NHS Bradford District and Craven

BRADFORD DISTRICT & CRAVEN CCG BD&C CCG Governing Body - Public Tuesday 9 March 2021 13:15 –15:25 To be held via Zoom – details to be circulated separately

AGENDA

ATTENDEES TO NOTE: the meeting may be audio-recorded to assist with minute-taking. Whether a meeting is being recorded will be confirmed at the start of the meeting by the Chair. All recordings will be destroyed after approval of the minutes to which they relate.

Page Item Lead Purpose Time Mins No 1. Welcome & Apologies James Thomas Information - note 13:15 2 Verbal Report 2. Declarations of Interest James Thomas Action - as 13:17 1 Verbal required Report

3. Questions from the public James Thomas Action - discuss 13:18 2 Verbal Report 4. Minutes of the previous meeting James Thomas Decision - approve 13:20 5 held 12 January 2021 and action 7-17 log 5. Chief Officer & Clinical Chair’s Helen Hirst Information - note 13:25 10 18-28 Report James Thomas 6. ICS Next Steps Helen Hirst Information & 13:35 15 Verbal Assurance Report 7. Review of the Strategic Partnering Vicki Wallace Information & 13:50 15 29-33 Agreement Assurance 8. Update on Children’s Autism Ali Jan Haider Information & 14:05 15 Services Assurance 34-40

9. Finance Robert Maden Information & 14:20 15 41-58  Update Report Assurance  Operational Planning 2021/22 10. Patient Safety and Quality Michelle Turner Information & 14:35 10 59-78 Improvement Report Assurance 11. Safeguarding Annual Report Michelle Turner Assurance 14:45 5 79-102

Comfort Break 14:50 5

12. Assurance Framework Sue Baxter Decision – approve 14:55 10 103-138

13. Review of Policies: Sue Baxter Decision - approve 15:05 5  Policy on Receipt of Gifts, 139-209 Hospitality & Sponsorship  Conflicts of Interest & Business Conduct Policy 14. High Level Risk Report Sue Baxter Assurance 15:10 5 210-237

1 15. Exception reports from Committee Bryan Millar Information & 15:15 5 Verbal Chairs David Richardson Assurance Report Neil Fell Ruby Bhatti

Items to receive and note

Page Item Lead Purpose Time Mins No 16. Primary Care Commissioning Ruby Bhatti Assurance 15:20 3 238-244 Committee minutes: 10 November 2020 17. Finance and Performance Neil Fell Assurance 245-269 Committee minutes: 3 December 2020 & 7 January 2021 18. Quality Committee minutes: 3 David Richardson Assurance 270-286 December 2020 & 7 January 2021 19. Audit & Governance Committee: 2 Bryan Millar Assurance 287-297 November 2020 20. Exclusion of the public - it is James Thomas Decision - approve 15:23 1 Verbal recommended that the following report resolution be passed: "That representatives of the press and other members of the public be excluded from the remainder of the meeting, having regard to the confidential nature of the business to be transacted, publicity on which would be prejudicial to the public interest 21. Date and time of next meeting: 11 James Thomas Assurance 15:24 1 Verbal May 2020, 1.15pm – 4.15pm Report

For any queries regarding this agenda, please contact: Stacey Fleming, Senior Governance and Resilience Manager,[email protected]

We are working to make our meeting papers accessible. If you need these papers in a different format, please contact Stacey Fleming on the above details.

2 Conflicts of Interests Check List for Meeting Chairs

(Appendix C of the Conflicts of Interest and Business Conduct Policy)

Meeting Chairs have responsibility for ensuring the appropriate management of conflicts of interest during the course of CCG meetings (see below for a definition and examples of ‘interests’). In particular they must ensure:

 They prepare for the meeting mindful of any actual or potential conflicts of interest that may arise relevant to the business of that meeting. Where conflicts of interest are known in advance, the individual concerned must not receive the supporting papers or minutes of the meeting which relate to the matter(s) which give rise to the conflict.

 That declarations of interest are always an item on the agenda.

 That the meeting is quorate and that this is recorded in the minutes.

 That members are asked to declare any interests that are likely to lead to a conflict or potential conflict that could impact (or has the potential to impact) on any items on the agenda. This should be repeated again at individual item(s) where it is considered a conflict is likely to or could potentially arise.

 Any declaration must be made clearly noted in the minutes both at the start of the meeting and at the relevant item. If there is any doubt as to whether or not a conflict of interest could arise, a declaration should be made and noted in the minutes.

The minutes must specify how the Chairs have decided to manage the declared interest. The appropriate course of action will depend on the particular circumstances, but could include one or more of the following:

 Where the Chair has a conflict of interest, deciding that the vice Chair (or another non-conflicted member of the meeting if the vice Chair is also conflicted) should chair all or part of the meeting;  Requiring the individual who has a conflict of interest (including the Chair or vice Chair if necessary) not to attend the meeting;  Ensuring that the individual concerned does not receive the supporting papers or minutes of the meeting which relate to the matter(s) which give rise to the conflict;  Requiring the individual to leave the discussion when the relevant matter(s) are being discussed and when any decisions are being taken in relation to those matter(s). In private meetings, this could include requiring the individual to leave the room and in public meetings to either leave the room or join the audience in the public gallery;  Allowing the individual to participate in some or all of the discussion when the relevant matter(s) are being discussed but requiring them to leave the meeting when any decisions are being taken in relation to those matter(s). This may be appropriate where, for example, the conflicted individual has important relevant knowledge and experience of the matter(s) under discussion, which it would be of benefit for the meeting to hear, but this will depend on the nature and extent of the interest which has been declared;  Noting the interest and ensuring that all attendees are aware of the nature and extent of the interest, but allowing the individual to remain and participate in both the discussion and in any decisions. This is only likely to be the appropriate course of action where it is decided that the interest which has been declared is either immaterial or not relevant to the matter(s) under discussion. The conflicts of interest case studies include examples of material and immaterial conflicts of interest.

In making this decision the Chairs will need to consider the following points:

- the nature and materiality of the decision - the nature and materiality of the declared interest(s) - the availability of relevant expertise - as a general rule (and subject to the judgement of the Chairs), if an interest involves a financial interest or a significant non-financial interest, the individual should be asked to leave the meeting for the whole item

 Who has the interest  The nature of the interest and why it gives rise to a conflict, including the magnitude of any interest  The items on the agenda to which the interest relates  How the conflict was agreed to be managed, and  Evidence that the conflict was managed as intended (for example recording the points during the meeting when particular individuals left or returned to the meeting).

 Quoracy of the meeting or for individual items must be checked if an interest is declared. If the meeting is no longer quorate (in full or for particular items) or there is insufficient relevant expertise to inform decision-making once those with conflicts of interests are excluded, the Chairs must agree how this should be managed, i.e. defer the item / meeting or refer any decisions for particular items(s) to another Committee for consideration and formal approval.

 Refer to Standard Financial Instructions for Delegated Limits

Definition of Conflicts of Interest (Section 5 of the CCG Conflicts of Interest Policy)

Conflicts of interest may arise where personal interests or loyalties conflict with those of the CCG. Such conflicts may create problems such as inhibiting free discussions which could result in decisions or actions that are not in the best interests of the CCG, patients or the public and risk creating the impression that the CCG has acted improperly.

NHS England defines a conflict of interest as occurring:

“Where an individual’s ability to exercise judgement or act in a role is, could be, or is seen to be impaired or otherwise influenced by his or her own involvement in another role or relationship.

In some circumstances, it could be reasonably considered that a conflict of interest exists even when there is no actual conflict” (i.e. a perceived conflict).

The latest version of this guidance is Managing Conflicts of Interest: Revised Statutory Guidance for CCGs, June 2017. This guidance supersedes the previous version (June 2016) and has been fully aligned with the new cross-system guidance on Managing Conflicts of Interest in the NHS which was published in February 2017.

NHS England identifies four categories of conflicts of interest:

1. Financial interests: This is where an individual may get direct financial benefits from the consequences of a commissioning decision. This could, for example, include being:

4  A director, including a non-executive director or senior employee in a private company or public limited company or other organisation which is doing, or which is likely, or possibly seeking to do, business with a health or social care organisation.  A shareholder (or similar ownership interests), a partner or owner of a private or not-for-profit company, business, partnership or consultancy which is doing, or which is likely, or possibly seeking to do business with a health or social care organisation.  A management consultant for a provider

This could also include an individual (or their practices, in the case of GPs) being:

 In secondary employment (see Section 7.2)  In receipt of secondary income from a provider.  In receipt of a grant from a provider.  In receipt of payments (for example, Honoria, one-off payments, day allowances or travel or subsistence) from a provider.  In receipt of funding from the pharmaceutical or med-tech industry as part of a joint working arrangement.  In receipt of research funding, including grants that may be received by the individual or any organisation in which they have an interest or role; and  Having a pension that is funded by a provider (where the value of this might be affected by the success or failure of the provider).

2. Non-financial professional interests: This is where an individual may obtain a non-financial professional benefit from the consequences of a commissioning decision, such as increasing their professional reputation or status or promoting their professional career. This may, for example, include situations where the individual is:

 An advocate for a particular group of patients;  A GP with a special interest(s);  A member of a particular specialist professional body (although routine GP membership of the Royal College of General Practitioners, British Medical Association or a medical defence organisation would not usually by itself amount to an interest which needed to be declared);  An advisor for the Care Quality Commission (CQC) or the National Institute for Health and Care Excellence (NICE);  A medical researcher.

3. Non-financial personal interests: This is where an individual may benefit personally in ways which are not directly linked to their professional career or do not give rise to direct financial benefit. This could include, for example, where the individual is:

 A voluntary sector champion for a provider;  A volunteer for a provider;  A member of a voluntary sector board or has any other position of authority with a voluntary sector organisation.  A member of a lobby or pressure group with an interest in health.

4. Indirect interests: This is where an individual has a close association with an individual who has a financial interest, a non-financial professional interest or a non-financial personal interest in a commissioning decision, for example:

 Spouse / partner  Close relatives e.g. parent, grandparent, child, grandchild or sibling;  Close friend;  Business partner. A declaration for a “business partner” in a GP partnership should include all relevant collective interests of the partnership and all interests of their fellow GP partners (this could be done by cross-referring to the separate declarations made by those GP partners).

It is not possible to define all instances in which an interest may be a real or perceived conflict.

If in doubt it is better to assume the existence of a conflict of interest and declare it, rather than ignore it.

6 DRAFT Minutes of the Governing Body PUBLIC Tuesday 12 January 2021, 13:15 – 15:10 Meeting held via Zoom Present: Sohail Abbas Deputy Clinical Chair and Strategic Clinical Director Population Health & Wellbeing Ruby Bhatti Lay Member for Primary Care Commissioning & Communities (Meeting Chair) Peter Brunskill Secondary Care Consultant Louise Clarke Strategic Clinical Director of Strategy and Planning Angie Clegg Registered Nurse Neil Fell Lay Member for Finance & Performance Helen Hirst Chief Officer Robert Maden Chief Finance Officer Bryan Millar Lay Member for Audit & Governance David Richardson Lay Member for Quality Michelle Turner Strategic Director of Quality and Nursing

In Attendance: Liz Allen Strategic Director of Organisation Effectiveness Bev Denton Governance & Corporate Manager (observing) Sarah Dick Head of Corporate Governance Pam Essler Lay Chair of the Individual Funding Request Panel Stacey Fleming Governance & Corporate Manager (Minutes) Ali Jan Haider Strategic Director of Keeping Well at Home Charles Strachan Chair, CCG Council

Apologies: James Thomas Clinical Chair

Members of the public: 1

1 Welcome and Apologies

Ruby Bhatti, acting as meeting Chair welcomed everyone to the meeting of the Governing Body of Bradford District & Craven Clinical Commissioning Group (BD&C CCG).

James Thomas had given his apologies for the meeting.

The meeting was noted to be quorate.

2 Declarations of Interest

No declarations of interest were made against any agenda items. The register of interests records can be found at: https://www.bradfordcravenccg.nhs.uk/ccg-information/publication-scheme/lists-and-registers/

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3 Questions received from the public

No questions had been received from the public ahead of the meeting.

4 Minutes of the previous meeting held 10 November 2020

The minutes of the previous meeting held on 10 November 2020 were agreed to be a true and accurate record.

RESOLVED: The Governing Body:

 Approved the minutes of the public meeting of the Governing Body held on 10 November 2020

5 Clinical Chair and Chief Officer’s Report

Helen Hirst, Chief Officer, presented the item, which provided an update to the Governing Body about key issues, meetings and partnership activities affecting the CCG together with updates on national guidance and, where relevant, local impact of this guidance.

An update was provided regarding the Covid-19 vaccination programme where it was noted that provision of vaccines was being delivered via the hospitals, Primary Care Networks (PCNs) and Community Pharmacy. Vaccination centres were also being established in locations such as Jacob’s Well in Bradford. It was noted that the supply of vaccines was coordinated nationally to ensure fair and equal distribution. Helen updated that there had been a change in policy to deliver as many first doses of the vaccine as possible and delay administering the second dose until 12 weeks, which was based on evidence based guidance which was publicly available. It was noted that NHS England (NHSE) had provided assurance about the supply of the second dose.

It was noted that the nationally mandated cohorts of people being prioritised for vaccines were the over 70’s, care home residents and those who were clinically extremely vulnerable (CEV). Vaccines were also being made available to frontline health and care staff in line with national guidance.

Helen drew attention to the outstanding response across the system in delivering the vaccines. On behalf of the Governing Body, Ruby wished to thank all involved for their hard work in supporting the vaccination programme.

Responding to a query regarding the process of inviting people for a vaccine, Helen advised that the PCNs / practices were inviting people at this stage. . It was noted that work was ongoing through the Act as One (AaO) programme to support people who may not be registered with GP, such as the homeless, to access vaccinations. Work was also ongoing to identify people in the wider system, such as dentists, optometrists, who may not be identified through the usual routes.

Helen advised that in response to concerns about low take up in some communities resources were available in different community languages and the promotion of positive messages relating to vaccine uptake was noted.

Helen went on to report that responses to the NHSE/I paper on next steps for Integrated Care Systems (ICSs) had been submitted from the CCG, the Bradford district and Craven Partnership and as an ICS (copies of the responses had been circulated prior to the meeting). It was reflected that the Lay Members had appreciated the opportunity to contribute to the responses.

There were no questions on the reports from the Senior Leadership Team included in the update.

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RESOLVED: The Governing Body:

 Noted the information and assurance provided by the Clinical Chair & Chief Officer’s report.

6 Business Continuity and Resilience Update

Liz Allen, Strategic Director of Organisation Effectiveness, and Michelle Turner, Strategic Director of Transformation and Change & Deputy Chief Officer, presented the item, noting that the update was being presented today to provide information and assurance on the CCG’s approach to managing Covid- 19 in Bradford district and Craven. The paper also provided an update on the CCG’s arrangements for responding to the end of the EU exit transition period and the arrangements in place to manage surge and escalation (winter) pressures with partners across the system.

Liz reported that the numbers of incidences of Covid-19, positivity rate, number of hospitalisations and the number of deaths had increased since the report had been written. It had been anticipated that the peak in Bradford was expected to occur this week, however the data was awaited to see if this was the case.

An update was provided around the EU exit and it was noted that organisations across the NHS had been encouraged to ensure measures were in place regarding supplies of medicines and consumables, workforce, data, reciprocal healthcare, vaccines, blood & transport and research & development. The CCG was required to complete a daily return to NHSE and so far, no issues had been reported in any of the areas noted.

Liz updated those present on the CCG tactical actions that had been agreed at the fortnightly CCG silver command meetings. It was reported that the Covid secure risk assessment for Scorex House had been updated in light of the new lockdown measures and this had resulted in a reduction in the number of staff currently working from the premises.

Ruby raised a point about the factors involved in the increase in numbers relating to those affected by Covid-19. It was suggested that the transmissibility of the new variant of Covid-19, along with the increased interaction between households over the Christmas period could be contributing to the increases.

Michelle Turner updated that she had taken on the co-chairing of the Health & Care System Silver meeting along with Iain MacBeath in November 2020. The meeting focussed on tactical decisions across the system and involved wide ranging, collaborative input from system partners. Discussions had focussed on patient flow through the system and the safe discharge home of patients once they were medically fit. There had also been discussions around the monitoring of workforce, including the factors contributing to staff absence from work, such as Covid-19 and stress. The impact of the pandemic on general practice had also been discussed.

Michelle updated that there had been a real focus on not losing the ways of working developed throughout phase 1 & 2 of the pandemic, and that there had been discussions around supporting the care sector throughout the current phase, such as supporting the work around the super rota.

David Richardson raised a query relating to the capacity of the system in the local area and Michelle advised that whilst the numbers of hospitalisations had risen, the increase was not as significant as had been experienced in other areas. The data would continue to be monitored to understand the position across the system.

Michelle reflected on discussions that were occurring at the Health & Care System Silver meetings around achieving more pace behind aspects of the medium term strategy. Three programmes noted in particular were the Ageing Well/Frailty programme, led by Rob Aitchison, the Access programme led by Sajid Azeb, and the Respiratory Programme led by Karen Dawber.

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RESOLVED: The Governing Body:

 Noted the update on the current Covid-19 situation in Bradford district and Craven and the CCG’s approach to managing COVID-19 both within the organisation and across ‘place’  Noted the phased roll-out of COVID-19 vaccination programme  Noted the CCG’s arrangements for managing the end of transition period for EU exit  Noted the CCG’s contribution to the management of surge and escalation (winter) pressures.

7 Restart and recovery

Louise Clarke, Clinical Director Strategy and Planning, presented the item, noting that the item was being presented to provide an update on the restart and recovery of elective care in Bradford district and Craven throughout the Covid-19 pandemic.

It was noted that there was a system approach to restart and recovery and there had been agreement to restart activity by prioritising patients in terms of clinical need. An operational group had also been established to develop the planning behind this work and to ensure any activity was carried out safely and in line with social distancing measures in place.

Louise updated that additional capacity had been secured from the independent sector through a national contract put in place by NHSE/I. For Bradford district and Craven, this was with the Optegra Yorkshire Eye Hospital and the Ramsay Yorkshire Clinic who have played a key role in supporting our two hospitals to continue providing safe, high quality and effective care.

It was noted that the purpose of the Access to Care programme is to reduce inequalities between patients in their access to, and outcomes from, healthcare services by providing integrated services. Louise reflected on the collaborative approach between the two hospital trusts, noting the support they were offering each other in some specialities in order that patients with the highest priority of need could be treated quickly.

Louise advised that all patients on waiting lists had been clinically assessed and had been written to by the hospital advising them of this. Consideration was being given as to what support from system partners could be offered to patients on waiting lists for procedures, such as access to voluntary care sector (VCS) organisations.

The difficulty in being able to predict levels of elective care as we respond to further waves of Covid-19 was noted and the challenging position in clearing the backlog was reported, however work continued to look at the totality of the resource available across the system and consider how this could best be used. It was noted that despite the challenging position on elective recovery, both trusts have continued to perform well for patients who need to be seen on the 2 week wait cancer referral pathways and they have continued prioritising cancer treatment.

The service offered by community based providers in supporting key areas such as ultrasound and anticoagulation was noted as a key factor in trying to alleviate the pressure faced by the system currently.

Consideration had been given as to how the NHS estate could be fully utilised to alleviate pressure in the system. Sites such as Eccleshill and Westwood Park were being used to support the main sites.

Neil Fell reflected on the good work noted in the report, especially in relation to the collaborative approach seen across the system. Responding to a query raised by Neil in relation to the reported waiting list position for the two acute hospitals, Louise advised that during the first wave, the ability to make referrals was shut down for anything other than cancer or emergencies. Some specialities

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10 continued to provide access through community based services, however some did not, and therefore there was the possibility that there was an un-presented demand.

Pam Essler noted the hard work around restarting activity, however noted the potential for some of the issues experienced may exacerbate health inequalities, especially for people who may find it difficult to navigate through the system to access the help they needed. Louise provided an update on the work that was ongoing to recognise patients who may be struggling in accessing services and identify what support can be put in around them to enable people to access the help they required.

RESOLVED: The Governing Body:

 Noted the content of the restart and recovery report.

8 BAME communities and staff: work at system and place

Sohail Abbas, Deputy Clinical Chair and Strategic Clinical Director Population Health & Wellbeing, noted the item was being presented for information and assurance. The paper provided a summary of the West Yorkshire and Harrogate (WY&H) health and care partnership’s BAME review in light of Covid-19, recommendations and the high level action plan approved by the health and care partnership (HCP). The paper also provided an update on the BAME staff network of BD&C CCG and the primary care BAME network, the work already undertaken, future planning and next steps.

Sohail reflected that whilst Covid-19 had impacted on every person in WY&H, some of the biggest impacts had been felt by the BAME community. In July 2020, WY&H HCP launched a review to understand the impact on BAME communities and staff.

Following the review, 16 recommendations had been identified under four main themes:  Improving access to safe work for BAME colleagues in WY&H  Ensuring the partnership’s leadership is reflective of communities  Population planning (using information to make sure that services meet different groups’ needs)  Reducing inequalities in mental health outcomes by ethnicity.

An action plan had been produced following the recommendations which would support planning at place level.

Sohail went on to update on the development of a BAME staff network at the CCG. So far, the network had been involved in facilitating a development session and had been involved in discussions around recruitment policies and processes. Ruby reflected on the discussions held at the development session attended by the CCG BAME network and thanked staff for their open and honest contribution.

It was noted that a representative of the network attends the weekly Senior Leadership Team (SLT) meetings. Further input would be sought from the network as the CCG develops its People Plan. A development session has been planned where members of the network can access group coaching to inform thinking on how the group operates and can mutual support can be utilised to enhance the experience of staff.

An update was provided regarding the development of the primary care BAME network in Bradford district and Craven. Expressions of interest had been sought from BAME staff across Bradford district and Craven to help establish the network and staff had been contacted to identify who would be interested in joining the network and to understand what key issues would be discussed at the first meeting due to be held in early 2021.

Sohail advised that Bradford Teaching Hospitals NHS Foundation Trust (BTHFT) had established an Equality & Diversity (E&D) network which was chaired by Mel Pickup and was due to meet later in January 2021. There was a focus for BTHFT to work with local communities to address inequalities.

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Ruby queried how the actions from the BAME networks could be taken forward in light of the development of ICSs. Sohail reflected that the principles that had been developed would be taken forward into a new organisation and the commitment would remain to make a positive impact on equality and diversity. The principles that had been established would be included in planning discussions and shared across the other organisations within the system.

RESOLVED: The Governing Body:  Noted the progress at the WY&H health and care partnership level  Noted the work the CCG is undertaking to create a skilled, motivated workforce with a culture of continuous improvement  Noted the work to establish a primary care BAME network  Endorsed the WYH BAME review recommendations.

9 Finance Update

Robert Maden, Chief Finance Officer (CFO), presented the item.

It was noted that the temporary financial regime established by NHSE/I had now ended. At the previous meeting, the final retrospective resource allocation adjustments for the first six months of the year had been outstanding. Robert confirmed that these had now been actioned which confirmed the break-even position for this period.

The report focused on the second part of the financial year (October 2020 – March 2021) and it was noted that the CCG had received a fixed funding envelope within which it was expected to manage costs.

At the previous meeting, an issue had been raised in relation to an allocation shortfall of £4.9m. Since that meeting, an adjustment of £2.1m had been agreed with NHSE which reduced the gap to £2.8m. The paper set out how the £2.8m baseline allocation shortfall would be addressed through local financial risk share agreements, deferral of development expenditure and other forecast budget underspends.

Robert provided an update on the year to date and forecast positions for costs within the fixed resource baseline, which show operational budget underspends of £0.2m and £0.65m respectively.

It was noted that Covid-19 related costs remained in line with the budget set of £1.3m and no further demand relating to these costs had been experienced in the current pandemic situations.

The paper highlighted the main financial risks and mitigations, which included hospital discharge scheme costs not being fully reimbursed, uncertainty relating to the financial impact of clearing the continuing healthcare assessment backlog and increased mental health inpatient demand.

RESOLVED: The Governing Body:

 Noted the year to date financial position to the 30 November 2020 and the forecast financial position to March 2021  Noted the receipt of £2.1m to correct the CCG’s primary care co-commissioning allocation and the corresponding reduction in the additional savings required to breakeven for the year  Noted the level of residual financial risk and how this is expected to be addressed.

10 Patient Safety and Quality Improvement report

Michelle Turner, Strategic Director for Quality and Nursing, noted that the report provided an overview of the key quality and safety issues arising from Covid-19 with consideration to the crisis response, the impact on the system and emerging issues. The update also noted key concerns regarding system Page 6 of 10

12 resilience, the rollout of the vaccine, safeguarding children and possible options to implement the new hosted commissioner responsibilities.

An update was provided regarding living with Covid-19 and it was noted that 900 pulse-oximeters had been distributed to PCNs for people who are experiencing significant respiratory issues to use at home. Through closely monitoring people, it was felt that this could allow for quick responses should this be required.

Work was ongoing as to what could be done for people suffering from the long term complications of Covid-19 and it was noted that a lot of work had been done on this on both a national and local basis. The data gathered from a local project monitoring patients who had Covid-19 but were now at home again was being shared with the ICS.

Michelle provided an update regarding the work that was ongoing to encourage uptake of the flu vaccine, such as initiatives like the ‘Flu Bus’ scheme. Michelle reflected on the hard work of the system in meeting the target for vaccine uptake and noted the learning that could be taken forward into next year around sharing information as a system by utilising system dashboards.

It was noted that there had been in-depth discussion at Quality Committee (QC) regarding health assessments for ‘Children Looked After’, where it had been noted that a more sustainable clinical model had been agreed at System Quality Committee (SQC). The model would be implemented in April 2021 and would involve GPs with a special interest in this area. The model had been supported by members of the Care Trust and both acute hospitals and had been a good example of the ‘Act as One’ approach and system working.

Michelle provided an update on discussions regarding the draft system model for designated doctor and named doctor in light of intercollegiate requirements. Offers of help had been received from across the system and it was noted that since the discussion at QC, a person had been identified to work to the system to support the strategic nature of the model. NHSE had approved the interim arrangements that had been put in place and it was noted that they had been kept briefed on the process.

Michelle advised that there had been discussion at QC in December 2020 regarding the Ockenden Report and reflected on the learning that had followed its publication. It was noted that the initial findings from 250 cases had been shared nationally with designated maternity units and Bradford and Airedale had been a part of the review. The recommendations had been given to each region to look at quality assurance and implement learning across the ICS and at place. Locally, the Better Births programme was in place and would oversee the work being done to address the recommendations.

An update was provided on the development of the SQC and Michelle advised this committee had been meeting for approximately 18 months. Discussions had focussed on ‘doing things once’ and looking at areas to add value to. There had been system discussions regarding children’s services, maternity services and care home resilience. Discussions were due to be held regarding the priorities identified in the next planning round where the system could address safety and safeguarding issues.

RESOLVED: The Governing Body:

 Noted the information and assurance provided by the report, including key actions taken by the CCG to manage quality and safety issues and risks arising from Covid-19.

11 High Level Risk Report

Sarah Dick, Head of Corporate Governance, presented the high level risk report, which provided the Governing Body with details of risks with scores of 15 or above, new risks and risks closed during the current risk review cycle (Cycle 4 covering months November - December 2020).

