What’s on the safety and regulatory horizon for independent practitioners? David Hare reports.
Responding to Covid-19 has, of course, dominated the lives of independent practitioners for the last few years.
And while we can expect another winter of potential new variants of the virus and the return of the flu season, we are gradually starting to get back to ‘normal’.
This includes the introduction of a number of new safety and regulatory initiatives that have been delayed due to the pandemic that independent practitioners should be aware of in the coming months.
1 The Care Quality Commission (CQC) is continuing to develop its new regulatory model
While the CQC will continue to use its existing five key questions around a service – is it safe, effective, caring, responsive and well-led? – under each key question, there will be a set of topic areas and quality statements which describe what good care looks like.
The CQC has now published those quality statements and include for example: ‘We have a proactive and positive culture of safety based on openness and honesty, in which concerns about safety are listened to, safety events are investigated and reported thoroughly, and lessons are learned to continually identify and embed good practices.’
Another example of its quality statements is: ‘We work effectively across teams and services to support people.
‘We make sure they only need to tell their story once by sharing their assessment of needs when they move between different services.’
Independent practitioners and providers are rightly proud of their high CQC scores. Currently, 94% of Independent Healthcare Providers Network (IHPN) member locations are rated good or outstanding.
Moving to a new regulatory framework is, however, always both an opportunity and a challenge.
It is an opportunity to make sure that innovation and new models of care are considered, and a challenge due to an approach where, for example, ratings could be changed without an on-site inspection.
At the IHPN, we are fully engaged with the CQC through our regular engagement activities and also as a member of its Provider Implementation Steering Group.
And we will be working with our members to ensure they are fully prepared for the CQC’s changes and can continue to demonstrate the high-quality care they deliver.
2 Next up is a major change in the way patient safety incidents will be conducted
As I write, we will soon see the publication of the new Patient Safety Incident Response Framework (PSIRF).
Secondary care providers will, by the time you read this, have been asked to prepare for the transition to PSIRF from September, with all organisations transitioning to PSIRF by Autumn 2023.
This will replace the current Serious Incident Framework (SIF), with the aim of moving away from reactive and hard-to-define thresholds for ‘serious incident’ investigation and towards a proactive approach to learning from incidents.
Ultimately, PSIRF will give individual organisations the responsibility for deciding which incidents are to be investigated, and expectations will be clearly set for informing, engaging and supporting patients, families, carers and staff involved in patient safety incidents and investigations.
This will very much be a new way of working for providers and practitioners, and the IHPN will be working to support members through this transition.
Sharing best practice and learning among members will be included, as well as ensuring that independent providers and practitioners are fully part of local system working on PSIRF.
Each NHS Integrated Care System (ICS) is expected to employ a PSIRF lead, who will support patient safeguarding reporting within the ICS.
3 Another change this year will be around preparing for the implementation of a statutory medical examiner system
This is designed to introduce an additional layer of scrutiny of the cause of death by a medical practitioner.
The aim is to help both improve the quality and accuracy of the medical certificate of cause of death and inform the national data on mortality and patient safety.
Once secondary legislation has been laid and the statutory medical examiner system commences, the intended requirement is for medical examiners to provide independent scrutiny of all deaths not taken for investigation by a coroner, including in the independent sector.
This system will formally commence from April 2023 and a key change with be around amending the Medical Certificate Cause of Death to enable the recording of the Medical Examiners’ view.
We will be liaising with the team at the National Medical Examiners Office on this to ensure independent providers and practitioners are fully aware of what they need to do.
4 This autumn will see the refresh of IHPN’s Medical Practitioners Assurance Framework (MPAF)
The MPAF is currently part of the CQC’s inspection framework and is designed to foster a more standardised approach to medical governance in the sector and ultimately drive up the quality and safety of care for patients.
Always designed to be an iterative document, the refresh will include strengthened wording to ensure it remains in keeping with current best practice around medical governance in the health system.
We have been so pleased with how independent practitioners and providers have embraced the principles in the MPAF and we will be working in the autumn to ensure the refresh is fully embedded in the sector’s work to drive continuous quality improvement.
It is clearly going to be a busy time for safety and regulation in the independent healthcare sector this autumn.
And here at the IHPN we will continue to play our role in making sure providers and practitioners are fully factored into all regulatory and policy changes, enabling them to continue delivering high-quality care to so many millions of patients.
David Hare (right) is chief executive of the IHPN