a measurement of an actual incident rate. 20 Table A1 Consequence scores Descriptor 1 2 3 4 5 Insignificant Minor Moderate Major Catastrophic Insignificant cost Objectives/ Projects increase/ schedule slippage. Barely noticeable reduction in scope or quality Injuries Patient Care <5% over budget/ 5-10% over budget/ schedule slippage. schedule slippage. Minor reduction in Reduction in scope or quality/ scope quality. Minor injury or RIDDOR/ Agency illness, first aid reportable. Moderate treatment needed injury. Unacceptable Moderate Acceptable management but no Mismanagement of management adverse outcome patient care with Minor Injury not requiring first aid adverse outcome Complaints/ Locally resolved Claims complaint Service/ Business Interruption Justified complaint peripheral to clinical care Below excess claim. Justified complaint involving lack of appropriate care 10-25% over budget/ schedule slippage. Doesn’t meet secondary objectives Major injuries, or long term incapacity/ disability (loss of limb) >25% over budget/ schedule slippage. Doesn’t meet primary objectives Death or major permanent incapacity Serious Mismanagement of Death patient care with an adverse outcome Claim above excess Multiple claims level. Multiple or single major justified complaints claim Loss/ interruption > 1 Loss/ interruption > Loss/ interruption > 1 Loss/ interruption > hour 8 hours day 1 week Permanent loss of service or facility Non delivery of Short term low Staffing and Competence staffing level On-going low temporarily reduces staffing level reduces service quality (<1 service quality day) Late delivery of key Uncertain delivery key objective/ objective/ service due of key objective/ service due to to lack of staff. Minor service due to lack lack of staff. Loss error due to poor of staff. Serious of key staff. training. On-going error due to poor Critical error due unsafe staffing training to insufficient training Financial Small loss Minor Inspection/ Audit recommendations Minor noncompliance with standards Adverse Publicity/ Reputation Rumours Loss > 0.1% of budget Recommendations given. Noncompliance with standards Loss >0.25% of budget Loss of >0.5% of Loss of >1% of budget budget Reduced rating. Enforcement Action. Challenging Low rating. Critical recommendations. report. Major non- Non-compliance with compliance with core standards core standards Local Media – short Local Media – long term. Minor effect term. Significant effect on staff morale on staff morale National Media < 3 Days Prosecution. Zero Rating. Severely critical report National Media > 3 Days. MP Concern 21 (Questions in House) Table A2 Consequence Modifiers C = -1 (Minimum 1) C = +1 (Maximum 5) C = +2 (Maximum 5) Number of people More than a single ward or More than the whole Trust Affected department (Local Health Economy) Importance of service, Minor service/ project/ Service/ project/ objective Service/ project/ objective project or object at risk objective important to the whole Trust critical to the whole Trust Table A3 Likelihood Score Descriptor Frequency Probability 1 2 3 4 5 Rare Unlikely Possible Likely Almost Certain Not expected to occur for Expected to occur Expected to occur at Expected to occur Expected to occur years at least annually least monthly at least weekly at least daily < 1% 1-5% 6-20% 21-50% >50% Will only occur in exceptional circumstances Unlikely to occur Reasonable chance of occurring Likely to occur More likely to occur than not 22 Appendix 2 - Risk Assessment Proforma Risk Assessors Name: Date of Assessment: Overall Risk Assessment Score (highest original risk score): Area / Speciality (completing Location of Risk: Type of risk (e.g., clinical, non-clinical, finance) Proforma): Description of Risk Assessment (include here: Main Risk, Source of risk, & Reason for assessment): Through a description of the background to the problem being considered, hazards may be identified. Descriptions of the background would answer the questions: What are we risk assessing? Some answers are given in the tables at Appendix B What are the drivers? Some answers are given at Section 5 above What is the problem? This is the heart of the description and may refer to a piece of equipment, may describe a work area; it may describe the findings of an incident investigation; it may summarise e the findings of an external or internal audit report or review. hazards occurring. REQUIRED to reduce / eliminate the effects (Inc. Responsibility PLACE to prevent risk & ACTIONS / TREATMENT Time scale with the description) HAZARDS CONTROL MEASURES IN RISK SCORE RISKS & HAZARDS (associated EFFECTS OF THE RISKS & costs) 23 Appendix 3 Risk Assessment Options Appraisal Location of risk: Risk Assessment Ref.: Author of submission: Date: Essential Background Information: (maximum of 500 words – an outline of background information to support this submission) Results of Risk Assessments: (E.g. general risk assessment or specialist assessments such as COSHH, handling (patient and non-patient, display screen, personal protective equipment, violence and aggression, latex etc.) Options for Discussion: Implications for the Trust: (including financial and other resource implications) Recommendation: Outcome: (to be completed by the chair of the group to which the submission has been made) Signature: ……………………………………………. Date: ……………………………. Title: ………………………………..………………… 24 Appendix 4 Risk Assessment Options Appraisal on the risk register An appraisal of the benefits of identified controls may be undertaken directly on the risk register. Choose the solution type Describe the solution Weigh up the pros and cons Add in any 25 Click on the pencil to open a larger window with the boxes to fill out 26 APPENDIX 5 GOVERNANCE TRAINING NEEDS ANALYSIS Foundation Governance Training Topic areas Staff Advanced Governance Training Incident reporting Complaints Claims and Inquest Incident management and investigation SIRI investigation Risk Management Security Management Statement writing Complaints Investigation Health and Safety Risk Register Management Policies Processes Responsibilities Risk Awareness All Staff Ward Managers Department Managers Speciality Managers Service Managers Directorate Managers DLR Investigators SIRI chairs Refresher frequency Every 2 years Need determined on individual basis through PDR Delivery Class-room learning sessions Moodle Blended delivery of class-room learning sessions supported by online resources. 27