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Three new risks had been added to the Corporate risk register during the current cycle, relating to October 2020 – March 2021financial position (scoring 16), the underlying financial position (also scoring 16) and compliance with website and mobile applications accessibility regulations (scored at 5).

Two risks had been closed this cycle relating to the financial position for the first six months of the year and relating to the supply of flu vaccine.

It was reported that there were currently 14 risks on the Covid risk register, four of which were scored as ‘critical’ risks. One of these risks (relating to quality in care homes) transferred from the Corporate risk register to the Covid risk register during this cycle.

One risk relating to increased mortality due to fear of presentation to health services had reduced in score and had been marked for closure.

A request was made for the Governing Body to receive an update on autism services for children and it was agreed that Ali Jan Haider would provide this at the next meeting.

ACTION: Ali Jan Haider to present an update on children’s autism services at the next meeting of the Governing Body.

RESOLVED: The Governing Body:  Received and noted the Risk Register Report and High Level Risk Register Log as at the end of Cycle 4 2020/21.

12 Exception Reports from Committee Chairs

Verbal updates were provided by Committee Chairs in order to share key messages with those present. Minutes of the most recent committee meetings had also been shared as part of meeting papers and would be noted under the ‘items to receive and note’ section of the agenda.

Audit and Governance Committee Bryan Millar, Chair of Audit & Governance (A&G) Committee, drew attention to thorough work of Sue Baxter and the team around One CCG.

Discussions had also been held regarding the work plan of the committee, with a focus on the development of good governance arrangements to support the oversight of the transition work, given the direction of travel for the development of ICSs.

The tendering process for the appointment of external auditors had been undertaken and an evaluation had been carried out. Bryan reported that the members of the committee were confident that a high quality appointment could be made that offered value for money. The next steps in the process were outlined and it was noted that the appointment would be formalised at the next meeting of the Governing Body in March 2021.

Finance and Performance Committee Neil Fell, Chair of the Finance and Performance Committee (FPC), thanked Robert for his comprehensive update around the financial position.

An update was provided on the discussions around the collaborative approach to restarting activity and addressing the backlog. There had also been discussion where the clinical priorities had been endorsed.

The two parts of the year had been discussed, noting the balanced first half and the challenges presented in the second half. There had been acknowledgement of the role of the ‘place’ to address resource shortfall. There had also been discussion relating to the need to be able to monitor on a local level where there may be issues.

Page 8 of 10

Quality Committee David Richardson, Chair of the Quality Committee (QC), updated on the discussions that had been held regarding the vaccine trials and analysis of safety data.

It was noted that Sasha Bhat had provided a thorough update on actions taken following the system review of Child an Adolescent Mental Health Services (CAMHS). A clearer pathway had been developed, action had been taken to address the waiting list, information and support packages had been available to parents and there had also been a focus on workforce development.

The internal audit report had been received following the review of the continuing healthcare, where it was noted that ‘limited assurance’ had been provided. A further update on actions following the audit was expected at the QC due to be held in March 2021.

Primary Care Commissioning Committee (PCCC) Ruby Bhatti, Chair of the PCCC, advised that assurance had been received on primary care provision during Covid-19 including an overview of the NHS vaccination programme and test & trace arrangements for primary care staff.

Decisions made outside of committee regarding the repurposing of the local enhanced services and devolving the unallocated additional roles had been ratified.

Assurance had been received on a list of contractual requirements which had been passed during Covid- 19.

The allocation of General Practice Forward View (GPFV) funding had also been approved for the remainder of 2021.

RESOLVED: The Governing Body:

 Received and noted the verbal updates from Committee Chairs.

13 Primary Care Commissioning Committee Minutes

The minutes of the Primary Care Commissioning held on 8 September 2020 were presented to the Governing Body for information and assurance.

RESOLVED: The Governing Body received and noted the minutes of the Primary Care Commissioning Committee held on 8 September 2020.

14 Finance, Contracting and Performance Committee Minutes

The minutes of the Finance, Contracting and Performance Committee held on 1 October 2020 & 5 November 2020 were presented to the Governing Body for information and assurance.

RESOLVED: The Governing Body received and noted the minutes of the Finance, Contracting and Performance Committee held on 1 October 2020 & 5 November 2020.

15 Quality Committee Minutes

The minutes of the Quality Committee held on 1 October 2020 & 5 November 2020 were presented to the Governing Body for information and assurance.

RESOLVED: The Governing Body received and noted the minutes of the Quality Committee held on 1 October 2020 & 5 November 2020.

Page 9 of 10

15 16 Date and Time of Next Meeting

The date and time of the next meeting is Tuesday 9 March 2021, 1.15pm – 4.15pm. VENUE: To be confirmed but likely to be a Zoom meeting held in public.

17 Exclusion of the Public

It was recommended that the following resolution be passed: “That representatives of the press and other members of the public be excluded from the remainder of the meeting, having regard to the confidential nature of the business to be transacted, publicity on which would be prejudicial to the public interest”.

RESOLVED: The Governing Bodies passed the resolution to exclude representatives of the press and other members of the public for the remainder of the meeting.

Page 10 of 10

16 Presented to the meeting held 9 March 2021

Governing Body: 2020/21 Action Log

Ref. Meeting Agenda Item Action Required Responsibility Due Date Comment Update to be provided on children’s Complete: Added to agenda for 12.01.2021 12.01.2021 11. Risk Register autism services at the next meeting of Ali Jan Haider Jan-21 meeting. 2 the Governing Body.

17 1 NHS Bradford District and Craven CCG This document provides a summary and/or key discussion points and recommendations relevant to the subject of an item for consideration at the specified CCG meeting for the purpose of assurance, information, decision or action.

Agenda item 5

Name of meeting Governing Body Meeting date 9 March 2021 Helen Hirst, Chief Officer Title of report Chief Officer/Clinical Chair report Report author(s) James Thomas, Clinical Chair Lead(s) / SRO Helen Hirst Report lead(s) Helen Hirst James Thomas James Thomas

Paper summary and/or key discussion points This paper provides a brief update of the key issues, meetings and partnership activities affecting the CCG together with updates on national guidance and, where relevant, local impact of this guidance.

Appendix 1 provides a summary of the Senior Leadership Team meeting discussions and decisions.

Outline how this will help us to achieve our vision through our strategic ambitions:  Our population – improving health and equity for local people, and/or  Our partnerships – as the vehicle for enabling people to take more responsibility for their health, and/or  Our people – a skilled, motivated workforce with a culture of continuous improvement, and/or  Our leadership – assuring sustainability of our health and care system.

This report is relevant to all strategic objectives.

Purpose assurance information decision action

approve / recommend / review / consider / support / ratify comment / discuss Recommendation(s)

1. The Governing Body is asked to note the information and assurance provided by the report.

Appendices (or other supporting papers)

1. Summary of Senior Leadership Team meeting discussions and decisions.

18 Page 1 of 5 1. West Yorkshire & Harrogate Health and Care Partnership (WY&H HCP)

At the January meeting of the system leadership executive (SLE) group, members:  Received the key messages from WY&H System Oversight and Assurance Group Meeting on 23 November 2020 and 16 December 2020;  Were presented with the current position on COVID-19 and Sector Updates;  Discussed the WY&H Integrating Care and next steps document;  Confirmed continued support for the targeted campaign to help reduce suicide across WY&H  Received and supported a proposal from WY&H Health and Care Champions to improve the lives of people with learning disabilities;  Received a progress update on the delivery of the actions in response to the Tackling health inequalities for BAME communities and colleagues review.

In February members:  Were updated on the current COVID-19 position;  Received key messages from WY&H System Oversight and Assurance Group Meeting on 25 January 2021;  Received the WY&H Partnership response to Learning disability deaths and COVID-19 and supported a number of recommendations;  Discussed the Integrated Care System operating model review;  Agreed an approach to measuring delivery of our 10 Big Ambitions;  Received an update on the work taking place to develop an area wide antiracist campaign aimed to support colleagues and communities;  Supported a proposal around reducing serious violence and making WY&H a trauma informed and responsive system

The Joint Committee of CCGs: In January the Committee:  Received a presentation on the Care Quality Commission (CQC) provider collaboration review (PCR) which had reviewed how health and social care providers were working together in response to Covid;  Considered a report on primary medical care services in West Yorkshire, which were provided by Local Care Direct (LCD). The Committee agreed to extend the current service from LCD for three years from 1st April 2021;  Agreed an amendment to the WY&H Flash Glucose Monitoring policy, the policy now includes type 2 diabetes patients with learning disabilities who need to use insulin;  Received a high level summary of progress of implementation if the Joint Committee work plan.

At the February Joint Committee development session, the committee:  Noted the progress of the work undertaken on the proposal to reconfigure the ATU provision across the ICS from 3 units to 2 and develop a single system / centre of excellence.  Received the Tackling health inequalities for Black, Asian and minority ethnic communities and colleagues reports and discussed how the Committee can support the delivery of the action plan recommendations.  Received an update report on Unpaid Carers during COVID and beyond and supported a proposal to explore further areas of collaboration.

2. Business Continuity and resilience update

This section of the chief officer and clinical chair report outlines the current COVID situation in Bradford district and Craven. Updates on the CCG’s arrangements for the management of surge and escalation (winter) pressures across the system, responding to the end of the EU exit transition.

2. 1 Overview of local COVID-19 figures The CCG produces a COVID-19 daily dashboard (Monday-Friday) that is shared with health and care partners across the system to allow early identification of service pressures and the impact upon recovery. The City of Bradford Metropolitan District Council (CBMDC) Public Health team also produces a twice-

19 Page 2 of 5 weekly report with details of numbers of cases, hospitalisations and outbreaks. A verbal update of the current position will be provided in the Governing Body meeting.

2.2 COVID-19 vaccination programme roll-out The COVID-19 vaccination programme continues to roll out at pace. There are multiple vaccination sites across our footprint, including hospital, primary care network (PCN) and community vaccination hubs. Our district met the target of vaccinating all residents in 65+ care homes by the end of January and all people in the Joint Committee of Vaccination and Immunisation (JCVI) cohorts 1-4 were offered a vaccine by the 15th February. We will be starting the provision of a second dose of vaccine to our population from the beginning of March in line with national timescales. A verbal update of current numbers and cohorts vaccinated will be provided in the Governing Body meeting.

2.3 Health and care silver meeting The Bradford district and Craven health and care silver command meetings continue to take place weekly and are split into two sections:  surge and escalation (winter) pressures  COVID-19 and EU exit

Tactical actions are developed in response to the system service delivery requirements applicable to surge and escalation (winter) pressures, in relation to COVID-19 and the EU exit transition period. This includes ensuring that we have a co-ordinated system response to individual sector challenges as organisations respond to varying activity, staffing and other pressures.

2.4 End of transition period for EU exit The CCG continues to submit situational reports (sit-rep) to NHS England applicable to the CCG as commissioner and on behalf of the small non-statutory providers, community interest companies (CICs), independent sector (IS) and primary care providers that the CCG commissions healthcare services from. The CCG is required to report any EU exit related issues which may impact business critical services for each of the following areas: supply of medicines, medical devices, consumables, goods and services; supply of blood products, transplant organs and tissues; workforce; estates and facilities; clinical trials; data sharing, processing and access; reciprocal healthcare and cost recovery; partner organisations that are essential to delivery of healthcare. To date, these sit-reps have all been a nil return. The CCG continues to meet informally with CBMDC to ensure that any required responses to the end of transition are coordinated.

2.5 CCG silver command meeting The requirement for taking tactical decisions within the CCG silver command meetings has diminished over the last couple of months so the decision was taken in February to reduce the meeting frequency to monthly, with the option to introduce extra meetings if required. As with the other elements of this report, any current issues for assurance to the Governing Body will be provided in the meeting.

3. Bradford District and Craven Partnerships

3.1 Wellbeing Board (Previously Health & Wellbeing Board)

At the Wellbeing Board in January members discussed the Integrating Care paper and the proposed changes to Integrated Care Systems and place-based Integrated Care Partnerships’ The discussion focused on the main opportunities and challenges, and how this will be handled within our local place based partnership for health and care. Members also received a report which provided an overview of the Bradford District Economic Recovery plan that has been developed by the Bradford District Economic Recovery Board and formalised the Wellbeing Board governance arrangements

At the Wellbeing development session in February members received a presentation which set out a Workforce and Leadership diversity strategy and action plan and also discussed the sustainable development partnership and a place based approach to inequalities.

3.2 Health and Care Executive Board In January the board met with colleagues from across the West Yorkshire and Harrogate Health and Care partnership for the 2020/21 Quarter 3 Bradford District and Craven Quarterly Review. The significant amount of inspirational work being undertaken in Bradford was recognised, in particular the BAME review

20 Page 3 of 5 work and alongside this the challenge of inequalities in our place and the further impact on inequalities resulting from the COVID19 pandemic.

Members received an update from the System, Finance and Performance committee; it was agreed that that the planning arrangements for 2021/22 should be undertaken as a system. Updates on the review of the Strategic Partnership Agreement, ICP development, and System Assurance Framework were received.

3.3 Strategic Coordinating Group/Outbreak Control Board As we move to a more stable position we have now moved to fortnightly meeting of the Strategic Coordinating Group, the Outbreak Control Board continues to meet weekly and receives updates on infection, testing and vaccinations and then determines what strategic and operational actions are required.

4. NHS England / NHS Improvement paper on next steps for Integrated Care Systems (ICSs) On Thursday 11 February the government published a white paper outlining proposed legislative reform to the NHS. ‘Integration and innovation: working together to improve health and social care for all’ is available to read on the GOV.UK website. The paper sets out the proposals will come in force from 1 April 2022.

As previously reported much of the vision set fits well with the approach we are taking in Bradford District and Craven (Act as One – our Integrated Care Partnership (ICP) and in West Yorkshire and Harrogate (WY&H) Health and Care Partnership (our ICS). Most of the proposals (about integration and collaboration) are based on those set out in the NHS Long Term Plan. The Paper also signals there is further work to be done on reforming social care and public health. The legislation is described as ‘enabling’ allowing for flexibility in different ICSs, it does not set out what should happen at place but does suggest that the ICSs have responsibility for ensuring place based partnerships. The changes to commissioning include; strategic planning and allocation of resources being undertaken at an ICS level, a focus on population health management, improving outcomes and reducing health inequalities.

CCG functions will transfer legally to the ICS; our ICS will discharge the majority of those functions in place through the ICP. The White Paper suggests that CCG staff will transfer to the ICS. However, in line with the West Yorkshire operating model we would envisage the majority continuing to work in Bradford District and Craven as they do now. The detail of these arrangements is still being worked through.

The Chief Executives and others across our place are meeting regularly to design our ICP starting from the brilliant work we have done to create our Act as One approach and built on strong foundations of effective partnerships across the system over the past ten years.

5. Summary of Senior Leadership Team Discussions

Please see attached a summary of the SLT meetings during the last two months at appendix 1

6. National Updates

6.1 The future of Health and Care

For further information : ‘Integration and innovation: working together to improve health and social care for all’ is available to read on the GOV.UK website

6.2 Coronavirus (COVID‑19) The Government has announced that from 8 March, people in England will see restrictions start to lift. They have published details of a four-step road map which details the route back to a more normal life

For up to date guidance on all aspects of Covid-19 please visit the government website https://www.gov.uk/coronavirus

For local advice please visit the website below https://www.bradford.gov.uk/health/health-advice-and-support/coronavirus-covid-19-advice/

21 Page 4 of 5 Your COVID recovery website has been launched to support those recovering from COVID-19 The NHS has launched a new website, ‘Your COVID Recovery’, which is aimed at supporting people who are recovering from COVID-19. It is targeted at people who have survived the virus but have persistent concerns related to areas such as breathing or mental health

For more information and to get support, visit. https://www.yourcovidrecovery.nhs.uk/

22 Page 5 of 5 Appendix 1

SLT updates for Governing Body: December 2020 – February 2021

23rd December 2020 Strategic focus: Implications of the host commissioner guidance and surveillance Members received a presentation which described the background and context of the new host commissioner requirements for CCG commissioned inpatient care for people with a learning disability, autism or both and also the CCG responsibilities both as ‘placing’ and ‘host’ commissioners. It was agreed option 3 (Delegate host commissioner responsibilities at ICS level) is where we want to be but a further conversation was needed with the ICS to work through the interim options.

Living with and recovery from Covid System dashboard: Members noted the Covid dashboard and the activity highlighted within the dashboard.

System restart issues: It was reported that BTHFT had been under some scrutiny from the national team around their activity. They prepared a collaborative narrative on what we are doing as a system and It was felt this was well received.

Quality and safety issues Updates were provided on the progress on the governance around Covid vaccinations. It was reported that the backlog of personalised commissioning assessments cases as a result of Covid are on track to be achieved.

Bradford district and Craven and wider system Health and care: The Executive Board have started discussions around the design and development of an ICP. It was reported that all partners have the same vision for the ICP. Formal responses were being prepared for the ICS engagement.

Update on children’s services An update was provided on the special needs school nursing, learning disability services and continence services for the children and young people of Craven which was being provided by Harrogate NHS Foundation Trust (HFT). HFT gave notice that the service would cease in August 2020. It was agreed that BDCFT would take on the Craven Special Needs School Nursing service from 1 December 2020 and also the Learning Disability Service to Craven children from 4 January 2021. HFT also gave notice on their continence service; the CCG agreed that BDCFT will undertake the re-assessment of any child receiving existing products and also the assessment of any new referrals for products. Bradford Teaching Hospitals Foundation Trust will be responsible for the ordering and provision of the products. The CCG intends to review continence service pathways and Learning Disability service provision across Bradford district and Craven to ensure equity of service, and ensure service specifications are in place and align to Bradford services.

CCG corporate risk register Members reviewed the risk register prior to presentation to the Governing Body.

Covid risks and issues log The log was reviewed and changes highlighted.

6th January 2021 Strategic focus: System and place responses to ICS legislative change proposals A discussion took place around the response to the ICS legislative change proposals.

Act as One - transformation programmes update: A number of ‘breakfast bite’ sessions were held in December which described the work of the individual programmes. It was reported that during January key people from across our place who we want stronger representation from will be asked to have direct interaction with programme leads to help form the plans. An update was provided on the Access to care programme work streams.

Living with and recovery from Covid System dashboard: members received the Covid dashboard and noted an increase in demand in the acute trusts. An update was provided around the vaccination programme roll out which was beginning to expand.

Quality and safety issues: (Covid exception report). It was reported grant money would be made available to support care homes from an infection prevention and control perspective. Discussions were ongoing around whether there was sufficient assurance in place now to step down the Strategic Hospital Discharge Task and Finish Group. The majority of this work would be picked up by the Frailty programme with support from commissioners.

Outline Council budget Chris Chapman, finance director from Bradford Metropolitan District Council presented an overview of their 2021/22 budget proposals to answer any queries SLT may have around the unintended consequences for health, prior to the CCG’s formal response. It was reported there was some national uncertainty in a number of areas, as budgets are unknown and implications from the Covid-19 pandemic are ongoing. A proposal was being drafted to support the care market due to the lower levels of occupancy due to Covid pandemic, this would come from Covid monies

13th January 2021 Strategic focus: PHM restructure and resource requirements: SLT/ALT supported a proposal for a restructure of BI. Whilst this would be mean an increase in budget, the proposals fit with the CCG strategy and offer to the system and would create resilience going forward.

It was agreed that ALT should have sight of the totality of running costs in the context of vacancy control to ensure we make the right and informed decisions.

Children's services monthly report Childrens Autism and Health: Childrens autism has an increasing waiting list. To address this, the ASC/ADHD pathway across the system has been combined and some non- recurrent funding has been secured to address the backlog of cases. Work is ongoing to reduce the waiting times for diagnostic assessment of autism to meet NICE guidelines. Work is ongoing to ensure services are co-designed and to develop a collaborative district wide autism assessment service between three providers.

Child and adolescent mental health services (CAMHS): The waiting times have reduced from 256 days to 31 days, there is a co-designed single pathway and access. Work is underway to look at how we address variation and align service commissioning across the whole system. Children with special educational needs or disabilities will be prioritised for CAMHS.

Health assessments for children looked after: The new clinical model will commence on 1 April 2021. Interim arrangements are in place currently in terms of designated and main doctor. There will be a system operational group to oversee recruitment and delivery of the new model and governance. £100/150k maximum recurrent funding has been secured to support this. Whilst the underlying trend is increasing, by April 2022 it is envisaged the waiting list will be greatly reduced.

BAME staff network item: updated WRES action plan and recruitment proposal: The NHS Bradford District and Craven CCG Workforce Race Equality Standard (WRES) action plan was approved. In response to feedback received from the WellbeingAndAble (WAA) staff network, it was agreed some underlying principles around how the CCG implement HR policies for different groups of staff would be built into the workforce equality plan.

Draft assurance framework: A discussion was held around reviewing the framework. It was agreed later that because the new CCG strategy is about how we work rather than what we achieve, this cannot be easily translated into a new assurance framework. Therefore, given there is one more year to run with a CCG assurance framework, we will continue with the GBAF, which is focused on what we want to achieve. The strategy will form part of the control and mitigation of risk.

20th January 2021 Strategic focus: Integrating care - next steps for Integrated Care System (ICS): implications for commissioning: A discussion took place around the ICS development work. It was noted that the CCG has already started the journey described in the Next Steps document. It was reported the Health and Care Executive Board would be the forum which oversees how we work as a place.

Living with and recovery from Covid: It was reported Bradford teaching Hospitals Foundation Trust (BTHFT) and Airedale NHS Foundation Trust (ANHSFT) submitted an application to start the surge/escalation process as patient numbers were increasing locally. It was subsequently reported at SLT on 27/01/21 that this was not needed as the Trusts had secured 100% capacity from the Yorkshire Clinic. Public Health reported that were some recurrent issues in a number of wards across the district.

IFR - blood glucose monitoring/control policy: It was reported that Bradford and Airedale had different agreements around prescribing glucose monitoring devices. SLT agreed that to stay within the parameters of the West Yorkshire agreement. There would be a cost pressure associated with this which will be included in the funding priorities for 2021/22.

Impact of NHS choices framework Patient choice for diagnostic assessment for Autistic Spectrum Condition (ASC) and Attention Deficit Hyperactivity Disorder (ADHD): NHSE/I have confirmed that individuals have a legal right to choice of provider for a diagnostic assessment of ASC and ADHD. Commissioners will need to make arrangements so that people can choose and go to the provider they think best meets their needs. There will be no requirement to demonstrate exceptionality. This could impact on future requirement for involvement with the Individual Funding Request panel and the contract in place in Bradford District and Craven. It was noted there are a number of unknowns around prescribing, quality, and safety and uncertainty around how an external assessment then gets linked back into local services. The CCG supported the approach, though acknowledging there were issues around finance and monitoring to be resolved. It was suggested this could be a potential risk in the future therefore the IFR panel would monitor referrals and provide a further update.

27th January 2021

Strategic focus: Approval of key HR policies and procedures The following were approved:  Home-based working policy  Flexible working and special leave procedures

25  Recruitment, selection and promotion policy

To ensure consistent application of the policy all managers will be required to attend an engagement event aimed at promoting best practice in implementation of the new and revised policies and procedures.

Living with and recovery from Covid System dashboard: Data showed that Bradford was beginning to see the impact impact of social mixing at Christmas; concerns were raised around an increasing risk of sustainability for the Care Home market, it was noted that financial arrangements and support for care homes would be built into to the planning assumptions for next year. Whilst Bradford numbers were decreasing slowly, there was still a high baseline in Bradford. Public Health reported that they were starting to see more complicated cases due to new Covid variant.

Bradford district and Craven wider system; Act as One update The Q3 system assurance meeting with ICS colleagues took place on 22/01/21. There was generally good feedback particularly around our approach to the BAME review and inequalities. The Airedale capital development was discussed in the context of the urgent issue it currently faces, alongside the estate strategy for our system. A strategy that will drive our future decisions (vision and ambition) is being developed. A meeting to discuss principles for shifting resources will be convened and this is being led by James Thomas.

Monthly quality report: Quality Updates were provided on serious incidents; the update to the Health Overview and Scrutiny Committee (13/02/21) around end of life care, to provide an understanding of Bradford’s position on DNACPR and implications of this during COVID-19. It was reported a task and finish group had been convened for four weeks to ensure pace around some of the bigger issues relating to Childrens services.

CCG corporate risk register Members reviewed the risk register prior to presentation to the Governing Body.

Covid risks and issues log The log was reviewed and changes highlighted.

3rd February 2021 Sharing successes: SCD hub - strategy and planning Members of the SCD gave a presentation which described how they have worked together to develop a strategy for staff to use, the strategy was designed to be a living document and will set us up for the future. They talked through how they addressed their different styles of working to get to the point where they were able to have honest conversations, challenge each other and understand each other’s strengths and weaknesses and build on this. They reflected on they often felt were constrained by their job title, therefore a matrix style of working was brought in which provided the ability to draw on an individual’s expertise. They noted how they had built good relationships and felt they are making a difference; this is keeping staff morale high. They believe that partnership working is important and the strategy will help bring partners together.

Monthly report: Act as One Presentation to Bradford Health Overview and Scrutiny Committee: A presentation on Act as One was well received by committee members, they have requested a further update in a year’s time and in the meantime have requested updates on better births, inequalities and respiratory. Work is underway to strengthen the links to the system enabling groups, particularly Living Well and Digital/IT. There are plans in place for the Act as One spring

26 festival, which will be held end of April/beginning of May. There will be a week’s worth of events, which will celebrate the partnership and work across place.

System (ICS) and place (ICP) updates Members received feedback from the West Yorkshire System Leadership Executive Group (SLEG) and Joint Committee of CCGs.

It was reported the ICS operating model is dependent on five functioning ICPs at place. It is anticipated there will be a statutory joint committee between partners at place, For Bradford district and Craven this will likely be based on the Health and Care Executive Board. It was reported the Strategic Partnering Agreement will be a critical part of the governance and is currently being reviewed. It will need to hold itself up to some form of delegation, accountability and support the operation of a joint committee.

Draft audit plan Members approved a three-year strategic audit plan for the new CCG was agreed for the period 2020/21 to 2022/23. Because of the ongoing challenges, the plan would remain under review and flex where appropriate. It was reported some days have been set aside to support the transition arrangements of the CCG, all five CCGs in West Yorkshire are represented and there is an intention to have some shared CCG transition arrangements to do things once across the five CCGs.

CHC Backlog It was reported that there was an additional backlog of cases above what was first reported; this was due to the pause in activity due to supporting Covid. NHSE have requested that these are completed by the end of March 2021. A tender waiver agreement had been made to bring in some support to address the backlog.

10th February 2021 Draft workforce equality plan The workforce plan was shared. It was suggested that we take a population health approach to workforce, acknowledging not all staff members are the same therefore it is felt that we miss opportunities to reduce inequalities. Support needs to take into account the individual and we need to build on what’s already in place and use the partnership to connect staff to the broader wellbeing offers, this will be even more important as we go through transition. The wellbeing task and finish group are working on some principles to make wellbeing support offers more attractive to staff. There are plans to establish a transition fairness think tank to provide feedback on what staff are feeling and ensure transition is conducted in a fair and transparent way.

Associate leadership team (ALT) focus The Associate leadership team terms of Reference were approved, it was agreed SLT and ALT should hold each other to account to ensure both are working within their respective ToR.

A discussion took place around mutual aid, support and resources across CCG and system. It was noted the CCG has been balancing supporting the health and care system alongside the impact of Covid over the last 12 months, alongside this the publication of the NHSE ‘next steps’ paper has caused a sense of uncertainty for the future for CCG staff. It can be anticipated that this is likely to impact on the CCG’s ability to undertake the transition work and fulfil its role as a commissioner and transfer its functions to the new model. It was reported work is ongoing to understand which functions will go to an ICP and staff engagement sessions will be organised to provide briefings as we transition, other support will also be available e.g. HR

27 Monthly report: Performance It was reported that Covid has had a significant impact on the delivery of acute activity, particularly around elective/day cases and inpatients; outpatient activity has been less affected. We are starting to see a decrease in numbers but there are still approximately two thousand 52-week waiters on the waiting list, which will be a huge challenge to clear. Mental health referrals are expected to increase and be more complex, there will be some work to do around prioritising, taking into account demand and capacity. It was also highlighted that we need to have a focus on staff wellbeing in the context of clearing backlogs.

Launch of the Living Well physical activity campaign Members received a presentation on The Living Well ‘20 minute movement’ campaign, which has been designed directly in response to a recent stakeholder engagement exercise with over 1800 participants in Bradford who said that their priority for their wellbeing was to be more active. This is the first of many future campaigns to promote wellbeing messages

28 NHS Bradford District and Craven CCG This document provides a summary and/or key discussion points and recommendations relevant to the subject of an item for consideration at the specified CCG meeting for the purpose of assurance, information, decision or action.

Agenda item 7

Name of meeting Governing Body Meeting date 9 March 2021 Vicki Wallace, Interim Update on Strategic Partnering Title of report Report author(s) strategic director, Agreement review transformation and change Lead(s) / SRO Vicki Wallace Report lead(s) Vicki Wallace

Paper summary and/or key discussion points

 The Strategic Partnering Agreement (SPA) has been in place since 2019 and it was acknowledged that a review was needed to ensure this document continued to reflect our ways of working across our system.  This work is being undertaken by the SPA Design Group which reflects the BD&C partnership.  By the end of March 2021 the SPA will reflect our current working arrangements and will be brought to Governing Body in May 2021 for sign off.  The next phase of the work post April will be a critical part of our move towards the establishment of an Integrated Care System (ICS) across West Yorkshire and our Bradford District and Craven Integrated Care Partnership (ICP).  The SPA will include a schedule which sets out the key areas of work to complete prior to October 2021 to allow our place to operate as an ICP in shadow form prior to April 2022.  The SPA is just one element to the new governance arrangements that will need to be in place moving forward to allow us to operate locally as an ICP.

The review of the SPA will help us to achieve our strategic ambitions for each element of our PPPL. The current and future work will allow the continuation of a strong place based focus for Bradford District and Craven: ensuring a continued focus on the needs of our population; further embedding how we work as a partnership; empowering and enabling our people to continue to develop and succeed; while ensuring a continued focus of our leadership on our place.

Purpose assurance information decision action

Recommendation(s)

The Governing Body is asked to: 1. Receive the update on the review of the Strategic Partnering Agreement and next steps

Appendices (or other supporting papers)

29 Page 1 of 2 2. Update on Strategic Partnering Agreement review presentation

30 Page 2 of 2 Update on Strategic Partnering Agreement review Vicki Wallace Interim Strategic Director Transformation and Change

31 Current activities

• Recognition that our partnership had moved beyond what is documented in the original Strategic Partnering Agreement (SPA) • Under remit of Executive Board • Phase 1 – interviews of key individuals working across our partnership to understand what works and what we can improve – completed November 2020 • Phase 2 – SPA design group to update the SPA document to reflect how we work now – with an eye on the future • Key areas – finance, governance, left shift, health inequalities, current partners – COVID-19 has accelerated our partnership working • Attend Governing Body in May 2021 to sign off the updated SPA 32 Happy, healthy at home in Bradford District and Craven Post April 2021 • SPA to contain a schedule which sets out key areas of work to enable BD&C to operate as a shadow Integrated Care Partnership from October 2021 • Enable us to be ‘load bearing’ by April 2022 • Includes: governance structures; services; schemes of delegation; shared functions; workforce; quality principles; financial flows • SPA is one part of the wider work to move to ICP/ICS (Integrated Care System

Behaviours & Structure & Strategy & Vision Organisational Development Governance

33 Happy, healthy at home in Bradford District and Craven NHS Bradford District and Craven CCG This document provides a summary and/or key discussion points and recommendations relevant to the subject of an item for consideration at the specified CCG meeting for the purpose of assurance, information, decision or action.

Agenda item 8

Name of meeting BD&C CCG Governing Body Meeting date 9 March 2021

Title of report Update on Children’s Autism Report author(s) Ali Jan Haider

Lead(s) / SRO Ali Jan Haider Report lead(s) Ali Jan Haider

Paper summary and/or key discussion points

This paper provides an update on work that has been undertaken across Bradford district and Craven to address the long wait that children and young people are experiencing to access the neurodiversity assessment pathway and sets out our next steps to improve timely access. The numbers of children on the referral pathway for children’s autism has increased disproportionately over the last 7 years. However, this is a national trend and many organisations are facing challenges identical to Bradford District and Craven. The paper provides a summary of:  our progress to-date  our current finances, capacity and demand  our priorities for 2021/22 Children and Young People are still waiting far too long for an assessment. Pathway changes and the new service model have not embedded at the expected pace due to COVID-19. Additional non-recurrent investment has increased the numbers of assessments but not to the volume where it can match the demand from the increasing level of referrals. Further refinements to the current model and additional work in other areas will provide greater efficiency but additional recurrent investment is also an essential factor to ensure the CCG meets the 13 week NICE standard waiting time for assessment.

We work in partnership with our local service providers and local authority colleagues to improve access to neurodiversity assessment service provision. There is a risk that without recurrent additional investment and improved early help any progress made will not be sustained as waiting lists will continue to rise. The consequence of a delay in diagnosis for children and young people results in undiagnosed health need, reduced access to support and can impact adversely on the emotional, social and mental health of the child/young person and their families.

Purpose assurance information decision action

approve / recommend / review / consider / support / ratify comment / discuss Recommendation(s)

The Governing Body is recommended to receive and note this report and, if appropriate, seek additional

34 Page 1 of 2 assurance

Appendices (or other supporting papers)

1. Update on Children’s Autism attached

35 Page 2 of 2

Update on Children’s Autism

1.0 Executive Summary

A significant increase in referrals for children’s autism diagnosis has been met with a coordinated and sustained set of interventions by Bradford district and Craven health and care partners. This includes the following points:

 Embed co-production and design in all elements of pathway redesign  Implement new neuro-diversity clinical pathways based on latest evidence-based models  Simplify and streamline our data to accurately understand the scale of demand and maximise the capacity of provision  Optimise our resources by exploring outsourcing and making better use of prevention and early help.

We have continued to improve our local service offer despite the impact of COVID-19 and utilised non recurrent funding to increase our capacity by commissioning external service providers. We are working with local authority and VCS partners to identify robust approaches that provide early help and support to families, children and young people as they await assessment and at the same time reduce the avoidable demand for a formal autism assessment. We will continue to work in partnership with key partners to address the waiting list numbers and align our ‘referral to first contact for assessment’ timing with NICE guidance of 3 months.

2.0 Purpose and Context

3.0 Summary of Key Actions Following the Last Governing Body Update 3.1 Working with our services providers we have:  Developed our partnership working and engagement with service users including the co-production of resources for families and ‘You said – We did’ update following engagement with AWARE1  Taken advice and learning from other areas to support local developments

1 Airedale and Wharfedale Autism Resource (voluntary organisation supporting parents of children with autism)

36  Continued to build our understanding of the data through the development of a Patient Tracking List (PTL)  Implemented changes to the referral pathway  Managed the impact of COVID: o on service delivery in terms of national guidance around ceasing face to face contact through innovative approaches o on staffing levels due to redeployment or sickness rates  Secured additional capacity from external service providers to carry out extra children’s autism assessments  Agreed to further support the work of the Centre for Applied Educational Research who are looking at the value of value of the Early Years Foundation Stage Profile (EYFS) as a screening pathway for social communication problems and other development difficulties which could lead to earlier identification of autism traits  Introduced the role of Improvement Lead for Children & Young People’s LD/ASD within health  Worked with One Adoption to develop a streamlined multi-disciplinary process for neuro developmental assessment for any children going through the adoption process

We are currently working with children’s commissioners within the West Yorkshire and Harrogate Health and Care Partnership and NHS England/Improvement to agree a consistent reporting measure of ‘waiting times for assessment’. In common with the other places in West Yorkshire we are now using the following measure to define waiting times ‘from referral to initial contact for assessment’. In the past we have continued to count people as ‘wating’ until the completion of their diagnosis. 3.2 Finances, Capacity and Demand

3.2.1 Finance

Recurrent investment into this service was increased as a result of the business case which was presented to the health system in 2019

Core investment Recurrent % Increase additional 2019/20 investment agreed 2020/21

BTHFT £197,484 £155,000 78%

AFT £120,680 £52,000 43%

BDCFT £210,648 £366,000 174%

TOTAL £528,812 £573,000 108%

We have also utilised non-recurrent investment of £1.25 million to address the backlog of children and young people waiting for an assessment through the use of external service providers. Some of this non-recurrent investment was additional funding for the system whilst the remainder was slippage against recurrent funding above.

The non-recurrent funding has allowed us to commission 602 assessments at a cost of £1,259,800 (an average cost of £2,093 per assessment) and will support us to further reduce the length of time children are waiting for an autism assessment.

pg. 2 37 This non-recurrent funding has enabled us to explore the use of external providers thereby expanding our capacity to deliver a greater number of diagnoses. The cost per case with external providers can afford good return on investment. 3.2.2 Waiting list data

If we apply the criteria for measuring our waiting list and times as used by neighbouring CCGs (see 3.1) we had 1477 children waiting for assessment (bottom line) at December 2020. The average waiting time is 49 weeks. The top line reflects the number of children still on the pathway who have not yet received their final diagnosis (1952).

Combined ASD/ADHD waiting list at December 2020

NOTE: We have identified issues with initial assessment date used within CAMHS which requires further investigation – we understand some children may have commenced investigations before their recorded initial investigation date. This will be addressed in our next PTL report. 3.2.3 Projections

Over the last 12 months we received 1005 referrals. Assuming this level of referral continues, our current recurrent resources will secure 665 timely assessments leaving approximately 340 on a waiting list that will build.

This creates an immediate problem. By July 2021 we will, without further additional action, have a waiting list of approximately 1800 people.

We have secured further additional non-recurrent funding of £645k and, over the next six months we anticipate the waiting list will reduce to around 1400 people. Managed chronologically and assuming all children are suitable for an outsourced assessment (which they won’t be) we will still not reach the waiting time standard of 13 weeks and average waiting times will remain around 49 weeks.

The additional non-recurrent investment together with the new pathway will have dealt with the current backlog but not created a sustainable model going forward. We have considered a number of options building on the experience of remote assessment during Covid and estimate that an additional £2m recurrently would be required to ensure the service was able to meet the waiting time standard. This could be reduced by contracting for the remote assessment on a more secure basis (than one off outsourcing). But for planning assumptions we suggest £2m.

pg. 3 38 4.0 Priorities for 2021/22 4.1 Understanding the current model

As a result of Covid we have been unable to fully understand the implementation of the new model of care. Workforce challenges, changes to the financial regime and disruption and reductions in service have all impacted. Although the remote assessment has been popular with families and young people (and has helped significantly for our longest waiters) we do not have a detailed understand of the role of remote assessment going forwards. At face value it seems to be a cost effective and efficient way to manage some assessments. 4.2 Strategy and planning

We need to continue to build and join up the partnership work that has emerged both within health and across the broader health and care system to further develop the neuro-diversity service which both meets the needs of our local population and delivers against national targets around assessment and diagnosis. 4.3 Pathway development

Pathways will be reviewed in light of changes made during COVID. The National Autism Programme is working on a Neuro-Developmental Diagnostic Pathway and further information is awaited and will be incorporated into local pathway development and service delivery. 4.3 Data cleansing

The PTL has provided improved data and development has continued over the last 12 months. There are further actions required to enhance accurate reporting and these will be implemented imminently. 4.4 Financial investment

We will work as a system to ensure we get best value from the funding currently available to the service. We will invest any additional non-recurrent funding that may be identified to further reduce the waiting list. Alongside this, we are undertaking a more detailed analysis of the true cost of an effective service that is designed to meet the needs of the population. 4.5 Partnership working

5.4.1 Educational Psychologists

We will continue to learn from previous application of non-recurrent funding to increase service provision by working closely with educational psychologists within the children’s service at the local authority.

We will work with educational psychology colleagues to identify common areas of assessment or support which we can build on to enhance our service offer. 5.4.2 Early Help and Prevention

We are exploring interventions tested in other parts of the country that rely on much earlier support work with children that takes place in educational settings. This reduces the need for children then to be referred for a formal assessment as it is not needed in light of other structured support they receive.

pg. 4 39 5.4.3 VCS

We will work with WY&H HCP to review the impact of the NHSE funded BEAT project. This pilot project, delivered by AWARE, provides support and training to families who may have a child or young person on the waiting list. Over 50 families are currently being supported by BEAT who are developing training to be delivered in Urdu.

We will work with the VCS to consider how we develop the role of key worker further. 5.4.4 Providers working more effectively together

We will build on the collaborative working across partners to further enhance the support and resources available to families, the use of data across they system and to ensure the optimum use of all available resource.

pg. 5 40 NHS Bradford District and Craven CCG This document provides a summary and/or key discussion points and recommendations relevant to the subject of an item for consideration at the specified CCG meeting for the purpose of assurance, information, decision or action.

Agenda item 9

Name of meeting Governing Body Meeting date 9 March 2021 – Title of report CCG Finance Report for the period Report author(s) Diane Lawlor Strategic to the 31st January 2021 Head of Finance Lead(s) / SRO Robert Maden – CFO Report lead(s) Robert Maden - CFO

Paper summary and/or key discussion points

This report provides information on the financial position of the CCG as at the 31st January 2021 and the forecast financial performance for the year to March 2021. For the first six months of the financial year the CCG operated within the temporary CCG finance regime established by NHS England and Improvement (NHSE&I) and reported a break-even financial position to the end of September 2020. For the last six months of the financial year (October 2020 to March 2021), the CCG has received a fixed funding envelope which it is expected to manage costs within, except for specific items where additional cost reimbursement will be available. Therefore, this report concentrates on financial performance for the October 2020 to March 2021 (M7 to M12) period with the year to date position reflecting financial performance from October to December 2021.

Appendix 1 contains information on summary budget performance for M7 to M12 and a summary of the full year position that incorporates performance from April to September 2020.

Key Points:

 The year to date and full year forecast positions for costs within the fixed resource baseline show operational budget underspends of £1.2m and £2.8m respectively. These underspends are net of costs for which additional funding can be claimed. The forecast underspend has increased over last month mainly due to net reductions to local NHS Trust block contract values and lower prescribing costs (£302k), partially offset by higher primary care costs and additional Better Care Fund costs.

 The baseline savings target of £1.2m continues to be covered by premises cost and support function savings, and a reduction in forecast prescribing costs.

 Underspends against budgets for which additional funding can be claimed, i.e. the Hospital Discharge Scheme and local Independent Sector activity costs, are offset by a reduction in the value of the reclaim resulting in no impact on the CCG’s financial position.

 Reimbursement for Hospital Discharge Scheme costs for October and November has been received, but Hospital Discharge Scheme claims for December and January are outstanding as are claims for independent sector activity from October to January. There is a risk that full reimbursement may not be received, but as no queries have been raised with the CCG regarding the claims, the financial position continues to assume full cost reimbursement.

41 Page 1 of 2

 The position includes a net £1.74m and £3.04m for year to date and forecast COVID-19 costs (October to March budget of £2.91m). This includes an additional allocation of £1.6m to help maintain capacity required in General Practice to respond effectively to the pandemic.

 Full year forecast budget underspends are now expected to fully offset the additional savings target of £2.8m which means that there is no residual financial risk in the reported position.

 On the basis of the forecast operational budget performance, the CCG expects to meet its break- even financial target and its statutory financial targets for 2020/21.

Contributes to financial sustainability and improves quality of commissioned services.

Purpose assurance Information Decision action

approve / recommend / review / consider / support / ratify comment / discuss Recommendation(s)

The Governing Body is asked to:

1. Note the year to date financial position as at the 31st January 2021 and the forecast financial position to March 2021; and

2. Note that there is no remaining residual financial risk in the reported financial position.

Appendices (or other supporting papers)

1. Summary CCG Financial Performance

42 Page 2 of 2 BRADFORD DISTRICT AND CRAVEN CCG

FINANCE REPORT FOR THE PERIOD TO 31 JANUARY 2021 (MONTH 10)

1. Introduction.

1.1 This report provides information on the financial position of the CCG as at the 31st January 2021 and the forecast financial performance for the year to March 2021.

1.2 For the first six months of the financial year the CCG operated within the temporary CCG finance regime established by NHS England and Improvement (NHSE&I) and reported a break- even financial position to the end of September 2020.

1.3 For the last six months of the financial year (October 2020 to March 2021), the CCG has received a fixed funding envelope which it is expected to manage costs within, except for specific items where additional cost reimbursement will be available. Therefore, this report concentrates on financial performance for the October 2020 to March 2021 period.

1.4 Financial performance for this period continues to be based on the application of the COVID-19 contracting and payment arrangements for services commissioned from NHS and non-NHS Providers. Under these arrangements, block contract values have been determined for our main NHS Trusts and budgets have been set in-line with these.

For other services, where activity information is available, this has been used to support the assessment of financial performance. The main budget areas concerned are Primary Care Prescribing and Continuing Healthcare where activity information was available as follows:

- Prescribing November activity - Continuing Healthcare December activity.

Where no activity information is available and the service has continued, performance is shown in-line with budget.

The additional costs related to responding to the pandemic are included in the relevant budget line and highlighted on the budget report as COVID-19 costs.

1.5 Full year forecast financial performance is reported in Appendix 1 which aggregates the first six months and last six months of the financial year.

1.6 Key points for performance in the period October 2020 to March 2021 are highlighted for the Committee.

2. Resource Allocation Adjustments.

2.1 For October to March 2021, the CCG has received an allocation of £484,284k which represents the CCG’s share of the West Yorkshire ICS funding envelope. This includes an allocation for additional COVID-19 related costs.

43 2.2 Further allocations have been received in the months October to January as follows:

October - March April - September Full Year

Opening RRLA Closing Closing Closing allocation (non recurrent) allocation allocation allocation April 329,395 329,395 May -59 -59 June 1,830 1,830 July 160,976 160,976 August -2,086 -2,515 September 0 0 October 484,284 615 484,899 1,941 487,269 November 3,418 3,418 -912 2,506 December 3,301 3,301 0 3,301 January 1,752 1,752 0 1,752 Actioned to date 484,284 9,086 493,370 491,085 984,455

Non-recurrent resource allocations of £1,752k were received in January for:  £113k fair share allocation of Treatment & Care funding;  £14k IPC funding to allocated to places;  £10k Ageing Well system leadership funding;  £452k Mental Health Discharge support;  £20k Health Information Champions;  £35k Winter Volunteers funding (BDCFT and AHFT);  £30k additional Oximetry @ Home allocation for NHSX site setup;  £545k pension uplift @ 6.3%;  £82k remote monitoring licence costs;  £59k funding for children and young people respite provision;  £15k personalised care implementation;  £302k annual allocation for flash glucose monitoring;  £75k taskforce projects - Films For Parents.

These resource allocation changes have been reflected in budgets as appropriate.

2.3 The income budget for items reimbursed outside of the fixed funding envelope has remained unchanged and comprises:

£'000 Hospital Discharge Programme -7,174 HDP (staff costs to clear backlog) 0 to a maximum of £554k Flu Vaccinations (additional costs) 0 to a maximum of £140k Primary Care Additional Roles -1,982 40% of maximum allocation of £4,925k Local Independent Sector Activity -2,872 -12,028

Amounts received will depend on the actual costs incurred and NHSE have confirmed reimbursement of £1,648k for October and November for the Hospital Discharge Scheme.

44 Reimbursement for Hospital Discharge Scheme costs for December and January and additional local acute independent sector activity costs through to January has not been confirmed yet, although no queries have been raised on the claims submitted.

Reimbursement will be by way of a resource allocation adjustment, but no adjustment to budgets will be made for this. Instead, expenditure and income will continue to be shown gross to maintain reporting against plan values.

3. Financial Performance at Month 10 – Key Points.

3.1 Overall Position.

October 2020 - March 2021 October - FOT March Year to Date January of which is of which is Over / COVID19 Over / COVID19 Mvt from last Budget Budget (Under) Costs (Under) Costs month Commissioning Budget 502,358 333,469 -3,531 4,421 -5,677 7,348 -678 Running Costs 5,866 4,092 -248 134 -258 167 14 Additional Savings Target -2,826 -1,179 1,179 0 2,826 0 0 Residual Financial Risk 0 0 0 0 0 0 1,948 Gross Expenditure 505,398 336,382 -2,600 4,555 -3,109 7,515 1,284

Funding to reclaim -12,028 -8,020 2,600 -2,813 3,109 -4,478 -1,284 Net Expenditure 493,370 328,362 0 1,742 0 3,037 0

Net Summary: Net Commissioning Budget 490,330 325,449 -931 1,608 -2,568 2,870 -1,962 Running Costs 5,866 4,092 -248 134 -258 167 14 Additional Savings Target -2,826 -1,179 1,179 0 2,826 0 0 Residual Financial Risk 0 0 0 0 0 0 1,948 Net Expenditure 493,370 328,362 0 1,742 0 3,037 0

 The year to date and forecast positions for commissioning costs within the fixed resource baseline show operational budget underspends of £0.93m and £2.57m respectively. These underspends are net of costs for which additional funding can be claimed. After taking running costs into account, there is an operational budget underspend of £1.18m (year to date) and £2.83k (full year forecast).

 The baseline savings target of £1.2m is covered by premises cost and support function savings, and a reduction in forecast prescribing costs.

 The position includes a net £1.74m and £3.04m for year to date and forecast COVID-19 costs (October to March budget of £2.92m).

45  After allowing for forecast budget underspends, the full year additional savings target of £2.8m is fully covered leaving no residual financial risk. This improved position reflects an increased level of underspend mainly in relation to reduced block contract payments with local NHS Trusts. The reductions in block contract values with local acute Trusts reflect underperformance on elective activity which has produced some non-pay underspends. The reduction in the block contract with Bradford District Care Trust reflects slippage on planned developments.

3.2 COVID19 Costs

COVID19 costs against budget are detailed in the following Table. There has been a decrease in costs resulting in a reduction in the forecast overspend against budget. The overspend reflects overtime costs as CCG staff continue to be deployed to support the on-going pandemic response and additional primary care Red Hub and Super Rota costs offset by lower levels of ambulance activity. The decrease is mainly due to reduced costs for primary care staff transport and lower than anticipated admin costs particularly relating to the digital team, including the purchase of IT equipment.

October 2020 - March 2021 October - Year to Date FOT March January Over / Over / Mvt from last Budget Budget (Under) (Under) month Patient Transport Services 520 348 -125 -145 0 Telehealth 291 196 -3 0 0 Mental Health Digital Plan 15 10 -10 0 0 Primary Care Red Hubs 156 104 29 60 -33 Primary Care Super Rota 173 116 23 36 0 Primary Care Staff Transport 35 24 -18 -14 -44 Primary Care GP Expenses 59 40 28 14 36 GP Second Wave Resilience 1,575 788 0 0 0 Admin Support Costs 90 60 132 172 -116 2,914 1,686 56 123 -157

3.3 The main factors affecting financial performance and expenditure for the period October 2020 to March 2021 include:

 Acute Care – Net year to date overspend after the reclaim of additional independent sector activity costs of £267k. After adjusting for NHS Trust block contract reductions, the net forecast outturn position shows an underspend of £1,452k.

The forecast reclaim value for independent sector activity has increased by just under £2m due to the inclusion of Yorkshire Eye activity for the final quarter and increased GPwSI and AQP activity.

 Community Services - Year to date and full year forecast underspends of £352k and £784k. The only significant change relates to a reduction in the block contract with Bradford District Care Trust to reflect slippage in planned developments. This was offset by the additional costs of the special school nursing and learning disability service transfer from

46 Harrogate NHS Foundation Trust resulting in a net underspend against the Care Trust contract of £273k.

 Personalised Commissioning – Year to date and full year forecast underspends before additional cost reclaims of £2,250k and £2,920k. This covers both normal CHC costs and HDP costs with the full year forecast underspend reflecting an unchanged £212k overspend on normal CHC and funded nursing care costs and a £3,132k underspend against the Hospital Discharge Scheme budget.

These underspends will be offset by a reduced cost claim leaving a net full year forecast overspend of £212k. We continue to work with the Local Authority to ensure that costs are appropriately allocated to either core continuing care or the Hospital Discharge Scheme.

 Prescribing - Year to date and full year forecast underspends of £299k and £549k are reported based on actual cost information for the period to November 2020. This shows a 4.05% increase in costs compared to the same period last year (a lower number of items but higher prices) with full year forecast costs decreasing slightly this month. The total full year forecast underspend has increased by £302k reflecting the additional resource received to fund increased flash glucose monitoring devices. As these costs were already in the reported position the additional funding has resulted in an increased underspend. Prescribing reserves of £494k have been retained to manage any increase in outturn prescribing costs whether related to the pandemic or other cost pressures.

 Primary Medical Care - Year to date and full year forecast budgets are underspent by £735k and £826k respectively before additional cost reclaims. This is due to an underspend against the gross Additional Roles Reimbursement Scheme budget offset by increased flu vaccination prescribing fee costs and additional premises and other smaller budget overspends. The ARRS forecast has increased this month to reflect the proposed use of uncommitted ARRS funding for overtime costs for the ARRS posts and there has been a corresponding increase in the reclaim value to reflect this. Agreed levels of GP income protection for activity based services, in line with the approach being taken across West Yorkshire, have also been recognised in the position.

 Other Primary Care - Year to date and full year forecast budgets are overspent by £36k and £9k respectively before additional cost reclaims. The forecast costs have reduced by £126k due to the release of uncommitted GP Forward View budgets and reduced COVID19 costs including those related to Flu Vaccinations. A corresponding reduction in the value to reclaim has been recorded.

 Other Commissioning - costs are forecast to overspend by £313k against budget before additional cost reclaims mainly due to the staff costs associated with the clearing of the Hospital Discharge Scheme assessment backlog and additional commitments relating to 2019/20 charges from BMDC after finalisation of the 2020/21 Better Care Fund. After allowing for the reclaim of staff costs relating the forecast overspend becomes an underspend of £84k.

 Running Costs - Year to date and full year forecast underspends of £248k and £258k respectively are reported. These relate to staff vacancies and reduced non- pay corporate

47 costs partly offset by the additional costs of COVID19 attributable to supporting remote working. An additional allocation of £545k has been received to cover the costs of increased employer pension contributions.

Appendix 1 shows a summarised budget position and a detailed break-down of each area for the period October 2020 to March 2021. It also shows a summarised position for the full financial year.

4. Performance Against Savings Target

There has been no change concerning the achievement of the 1% savings target of £1.2m which is expected to be delivered in full from primary care rates rebates (£260k) and support cost function savings (£140k) with the balance of the savings target being applied against the prescribing budget (£800k). The additional savings target of £2.8m relating to the national change in budget setting methodology for local independent sector services in the second half of the financial year is now expected to be fully offset by operational budget underspends which are now shown in the reported financial position.

5. Financial Risk and Risk Mitigation.

The main financial risks and mitigations are as follows with updates shown in italics.

Confirmation of the reimbursement of Hospital Discharge Scheme costs and additional local acute independent sector costs is still awaited. There is a risk that not all costs will be reimbursed, but no queries have been raised with the CCG to date regarding the cost reclaim and therefore the CCG expects to receive full reimbursement.

Risk Mitigation i) Allocation shortfall of £2.8m not - Offset with other budget underspends. corrected. - Defer development expenditure. - Apply local / ICS financial risk share Risk now fully mitigated by arrangements. operational budget underspends.

ii) Hospital Discharge Scheme costs not - Consistent approach with other WY fully reimbursed. CCGs being taken. - Ensure costs reported consistently with October and November other WY CCGs. reimbursement received.

iii) Uncertain financial impact of clearance - Monitor and report on progress with of continuing care assessment backlog clearance and cost of health backlog. funded care packages. - Update financial forecasts to identify Working with BMDC to confirm all the need for other budget savings. activity captured.

iv) Increased Mental Health inpatient - Liaise with Bradford District Care Trust demand leading to further out of area to minimise out of area costs. PICU costs. - Monitor and report on out of area PICU activity and costs to identify the need for other budget savings. Risk fully mitigated. No additional activity charges will be raised in Risk now likely to be fully mitigated by 2020/21. additional resources allocated to the Care Trust by NHS England & Improvement.

v) Volatility in prescribing costs and - Review PPA actual cost data and forecast expenditure to March 2021. update prescribing forecast. - Continue to identify other budget savings to offset potential pressures.

The risk assessment assumes that the current COVID situation will not deteriorate significantly and in light of the impact of the national lockdown, this is considered to be a reasonable assumption.

Therefore, on the basis of the forecast operational budget performance which is expected to offset the £2.8m additional savings target, the CCG expects to meet its break-even financial target and its statutory financial targets for 2020/21.

6. Recommendations.

The Governing Body is asked to:

a) Note the year to date financial position to the 31st January 2021 and the forecast financial position to March 2021; and

b) Note that there is no remaining residual financial risk in the reported financial position.

49 APPENDIX 1 CCG Financial Performance (October 2020 to March 2021)

October 2020 - March 2021 October - Year to Date FOT March January of which is of which is Over / COVID19 Over / COVID19 Mvt from Budget Budget (Under) Costs (Under) Costs last month £'000 £'000 £'000 £'000 £'000

Acute Care 224,658 149,781 369 0 -761 0 193 Urgent Care 18,996 12,664 -36 0 -66 0 2 Community Services 38,487 25,685 -352 416 -784 666 -276 Personalised Commissioning 34,187 22,002 -2,250 2,524 -2,920 4,042 -1,017 Mental Health and LD Services 51,148 34,113 -128 -1 -93 14 -75 Prescribing 52,732 35,436 -299 0 -549 0 -302 Primary Medical Care 55,948 37,019 -735 787 -826 1,575 400 Other Primary Care 6,421 3,887 36 364 9 558 -126 Other Commissioning 16,507 10,812 -136 331 313 493 523 RIC Investments 3,274 2,070 0 0 0 0 0 QIPP Savings Balance -2,826 -1,179 1,179 0 2,826 0 0 Residual Financial Risk 0 0 0 0 0 0 1,948

Total Operating Costs 499,532 332,290 -2,352 4,421 -2,851 7,348 1,270

Contingency Reserves 0 0 0 0 0 0 Other Reserves 0 0 0 0 0 0 0

Total Reserves 0 0 0 0 0 0 0

Total Healthcare Expenditure 499,532 332,290 -2,352 4,421 -2,851 7,348 1,270

CCG Running Costs 5,866 4,092 -248 134 -258 167 14

Gross Expenditure 505,398 336,382 -2,600 4,555 -3,109 7,515 1,284

Additional funding to reclaim -12,028 -8,020 2,600 -2,813 3,109 -4,478 -1,284

Total Net Financial Position 493,370 328,362 0 1,742 0 3,037 0

MEMORANDUM Additional funding to reclaim: Hospital Discharge Programme -7,174 -4,783 2,259 -2,524 3,132 -4,042 1,017 HDP (staff costs to clear backlog) 0 0 -241 -241 -361 -361 -100 Flu Vaccinations (additional costs) 0 0 -19 -19 -39 -39 28 COVID-19 Vaccination Programme 0 0 -29 -29 -36 -36 -36 Primary Care Additional Roles -1,982 -1,321 732 1,104 -200 Local Independent Sector Activity -2,872 -1,916 -102 -691 -1,993 -12,028 -8,020 2,600 -2,813 3,109 -4,478 -1,284

50 APPENDIX 1 cont. – CCG Financial Performance (April 2020 to March 2021)

Full Year April 2020 - March 2021

April - October - FOT September March Full Year of which is Over / COVID19 Budget Budget Budget (Under) Costs £'000 £'000 £'000 £'000

Acute Care 222,680 224,658 447,338 -761 0 Urgent Care 18,862 18,996 37,858 -66 0 Community Services 37,745 38,487 76,232 -784 1,364 Personalised Commissioning 33,024 34,187 67,211 -2,920 9,887 Mental Health and LD Services 46,284 51,148 97,432 -93 101 Prescribing 51,434 52,732 104,166 -549 0 Primary Medical Care 52,993 55,948 108,941 -826 2,228 Other Primary Care 6,036 6,421 12,457 9 2,044 Other Commissioning 15,858 16,507 32,365 313 1,012 RIC Investments 1,130 3,274 4,404 0 0 QIPP Savings Balance 0 -2,826 -2,826 2,826 0 Residual Financial Risk 0 0 0 0 0

Total Operating Costs 486,046 499,532 985,578 -2,851 16,636

Contingency Reserves 0 0 0 0 0 Other Reserves 0 0 0 0 0

Total Reserves 0 0 0 0 0

Total Healthcare Expenditure 486,046 499,532 985,578 -2,851 16,636

CCG Running Costs 5,039 5,866 10,905 -258 377

Gross Expenditure 491,085 505,398 996,483 -3,109 17,013

Additional funding to reclaim 0 -12,028 -12,028 3,109 -4,478

Total Net Financial Position 491,085 493,370 984,455 0 12,535

MEMORANDUM Additional funding to reclaim: Hospital Discharge Programme -7,174 -7,174 3,132 -4,042 HDP (staff costs to clear backlog) 0 0 -361 -361 Flu Vaccinations (additional costs) 0 0 -39 -39 COVID-19 Vaccination Programme 0 0 -36 -36 Primary Care Additional Roles -1,982 -1,982 1,104 Local Independent Sector Activity -2,872 -2,872 -691 0 -12,028 -12,028 3,109 -4,478

NHS Bradford District and Craven CCG This document provides a summary and/or key discussion points and recommendations relevant to the subject of an item for consideration at the specified CCG meeting for the purpose of assurance, information, decision or action.

Agenda item 9

Name of meeting Governing Body Meeting date 9 March 2021 Operational and Financial Planning Title of report Report author(s) Robert Maden - CFO Update for 2021/22. Lead(s) / SRO Robert Maden – CFO Report lead(s) Robert Maden - CFO

Paper summary and/or key discussion points

This paper provides an update on our current understanding of the operational and financial planning process for 2021/22. At the time of writing, no detailed planning guidance has been issued by NHS England and Improvement. The current financial arrangements operating for the October to March 2021 period will be rolled forward to cover the first quarter of 2021/22 and the operational planning process for 2021/22 covering activity, workforce and finance for the remainder of the financial year has been deferred to Quarter 1 of 2021/22. This means that we will have a financial plan for Quarter 1 (2021/22) and a full operational and financial plan for Quarter 2 to Quarter 4 (2021/22). As in 2020/21, resources will be allocated to the West Yorkshire and Harrogate ICS and a process overseen by the West Yorkshire and Harrogate Finance Forum will determine organisational level resource allocations for both planning periods within 2021/22. Individual organisational plan approval will be required to support the approval of the overall West Yorkshire and Harrogate ICS plan. Resource availability in both planning periods is expected to include funding for Mental Health Forward View and new GP Contract commitments. For Quarter 2 to Quarter 4, resources will also include a share of the Spending Review 2020 settlement of £3bn which is intended to help address elective waiting list pressures, mental health service pressures and to help ease existing pressures (including the loss of productivity in 2020/21). Further guidance is awaited to confirm the detailed roll-forward financial arrangements and operational and financial planning guidance for Quarter 2 to Quarter 4 (2021/22) is expected at the end of April 2021. Plan submission dates are expected to be the end of April for Quarter 1 plans and the end of June for Quarter 2 to Quarter 4 plans. CCG Finance and Performance Committee and Governing Body approval dates will be confirmed once further guidance is issued by NHS England and Improvement.

Locally, whilst each organisation still has to develop and sign off its own plan for 2021/22, the plans will be developed collaboratively in line with the principles set-out in the Strategic Partnering Agreement, the expectation of the ICS and in preparation for moving to a shadow Integrated Care Partnership from the Autumn. The Executive Board is expected to collectively sign-off plans for the Bradford Place.

53 Page 1 of 2 Outline how this will help us to achieve our vision through our strategic ambitions:  Our population – improving health and equity for local people, and/or  Our partnerships – as the vehicle for enabling people to take more responsibility for their health, and/or  Our people – a skilled, motivated workforce with a culture of continuous improvement, and/or  Our leadership – assuring sustainability of our health and care system.

Contributes to financial sustainability and improves quality of commissioned services.

Purpose assurance Information Decision action

approve / recommend / review / consider / support / ratify comment / discuss Recommendation(s)

The Governing Body is asked to: 1. Note the update on the operational and financial planning process for 2021/22.

Appendices (or other supporting papers)

54 Page 2 of 2 OPERATIONAL AND FINANCIAL PLANNING UPDATE – 2021/22.

1. Introduction.

1.1 In light of the ongoing pandemic pressures and roll-out of the COVID vaccination programme, the operational and financial planning round for 2021/22 has been deferred to Quarter 1 of the new financial year.

1.2 This means that the current financial arrangements for H2 (October to March 2021) will be rolled forward to Quarter 1 of 2021/22 (Q1). The detailed arrangements for Quarter 1 have yet to be confirmed and the total quantum of resource available is subject to Government agreement. Further guidance is awaited regarding the continued operation of the Hospital Discharge Scheme and contracting arrangements for acute independent sector activity.

1.3 Resources available for Q1 are expected to be based on:

- Organisational level budgets calculated nationally, based on H2 2020/21 information; and - Additional funding for continued investment in Mental Health services and General Practice contract commitments.

Also, other new national investments and policies are likely to be delayed unless critical in order to maximise capacity for the response to COVID-19.

1.4 Operational and financial plans will then need to be produced for Q2 to Q4 (2021/22). Nationally, resources available for Q2 to Q4 (2021/22) are expected to be in line with the previous Long Term Plan financial settlement (based on CCG allocations) plus funding announced in the Spending Review 2020 (£1bn for elective waiting lists, £0.5bn for mental health services, and £1.5bn to ease existing pressures (including allowing for lower productivity in 2020/21)).

1.5 The following sections set out the broad approach for setting financial plans for ‘Q1’ and ‘Q2 to Q4’ 2021/22 based on our current understanding of the process. The approach will be updated in line with planning guidance issued by NHS England and Improvement when this becomes available.

1.6 Locally, whilst each organisation still has to develop and sign off its own plan for 2021/22, the plans will be developed collaboratively in line with the principles set-out in the Strategic Partnering Agreement, the expectation of the ICS and in preparation for moving to a shadow Integrated Care Partnership from the Autumn. In particular, this means that:

 We will manage NHS expenditure in aggregate across the system in an open and transparent way;

 We will agree and use one set of activity and finance data for the purposes of planning,

55 managing transformational changes, and agreeing any risk /reward mechanism;

 The financial focus for decision making will balance service delivery, quality and safety, as well as cost/expenditure;  The System Finance and Performance Committee and System Quality Committee will jointly review investment priorities and make recommendations to the Executive Board to support the collective sign-off of plans for the Bradford Place; and  Place based financial risk management arrangements are expected to operate in a similar way to the current financial year to support the delivery of the plan for the Bradford Place.

2. Financial Plan (Revenue) - Q1 (2021/22).

2.1 As for H2 2020/21, a system revenue funding envelope will be allocated to the West Yorkshire and Harrogate Integrated Care System (WY&H ICS), built up from nationally determined organisational level budgets and including a range of other national adjustments, e.g mental health funding, GP contract funding, ongoing COVID costs.

2.2 The allocation of system resources to organisations will follow the same process as for H2 2020/21, i.e

a) The WY&H ICS Finance Forum will oversee the financial planning work and discussions required (in organisations, Places, and across the ICS) to assess whether the overall system financial envelope is sufficient to allow credible financial plans to be developed across all NHS organisations;

b) Each organisation and Place will develop draft financial plans (supported by assumptions around activity and workforce) to assess the fit between these and the nationally calculated allocations for each organisation and Place. A peer review process will be deployed to support the development of organisational level plans;

c) Mismatches between the draft organisational financial plans and the nationally calculated allocations for Q1 2021/22 will be identified and reviewed. Given the likely differences between the national assessment of organisational resource requirements and the local assessment of operational requirements, mismatches are expected. Therefore, in the event that this occurs, collective consideration will be given at the WY&H ICS Finance Forum about the redistribution of system funding (informed in part by the results of peer review analysis) and the extent to which organisation or Place plans contained known and understood risk; and

d) Each organisation will secure the appropriate approval for their organisational financial plans, which by implication will support the system financial plan.

56 2.3 Provisional timetable for Q1 Plans:

 System funding envelope for Q1 confirmed. Mid to late March 2021  Submission of Q1 financial plan. End of April

CCG Finance and Performance Committee and Governing Body approval dates will be confirmed once further guidance is issued by NHS England and Improvement.

3. Financial Plan (Revenue) – Q2 to Q4 (2021/22).

3.1 National revenue resources available for Q2 to Q4 will be allocated to the WY&H ICS. They are expected to be based on the existing CCG allocations (as per the Long Term Plan financial settlement), plus financial recovery funding that would have been distributed to organisations and a share of the £3bn Spending Review 2020 settlement. This means that baseline resources for this period will include funding for Mental Health Forward View and new GP contract commitments.

3.2 The Spending Review settlement includes non-recurrent funding for elective waiting lists (£1bn) and mental health services (£0.5bn), and other funding of £1.5bn for existing pressures that recognises some of the lost productivity in 2020/21 (not clear if this is recurrent funding).

3.3 The allocation of system resources to organisations for Q2 to Q4 (2021/22) will follow a similar approach to that set out for Q1 (2021/22), although further guidance is required regarding the approach to determining NHS Trust contract values. For Q1 (2021/22), NHS Trust contract values will be based on nationally calculated values, but for Q2 to Q4 (2021/22) it is expected that NHS Trust contract values will need to be agreed locally.

3.4 Again, each organisation will secure the appropriate approval for their organisational financial plans, which by implication will support the system financial plan.

3.5 The WY&H ICS plan approvals process will be adjusted to incorporate an approval step at Place level of financial plans (using the place-based partnership governance arrangements that already exist). Whilst it is recognised that these arrangements will have no statutory authority in 2021/22 to approve financial plans, it does recognise the direction and intent incorporated in the recent White Paper on ICS development.

3.6 Provisional timetable for Q2 to Q4 Plans:

 Operational Planning Guidance Issued. Early April  Submission of Q2 to Q4 operational and financial plan. End of June

As for Q1 plans, CCG Finance and Performance Committee and Governing Body approval dates will be confirmed once further guidance is issued by NHS England and Improvement.

57 4. Recommendation.

4.1 The Governing Body is asked to:

i) Note the update on the operational and financial planning process for 2021/22.

58 NHS Bradford District and Craven CCG This document provides a summary and/or key discussion points and recommendations relevant to the subject of an item for consideration at the specified CCG meeting for the purpose of assurance, information, decision or action.

Agenda item 10

Name of meeting Governing Body Meeting date 9 March 2021 Gill Paxton Associate Director of Quality and Nursing Title of report Patient Safety and Quality Report author(s) Improvement report Michelle Turner Strategic Director of Quality and Nursing Michelle Turner Michelle Turner Lead(s) / SRO Dr James Thomas, Clinical Chair Report lead(s) Dr David Tatham ,Clinical Lead

Paper summary and/or key discussion points This report provides an overview and key messages of the following:

 Living with Covid-19 and system resilience  Key messages about the health and care providers  Medicines Optimisation key messages – including Covid-19 vaccinations  Personalised Commissioning  Care of Vulnerable Children  Research and Development  Safeguarding Adults  Host Commissioner responsibilities for people with Learning Disabilities and Autism in inpatient settings  Maternity Services  System Quality Committee – including staff resilience  Staff Resilience

Each week the CCG’s senior leadership team has also received a more detailed overview of the emerging issues and the steps taken to mitigate. These have been reviewed by the CCG’s Quality Committee along with the Covid-19 risk register and the CCG’s corporate risk register.

Key issues regarding living with Covid-19, the roll out of the vaccine, system resilience, the care of vulnerable children and progress by the system quality committee are noted Outline how this will help us to achieve our vision through our strategic ambitions:  Our population – improving health and equity for local people, and/or  Our partnerships – as the vehicle for enabling people to take more responsibility for their health, and/or  Our people – a skilled, motivated workforce with a culture of continuous improvement, and/or  Our leadership – assuring sustainability of our health and care system.

The quality and safety of services is core to the CCG’s strategy. Patient feedback is included within the paper and a more detailed overview will be considered at the CCG’s Quality Committee. Equality Impact Assessments have been conducted throughout the period and the outcomes have informed the CCG’s approach to risk assessment and to mitigation.

Purpose

59 Page 1 of 2 assurance information decision action

approve / recommend / review / consider / support / ratify comment / discuss Recommendation(s)

The Governing Body is asked to:  Note the information and assurance provided by the report, including key actions taken by the CCG to manage quality and safety issues and risks arising from COVID 19.  Note the substantial progress made by ‘health’ in address some of the concerns raised about the care of vulnerable children

Appendices (or other supporting papers)

1. Governing Body Quality Report (Mar 2021)

60 Page 2 of 2 Governing Body Medicines Covid-19 Quality and Safety Related IssuesSafeguarding and MarchRisks 2021 Optimisation

Michelle Turner Patient Quality safety Improvement

Research & Personalised development Commissioning

61 Living with Covid-19 and System resilience Care Homes • Infection Prevention and Control (IPC) is provided to all care homes + additional support to those who have experienced Covid-19 outbreaks. Risks of capacity and resource to the IPC team (BMDC) highlighted – a business case is being considered for a jointly funded IPC Practitioner role. • There are emergent patterns of smaller outbreaks, particularly within supported living units for learning disabilities and autism (LDA) clients. With smaller providers, this is posing additional challenges. • People living with LDA are at greater risk of death from Covid-19 than those in the general population. In order to improve the outcomes for LDA residents in care settings the ICS has allocated 14k funding to support improvements within this sector. The IPC sustainability group has engaged with and agreed options with local stakeholders. • The New Covid-19 variant is becoming more dominant with a slightly higher death rate (Spreads 30- 70 percent easier) • Lateral flow testing – confirmed testing at home has now been approved for care homes and is supported by published guidance to aid implementation. • All the residents of Care Homes, except one (due to an outbreak), have been offered a Covid-19 vaccination • There are variable standards across the Care Home sector in responding to and managing COVID outbreaks. Targeted interventions and support is offered and co-ordinated through the Care@Home system and multi-agency Out of Hospital multidisciplinary teams (MDT) 62 Living with Covid-19 and System resilience  Designated accommodation: There have been some gaps in provision of COVID-19 nursing beds in Craven, resulting in a system-wide response and 10 additional beds commissioned.  The West Yorkshire and Harrogate System has enabled:  The Super-Rota to continue 8-8 until the end of March 2021 and then on reduced hours until May 2021. A dietetic resource is working alongside the Super-Rota to provide targeted support, training and interventions  The development and delivery of a range of training and educational resources aimed at reducing deconditioning ( a reduction in the harmful physical and mental health impacts)  Asset Based Community Development grants to deliver community based initiatives to reduce the risk of deconditioning within our over 40’s population.

Stroke - The management of Stroke patients sits within the systems healthy hearts programme as an interim measure. Projected SSNAP (Sentinel Stroke National Audit Programme) for Oct - Dec 2020 is a C/B overall. This reflects projected improvements in scanning, Speech and Language Therapy and MDT working. There has been a decrease in performance in stroke unit wait times and actual time spent on the unit. Despite the Covid-19 challenges a comparison between Oct- dec 2019 and Oct –Dec 2020 demonstrates an overall improvement from a D to a B (where B is an improved position).

63 Provider Update • Bradford Teaching Hospitals NHS Foundation Trust Overall increases in self-harm suicide and alleged abuse incidents/Disruptive/aggressive incidents have been compared over a two year period with all the main providers. Further work is underway as early indications are of an increase over the 20/21 period. Some joint work has progressed with BDCT and ANHSFT regarding the learning from mental health serious incidents.(e • Bradford District Care Foundation Trust A focused CQC inspection reported on 18th Feb 2021, acknowledged the progress made in those areas previously highlighted as requiring improvement. The Quality Team Patient safety manager is also a regular member of the Trust monthly Patient safety and learning forum, which is helping towards the emerging Quality Assurance model. • Airedale NHS Foundation Trust ECIST (Emergency Care Improvement Support Team) have been providing support to aid effective discharges. Overall increases in self-harm suicide and alleged abuse incidents have been compared over a two year period with all the main providers showing an an increase over the 20/21 period. CCG staff have been invited to part of the learning review. • CQC Strategy consultation The proposed CQC strategy and approach to regulation ‘The world of health and social care is changing. So are we’ has been published. The CCG will submit a ‘place’ based submission. • The CCG’s Quality team has recently established good links with the Healthcare Safety Investigations Branch (HSIB) , in line with the new Patient Safety strategy (2020) which will enable greater quality improvement, shared learning and assurance at ‘place’. 64 Primary Care and Care Sector Update  CQC Practice Ratings: As inspections are and remain suspended there are no changes to practice ratings; Bradford District and Craven CCG currently have 67 practices CQC rated as ‘Good’; 3 ‘Outstanding’ and 1 ‘Requires Improvement.’  To ensure continued safety and assurance throughout the pandemic, the CQC introduced an interim Emergency Support Framework (ESF). To date only one practice across Bradford and Craven received an ESF contact; Parkside Medical Practice - no further action was required following this  The ESF has now been replaced with the Transitional Regulatory Approach, also known as Transitional Monitoring Approach (TMA); a risk based approach to monitoring services focussing on a review of key lines of enquiry, patient/staff feedback, and a phone call followed by a visit.  A number of TMA’s have already taken place at the following GP Alliances/GP practices; WACA (Wharfedale, Airedale and Craven Alliance), Wibsey and Queensbury, Kensington Partnership and Bowling Highfield, Parkside, Farrow and Modality and no issues have been highlighted to date  TMA’s in January 2021 are planned for Ashwell Medical Practice - The CQC will undertake a TMA to provide assurance until such time as they are to undertake a face to face visit.  From Monday 15th February the Monday session at the red hub has returned to one GP from two GPs. This reflects the decrease in activity going through the site. It was agreed by the senior leadership team that the red hub would remain post March 2021 – (a three month contract) with a 3 month extension period awarded to BCA to continue to provide the staff to the site.  A joint appreciative inquiry is being held with GP practices to improve further interagency working with Palliative care and District Nursing. New ways of working will be explored as a result of working within the pandemic to do GP home visits. 65 Medicines Optimisation COVID-19 Vaccinations: • All Primary Care Networks (PCNs) are offering vaccinations following the Joint Committee on Vaccination and Immunisation (JVCI): vaccines are now being offered to group 6 as per national direction ( adults aged 16 -65 in an at risk group) • All PCNs confirmed that they met the national directive of offering all patients within JVCI groups 1- 4 for a vaccine by 14th February ( 1. residents in a care home for older adults and staff working in care homes for older adults, 2. All those 80 years of age and over and frontline health and social care workers,3. All those 75 years of age and over 4. All those 70 years and over and clinically extremely vulnerable individuals ( not pregnant women and those under 16 years of age) • Second doses will commence at the start of March 2021 in line with the national position. • Some concerns noted relating to the uptake of vaccines from specific communities. • A new Clinical Reference Group will review incidents + ensure safety. There has been an increase in complaints regarding the availability of vaccines. This is controlled via the JCVI. • Significant support was given to PCNs by the Medicines Optimisation Team to re-arrange the 2nd vaccination appointments in line with the updated national guidance. A governance log of Primary Care guidance and local Standing Operating Procedures has been created. Warfarin Monitoring: Some supply issues and switch opportunities which are being addressed Flash Glucose Monitoring for diabetes: New guidance enables enhanced support for patients with a learning disability and type 2 diabetes. 66 Medicines Optimisation Flu Vaccinations • Lessons learned from the Flu programme are being identified and shared with the Flu System meeting to inform the 2021/22 Flu programme • Given the required focus on COVID-19 vaccinations and the time needed between Covid-19 and flu vaccinations, the group decided to step back from any further media work.

Flu Dashboard • The dashboard will provide a final monthly update for March 2021 which will be circulated to all GP practices. • The focus now needs to be on analysis of this year’s data to provide insight into areas for improvement for 2021/22 and to inform the COVID-19 vaccination programme • The Flu vaccination programme and the dashboard will continue to be overseen by the systems respiratory programme.

Antibiotic prescribing is 6.7% higher than expected in general practice. This possibly reflects a greater diagnostic uncertainty from an inability to examine patients face to face.

67 Personalised Commissioning • Continuing Health Care (CHC) Covid-19 Backlog – the backlog and trajectory are currently not on track to be completed by March 31st (8 outstanding). Back log cases have been prioritised rather than new referrals. Those clients with highest clinical risk have been prioritised. • New referrals have now created a backlog of a further 19 cases , monitored through the CHC Oversight Group activity report. Delays are caused due to clinical staff capacity. No individual on this waiting list is self-funding and all are in receipt of a care package • CHC Audit – Good progress is being made to address the audit recommendations. Activity and updates are being monitored through the CHC Oversight Group, and the CCG’s Quality Committee. • Learning Disability clients – joint work with Bradford District Metropolitan Council resulting in a decrease in disputes and escalations within this caseload. • Providers – the team is working alongside finance to determine a new process, to ensure CHC Framework compliance, with regards to CHC Top Up’s and lifestyle choice payments. • There is a backlog of CHC (non covid-19 reviews – this is being supported by VATLG (VAT Liaison Group), to ensure the Covid-19 backlog trajectory remains on track. • There are 27 appeals for eligibility decisions pending, there is a dialogue with the VATLG (VAT Liaison Group) regarding the support for these appeals. A nurse has recently been employed to action. • Continuing Healthcare Assurance Tool (CHAT) – this is being completed to ensure compliance with CHC processes. There are positive signs of a green RAG rating in all fields, due predominantly to work which has been completed over the past 9 months68 Research and Development  LAMP (Lowering antimicrobrial prescribing) continues with report 14 due in early March 2020, this continues to form part of the antimicrobrial prescribing response across the region and is integral to the AMR strategy

 Funding has been to take forward the collaborations developed in the 3 vaccine trial hubs across West Yorkshire, this partnership working in the 3 hubs will be solidified over the coming months

 The Novavax vaccine trial; There has been such a positive response as a region to recruiting participants, that the study team requested to double the initial recruitment target, The team completed this within the timeframe and the study is now in follow up

 The Astrazeneca monoclonal antibody trial; one hub achieved the first global recruit to the study, the study being open in 7 countries currently. The recruitment target was met and the study has now moved into follow up

 There are now moves to restart a number of projects that were all paused at the start of the pandemic. One study successfully restarted is the Genes and Health study

69 Safeguarding Adults

• There has been an increase in the number of Care homes that require improvements. The system; (CCG, Bradford Council and North Yorkshire Council) are supporting providers through action planning, consultationCovid-19 and sharingQuality best practice. and SafetyGreystones Relatednursing home Issueswas rated inadequate and by the CQC Risks • Cygnet: Cygnet Woodside remains under an Organisational Safeguarding Enquiry (OSE) due to concerns regarding the sustainability of the actions implemented in response to the recent CQC inspection resulting in an Inadequate rating. Cygnet Wyke went in as an OSE which will be closed at stage 2. Cygnet Bierley has an open OSE stage 2. Quarterly quality review meetings planned to oversee 3 local cygnet providers chaired by the CCG with NHSE, CQC, Bradford Safeguarding Board. • Exploration is underway with BMDC regarding a possible link safeguarding role to support Cygnet

• The Mental Capacity Act (MCA) Practice and Implementation of the Liberty Protection Safeguards (LPS): Health System Wide Strategy was presented at the System Quality Committee on February 22nd 2021

70 Vulnerable Children • Children Looked After – new clinical model to be implemented April 2021 funded recurrently, planned trajectory to reduce backlog by April 2022. Interim system arrangements in place for designated doctor and named doctor signed off by NHSE. New model being developed to enable system to meet intercollegiate guidance. • Childrens Young People mental health – system suites of data available from Feb 2021 for the programme, improved waiting times for children waiting for an assessments on the Acute Pathway, some concerns re length of time to an intervention. The CCG has prioritised £350k the Be Positive Pathway and £176k for trauma informed therapeutics interventions by the voluntary services. • Childrens Autism – concerns re waiting list (1948) remain. The CCG has provided an additional 660k non recurrent funding to source additional capacity from the private sector. Impact of new clinical model and pathways for new referrals to be reviewed to identify gaps and solutions. Additional expertise to be provided by a full time educational psychologist from BMDC. • Complex Children - Joint review of the Joint Placement Panel (JPP) completed 22.01.2021 with BMDC with very positive feedback. The review showed that the panel was Bradford’s version of the Doncaster model not the Doncaster model per se. The CCGs senior leadership team has asked for an update in March 2020 to understand the implications of moving to the Doncaster model. The inaugural joint report will be produced for the end of March 2021. This will be produced quarterly and shared through agreed governance arrangements. The PCD team is working with the CCG SEND team to develop

activity reporting 71 Vulnerable Children • 0-19 health visiting (and school nursing review) – timeframe to be agreed by the Director of Public Health. BMDC has provided non recurrent funding to provide additional support for the school nursing service ( reduced in 2018) in light of 40% increase in demand for safeguarding. Review of school nursing service has commenced to be completed by May 2021.

• Governance – review of Childrens Looked After action plan March 2021, CCG Designated Clinical Officer for SEND (Special Educational Needs and Disabilities) – to launch dynamic support register and communications with stakeholders including parent and carers groups by April 2021, review of quality assurance framework and audit tool for educational health care plans quarter 3 2021. Childrens and Youngs peoples dashboard in place with reporting to SEND partnership

• Joint Childrens Strategy and plans to be finalised by May 2021. Joint commissioning principles for SEND have been developed by the joint commissioning sub group – Feb 2021

72 Host Commissioner responsibilities for people with Learning Disabilities and Autism in inpatient settings Learning • The CCGs are required to implement CCG Host Commissioning arrangements by 31st March 2021. This is being led by the Director of Keep Well at home. A CCG Task and finish group has been convened to implement interim oversight measures to include establishing links, stakeholder engagement and communications and QA oversight process – consideration needed re Memorandum of Understanding (MOU) with independent hospitals. The new quality assurance process, were it to be required, will be led by the CCGs quality team • There are currently 141 out of area placements to 5 hospitals (Learning Disabilities, Mental health and Autism ) from 34 CCGs • Discussions with Partners both at Place and ICS to ascertain the most appropriate HOST Commissioner model. The CCGs senior leadership team advised that a WY ICS model should be commissioned in the long term. Learning Disabilities Mortality Review • Hosting service position statement for West Yorkshire as at 9th February 2021 are: 64 in progress - including those agreed exemptions for statutory processes, and those being reviewed externally. 15 cases have been submitted/closed.

73 Maternity Services Outstanding Maternity Services (OMS) - Progress has been made against the five focus areas: The Women’s Journey and Clinical Excellence, Investing in our Workforce, A Building Fit For The Future, Moving To Digital, Linking Learning & Quality Through Our Information Risks to OMS Delivery – COVID-19 impact on service + staffing. Midwifery and support staffing shortfalls, other priorities impacting on workforce, time to participate.

System Response to the Ockenden Report • Assurance provided 15 February 2021. All providers will present their position in public at their respective Boards. • The first Ockenden report and associated actions will be presented to the NHS Public Board in March 2021

A System wide quality assurance model for maternity services is being developed to maximise opportunities to strengthen the care of women and their families.

All Maternity cases referred to Healthcare Safety Investigation Brach (HSIB) are now to be classed as an Serious Incident

74 System Quality Committee - Update 26th February 2021 (health and care)

SQC 2020 -2021 key areas of focus Covid-19 • Sharing of experiences and stories and consensus re looking after our workforce • Focused discussions and greater collaboration on key guidance to support decision making at a system level e.g; hospital discharge, infection prevention and control, support to the care sector and care home resilience accessing external financial support. • Development of System Ethics committee, framework and toolkit using academic ethicist input – visiting practices, dental care, recovery, end of life conversations and DNACPR. • Post Covid-19 discussions, recovery and VCS resilience - x 2 System Quality Assurance and Surveillance • Alignment with WYH ICS thinking , role of the Quality Board and system oversight • Agreement to test a new model and way of working with providers to enable continuous improvement of quality ( and therefore provide assurance) to enable: • A shift from performance to ‘trust’, develop an open and learning culture • Collaboration with partners and People focused experience of care • Improvement in health and care pathways • Address health inequalities 75 System Quality Committee • A system wide response has been made to the CQC strategy consultation • A quality improvement strategy has been drafted in collaboration with stakeholders and further engagement is underway

Staff Resilience; • There has been an increase in reported incidents of Violence and Aggression, especially verbal abuse against staff. Further exploration is being undertaken to establish whether this escalation in incidents is secondary to a deterioration in the Mental Health of patients or simply difficult behaviour in relation to lockdown pressures. • A variety of initiatives have been launched to support staff maintain their health and wellbeing . #20 min movement, Recovering from COVID– 19 Support, Staff “temperature checks”. • Mutual aid staffing support is provided to the discharge, community pathway - for the Fast Track service, Telemedicine hub, Super-rota , post-discharge reviews and therapy services, and registered nursing support into the infection prevention and control team. • National and system wide initiatives continue to provide support although with limited impact. These include a staff sharing agreement and the Bring Back Staff scheme.

76 System Quality Committee - Update 26th February 2021 (health and care)

SQC 2020 -2021 key areas of focus: Mental Health SIs and System Review • Escalation in concerns regarding mental health restraints, challenging behaviour from patients and violence and aggression towards staff in acute settings led to consideration of levels of risk across the system, support for mental health and wellbeing, escalation routes and future learning events. Planning and prioritisation and impact on safety - one of our biggest concerns is the impact on Covid-19 on our workforce • Strengthened relationships and connectivity between System Quality Committee, Clinical Forum, prioritisation of work streams to ensure that impact on outcomes, population experience and safety is integral to the conversations and strategic planning • Areas of concern to be prioritised is the overarching need to improve outcomes for children and adults in the local population. We need a collective view of priority areas of concern by March 2021. • Areas of poor outcomes and safety as well as activity and resource requirements to be included in a collective framework for planning and prioritisation and proposed prioritisation framework

77 System Quality Committee - Update 26th February 2021 (health and care)

SQC 2020 -2021 key areas of focus Children Looked After & Vulnerable Children • Agreed system clinical model for health assessments – implementation April 2021 • Agreed system interim designated doctor arrangements – approved by NHSE Feb 2021 • Oversight of key priorities for vulnerable children for health – owned by health and care execs Jan 2021. Progress report re plans to address concerns - Feb 2021 User/community stories • System Grassroots approach agreed – paused due to Covid -19 • The power of Karin + Kevin’s story to the Council – agreement to develop a service improvement framework which ensures that we implement learning and measure impact of changes through our Act as One programmes/collab commissioning. Future Plans – next 6 months • Greater alignment with WY ICS - with key roles at ‘place’ engaged at an ICS level • Finalise Quality Improvement/Assurance framework - keep an eye on Quality Board, Regional and ICS thinking. • Potential benefits of an independent chair • Forward planner to include updates from programmes; Better Births – march 2021, Mental Health – April 2021, CVD – May 2021 • Agree formal system response to the CQC strategy consultation – ‘The world of health and social care is changing. So are we. We are taking off into the future.’ 78 NHS Bradford District and Craven CCG This document provides a summary and/or key discussion points and recommendations relevant to the subject of an item for consideration at the specified CCG meeting for the purpose of assurance, information, decision or action.

Agenda item 11

Name of meeting Governing Body Meeting date 9 March 2021

Title of report Safeguarding Children and Adults Report author(s) Helen Hart/ Jude Annual Report 2019/20 MacDonald/Matt O’Connor Lead(s) / SRO Michelle Turner Report lead(s) Michelle Turner

Paper summary and/or key discussion points The Annual Report demonstrates the activities undertaken by the Safeguarding team during the period 2019-2020, evidenced against the key priorities outlined in the team safeguarding strategy. The report summarises: Significant changes within the team personnel with further recruitment planned in the next reporting period Additional resource allocation within the team Increased activity levels across multi-agency partnerships to meet statutory and legislative changes and changed responsibilities Priorities for the forthcoming year Outline how this will help us to achieve our vision through our strategic ambitions:  Our population – improving health and equity for local people, and/or  Our partnerships – as the vehicle for enabling people to take more responsibility for their health, and/or  Our people – a skilled, motivated workforce with a culture of continuous improvement, and/or  Our leadership – assuring sustainability of our health and care system.

The report demonstrates how the team contribute to strategic ambitions through: Working to ensure the CCG meet their Statutory requirements and discharging their responsibilities for safeguarding adults and children Providing leadership, governance and challenge across the health community ensuring that safeguarding systems are robust Facilitating innovative practice within health to meet the challenges of population safeguarding Fully collaborates in all aspects of safeguarding partnership working to meet agreed outcomes and drive forward service developments/improvements Provision of guidance and expertise through a safeguarding lens across the whole spectrum of commissioning activities

Purpose assurance information decision action

approve / recommend / review / consider / support / ratify comment / discuss Recommendation(s)

The Governing Body is asked to:  Note the report which was received and accepted at Quality Committee on 4 February 2021 with no amendments required.

79 Page 1 of 2 Appendices (or other supporting papers)

Safeguarding Annual Report 2019/20

80 Page 2 of 2

Safeguarding Children and Adults

Annual Report 2019/20

Lead authors:

Matt O’Connor Designated Nurse: Safeguarding Adults (until October 2020)

Jude MacDonald Designated Nurse: Safeguarding Children and Children in Care

Helen Hart Designated Nurse: Safeguarding Adults (from September 2020)

With contributions from the CCG Safeguarding Children and Adults Team

Version 0.1 1

81 CONTENTS

Section Page

1. Introduction 3

2. Current Context 3

3. Safeguarding Team Strategy 5

4. Aim 1 – Service Planning and Procurement 6

5. Aim 2 – Governance and Assurance Arrangements 7

6. Aim 3 – Leadership, Support and Advice 9

7. Aim 4 – Multi-Agency Working 12

8. Aim 5 – Learning and Development 18

9. Forward Plan 2020/21 21

Appendix 1 Safeguarding Team Structure 22

1. Introduction

1.1 The safeguarding team is pleased to present the annual safeguarding report for Airedale, Wharfedale and Craven, Bradford City and Bradford Districts Clinical Commissioning Groups (AWC, BC, BD, CCGs). The report covers the period from 1st April 2019 - 31st March 2020 and aims to give assurance that the organisations are meeting their statutory duties and obligations in relation to safeguarding.

1.2 These obligations include the statutory duty for CCGs to discharge their functions with due regard to safeguarding children and adults at risk of abuse, within both their internal processes and their role as commissioners of health care for the local population (Safeguarding Children, Young People and Adults at Risk in the NHS: Accountability and Assurance Framework. NHS England, Updated August 2019).

1.4 The focus of the report is on the safeguarding of children and adults at risk, but includes the CCGs contribution to wider safeguarding agendas which can affect anyone – e.g. Domestic Violence, Modern Day Slavery and PREVENT.

1.5 The CCGs are committed to working in close collaboration with provider organisations and all members of local strategic partnerships, to help ensure that children and adults at risk of abuse are identified and protected from harm in the Bradford and Craven Districts.

2. Current Context

2.1 Bradford is the youngest city in Europe, with 26.5% of our population aged below 18 years. It is also one of the most deprived. The district has some newly establishing communities that are growing relatively fast through inward migration. Child poverty remains higher than the national average, and the numbers of children and young people with severe disabilities and long-term health problems (already higher than average) is predicted to increase. The number of Children In Care (CIC) in the district has been rising steadily and is at an all-time high. For adults, national comparisons show higher rates of learning disability and autism and suggest higher levels of undiagnosed dementia amongst older people.

2.2 The context of safeguarding practice continues to be shaped by a range of factors, including the outcome of national inquiries, individual case reviews, new legislation and media focus.

Local social and economic factors mean that the district remains a priority area in relation to the PREVENT counter extremism initiative and our population of adults and children are at increased risk of exploitation from a

83 wide range of criminal activities. The links between these forms of abuse and organised crime is widely recognised and are known to have significant and long lasting effects on health outcomes.

The CCG safeguarding team support the organisation and wider health and care system with meeting its obligations in relation to the wide range of safeguarding challenges. Some of the team’s current work-streams relate to:

 Children in Care  Non Recent and current child sexual abuse.  Child and adult exploitation in all its forms.  The experience of unaccompanied asylum-seeking children.  Children who go missing from home, care or education.  Forced labour through trafficking and modern day slavery.  Radicalisation and grooming for violent extremism.  On-line grooming and cyber-crime affecting children and adults at risk.  Quality of residential and nursing home care.  Organisational Safeguarding Enquiries.  Making Safeguarding Personal.  Domestic abuse, including domestic homicides.  Forced marriage.  Co-ordinating and facilitating the health community in meeting the recommendations from CQC CLAS Review (Feb 2019).  Supporting LA partners in the Improvement journey.  Implementation of new partnership arrangements for safeguarding children responsibilities, Child Safeguarding Practice Reviews and the new Child Death review Process.

2.3 Nationally, in 2018 the statutory guidance ‘Working Together to Safeguard Children’ was reviewed and revised, building on legislative changes via the Children and Social Work Bill. These new arrangements have changed the landscape of accountability for multi-agency safeguarding children activity, strengthening and increasing the responsibilities and duties of CCGs, as set out in more detail in Section 7.

For safeguarding adults, the ‘Making Safeguarding Personal’ agenda continues to drive a personalised and proportionate approach, centred on the outcomes the person wants to achieve.

2.4 There have been several changes in the team during the period being reported

 June 2019: Dr Qureshi, Named GP for Safeguarding Children left the team; hours were absorbed by existing Named GPs.

84  Domestic Abuse Manager/ Acting Deputy Designated Nurse: Safeguarding Children (0.4 WTE) recruited to Acting Deputy Designated Nurse: Safeguarding Adults 0.6 WTE until November 2019 to cover secondment.  Domestic Abuse Manager secondment secured (0.6WTE) increased to 1 WTE to support Multi Agency Safeguarding hub in June 2019  In November 2019, the Deputy Designated Nurse: Safeguarding Adults was welcomed back to her substantive role following her secondment to the Quality Team.  February 2020: Designated Nurse: Safeguarding Children notifies intention to retire 31/5/2020.  February 2020: Designated Nurse: Safeguarding Children and Children in Care appointed to full time.

Admin

 0.4 WTE Admin worker left the team leaving only 0.6 WTE.  The remaining team member retired shortly after and was replaced resulting in 1WTE.  Successful appointment of 0.6 WTE PA/Administrator post commencing June 2019 and 0.4 WTE PA/Administrator post commencing May 2019.  Successful recruitment to 1 WTE Band 2 Administration Assistant post in March 2020.

3. Safeguarding Team Strategy 2018-2020

3.1 This report is structured around the current safeguarding team strategy which was agreed in 2018. The strategy takes account of national drivers, local needs and the changing context of health and social care. It sets out 5 overall aims, and the ways in which the team works to achieve these.

Aims:

1. To ensure that the safeguarding of adults, children and young people is at the heart of the commissioning cycle. 2. To build on existing frameworks to strengthen assurance processes. 3. To lead, support and facilitate safeguarding practice across the health economy of the district. 4. To support and continue to develop strong multi-agency partnerships across the district. 5. To lead and support the development of a robust safeguarding culture in respect of learning and development across the health economy.

85 4. Aim 1 - Service Planning and Procurement

4.1 The Domestic Abuse Manager has worked with colleagues from the Local Authority, Police, Housing, Children’s Services and CCGs throughout the year on the re-procurement of services for people affected by domestic and sexual abuse, building on the findings and recommendations of the Joint Targeted Area Inspection (JTAI), completed in Bradford in 2017. The new model being proposed is a significantly different approach, combining the commissioning of victim support for adults and children, perpetrator programmes and housing support services.

4.2 Further to Public Health procurement of 0-19 services in 2018 the Designated Nurses attended 0-19 System Partnerships Meetings to ensure oversight and identification of any safeguarding gaps within new service delivery plans

4.3 A Safeguarding Impact Assessment has been previously developed for CCG commissioning and programme leads to use with support and expertise from the safeguarding team. This is in order to make sure that safeguarding implications are considered in any service change, redesign or procurement. The team have had few requests for support completion of the impact assessment and further work is needed to provide assurance that programmes are properly considering safeguarding impacts. This needs to include delegated or joint commissioning with the local authority.

The safeguarding team have become increasingly involved with service development and re-commissioning programmes at both a local health and care System and Integrated Care System footprint level, in order to ensure these programmes fulfil the CCGs safeguarding obligations.

The Deputy Designated Nurse: Safeguarding Adults, working in partnership with teams in the Quality Hub and wider CCG, represented the Quality and Nursing Directorate contributing to the work of the Transition Working Group to support the move to one CCG.

4.4 The Safeguarding Children Team continued to work collaboratively with the Director of Quality and Nursing, Public Health, NHS England, Mountain Health Care (providers of Sexual Assault Referral Centres SARC) and both the acute and community trusts to resolve the challenges when gaps in service provision were identified by Paediatricians and Sexual Health Services. Outreach care was implemented and a service for medical for Female Genital Mutilation; as a result of this the steering group was dissolved with assurance that it would meet again by exception.

86 5. Aim 2 - Governance and Assurance Arrangements

5.1 In relation to internal governance systems, the risk register has been regularly updated throughout the year to ensure high-level strategic risks in relation to safeguarding are identified.

The risk around unauthorised deprivation of liberty in NHS funded services remains, pending Liberty Protection Standards implementation and the Personalised Commissioning Team continue to mitigate some of the risk by taking contested or complex cases of mental capacity to the Court of Protection.

Implementation of the new Liberty Protection Safeguards (expected in April 2022 at the time of writing) is intended to mitigate risk of unauthorised deprivation of liberty, but will bring additional resource pressures along with risk of challenge and litigation and will require a considerable amount of work within the CCG and the wider system in order to prepare for its new statutory responsibilities.

5.2 The risk relating to the health needs of CIC has remained at high level on the register throughout the year, with the Designated Nurses being part of the working group reviewing the provision of health services to this population.

5.3 In line with the Standard Operating Procedure for Managing Safeguarding Serious Incidents, the safeguarding team continues to work collaboratively with the Risk Team to monitor Serious Incident (SIs) notifications from providers in order to identify potential safeguarding concerns. They will act in the role of lead or second reviewer in SI’s with a safeguarding component. The team also maintains an overview of statutory safeguarding reviews (Domestic Homicide Reviews, Serious Case Reviews for children and Safeguarding Adults reviews); reported as Safeguarding SIs with oversight from NHS England.

5.4 Review of the Safeguarding Children Policy and Procedure was undertaken to take account of the new edition of ‘Working Together’ and the Children and Social Work Act has been revised and approved. The Safeguarding Adults Policy and Procedures were extant during this reporting period but in response to the transition to one CCG they were being revised for approval. Safeguarding policies and procedures are available on each CCG website and further resources are also available to staff online and included via a link for practitioners on SystmOne.

5.5 External assurance is provided to both Bradford and North Yorkshire SCBs of the CCGs duties under the Children Act (2004) through completion of Section 11 Audits. The Bradford SCB manages Sec 11 assurance via an on-line tool, enabling contemporaneous updating of assurance. A ‘challenge’ process is in

87 place to enable the constituent agencies of the Board to question and hold each other to account around specific aspects of the returns. The next Section 11 assurance will be submitted during the next reporting period; whilst the process is likely to continue to be via on-line tool the format has not yet been agreed by the partnership

5.6 No self-assessment was requested by either North Yorkshire or Bradford Safeguarding Adults Board during this reporting period. However previous submissions confirmed significant levels of assurance and recognised the strong approach to safeguarding adults within the three CCGs.

5.7 In relation to provider assurance, the Safeguarding Children and Adults Commissioning Policies contain safeguarding related standards expected of providers. These are based on a regionally developed document and are in line with requirements in section 11 of the Children Act 2004.

5.8 Both Safeguarding Commissioning Policies are current and due for review in September 2020 (Children) and August 2021 (Adults).

5.9 The safeguarding team presented a Provider Assurance Overview report to JQC in March 2020. The report summarised the levels of safeguarding assurance in relation to commissioned services.

 Assurance in relation to NHS Trusts remains generally good and the CCG has well established systems for monitoring safeguarding specific assurance.  There are currently no significant concerns about abuse or neglect in relation to larger independent providers commissioned by the CCG and safeguarding assurance has improved. The safeguarding team continue to offer support to provider safeguarding leads.  The team continue to gather basic safeguarding adult’s assurance from care homes, however the limitations of self-declaration are acknowledged. The overall quality of care home provision within the district appears to be improving with substantial support being given by the Local Authority and local NHS.  For grant agreements with voluntary groups, the CCG includes a statement in relation to safeguarding, but does not receive any direct assurance.  The CCG safeguarding team do not routinely receive direct safeguarding assurance from GP Practices or Dentists, Opticians or Pharmacists, however the CCG safeguarding team have developed a self-assessment document and safeguarding resources covering both adults and children. The roll out of this to GP practices commenced in Autumn 2019.  The CCG does not receive any specific safeguarding assurance for individually commissioned packages of care. The CCG is reliant on CQC inspection regimes and local authority led safeguarding processes in the provider’s area.

88 5.10 As part of an action plan following an inspection of Safeguarding and Children Looked After in North Yorkshire in February 2017, the safeguarding team piloted a self-assessment checklist for GP practices in Craven bringing assurance arrangements for children in line with the rest of North Yorkshire. The document was based on the previous NHSE self-declaration tool and benchmarked against a child learning lesson review undertaken by the SCB in North Yorkshire. The adult and children team have worked collaboratively to produce this assurance document for GP practices. If a practice is compliant against these standards it should ensure that they meet the CQC safeguarding requirements. Supporting templates for policy and procedures are also being developed for practices to use. The team rolled out the Assurance tool in October 2019; evaluation has not yet taken place.

5.11 In collaboration with internal audit the safeguarding team undertook a survey monkey audit of CCG staff’s safeguarding knowledge; the survey demonstrated that whilst staff in the main understood safeguarding responsibilities low numbers of respondents would suggest that it would require further audit for full assurance.

6. Aim 3 – Leadership, Support and Advice

6.1 The team continues to contribute to wider work-streams within the CCG and the local health and care system. The safeguarding team support a number of strategic forums including; the Community Safety Partnership, the Domestic and Sexual Violence Board, the Through Care Strategy Group, CONTEST (Gold and Silver), Anti Trafficking and Modern Day Slavery Network and the Signs of Safety Steering Group.

6.2 The ‘inadequate’ judgement following the Ofsted inspection of Bradford Local Authority Children’s Services in September 2018 has led to a significant increase in cross-health work streams and reviews, as health safeguarding teams contribute to, and act as ‘critical friend’ to the improvement journey.

6.3 The Designated Nurses are leading the development, implementation and monitoring of the action plan following the Children Looked After and Safeguarding (CLAS) inspection by the CQC in February / March 2018. As well as identifying areas of good practice in all local health organisations, a series of recommendations were made, with the requirement that an appropriate action plan was formulated. This was accepted by the CQC, and periodic updates will be requested until this is complete. One of the main areas of challenge from the CQC was the capacity of the safeguarding children team, demonstrating a lack of compliance with the Intercollegiate Document (2018) recommended WTEs and role specifications.

6.4 A review of the team structure and capacity in light of inspection recommendations and current challenges was undertaken and agreement

89 was made for additional resource for the team which will be recruited to during the next reporting period.

6.5 The team provide supervision to provider safeguarding leads using a reflective framework. One of the Named GPs (Children) provides safeguarding children supervision for GPs as needed. The team is considering how best to deliver group supervision at practice safeguarding lead meetings. The Designated Dr provides supervision to the Named GPs.

6.6 The team offers clinical advice in relation to complex safeguarding cases for provider leads, GPs and practice staff. The Designated Nurses and Named GPs (Children) continue to provide support and consultation via a phone service, Monday – Friday, enabling primary care staff to discuss concerns and seek advice around safeguarding children issues. Feedback regarding this service is extremely positive. Throughout 2020/21, the team will review support to primary care, particularly in light of the agreed additional resource and future recruitment to the roles of Specialist Health Practitioners for Safeguarding Adults and Safeguarding Children and Domestic Abuse.

6.7 The safeguarding teams have provided expert advice as panel members for Domestic Homicide, Safeguarding Adult Reviews and Child Case Reviews. This includes providing support to the CCG Independent Management Review authors and the children’s team have contributed to local learning lessons reviews. Changes in statutory guidance for the management of children’s case reviews will potentially have an impact on team capacity due to the very short turnaround period for reviewing cases and the impact of the National Panel on decision making. During the period of this report a thematic SCR involving 5 children was started and 1 Rapid Review undertaken for which a CSPR will be commissioned. The numbers of scoping’s and Safeguarding Adults Reviews has increased as a result of the implementation of the Care Act.

6.8 The quarterly safeguarding adult and children newsletters are used by the Named GPs and CCG Safeguarding team as a means of disseminating information to primary care staff. It covers topics such as Prevent, how to meet safeguarding competency requirements, changes in service provision, guidance that can be incorporated into practice policy and practical guidance on how to manage specific safeguarding situations e.g. sexual assault, domestic abuse.

6.9 The team continued to offer safeguarding expertise and support to IT, IG and clinical leads following the changes to eDSM and the impact of GDPR. This aimed to ensure continued safe flow of relevant, proportionate information regarding those most vulnerable at an early stage.

90 The Named GP for Adults has liaised with the New Direction, Change Grow & Live (CGL)service which supports service users with any alcohol & substance misuse issues in order ensure that information sharing across the District with this service is clear, effective and maintains safeguarding principles.

6.10 The Integrated Designated Professionals Network, a regional group began meeting in August 2019 and the team attend and contribute sharing learning with other CCGs as appropriate. Attending these can be challenging for the team due to increased demands and team capacity.

6.11 The CCG Safeguarding team organises and chairs the quarterly, multi-agency SystmOne Safeguarding group meetings. These meetings are well attended. The objectives of the meetings are to identify and address the strengths, weaknesses, opportunities and threats posed by SystmOne functionality (which is being continually updated), as well as to share learning and best practice. The group has developed a cross-agency best practice guidance to support the use of SystmOne to document and share safeguarding information.

6.12 The safeguarding team continue to support the safeguarding leads in our main provider organisations through regular meetings at the Health Safeguarding Children and Health Safeguarding Adults groups. The groups consist of safeguarding leads from acute trusts, the district care trust, independent health providers including: Local Care Direct, Locala, Mountain Healthcare, Ramsey Healthcare, Cygnet and Change Grow Live. The groups aim to promote a culture of positive, supportive learning within the services and across the partnerships to help bring about and embed innovation and continuous quality improvement. This is done through sharing and learning from practice experience within an environment which promotes openness, challenge and honesty.

The children’s group took the decision to meet more often during 2019, to enable discussion, sharing and coordination of actions arising from both the Ofsted and CQC inspections.

6.13 A cross health record review group is co-ordinated by the safeguarding children team. The piece of work to be undertaken during this period is to examine how health partners capture and record the voice of the child.

6.14 The work of the MASH and CSE post steering group is led by the Designated Nurses: Safeguarding Children.

91 7. Aim 4 - Multi-Agency Working

During this reporting period the administration and professional leadership of the boards came together into one business unit. The Business Unit has not been fully staffed during this time so it remains unclear what impact this has had on the work of the Boards and the CCG safeguarding team. The adult deputy manager only remained in post for a short period with an interim deputy currently in this post.

7.1 Safeguarding Children Boards

7.1.1 Following the changes set out in ‘Working Together to Safeguard Children’ (2018), Local Safeguarding Children Boards ceased to exist at the end of September 2019 Instead, the former duties and responsibilities of the Boards transferred to three safeguarding partners – the local Commander of Police, the Chief Executive of the local authority, and the Accountable Officer of one of the CCGs in each area and became known as the Bradford Partnership. These responsibilities include setting priorities via a business plan, holding member agencies to account for their safeguarding contributions and ensuring that learning from cases is disseminated and embedded into practice. The partners will also decide arrangements for finance, membership, dispute resolution, and the functioning of the new partnerships. The Executive Lead and Designated Nurse have been involved in discussions with local partners about local transition. Arrangements for the district were published at the end of June 2019, and embedded by end September 2019. The structure which includes an Executive Leadership Group, on which the CCG will be represented by the Accountable Officer or Executive Lead, and a wider partnership board comprising of the group of agencies who work with children and families in the district. The sub-groups of the board remained the same.

7.1.2 Changes to the child death overview panel (CDOP) were also set out with governance transferring from the DoE to DoH; the new Child Death Review arrangements are to be the responsibility of the Child Death Review partners (Local Authority and CCG). Discussions were held with providers and partners as to how best to meet the new requirements which involved a substantial financial resource to be allocated. The arrangements were published in June 2019 and in place by September 2019.

7.1.3 Changes to the process for Serious Case Reviews (SCRs) guidance were issued in June 2019. SCRs were replaced with Child Safeguarding Practice Reviews which allows a more flexible and local approach to case review. Cases for consideration for Review must follow new guidance to undertake Rapid Reviews which must be undertaken within 15 days of notification of an incident and is overseen by the National Panel. Rapid Reviews to be

92 undertaken by the 3 Safeguarding Partners will be chaired by the Designated Nurse. During the report period 1 Rapid Review has been undertaken

7.1.4 Some aspects of multi-agency work around safeguarding children and young people continue to be co-ordinated via co-located teams which facilitate timely information sharing and shared decision making. The Specialist Health Practitioner in the former Bradford multi-agency CSE Hub is an established and highly valued team member, whose role is now evolving into one which encompasses child exploitation in a wider sense (criminal exploitation, county lines etc.).

7.1.5 During 2017/18 a Specialist Health Practitioner was recruited to work within the Bradford Multi-Agency Children’s Safeguarding Hub (MASH), with a similar model of cross-health activity. Recruitment for an additional 0.5 WTE practitioner was undertaken; due to personal reasons the successful candidate was unable to commence in post and additional resource was found by means of a secondment. Both posts are overseen by a steering group comprising of safeguarding leads from the health organisations in the district, and line managed by the Deputy Designated Nurse (Children).

The group identified many challenges for both practitioners and areas of perceived risk in the MASH in light of the rapid changes following the Ofsted Inspection in CSC. The Designated Nurses and Doctor have collated concerns and the impact of changes on all health partners and presented to CSC leaders on behalf of the HSCG. This work with partners to resolve identified issues will continue into the next review period.

During the CQC CLAS inspection, the CCG was challenged about the capacity within these roles, given the value and size of the workloads of the specialist health practitioners. The action plan was received and acted upon in this reporting period with an options paper to support the CSE practitioner role taken to the steering group. Little additional support could be identified without financial investment; as a result the Deputy Designated Nurse and SHP met with health providers from YOT and CiC to explore how to maximise contributions from health and reduce repetition of some work undertaken. A fuller review of the SHP role within CE will be undertaken in 2020.

7.1.6 The BSCB and NYSCB annual reports provide statistical and qualitative data about children in need of protection and support, and the work of the boards and their sub-groups. These are available via the Safer Bradford website and North Yorkshire (Link).

7.1.7 Within Bradford, the Executive Lead for safeguarding is Vice-Chair of the board, with the Designated Nurse and Designated Doctor being advisory members. The Designated Nurse is the Chair of the Case Review sub-group which leads on the implementation of the new rapid review requirements the

93 Designated Doctor chairs the Learning and Development sub-group. Each of the SCB sub-groups has a contribution from one of the Designated Nurses, providing representation in multi-agency work streams commissioned by the Partnership as required. A representative from the safeguarding team attends the North Yorkshire Safeguarding Children Board and Craven forums, ensuring that communication with North Yorkshire Board is robust; it is particularly challenging to meet this commitment

7.1.8 The Health Safeguarding Children Group (an affiliated group to the Board) has the remit to facilitate a coordinated cross-health response to safeguarding children issues.

7.1.9 Regular meetings between the Bradford safeguarding children team and the Designated Nurses in North Yorkshire enables clear and effective communication between the teams, offering a forum for discussion of cross- border issues and the CLA population of Craven.

7.1.10 During the last 12 months, the children’s team has contributed 3 Individual Management Report (IMR) to one Thematic Serious Case Review (SCR) commissioned by the SCB (written by Named GPs) reviewing non recent child sexual exploitation: the Deputy Designated Nurse (Children) and Designated Dr contributed as panel members. The SCR will continue into 2020 and it is anticipated that publication which attract much media attention; one of the subjects has waived the right to anonymity and approached local news networks and the case is linked to criminal proceedings. Learning from the case will be disseminated to general practice clinicians via level 3 training and the safeguarding newsletter. The team has also completed a scoping exercise for a potential further SCR.

7.1.11 The children’s team has also contributed to the BSCB’s challenge panels which provide an opportunity for multi-agency scrutiny and audit of themed cases, resulting in learning for improvement of safeguarding children practice.

7.2 Safeguarding Adults Boards

7.2.1 Along with the Local Authority and Police, CCGs are statutory partners of Safeguarding Adults Boards (SAB) who oversee local arrangements to safeguarding adults at risk from abuse and neglect. In fulfilling its obligations as a statutory partner, the CCG has maintained its longstanding and active, contribution to the Bradford SAB with consistent attendance from the Executive Safeguarding Lead, supported by the Designated Nurse and Deputy.

7.2.2 The CCG are actively involved in the work of all the Bradford boards’ sub- groups, with the Designated Nurse chairing the Making Safeguarding Personal Group and the Deputy Designated Nurse chairing the Training

94 Group. The CCG team also frequently deliver face-to face multiagency training on behalf of the BSAB, as part of a small group of expert trainers running events for service managers and senior clinicians.

7.2.3 In Craven, the CCG is well engaged with the work of the North Yorkshire Safeguarding Adults Board, with the Designated Nurse attending Board meetings and being an active member of the Practice, Training and Development sub-group and the Local Safeguarding Adults Group covering Harrogate and Craven. The team have also contributed to the Board’s Learning and Review group and the arrangements for Safeguarding Adults Reviews in North Yorkshire.

7.2.4 The work of the safeguarding adults’ boards, including written contributions from the CCG and other partners, is published in their annual report. When published, the document will be available, along with previous reports, on the SAB pages of the Bradford (https://saferbradford.co.uk/adults) and North Yorkshire councils (https://safeguardingadults.co.uk/) web sites.

7.2.6 In January 2020, the Safeguarding Adults Board implemented the revised Multiagency Safeguarding Adults Procedures, which are shared with neighbouring local authorities. This was the culmination of a significant piece of work for the board and health partners, which places greater focus on the personalised approaches to safeguarding in order to promote self- determination and balance autonomy and protection.

7.2.7 The Safeguarding Adults team were involved with increased numbers of statutory Safeguarding Adults Reviews (SAR), within the reporting period. Two SARs were in progress, one SAR was published and one SAR was agreed but has not commenced at the time of writing this report. The frequency of the Safeguarding Adults Boards SAR sub group has been increased to manage the volume of SAR requests and subsequent workload.

7.3 Domestic Abuse and Sexual Violence Board

7.3.1 The Bradford Domestic Abuse & Sexual Violence Board has strategic responsibility for all forms of interpersonal violence and abuse in the household, as described in the Home Office definition of Domestic Abuse (2015).

7.3.2 The primary aim of the Bradford Domestic Abuse & Sexual Violence Board is to develop a strategic response to reduce violence against women and girls and inter-personal violence against men. The Domestic and Sexual Abuse Board recognises along with the Bradford Safeguarding Children’s Board and the Safeguarding Adults Board there will be on-going and one off pieces of work that will require continuity and ownership across all safeguarding partnership arenas. Domestic Abuse & Sexual Violence where victims are

95 vulnerable adults and children are issues of concern to be shared across all Boards. The Board is accountable to the Bradford Community Safety Partnership.

7.3.3. The CCG is represented on the main Board. The Deputy Designated Nurse/Domestic Abuse manager chairs one of the three strategic groups, and also chairs the Learning and Development sub group. Group chairs attend the Board meetings. The Domestic and Sexual Abuse Local Health Economy group sits within the Board structure and the Designated Nurse for Safeguarding Children and the Domestic Abuse Manager attend these meetings, which also includes representatives from Local Authority and Public Health.

7.3.4 The Domestic Homicide Review Standing Panel aims to support and advise the Community Safety Partnership regarding the initiation of a DHR. The panel then oversees the DHR process, from appointing an author and chair; through to monitoring the implementation of DHR overview report action plans and ensuring any lessons learned from the reviews is widely disseminated. The Deputy Designated Nurse for Safeguarding Children/Domestic Abuse Manager is a member of this group.

7.4 Domestic Homicide Reviews

7.4.1 For April 2019 to March 2020 one local DHR was published, one DHR report and action plan was submitted to the Home Office and awaits publication. Following recommendations from the Home Office two reports required the authors to review and resubmit, this process is on-going. There were two cases where the victim had links to Bradford but the DHR process was being completed by different local authorities. In this time period there was one new DHR identified and following an initial scoping exercise the process to tender for an author has been initiated.

7.4.2 The CCGs Safeguarding team produce action plans based on findings from the IMRs and the team is responsible for incorporating learning into GP safeguarding training and disseminating to GP staff via quarterly safeguarding newsletters and evaluating whether this is embedded into practice.

7.4.3 In addition the Deputy Designated Nurse Children/ Domestic Abuse Manager, through membership of the Learning and Development sub-group of the Board, is actively promoting the dissemination of learning from DHRs, and ensuring that it is reflected in training and practice across health services.

96 7.5 Children in Care (CIC)

7.5.1 Statistics show a continuing increase in Bradford’s number of children in the care of the local authority which is reflective of the national rise In March 2018, there were 851 children looked after by Bradford, which had risen to 1206 in June 2019. The numbers of children entering care each month ranged from 39 to 53 in the first three months of 2019.

7.5.2 Children entering care require a statutory health assessment, completed jointly by a paediatrician and a Specialist Nurse, within 20 days of becoming looked after. Thereafter, children require health reviews every 6 months if aged under 5, or annually aged 5-18. These review health assessments are completed by the specialist nurses unless there are on-going medical issues that need follow up.

7.5.3 The legislative and statutory framework for the health care of children looked after is set out by the guidance ‘Promoting the Health and Wellbeing of Looked after Children and Young People’ (DFE and DH, 2015), with additional guidance provided by the Quality Standard for the Health and Wellbeing of Looked after Children and Young People (NICE, last updated in 2015). The statutory guidance states that CCGs should have appropriate arrangements and resources in place to meet the physical and mental health needs of the CiC population.

7.5.4 The CCGs commission BDCFT to provide the specialist nursing health input to this client group, via the CLA Team. The statutory medical input is commissioned via paediatrics in the acute Trusts. The CLA team is responsible for the coordination and delivery of the statutory nurse-led health assessments and reviews to the looked after children population within the Bradford and Airedale district. In addition, the team is responsible for children looked after by Bradford Local Authority that are placed out of area. This responsibility is discharged either by the Specialist Nurses travelling to where the child is placed, or by commissioning the assessments (in partnership with the CCGs) from the equivalent team in the child’s locality. The commissioning for health assessments for CIC in Craven is with Harrogate District Foundation Trust.

7.5.5 The CCGs contribution to the local multi-agency strategic oversight of services to CiC is via the Through Care Strategy Group which during the latter part of 2019 was inactive The Designated Nurse and Doctors are members of this group. There is a sub-group with the specific remit of the health of CiC and care leavers, chaired by the Designated Nurse. The group sets health priorities and actions to feed into the strategy aligned closely with the CCG review of services; meetings were merged to ensure consistency

97 7.5.6 The Designated Nurse is a member of the Bradford Corporate Parenting Panel, the committee of the local authority responsible for overseeing and scrutinising the welfare of CiC.

7.5.7 The increase in the numbers of CLA has led to a critical reduction in the compliance rates for timeliness of statutory health assessments. In particular, the waiting list for Initial Health Assessments has grown to several months, against the statutory timescale of completion within 20 working days of entering care. In addition, paediatric availability is not always sufficient to enable timely completion of adoption medicals. The CCG regularly receives challenge from the local authority, health colleagues from out of area and the judiciary around this which is reflected in the CCG risk register. The CQC, during the CLAS inspection, recommended ‘urgent action to address provision shortfalls’. A CCG-led review of the provision of health services to CIC was undertaken during the period of this report with colleagues from health and the local authority meeting regularly to mitigate risk, maximise available resource and look at a sustainable model for the future with a business case being developed which will enable the CCGs to fulfil their statutory duty to CIC.

8. Aim 5 - Learning and Development

8.1 Safeguarding adults and children is everybody’s business. All health staff have a responsibility to help prevent abuse and to act quickly and proportionately to protect people where abuse is suspected. It is essential that all staff work actively to identify and safeguard people who may be at risk of or are experiencing abuse and work within agreed organisational and locally agreed multi-agency safeguarding policies and procedures relevant to their role and responsibility. There is a wide range of training and development sources available to access; this includes mandatory in-house face to face training, multi-disciplinary training, bespoke learning events and direct professional advice and support.

8.2 Work continues with the CCG governance team and Bradford District Care Foundation Trust Learning and Development team to ensure mandatory training compliance records are accurate and only record the CCG recognised face to face safeguarding training, as per the organisational policy.

8.3 There were four in-house Safeguarding Awareness sessions delivered by the team during 2019-20. The awareness training covers safeguarding children, adults and Prevent, addressing both the essential aspects of safeguarding and reference to the wider safeguarding portfolio, including areas such as financial scamming and statutory reviews. A review of training requirements against the Safeguarding Adults Intercollegiate Document published in August

98 2018 and Children’s in 2019 has been undertaken and in response the in- house training package for adults and children received a radical update.

8.4 The compliance levels of CCG staff between April 2019 and March 2020, according to BDCFT Learning and Development Team were:

 Safeguarding adult, children and Prevent Awareness Training: 79%  Prevent WRAP: 80%

The team monitor compliance regularly and make efforts to provide an adequate number of sessions to accommodate all CCG staff, however non- attendance has been an issue on occasions, which is reflected in the compliance level.

8.5 During the course of this year, the three Prevent WRAP sessions delivered by the safeguarding adult team and the Named GP for Safeguarding Adults have been opened up to both CCG staff and GP Practice Leads. This is to encourage a better attendance rate and create a more conducive learning environment promoting healthy debate and challenge.

8.6 The Named GPs for adults and children with the support of the CCG Safeguarding Team continue to deliver education and training to GPs. The majority of GP practices report having both a safeguarding adult and child lead (sometimes the same GP).

8.7 During 2019-20 the decision was taken to retire the safeguarding repository and move to using GP Assist as a route to share safeguarding information. The team also launched the GP Assurance Document in October 2019, supporting practices to benchmark their safeguarding practice against agreed standards.

The safeguarding team have produced model policies for GP practices to adopt should they wish to do so and can be used in conjunction with the assurance document. These policies include Child Safeguarding Practice policy and Practice Procedure guidance, guidance for addressing children not brought to appointments, and guides to achieving and maintaining competences in adult and child safeguarding, to name but a few. It is proposed that the team will continue their work to develop additional model policies.

8.8 The launch of the intercollegiate document: Safeguarding Children and Young People: Roles and Competencies for Healthcare Staff in January 2019 saw an increase in the amount of safeguarding training clinicians were expected to complete. The safeguarding team have continued to deliver training, producing quarterly newsletters and hold regular adult and child safeguarding lead meetings. These support clinicians to develop their safeguarding

99 knowledge and practice and to meet their safeguarding training requirements and have covered a wide variety of subjects including; changes to the child death process, bruising in non-mobile children, domestic abuse, Adverse Childhood Experiences, child exploitation. The safeguarding lead meetings allow for timely sharing of updates, best practice and case discussion, this learning can then be cascaded within GP practices

8.9 The Named GP for safeguarding adults has delivered two GP lead sessions and four GP update sessions. The training offered across primary care has focussed upon a range of safeguarding issues in order to ensure that practitioners are able to recognise & respond to abuse and neglect in keeping with the Care Act, 2014, Mental Capacity Act, 2005, joint multi-agency procedures, 2018 and ensuring adherence to the intercollegiate document. This included why, when & how to report a concern to the Local Authority in response to abuse and neglect, the raising of awareness of county lines and the implications this has for modern day slavery.

The Named GP for safeguarding adults provided GP Trainee safeguarding adult training and Registrar Safeguarding adult training.

The Named GPs for safeguarding children delivered four GP lead sessions and four GP level 3 updates, with support from the Safeguarding children’s team. They have provided level 3 training to both VTS (GP) training schemes

8.10 The team supported Safeguarding Week (2019) by offering a Mental Capacity Act Masterclass and the safeguarding children team facilitated and delivered briefings to Bradford practitioners (specialist nurses, doctors, education and social care staff) and BSCB of local research findings from 2018-19. The briefings evaluated as interesting and applicable to practice.

8.11 The Designated Nurses for Safeguarding Children have delivered Multi- agency training provided by BSCB and have contributed to bespoke training to launch the multi-agency CE protocol There has also been a cross health training session for supervisors which was facilitated by the CCG, ANHSFT and BTHFT safeguarding teams

The Safeguarding adult team have continued to contribute to the co-delivery of Multi-Agency training provided by Bradford Safeguarding Adults Board.

8.12 The safeguarding team continuously work hard to remain up to date themselves with current guidance, policy and practice relating both to safeguarding adults and children and the wider commissioning role and functions. Through personal study, contribution to and delivery of multi- agency training, participation and contribution to local and regional networks and attendance at local, regional and national related events, the team are

100 able to continue leading and supporting the safeguarding agenda within the CCGs and the wider health economy.

8.13 During 2019-20 one member of the team successfully completed the NHS England funded, Mary Seacole Leadership Development Programme and one member of the team attended a Quality Improvement development session.

9. Forward Plan 2020/21

9.1 In terms of the current context of safeguarding, as well as abuse from within families and in care settings, threats to the welfare of children and adults through exploitation by organised crime, online abuse and radicalisation is increasingly recognised as an area of concern. This is reflected in changing structures and procedures and will offer challenges in terms of information- sharing and consent issues.

9.2 The year 2020/21, will see the embedding of the new local arrangements for safeguarding children, which will include the increased responsibility and accountability for the CCGs, as one of the three statutory safeguarding partners.

9.3 For children, completion of the action plans from the CLAS inspection and partnership activity in the local authority’s improvement journey will mean continued review of and changes to ways of working, with resultant requirements for leadership, support, advice and guidance from the safeguarding team, as well as increased participation in multi-agency forums.

9.4 Areas of planned activity over the next year will include;

 Evaluation of the GP assurance tool.  Completion of the action plan and development of the business case re health services delivery to Children in Care.  Completion of the action plan re CLAS inspection, including recruitment to increase the capacity of the safeguarding team.  Recruitment and appointment to the Specialist Health Practitioner roles, Deputy Designated Nurse: Safeguarding Children  Robust induction process for newly formed team  Optimising the health contribution to the Children’s MASH and CE hub.  Continued review of training needs and delivery in light of the intercollegiate documents and changes to local safeguarding procedures.  Considering of options to strengthen hosting arrangements for guidance to GPs through GP assist.  Further development and strengthening of the team role regionally and within the Integrated Care System.

101 Appendix 1 Safeguarding Team (2019-20)

Designated Nurse Designated Doctor Designated Nurse

Safeguarding and Children Looked After Safeguarding Children Safeguarding Adults 1 WTE 5 PAs 1 WTE

Deputy Deputy Designated Nurse Domestic Abuse Designated Nurse Manager Safeguarding Health Safeguarding Children Adults 1 WTE 1 WTE 0.8 WTE

CSE Specialist Multi-Agency Named GPs Named GPs Named GP Practitioner Safeguarding Children Hub Practitioner Safeguarding Safeguarding Safeguarding

Safeguarding Children Children Adults Children Safeguarding Children

2 Sessions 2 Sessions 2.5 Sessions 1 WTE 0.5 WTE

Safeguarding Team Administrators - 1 WTE

102 22

Agenda item 12

Name of meeting Governing Body Meeting date 9 March 2021

Title of report Commissioning Assurance Report author Sue Baxter, strategic head Framework (strategic risks) of assurance Liz Allen, strategic director of Lead / SRO Report lead Sue Baxter organisation effectiveness

Paper summary and/or key discussion points Development of the commissioning assurance framework The combined (three former) CCGs’ governing body assurance framework was used as the basis for the new NHS Bradford District and Craven CCG commissioning assurance framework (CAF). This framework identifies the principal risks to delivery of the CCG’s contribution to the Bradford District and Craven vision and strategic ambitions from a commissioning perspective. Our role in the delivery of this strategy is set out in the new CCG commissioning strategy. The CAF sets out the controls that are in place to manage the risks and provides the key strategic assurance tool that evidences the extent to which the controls are having the desired impact. It clearly identifies gaps in control and describes the management actions being taken to reduce the risks level to the target risk score. It also identifies any gaps in assurance and what can be put in place to provide the required level of assurance for the CCG committees and Governing Body. Next steps include the development of the balanced scorecard.

Structure and frequency of the framework The commissioning assurance framework (appendix 1) has two tables. The first provides a summary of the strategic objectives, the strategic risks and highlights where gaps in control or assurance have been identified. The second table provides the detail for each strategic objective and risk. The commissioning assurance framework will be made available to Governing Body on a bi-meeting basis including: March 2021, July 2021, November 2021 and March 2022.

Scope and use of the framework The name change from ‘Governing Body Assurance Framework’ to ‘Commissioning Assurance Framework’ signals the move to a broader use of this strategic risk tool, with the aim of promoting wider use with members of the senior leadership team, associate clinical directors and the associate leadership team as well as the Governing Body. The aim of broadening out the use of this framework is to facilitate and engage our leaders and decision makers in the strategic risk management process and to provide this as an integral tool to assist our decision making. Supporting the way we manage and mitigate our strategic risks, this should over time become an embedded risk management tool just as the corporate risk and COVID19 risk registers currently provide.

February 2021 high level changes  one new risk (5.1) which relates to ICP readiness from 1 October 2021 (shadow form) and 1 April 2022 (in place)  an adapted risk regarding our people in transition (6.1) which now reflects the transition of CCG and other associated staff to the ICS, under the 11 February 2021 white paper ICS legislative changes  the strategic risk (7.2) is recommended to close, this is due in large part to the place based development of our Act As One way of working, which negates the need to describe the way we allocate resources separately. Across Bradford district and Craven our partnership has evolved over the past year and all 103 Page 1 of 3 partners are signed up to the strategic partnering agreement (SPA) and are working together across Bradford district and Craven. The SPA is currently being refreshed.

The table below provides a summary of the strategic risks and their current scores.

Table 1: Commissioning assurance framework strategic risk summary

Risk Strategic Risk rating 1.1 There is a risk of failure to improve population health outcomes and to reduce health inequalities due to COVID19. Poor outcomes and health inequalities have been highlighted by the COVID19 pandemic with both direct and indirect impacts of COVID19 on the economy, education as well as the 16  physical health and mental wellbeing of our population particularly those living in the areas of worst socioeconomic deprivation 2.1 There is a risk due to the growing financial pressures created by an increase in demand for services could result in agreed strategic and operational plans to deliver improved health and care 9 ↔ not being realised 3.1 There is a risk that unwarranted variations in quality and care cannot be effectively addressed due to shortfalls in workforce capacity, capability and skills resulting in failure to close the care and 16 ↔ quality gap (across BdC) 3.2 There is a risk that our efforts may not have the impact we desire due to some determinants of quality and outcomes which lie outside of the control of health and social care resulting in a failure to 12 ↔ close the care and quality gap (Quality improvement / assurance) 4.1 There is a risk that the changes to health services models required to achieve clinical and financial sustainability are not acceptable to key stakeholders, e.g. patients, the public or elected 9  representatives, and cannot be implemented. This would result in the failure of the act as one approach. 5.1 *new ICP readiness: There is a risk that we fail to gain sufficient organisational traction towards Integrated Care Partnership for Bradford district and Craven place, due to a range of factors. This includes: leadership challenges, failure to agree governance arrangements and future form and 12 function, resulting in failure to achieve a viable form in time to receive delegated responsibilities from the Integrated Care System 6.1 *new ICS people transition: there is a risk of CCG staff struggling to adapt to new, externally facing, system-focussed roles as we move towards the new Integrated Care System and Partnership operating model by 1 April 2022 due to the need for organisational form change and individual CCG 12  staff role flexibility and the normal factors associated with change, resulting in failure to successfully transition CCG staff.

7.1 There is a risk that we do not address the underlying financial deficit and establish a financially 16 ↔ sustainable position over the medium term as we exit the pandemic

7.2 *recommend close (superseded): There is a risk that the two Health and Care Partnerships are not financially sustainable due to the system financial gap not being closed resulting in action from 16 ↔ the regulators

 Our leadership: to provide assurance regarding delivery of our commissioning strategy, our strategic ambitions and specific outcomes.  Each of our ambitions has at least one associated strategic objective and strategic risk, as follows: o Our population - 1.1 and 2.1 o Our partnerships - 3.1, 3.2, 4.1 and 5.1 o Our people - 6.1 o Our leadership - 7.1 (and 7.2)

104 Page 2 of 3 Purpose assurance information decision action

approve / recommend / review / consider / support / ratify comment / discuss Recommendation(s)

The Governing Body is asked to: 1. review and approve the CAF / strategic risk log, as a fair and accurate reflection of the CCGs’ current strategic risk position and agree whether 7.2 strategic risk can be closed; 2. be assured that future Governing Body meetings will be provided with the commissioning assurance framework on a bi-meeting basis in July 2021, November 2021 and March 2022; and 3. be assured that the commissioning assurance framework use will be broader and will include consideration by: the senior leadership team, the associate clinical directors and the associate leadership team.

Appendices (or other supporting papers)

1. Commissioning assurance framework (at February 2021)

105 Page 3 of 3 Appendix 1

Our vision: by 2023 every person living in Bradford district and Craven will have the opportunity to spend more time enjoying life in the best of health

Commissioning assurance framework

Introduction Brought forward from the three predecessor CCGs’ governing body assurance framework the NHS Bradford District and Craven CCG commissioning assurance framework (CAF) identifies the principal risks to the delivery of the CCG’s strategic objectives and links to how we operate within the new CCG Commissioning Strategy. It sets out the controls that are in place to manage the risks and provides the assurances that show the extent to which the controls are having the desired impact. It identifies the gaps in control and therefore the key mitigating actions required to reduce the risks towards the target risk score. It also identifies any gaps in assurance and what actions can be taken to increase assurance to the CCG.

Summary overview The table below sets out the strategic objectives, the strategic risks that relate to them and highlights where gaps in control or assurance have been identified. Further details can be found on the supporting pages for each of the Strategic Risks.

Risk Are Risk Target there Are there

Strategic Objective Risk Strategic Risk Summary Current or GAPS GAPS in Risk Lead ID Score Appetite in assurance Score control Risk Risk Movement since Sept 2017 our Population improved health and equity for local people 1. Improving population health and reducing health inequalities by embedding There is a risk of failure to improve population Dr Sohail the population health health outcomes and to reduce health inequalities Abbas management approach, due to COVID19. Poor outcomes and health Strategic identifying population inequalities have been highlighted by the COVID19 clinical director needs and working 1.1 pandemic with both direct and indirect impacts of of population 16  6 Yes Yes collaboratively with our COVID19 on the economy, education as well as the health and partners and communities physical health and mental wellbeing of our wellbeing / to implement effective population particularly those living in the areas of deputy clinical interventions. In order to worst socioeconomic deprivation chair improve health, to promote healthy lifestyles and by Page | 1

106

Risk Are Risk Target there Are there

Strategic Objective Risk Strategic Risk Summary Current or GAPS GAPS in Risk Lead ID Score Appetite in assurance Score control Risk Risk Movement since Sept 2017 ensuring access to health and care services, particularly for those in areas of greatest need 2. Building strong relationships with local There is a risk due to the growing financial authorities and Health and pressures created by an increase in demand for Ali Jan Haider Wellbeing Boards to services could result in agreed strategic and Strategic ensure local priorities for 2.1 operational plans to deliver improved health and director of 9  6 Yes Yes improved health and care care not being realised keeping well at are met by jointly planning, home designing and monitoring the delivery of care our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care

3. Working at Bradford Michelle district and Craven place There is a risk that unwarranted variations in quality Turner we will develop and deliver and care cannot be effectively addressed due to strategic targeted programmes to 3.1 shortfalls in workforce capacity, capability and skills 16  4 Yes Yes director of address the gaps in the resulting in failure to close the care and quality gap quality and quality and outcomes of (across BdC) nursing our health and social care.

We will reduce unwarranted variations There is a risk that our efforts may not have the Michelle in the quality and care impact we desire due to some determinants of Turner provided for our patients quality and outcomes which lie outside of the strategic and residents. We will 3.2 12  9 Yes Yes improve outcomes and control of health and social care resulting in a director of experience for our failure to close the care and quality gap (Quality quality and improvement / assurance) nursing patients and residents

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107

Risk Are Risk Target there Are there

Strategic Objective Risk Strategic Risk Summary Current or GAPS GAPS in Risk Lead ID Score Appetite in assurance Score control Risk Risk Movement since Sept 2017 4. Working collaboratively at Bradford district and Craven place, our Act As One (AAO) way of working improves health and care Vicki Wallace services whilst ensuring There is a risk that the changes to health services (interim) / the clinical and financial models required to achieve clinical and financial Nancy O’Neill sustainability of our sustainability are not acceptable to key Strategic partnership. This will 4.1 stakeholders, e.g. patients, the public or elected director of 9  6 Yes Yes include our programmes representatives, and cannot be implemented. This transformation (Access to health and would result in the failure of the act as one and change care; Respiratory; approach deputy chief Diabetes; Healthy Hearts; officer Better births; Ageing Well; and Children and Young People’s mental wellbeing) and enabling strategies

5. Develop stronger collaborative partnerships in local places between the *new ICP readiness: There is a risk that we fail to NHS, local government Vicki Wallace gain sufficient organisational traction towards and others. Including a (interim) / Integrated Care Partnership for Bradford district and central role for primary Nancy O’Neill Craven place, due to a range of factors. This care, collaborative provider Strategic 5.1 includes: leadership challenges, failure to agree 12 N/A 6 Yes No arrangements and director of governance arrangements and future form and incorporate strategic transformation function, resulting in failure to achieve a viable form commissioning through and deputy in time to receive delegated responsibilities from the systems with a focus on chief officer Integrated Care System population health outcomes

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108

Risk Are Risk Target there Are there

Strategic Objective Risk Strategic Risk Summary Current or GAPS GAPS in Risk Lead ID Score Appetite in assurance Score control Risk Risk Movement since Sept 2017 our People a skilled, motivated workforce with a culture of continuous improvement 6. We will continue to review and develop our internal *new ICS people transition: There is a risk of resources, structures and CCG staff struggling to adapt to revised system- processes to ensure that and partnership-focussed roles as we move we are able to achieve our Liz Allen towards the new ICS and ICP operating model by 1 strategic objectives as our Strategic April 2022 due to the need for different commissioning functions 6.1 director of 12  8 Yes Yes organisational forms and individual CCG staff role transfer and, thereby, our organisation flexibility and the normal factors associated with CCG staff transition to new effectiveness change, exacerbated by the impact of the Covid Integrated Care System pandemic upon ways of working, resulting in failure (ICS) and Integrated Care to successfully transition our CCG staff Partnership (ICP) arrangements. our Leadership assuring the sustainability of our health and care system

There is a risk that we do not address the Robert Maden 7. Working at Bradford underlying financial deficit and establish a 7.1 Chief Finance 16  8 Yes No district and Craven place, financially sustainable position over the medium Officer we will maximise value for term as we exit the pandemic

money in the use of healthcare services to ensure we can make *recommend close (superceded): There is a risk shared decisions on how that the two Health and Care Partnerships are not Robert Maden to use our resources to 7.2 financially sustainable due to the system financial Chief Finance 16  8 Yes No improve population health gap not being closed resulting in action from the Officer regulators

The following pages set out the detail the level of risk against each strategic objective the management controls in place and outstanding actions to take as well as the internal and external assurance in place and the outstanding assurances to secure.

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109 Strategic Risk Log – Risk 1.1 our Population improved health and equity for local people Strategic Objective 1: Improving population health and reducing health inequalities by Risk Lead: Dr Sohail Abbas, strategic clinical director of population health and embedding the population health management approach, identifying population needs wellbeing / deputy clinical chair and working collaboratively with our partners and communities to implement effective Risk Owner: Kerry Weir, associate director of population health and wellbeing interventions. In order to improve health, to promote healthy lifestyles and by ensuring access to health and care services, particularly for those in areas of greatest need. There is a risk of failure to improve population health outcomes and to Specific outcomes: reduce health inequalities due to COVID19. Poor outcomes and health  Risk Share responsibility for leading healthier lives and preventing ill health inequalities have been highlighted by the COVID19 pandemic with both  rating Create opportunities for people to take control over their own health and direct and indirect impacts of COVID19 on the economy, education as well 16 care as the physical health and mental wellbeing of our population particularly  Use population health management solutions in areas with high health those living in the areas of worst socioeconomic deprivation. inequalities (partnerships) Risk Rating Rationale for current score: Financial pressures are impacting adversely on (Likelihood x local services, particularly those delivered by the VCS. Increased national Impact) focus on self-care, prevention and social prescribing as part of the NHS Long term plan. There is significant progress towards implementing a whole system Initial 4 x 4 = 16 approach to living well. However, COVID19 has increased health inequalities. (Sept 2017) Rationale for target score (risk appetite): We hope to reduce both likelihood Current 4 x 4 = and impact in the longer term by spreading and embedding the self-care and 16 (Feb 2021) prevention message and supporting work across the system to focus on health inequalities using a PHM approach; however, we recognise that change of this Target 3 x 2 = 6 nature takes time and that there are pockets of society where it will be very difficult to enact change.

Partners / stakeholders involved:  Patients  GPs & Community Partnerships  VCS  Patient Groups

 Trusts & BMDC Existing Controls (what are the key controls in place to prevent this risk occurring?) Gaps in Control (where are we failing to put effective controls in place and what more should be done to manage the risk)  Act as One initiative overseen via the Health and Care Executive Board  Population Health Management system enabling project in early stage of  Bradford district & Craven (BdC), Strategy 'happy healthy at home' development (Currently seen by some parties as primarily a health tool,  Health & Wellbeing Board and BdC system governance arrangements rather than also applicable to the wider determinants of health)  Primary Care Networks Direct Enhanced Service  Absence of a clear and credible baseline that indicates the starting  Looking at all initiatives from an inequalities perspective (e.g. COVID) position so that any programme progress can be reliably measured  ICS Health Inequalities Academy being launched February 2021  CCG Population Health Management structure to be implemented April Page | 5

110 Strategic Risk Log – Risk 1.1 our Population improved health and equity for local people Strategic Objective 1: Improving population health and reducing health inequalities by Risk Lead: Dr Sohail Abbas, strategic clinical director of population health and embedding the population health management approach, identifying population needs wellbeing / deputy clinical chair and working collaboratively with our partners and communities to implement effective Risk Owner: Kerry Weir, associate director of population health and wellbeing interventions. In order to improve health, to promote healthy lifestyles and by ensuring access to health and care services, particularly for those in areas of greatest need. There is a risk of failure to improve population health outcomes and to Specific outcomes: reduce health inequalities due to COVID19. Poor outcomes and health  Risk Share responsibility for leading healthier lives and preventing ill health inequalities have been highlighted by the COVID19 pandemic with both  rating Create opportunities for people to take control over their own health and direct and indirect impacts of COVID19 on the economy, education as well 16 care as the physical health and mental wellbeing of our population particularly  Use population health management solutions in areas with high health those living in the areas of worst socioeconomic deprivation. inequalities (partnerships)  Resources at place to support include: BMDC and North Yorkshire Public Health 2021 Teams to support the implementation of the programme; CCG Population Health Management team structure now agreed - capacity secured  Clear commitment to self-care and prevention by all partners  Reducing Inequalities in Communities (RIC) programme and funding targeting the most deprived area in Bradford  RIC being launched across WYH ICS as part of Health Inequalities Academy Controls Action Plan (what actions are being taken to address gaps in Implementation Progress to date control) date 1. Workshop scheduled to begin discussion around Population 26/02/2021 Workshop taking place on 26th February Health Management enabling programme (March 2021)

2. Workshop with HWB on inequalities Better Births complete, Ageing Well scheduled 18th March 3. Act as One programme workshops – PHM/HI presentations Assurance Mechanisms (where / how do we get assurance that the existing controls are Assurance Details (specific evidence of positive or negative assurances) working effectively) Internal: PHM enabling programme formally in place by April 2021  Ad-hoc reporting on specific initiatives and projects as required - PHM presentation Act as One programmes focussing on health inequalities to the CCG Senior Leadership Team in December  Performance reporting to both the Quality Committee and to the Finance and Performance Committee External:  Reporting to Health & Wellbeing Board and Act as One Health and Care Executive Board

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111 Strategic Risk Log – Risk 1.1 our Population improved health and equity for local people Strategic Objective 1: Improving population health and reducing health inequalities by Risk Lead: Dr Sohail Abbas, strategic clinical director of population health and embedding the population health management approach, identifying population needs wellbeing / deputy clinical chair and working collaboratively with our partners and communities to implement effective Risk Owner: Kerry Weir, associate director of population health and wellbeing interventions. In order to improve health, to promote healthy lifestyles and by ensuring access to health and care services, particularly for those in areas of greatest need. There is a risk of failure to improve population health outcomes and to Specific outcomes: reduce health inequalities due to COVID19. Poor outcomes and health  Risk Share responsibility for leading healthier lives and preventing ill health inequalities have been highlighted by the COVID19 pandemic with both  rating Create opportunities for people to take control over their own health and direct and indirect impacts of COVID19 on the economy, education as well 16 care as the physical health and mental wellbeing of our population particularly  Use population health management solutions in areas with high health those living in the areas of worst socioeconomic deprivation. inequalities (partnerships) Gaps in Assurance & Action Plan where are we failing to gain evidence Implementation Progress to date that our controls are effective and how can we address this? date No routine reporting on health inequalities at CCG nor Act as One TBC KW Not sure this is feasible Key changes since the last review of the 3xCCGs GBAF (now named CAF) Related risks on the Risk Register Number, brief description, current score 1.1  Increased national focus commitment to this area.  Risk 930: BI service and impact on data analysis abilities (12)  Review of previous self-care and prevention programme complete.  Risk 931: access to and understanding of mental health data (9)  New Living Well Programme launched (new branding, website, resources); new  Risk 1098: failure against key constitutional targets (9) Programme Board and governance structure in place.  Risk 1544: there is a risk that a single CCG may lose sight of the specific  Additional public health staff supporting the Living Well agenda needs and characteristics of our different communities (e.g. health  Reducing Inequalities in Communities launched inequalities in City or rurality in Craven) due to a larger CCG footprint and  PHM enabling programme workshop limitations in data analysis. (8)  Risk 1590: outcomes for population negatively impacted (COVID RR)  Risk 1582: increased health inequalities (COVID RR)

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112 Strategic Risk Log – 2.1 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Strategic Objective 2: Building strong relationships with local authorities and Health and Risk Lead: Ali Jan Haider, strategic director of keeping well at home Wellbeing Boards to ensure local priorities for improved health and care are met by Risk Owner: TBC, associate director of keeping well at home jointly planning, designing and monitoring the delivery of care There is a risk due to the growing financial pressures created by an increase Specific outcomes: Risk in demand for services could result in agreed strategic and operational plans  Make shared decisions on how to use our resources to improve population rating to deliver improved health and care not being realised. health 9  Look beyond health to where we can make the greatest difference to the wellbeing of local people Risk Rating Rationale for current score: (Likelihood x Financial pressures impacting on relationships and the ability to jointly Impact) commission services is considered fairly likely, with a moderate impact.

Initial 3 x 3 = 9 Rationale for target score (risk appetite): (Sept 2017) We believe we can reduce the likelihood of the risk by focussing on the benefits to users and business benefits for partners of closer working. Current 3 x 3 = 9 (Feb 2021) Partners / stakeholders involved: • Local Authority Target 2 x 3 = 6 • VCS • Patient Groups

Existing Controls what are the key controls in place to prevent this risk occurring? Gaps in Control where are we failing to put effective controls in place and what more should be done to manage the risk  Wellbeing Board membership including non-health and social care representatives  Unpredictability of financial pressures impacting on partner organisations  Joint working with CBMDC and collaboration with a wide variety of stakeholders  Lack of transparency and openness regarding the impact of funding and  Agreement to the principles of ‘no cost shunting’ decommissioning decisions  Living Well programme plan and Living Well programme board and collaborative  Reduction in true spend on self-care and prevention  Early help and prevention programme board  Key priorities of Living Well to be re-determined (with need for  Personalised Commissioning / Continuing Healthcare – differences in approaches fundamental analysis of the impact of COVID to support this) and working practices identified between health and social care. Joint policy is in  Limited training for staff in motivational interviewing and normalising self- development care  Agreed process for considering shared responsibilities for children placed in  Personalised commissioning and continuing health care joint policy educational establishments out-of-area (is under review)  Review of process for shared responsibilities in relation to placed children

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113 Strategic Risk Log – 2.1 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Strategic Objective 2: Building strong relationships with local authorities and Health and Risk Lead: Ali Jan Haider, strategic director of keeping well at home Wellbeing Boards to ensure local priorities for improved health and care are met by Risk Owner: TBC, associate director of keeping well at home jointly planning, designing and monitoring the delivery of care There is a risk due to the growing financial pressures created by an increase Specific outcomes: Risk in demand for services could result in agreed strategic and operational plans  Make shared decisions on how to use our resources to improve population rating to deliver improved health and care not being realised. health 9  Look beyond health to where we can make the greatest difference to the wellbeing of local people Controls Action Plan what actions are being taken to address gaps in Implementation Progress to date control date 1. Continue to influence partners and negotiate practical solutions in Ongoing regards to the unpredictability of financial pressures 2. Address the lack of transparency and openness regarding Status funding and decommissioning decisions 3. Collaborate with partners to redress the reduction in true spend Status on self-care and prevention 4. Analysis of the impact of COVID to re-determine priorities for the Status Living Well programme 5. Resolve the limited training available for staff in motivational status interviewing and normalising self-care 6. Personalised commissioning and continuing health care joint status policy in place 7. Complete the review of the process for shared responsibilities in status relation to children in educational establishments out-of-area Assurance Mechanisms where / how do we get assurance that the existing controls are working Assurance Details specific evidence of positive or negative assurances effectively  Reports and updates to Bradford Wellbeing Board   Minutes of CBMDC Executive meeting in relation to plans, funding and service changes  Reports to the Health and Care Executive Board  Reports to HOSC and the Wellbeing Board Gaps in Assurance & Action Plan where are we failing to gain evidence Implementation Progress to date that our controls are effective and how can we address this? date 1. No regular reporting to Governing Body on the Living Well Status programme

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114 Strategic Risk Log – 2.1 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Strategic Objective 2: Building strong relationships with local authorities and Health and Risk Lead: Ali Jan Haider, strategic director of keeping well at home Wellbeing Boards to ensure local priorities for improved health and care are met by Risk Owner: TBC, associate director of keeping well at home jointly planning, designing and monitoring the delivery of care There is a risk due to the growing financial pressures created by an increase Specific outcomes: Risk in demand for services could result in agreed strategic and operational plans  Make shared decisions on how to use our resources to improve population rating to deliver improved health and care not being realised. health 9  Look beyond health to where we can make the greatest difference to the wellbeing of local people Key changes since last review of 3x CCGs’ GBAF (now named CAF) Related risks on the Risk Register number, brief description, current score) 1.1 No update provided Risk 1101: health input to Education & Care Plans (SEND) (16) Risk 1094: child autism / ADHD services (16) Risk 1134: Health outcomes of children looked after (#) Risk 1135: adult autism / ADHD services (16) Risk 1404: 0-19 services; impact on CCG commissioned services (15)

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115 Strategic Risk Log – 3.1 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Strategic Objective 3: Working at Bradford district and Craven place we will develop Risk Lead: Michelle Turner, strategic director of quality and nursing and deliver targeted programmes to address the gaps in the quality and outcomes of our health and social care. We will reduce unwarranted variations in the quality and care Risk Owner: Gill Paxton, associate director of quality and nursing provided for our patients and residents. We will improve outcomes and experience for our patients and residents Risk There is a risk that unwarranted variations in quality and care cannot be Specific outcome: rating effectively addressed due to shortfalls in workforce capacity, capability  Improve our skills and knowledge to increase our personal value 16 and skills resulting in failure to close the care and quality gap (across BdC) Risk Rating Rationale for current score: (Likelihood x Impact) this is a long term plan

Initial 4 x 4 = 16 (Sept Rationale for target score (risk appetite): 2017) Ongoing local challenges in recruitment and retention of a skilled workforce continue to be reported across the Health Care Partnership systems. It is likely Current 4 x 4 = 16 that this will continue, risking sustainability for some services. Due to the (Feb 2021) development of the Commissioning People Plan, a Bradford District and Craven wide primary care workforce together with acute/mental health and Target 2 x 2 = 4 community provider workforce plans, we anticipate that workforce initiatives and movement across the health care partnership provider system delivery structures will reduce the likelihood and impact of any shortfalls within the system. Additionally further initiatives across primary care such as GP and Practice Nurse leadership schemes that have been held over the last year are beginning to yield strengthened leadership and therefore address variations in practice. Partners / stakeholders involved:  GP Practices and Primary Care Networks  Health Care Partnership Board stakeholders (AWC and Bradford HCP’s)  Demand needs to be owned by all stakeholders in the footprint  NHS England  WY stakeholders  HEE Existing Controls (what are the key controls in place to prevent this risk occurring?) Gaps in Control where are we failing to put effective controls in place and what more should be done to manage the risk  Wellbeing Board and West Yorkshire ICS  A lack of a consistent approach to understanding return on investment  Health and Care Executive Commissioning Board including investment of all resources (staff and money)  Finance and Performance Committee and performance report and Quality  Due to HEE allocation in education credits to HEI’s, the CCGs have noted the curtailment/limitation to relevant health courses available locally, this Page | 11

116 Strategic Risk Log – 3.1 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Strategic Objective 3: Working at Bradford district and Craven place we will develop Risk Lead: Michelle Turner, strategic director of quality and nursing and deliver targeted programmes to address the gaps in the quality and outcomes of our health and social care. We will reduce unwarranted variations in the quality and care Risk Owner: Gill Paxton, associate director of quality and nursing provided for our patients and residents. We will improve outcomes and experience for our patients and residents Risk There is a risk that unwarranted variations in quality and care cannot be Specific outcome: rating effectively addressed due to shortfalls in workforce capacity, capability  Improve our skills and knowledge to increase our personal value 16 and skills resulting in failure to close the care and quality gap (across BdC) Committees (CCG and System) and quality reporting will likely continue to impact in the short term of the availability of a local  Integrated People Board (IPB)/ Primary care strategy – Provider led including skilled workforce – outside of CCG control but we will try to influence in this representation from BCA. area by assessing workforce plans and skill gaps to inform further  West Yorkshire Quality Surveillance Group (includes regulators) discussions  West Yorkshire and Harrogate People Board and associated groups in place  Challenges in enabling and facilitating free movement across the system of  Development of the Commissioning People Plan qualified and capable staff have resulted in little uptake from staff within the  Health and Social Care Economic Partnership local system. No mechanism to balance the allocation of sufficient  Strategic Coordination Group – attended by Public Health colleagues resource to local requirements due to national shortage of skilled workforce  An agreement /MoU underpinning the movement of staff within the Health Care / allocations competing priorities. The new Government White Paper outlining the development of ICS/ICP’s may affect the ability of the system Partnership  The WYAAT trusts have signed an agreement that enables colleagues who are to recruit suitably qualified staff  competent to undertake roles and are cleared to work in one of our organisations to Inability to view the performance of the entire pathway due to unavoidable be able to work in another WYAAT trust without the need for an honorary contract data constraints (e.g., legal and information governance requirements) and all the associated checks Controls Action Plan Implementation Progress to date (what actions are being taken to address gaps in control) date 1. Discussions are ongoing with HEE and HEIs to identify priority Ongoing Primary Care workforce are now represented (via the Primary Care Workforce areas and agree engagement required when such decisions are and Training Hub) at the Bradford University Workforce Needs meeting and made, to ensure sustainability of local care services. also the work currently being undertaken to increase the number and quality of clinical placements across the system. Primary Care workforce needs were fed into the refreshed BD & C Integrated People Plan which will continue to be a ‘live’ document. All additional training needs have been fed into the Transformation Training Requirements for 2021/22 for WY/HEE and for the successful bids against the SSWDF to enable commissioning of education and training on a needs led basis. The Bradford Care Alliance organised a workforce system development day in February 2020 to engage on key priority areas for primary care for 2020/1 and a focus on Primary Care Workforce will be presented at the INTEGRATED PEOPLE BOARD (IPB) in March 2021. 2. Raise with the WYQSG and local CCGs across the HCP Ongoing Raised at WYQSG, DoN forum, primary and Community Care HCP workgroup. Page | 12

117 Strategic Risk Log – 3.1 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Strategic Objective 3: Working at Bradford district and Craven place we will develop Risk Lead: Michelle Turner, strategic director of quality and nursing and deliver targeted programmes to address the gaps in the quality and outcomes of our health and social care. We will reduce unwarranted variations in the quality and care Risk Owner: Gill Paxton, associate director of quality and nursing provided for our patients and residents. We will improve outcomes and experience for our patients and residents Risk There is a risk that unwarranted variations in quality and care cannot be Specific outcome: rating effectively addressed due to shortfalls in workforce capacity, capability  Improve our skills and knowledge to increase our personal value 16 and skills resulting in failure to close the care and quality gap (across BdC) footprint, approach to workforce challenges Challenges and workforce needs fed into the BD & C Integrated People Plan and primary care has a regular place at the Integrated People Board (IPB). Portability of staffing across the WYAAT is in place to support enabling recognition of employment check and mandatory training and thus releasing more clinical input into the system and a staff sharing MoU was developed in response to the Covid19 pandemic. Greater opportunities to ‘market’ the attractiveness of working in Bradford District and Craven via the health and care economic partnership and our Growing for the Future programme of work in the IPP will continue to a core area of work in the months ahead. 3. Development of a co-ordinated system delivery plan for Complete The Bradford District and Craven local general practice workforce group has workforce. developed a high level delivery plan that has fed into the system workforce delivery plan for ‘place’. The workforce heat map is being used by ‘the growing your own’ working group and by the community engagement officers for recruitment in local neighbourhoods. Assurance Mechanisms Assurance Details where / how do we get assurance that the existing controls are working effectively specific evidence of positive or negative assurances  Integrated People Board discussion and reporting shared with System Quality  Gap in assurance until there is a coordinated system plan against which to Committee, CCG Quality Committee (JQC) and programme work streams measure progress.  Reporting of gaps in care and workforce challenges across our providers reported monthly to the System Quality Committee  Quality assurance mechanisms of providers identify gaps and workforce challenges and agreement of actions required in place  Quality assurance and performance monitoring to address care delivery gaps actioned via provider contractual meetings including use of incentives such as CQUINS is in place / CQC inspections Gaps in Assurance & Action Plan (where are we failing to gain evidence Implementation Progress to date that our controls are effective and how can we address this?) date 1. Reporting against the system plan to Integrated People Board Ongoing Reporting against the system plan to IPB and Health Care partnerships (HCP) (IPB) and Health Care partnerships (HCP) x 2. x 2. 2. Implementation and use of refined integrated dashboards across Ongoing Building on the LTP narrative produced in 2019 and the integrated dashboard Page | 13

118 Strategic Risk Log – 3.1 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Strategic Objective 3: Working at Bradford district and Craven place we will develop Risk Lead: Michelle Turner, strategic director of quality and nursing and deliver targeted programmes to address the gaps in the quality and outcomes of our health and social care. We will reduce unwarranted variations in the quality and care Risk Owner: Gill Paxton, associate director of quality and nursing provided for our patients and residents. We will improve outcomes and experience for our patients and residents Risk There is a risk that unwarranted variations in quality and care cannot be Specific outcome: rating effectively addressed due to shortfalls in workforce capacity, capability  Improve our skills and knowledge to increase our personal value 16 and skills resulting in failure to close the care and quality gap (across BdC) providers are to include required detail regarding workforce and approach, the BD & C Planning Forum is meeting fortnightly to ensure the coordinated approach to quality assurance and workforce locally triangulation of NHS money, activity and workforce across ‘place’. Its focus is across delegation of primary care to identify clear workforce gaps looking at the reset and recovery planning requirements, against a backdrop of and priority areas. the Covid19 pandemic and the need for transformation of agreed pathways and development of new models of care – planning guidance is still waited for 2021/22. During 2020 the system workforce strategy was developed into an Integrated People Plan to reflect the 4 programmes of work in the NHS People Plan. The delivery plan to underpin this is being developed with key programme leads and clear priorities for the next 12 months and 1-3 years. Key changes since last review of 3xCCGs’ GBAF (now named CAF) Related risks on the Risk Register number, brief description, current score 1.1  Greater connectivity with primary medical care and neighbourhoods Risk 1171: quality of critical care services (8)  System passport for care agreed for ‘place’ Risk 1312: quality of primary care (12)  Greater alignment with health and care economic partnership to ‘market’ Bradford and Craven  Bradford District and Craven system wide Integrated workforce programme Board (IWPB) and West Yorkshire and Harrogate Local Workforce Action Board (LWAB) in place, however the impact and outcome of these are yet to be realised.

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119 Strategic Risk Log – 3.2 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Strategic Objective 3: Working collaboratively, we will develop and deliver targeted Risk Lead: Risk Lead: Michelle Turner, strategic director of quality and programmes to address the gaps in the quality and outcomes of our health and social nursing care. We will reduce unwarranted variations in the quality and care provided for our Risk Owner: Gill Paxton, associate director of quality and nursing patients and residents. We will improve outcomes and experience for our patients and (supported by John Hartley, Head of Patient Outcomes) residents. Specific outcome: Risk There is a risk that our efforts may not have the impact we desire due to rating some determinants of quality and outcomes which lie outside of the control  Through our partnerships, reduce the variation in people’s experience of the care and quality 12 of health and social care resulting in a failure to close care gap (Quality improvement / assurance) Risk Rating Commissioned services and programmes may not address all gaps in quality (Likelihood x Impact) and outcomes for our local population. This risk identifies that an increase in health inequalities with some patients receiving sub-optimal care and Initial 4 x 4 = 16 potentially poor patient experience outcomes could continue. (Sept 2017) Further cooperation between partners (see below) and more joined up system wide plans for improvement i.e. Act as One, SPA, ICS, APC, system Current 3 x 4 = 12 performance and quality groups has reduced the likelihood of the risk (Feb 2021) occurring, and improved the way we mitigate the risk. The impact should the risk materialise remains the same Target 3 x 3 = 9 November 2019 update – score amended

Rationale for target score (risk appetite): The impact of not closing the care and quality gap will always remain high but we expect long term interventions will likely reduce the gap. NHS 10 Year Plan signals more involvement / influence of NHS bodies in the wider determinants of quality and outcomes.

Partners / stakeholders involved: BDMC Health care Partnerships x 2 BPA BCA NHSE VCS Acute Provider Collaboration BTHFT / ANHSFT BDCFT CPs / PCNs

ICS Private Sector Partners Existing Controls what are the key controls in place to prevent this risk occurring? Gaps in Control where are we failing to put effective controls in place and what more should be done to manage the risk  EQIA process  Long term outcomes affected by wider determinants of health,  Serious Incident review process demographic and societal issues i.e. housing, debt, air quality  Patient experience process  System Quality Assurance framework Page | 15

120 Strategic Risk Log – 3.2 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Strategic Objective 3: Working collaboratively, we will develop and deliver targeted Risk Lead: Risk Lead: Michelle Turner, strategic director of quality and programmes to address the gaps in the quality and outcomes of our health and social nursing care. We will reduce unwarranted variations in the quality and care provided for our Risk Owner: Gill Paxton, associate director of quality and nursing patients and residents. We will improve outcomes and experience for our patients and (supported by John Hartley, Head of Patient Outcomes) residents. Specific outcome: Risk There is a risk that our efforts may not have the impact we desire due to rating some determinants of quality and outcomes which lie outside of the control  Through our partnerships, reduce the variation in people’s experience of the care and quality 12 of health and social care resulting in a failure to close care gap (Quality improvement / assurance)  A more direct influence on system wide quality, performance, and outcomes through  System agreement on prioritisation of resources to address safety issues joint working; SPA, SF&PC, SQC etc. specific funding allocated to reduce  Lack of sight of the proportion of EU nationals registered within BdC with / inequalities through i.e. RIC without settled status and the impact on their right to access NHS services  Act as One system programmes and WYH ten ambitions beyond June 2021  Further clinical engagement with primary care via the Clinical Forum  Corporate and COVID risk registers  West Yorkshire Quality Surveillance Group (includes regulators)  CCG Finance and Performance Committee and Quality Committee  BdC system Finance and Performance Committee and system Quality Committee  CCG Plans to close gap signed off by Governing Bodies  Assurance of plans by NHS England / NHS Improvement  Work at a Locality and Community Partnership level with partner organisations to understand and look to meet more specific local need  Focus on Population Health through specific group within the commissioning function (PHW Hub)  Programmes jointly undertaken with Public Health to improve wider determinants of health Controls Action Plan what actions are being taken to address gaps in Implementation Progress to date control date 1. No existing agreed action plan is in place; however we anticipate Ongoing CCGs continue to explore how best to close the care quality gap through that a combination of sector action and response to improve the system partnership plans overseen by local partnership arrangements, Clinical health, well-being, social determinants/living standards and Forum, Exec Board, HWB. employability will over time impact positively to improve outcomes for the people of Bradford and Airedale localities. 2. System QA framework for agreement by System Quality February 2021 QA Framework on Agenda for Feb 2021 meeting Committee Feb 2021 and then to be rolled out incrementally

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121 Strategic Risk Log – 3.2 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Strategic Objective 3: Working collaboratively, we will develop and deliver targeted Risk Lead: Risk Lead: Michelle Turner, strategic director of quality and programmes to address the gaps in the quality and outcomes of our health and social nursing care. We will reduce unwarranted variations in the quality and care provided for our Risk Owner: Gill Paxton, associate director of quality and nursing patients and residents. We will improve outcomes and experience for our patients and (supported by John Hartley, Head of Patient Outcomes) residents. Specific outcome: Risk There is a risk that our efforts may not have the impact we desire due to rating some determinants of quality and outcomes which lie outside of the control  Through our partnerships, reduce the variation in people’s experience of the care and quality 12 of health and social care resulting in a failure to close care gap (Quality improvement / assurance) 3. System agreement on prioritisation of resources to address Ongoing / May System Planning Forum and System Strategy Group work focus on joined up safety issues through planning and prioritisation processes and 2021 planning processes and a consistent approach to prioritising the use of governance protocols supported by system partners i.e. Planning resource to maximise returns around funding, quality of service provision, and Forum. F&PC, SQC, System Strategy Group improved outcomes for the population Assurance Mechanisms where / how do we get assurance that the existing controls are Assurance Details specific evidence of positive or negative assurances working effectively Internal: Link to NHS System Oversight Framework 2019/20 Q4: although there have  Monthly reporting to SLT and to CCG Quality Comm. and System Quality Comm. been marked improvements, the three predecessor CCGs  Quality report to Governing Body (bi-monthly)  145a: Expenditure in areas with identified scope for improvement: all three  Monthly Primary Care contract assurance and contract management groups (CAG & CCGs ranked amongst the worst in England PCCC)  109a: Reducing the rate of low priority prescribing: AMBER for BDs, and  Risk Register to include ongoing risk regarding quality of service provision – GREEN for AWC and BC reviewed as part of the risk cycle  121abc: Provision of high quality care ranking Q3 2019/20: AWC BC BDs External: Hospital middle lowest middle  Regulators (CQC, NHSE/I, OFSTED, MHRA and HSE etc) Primary care highest middle middle  Safeguarding Boards Adult social care middle lowest middle  Overview and Scrutiny Committee  132a: Evidence that sepsis awareness raising amongst healthcare professionals has been prioritised by the CCG green star for all three CCGs Gaps in Assurance & Action Plan where are we failing to gain evidence Implementation Progress to date that our controls are effective and how can we address this? date The CCG Programme Office and the Deputy Director of Performance are Reporting and assurance arrangements to be developed in Ongoing – to developing a common reporting framework to provide assurance, which will partnership with stakeholder organisations to ensure that the health review February include progess against outcomes. of the population is adequately measured / March 2021 Approach to Quality assurance and reporting of quality of service provision under review via the System Quality Committee

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122 Strategic Risk Log – 3.2 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Strategic Objective 3: Working collaboratively, we will develop and deliver targeted Risk Lead: Risk Lead: Michelle Turner, strategic director of quality and programmes to address the gaps in the quality and outcomes of our health and social nursing care. We will reduce unwarranted variations in the quality and care provided for our Risk Owner: Gill Paxton, associate director of quality and nursing patients and residents. We will improve outcomes and experience for our patients and (supported by John Hartley, Head of Patient Outcomes) residents. Specific outcome: Risk There is a risk that our efforts may not have the impact we desire due to rating some determinants of quality and outcomes which lie outside of the control  Through our partnerships, reduce the variation in people’s experience of the care and quality 12 of health and social care resulting in a failure to close care gap (Quality improvement / assurance) Key changes since last review of 3x CCGs’ GBAF (now named CAF) Related risks on the Risk Register number, brief description, current score 1.1  Assurance provided to System Quality Committee & CCG Quality Committee.  Risk 943: COVID19 impact on care home quality (COVID RR Score 20) Challenge regarding impacts to and on quality of service provision through updates  Risk 1094: BTHFT quality and safety of maternity services (#) and deep dive analysis  System Programmes delivering against identified priorities at a local level (including Act as One programmes) which include impacts on outcomes as a result of identified deliverables  System EQIA process utilised to highlight positive and negative impact of proposed service change  SI review process utilised to highlight areas for improvement including themes and trends – monthly reporting to Quality Committee and Senior Leadership Team as appropriate  Patient experience process utilised to highlight areas of excellence and poor service quality – fed into programmes, Quality Committee and Senior Leadership Team as appropriate  System QA framework being implemented on an incremental basis to provide assurance on provider service provision- to System Q comm. Feb/March 2021  Links to Population Health Management reporting and data availability to highlight areas for improvement  Use of PC data dashboard to highlight variation in practice at PCN & Practice level

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123 Strategic risk log - Risk 4.1 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Strategic Objective 4: Working collaboratively at Bradford district and Craven place, our Risk Lead: Vicki Wallace (interim) / Nancy O’Neill, Strategic director of Act As One (AAO) way of working improves health and care services whilst ensuring the transformation and change deputy chief officer / clinical and financial sustainability of our partnership. This will include our programmes Risk Owner: Vicki Wallace & Damien Kay, associate directors of (Access to health and care; Respiratory; Diabetes; Healthy Hearts; Better births; Ageing transformation and change Well; and Children and Young People’s mental wellbeing) and enabling strategies Supported by: James Drury, Programme Director Executive Board and Mark Hindmarsh, Programme Director for Act as One There is a risk that the changes to health services models required to Specific outcomes Risk achieve clinical and financial sustainability are not acceptable to key  use population health management in areas experiencing high deprivation rating stakeholders, e.g. patients, the public or elected representatives, and  facilitate health and care to become more joined up and coordinated 9 cannot be implemented. This would result in the failure of the act as one around people approach.  reduce unwarranted variation in people’s experience of care Risk Rating Rationale for current score: (Likelihood x Impact) Due to the response to the COVID19 pandemic programmes have been scaled back and refocussed to provide support for the response locally. Initial 3 x 4 = 12 (Sept 2017) Rationale for target score (risk appetite): We seek to reduce the likelihood and impact Current risk 3 x 3 = 9 (February 2021) Partners / stakeholders involved:  All signatories to the SPA, plus general practices Target 2 x 3 = 6

Existing Controls Gaps in Control where are we failing to put effective controls in place and what more what are the key controls in place to prevent this risk occurring? should be done to manage the risk  System governance structure, with oversight via Health and Care Executive Board  Strategic Partnering Agreement in place, being refreshed to be completed includes a system Finance and Performance Committee, a system Quality by March 2021 Committee and Health and Care Partnership Boards  BdC assurance / risk management framework, to be in place from October  Strategic Partnering Agreement in place and being reviewed to reflect current ways 2021 of working  ICP Organisation Development plan, to be in place from October 2021  Act as One initiative in place with programmes (Access to health and care, Page | 19

124 Strategic risk log - Risk 4.1 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Strategic Objective 4: Working collaboratively at Bradford district and Craven place, our Risk Lead: Vicki Wallace (interim) / Nancy O’Neill, Strategic director of Act As One (AAO) way of working improves health and care services whilst ensuring the transformation and change deputy chief officer / clinical and financial sustainability of our partnership. This will include our programmes Risk Owner: Vicki Wallace & Damien Kay, associate directors of (Access to health and care; Respiratory; Diabetes; Healthy Hearts; Better births; Ageing transformation and change Well; and Children and Young People’s mental wellbeing) and enabling strategies Supported by: James Drury, Programme Director Executive Board and Mark Hindmarsh, Programme Director for Act as One There is a risk that the changes to health services models required to Specific outcomes Risk achieve clinical and financial sustainability are not acceptable to key  use population health management in areas experiencing high deprivation rating stakeholders, e.g. patients, the public or elected representatives, and  facilitate health and care to become more joined up and coordinated 9 cannot be implemented. This would result in the failure of the act as one around people approach.  reduce unwarranted variation in people’s experience of care Respiratory, Diabetes, Healthy Hearts, Better births, Ageing Well, Children and Young People’s mental wellbeing)  Years of collaboration and relationship building that has been further enhanced by COVID19 response Controls Action Plan what actions are being taken to address gaps in Implementation Progress to date control date 1. Complete SPA refresh March 2021 Refresh currently underway Initial meeting held to discuss formalising a risk and assurance framework for 2. BdC risk management framework inc AF and RRs April 2022 the BdC place 3. ICP organisation development plan April/May 2021 Update being taken to the Health and Care Exec Board 26 February 2021 Assurance Mechanisms where / how do we get assurance that the existing controls are Assurance Details specific evidence of positive or negative assurances working effectively Internal:  Slimmed down Act as One programme updates provided throughout  Monthly report on Act as One to the CCG Senior Leadership Team COVID19 pandemic with satisfactory progress towards key milestones for  Monthly System & Place (ICS and ICP) report to the CCG Senior Leadership Team the refocussed programmes.  Chief Officer's Report to Governing Body External  Whole system quarterly review with NHSE / I and WY&H ICS  Bradford Wellbeing Board monitor progress against the metrics developed by LGA  Minutes of Bradford Wellbeing Board  Attendance at Overview and Scrutiny Committees

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125 Strategic risk log - Risk 4.1 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Strategic Objective 4: Working collaboratively at Bradford district and Craven place, our Risk Lead: Vicki Wallace (interim) / Nancy O’Neill, Strategic director of Act As One (AAO) way of working improves health and care services whilst ensuring the transformation and change deputy chief officer / clinical and financial sustainability of our partnership. This will include our programmes Risk Owner: Vicki Wallace & Damien Kay, associate directors of (Access to health and care; Respiratory; Diabetes; Healthy Hearts; Better births; Ageing transformation and change Well; and Children and Young People’s mental wellbeing) and enabling strategies Supported by: James Drury, Programme Director Executive Board and Mark Hindmarsh, Programme Director for Act as One There is a risk that the changes to health services models required to Specific outcomes Risk achieve clinical and financial sustainability are not acceptable to key  use population health management in areas experiencing high deprivation rating stakeholders, e.g. patients, the public or elected representatives, and  facilitate health and care to become more joined up and coordinated 9 cannot be implemented. This would result in the failure of the act as one around people approach.  reduce unwarranted variation in people’s experience of care Gaps in Assurance & Action Plan where are we failing to gain Implementation Progress to date evidence that our controls are effective and how can we address this? date Conversations commenced with health and care partnership leaders for the 1. Address visibility of enabling strategies May 2021 most appropriate reporting route for enabling strategies Key changes since last review of 3x CCGs GBAF (now named CAF) Related risks on the Risk Register (number, brief description, current score): New risk therefore not applicable Not applicable 1.1

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126 Strategic Risk Log – Risk 5.1 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Risk Lead: Vicki Wallace (interim) / Nancy O’Neill Strategic Objective 5: Develop stronger collaborative partnerships in local places Strategic director of transformation and change deputy chief officer between the NHS, local government and others. Including a central role for primary care, Risk Owner: Vicki Wallace & Damien Kay, associate directors of collaborative provider arrangements and incorporate strategic commissioning through transformation and change systems with a focus on population health outcomes Supported by: James Drury, Programme Director Executive Board *new ICP readiness: There is a risk that we fail to gain sufficient Specific outcomes: Risk organisational traction towards Integrated Care Partnership for Bradford  use population health management in areas experiencing high deprivation rating district and Craven place, due to a range of factors. This includes:  facilitate health and care to become more joined up and coordinated 12 leadership challenges, failure to agree governance arrangements and future around people form and function, resulting in failure to achieve a viable form in time to  reduce unwarranted variation in people’s experience of care receive delegated responsibilities from the Integrated Care System Risk Rating Rationale for current score:. (Likelihood x Impact)  New risk, initial risk rating and target risk provided

Initial 4 x 3 = 12 Rationale for target score (risk appetite): (February 2021)  We seek to reduce the likelihood and impact

Target 3 x 2 = 6 Partners / stakeholders involved:  All signatories to the SPA, plus general practices

Existing Controls what are the key controls in place to prevent this risk occurring? Gaps in Control where are we failing to put effective controls in place and what more should be done to manage the risk  System governance structure, with oversight via Health and Care Executive Board  WY&H ICS are developing an ICP Development Framework (led by Helen includes a system Finance and Performance Committee, a system Quality Hirst) - first draft due April 2021 - to be implemented at each of the five Committee and Health and Care Partnership Boards places that make up WY ICS  Strategic Partnering Agreement in place and being reviewed to reflect current ways  HM Gov white paper outlines the proposals to legislative changes affording of working the statutory basis to form ICS and ICPs, however the detail isn’t yet clear  Act as One initiative in place with programmes (Access to health and care,  Strategic Partnering Agreement in place, being refreshed to be completed Page | 22

127 Strategic Risk Log – Risk 5.1 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Risk Lead: Vicki Wallace (interim) / Nancy O’Neill Strategic Objective 5: Develop stronger collaborative partnerships in local places Strategic director of transformation and change deputy chief officer between the NHS, local government and others. Including a central role for primary care, Risk Owner: Vicki Wallace & Damien Kay, associate directors of collaborative provider arrangements and incorporate strategic commissioning through transformation and change systems with a focus on population health outcomes Supported by: James Drury, Programme Director Executive Board *new ICP readiness: There is a risk that we fail to gain sufficient Specific outcomes: Risk organisational traction towards Integrated Care Partnership for Bradford  use population health management in areas experiencing high deprivation rating district and Craven place, due to a range of factors. This includes:  facilitate health and care to become more joined up and coordinated 12 leadership challenges, failure to agree governance arrangements and future around people form and function, resulting in failure to achieve a viable form in time to  reduce unwarranted variation in people’s experience of care receive delegated responsibilities from the Integrated Care System Respiratory, Diabetes, Healthy Hearts, Better births, Ageing Well, Children and by March 2021 Young People’s mental wellbeing)  ICP assurance / risk management framework - to be developed by  Years of collaboration and relationship building that has been further enhanced by October 2021 COVID19 response  ICP Organisation Development plan - in development by October 2021  Detailed transition programme and organisational/way of working approach is yet to be defined/refreshed in-line with white paper Controls Action Plan what actions are being taken to address gaps in Implementation Progress to date control date 1. ICP development framework - Led by Helen Hirst for WYH ICS April 2021 Draft to be taken WY ICS for sign-off

2. Transition to ICS/P team to be established in response to the Initial discussions regarding establishing the group are underway, recognising legislation (system group to support the creation and readiness of April 2021 that there is a need to work with wider system partners the ICP)

3. Complete SPA refresh March 2021 Refresh currently underway

4. BdC risk management framework inc AF and RRs Initial meeting held to discuss formalising a risk and assurance framework for April 2022 the BdC place

5. ICP organisation development plan April/May 2021 Update being taken to the Health and Care Exec Board 26 February 2021

6. Lack detail on the organisational form at WY and BdC and on System leaders have commenced conversations at both BdC and WYH June 2021 readiness criteria to start, however deadline is to be ready Apr 22 footprints

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128 Strategic Risk Log – Risk 5.1 our Partnerships as the vehicle for enabling people to take more responsibility for their health and self care Risk Lead: Vicki Wallace (interim) / Nancy O’Neill Strategic Objective 5: Develop stronger collaborative partnerships in local places Strategic director of transformation and change deputy chief officer between the NHS, local government and others. Including a central role for primary care, Risk Owner: Vicki Wallace & Damien Kay, associate directors of collaborative provider arrangements and incorporate strategic commissioning through transformation and change systems with a focus on population health outcomes Supported by: James Drury, Programme Director Executive Board *new ICP readiness: There is a risk that we fail to gain sufficient Specific outcomes: Risk organisational traction towards Integrated Care Partnership for Bradford  use population health management in areas experiencing high deprivation rating district and Craven place, due to a range of factors. This includes:  facilitate health and care to become more joined up and coordinated 12 leadership challenges, failure to agree governance arrangements and future around people form and function, resulting in failure to achieve a viable form in time to  reduce unwarranted variation in people’s experience of care receive delegated responsibilities from the Integrated Care System Assurance Mechanisms Assurance Details where / how do we get assurance that the existing controls are working effectively specific evidence of positive or negative assurances Internal:  Links to NHS System Oversight Framework, including quarterly whole  BD&C Strategic Partnering Agreement system review meetings held with the Health and Care Executive Board  Section 75 agreement members chaired by Rob Webster and WYH ICS and with regional NHSEI  Engagement with NHS, LA and VCS partners representatives  Governance structure including Wellbeing Boards, Health and Care Executive  Checks and balances at system not currently built in part of the Board, System Finance and Performance Committee, System Quality Committee Governance (system committee structures) and Health and Care Partnership Boards  Monthly System & Place (ICS and ICP) report to the CCG Senior Leadership Team  Chief Officer's Report to Governing Body External  System Oversight including quarterly Whole System Review Meetings held at place with NHSEI and WYH ICS with partners across BdC  Bradford Wellbeing Board monitor progress against the metrics developed by LGA  Minutes of Bradford Wellbeing Board  Attendance at Overview and Scrutiny Committees Gaps in Assurance & Action Plan (where are we failing to gain evidence Implementation Progress to date that our controls are effective and how can we address this?) date 1. No equivalent system wide (at BdC) audit and governance TBC Initial conversations held with Bryan Millar around the potential role and Committee functioning of the current CCG Audit and Governance Committee Key changes since last review of 3x CCGs GBAF Related risks on the Risk Register (number, brief description, current score): New risk therefore not applicable Not applicable 1.1

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129 Strategic Risk Log – Risk 6.1 our People a skilled, motivated workforce with a culture of continuous improvement Strategic Objective 6: We will continue to review and develop our internal resources, Risk lead: Liz Allen, strategic director of organisation effectiveness structures and processes to ensure that we are able to achieve our strategic objectives Risk owner: Fiona Jeffrey, associate director of organisation effectiveness as our commissioning functions transfer and, thereby, our CCG staff transition to new Integrated Care System (ICS) and Integrated Care Partnership (ICP) arrangements. There is a risk of CCG staff struggling to adapt to revised system- and Specific outcomes: Risk partnership-focussed roles as we move towards the new ICS and ICP  develop our inclusion and diversity as a team to better reflect and rating operating model by 1 April 2022 due to the need for different organisational understand our communities 12 forms and individual CCG staff role flexibility and the normal factors  improve our skills and knowledge to increase our personal value associated with change, exacerbated by the impact of the Covid pandemic  be responsible, holding ourselves and each other to account upon ways of working, resulting in failure to successfully transition our CCG staff. Risk Rating Rationale for current score: Score increased since January 2020 due to the (Likelihood x impact on ways of working (due to Covid) and legislative changes that will Impact) result in the transfer of commissioning functions to the ICS and/or ICP.

Initial 3 x 4 = 12 Rationale for target score (risk appetite): (Sept 2017) As the impact of legislative change is clarified, and our plans to support staff are further developed, we aim to reduce the likelihood of staff not adapting to Current 3 x 4 =12 the transition. (Feb 2021) Partners / stakeholders involved: Target 2 x4 = 8  West Yorkshire ICS and Bradford district and Craven ICP stakeholders  CCG managers and clinical leads  CCG staff (including staff networks)

Existing controls Gaps in control where are we failing to put effective controls in place and what more what are the key controls in place to prevent this risk occurring? should be done to manage the risk  CCG People Plan agreed by SLT and in place  CCG People Plan - action plan needs to be finalised  Commissioning workforce development framework – our learning and development  Workforce development framework still to be launched (L&D) plan – aligns with our CCG People Plan and the NHS People Plan and was  Workforce development action plan needs to expand offer of blended informed by a skills preference audit undertaken in summer 2020 learning and development opportunities for all staff  Workforce development group in place  Requirement to develop common process for L&D applications including  Bitesize learning and development offers return for self, team, hub, organisation  Human resources (HR) and L&D contract in place with BDCFT extended to 31  Need to revise HR and L&D service specification to address priorities for March 2022 (end of transition period) the transition period Page | 25

130 Strategic Risk Log – Risk 6.1 our People a skilled, motivated workforce with a culture of continuous improvement Strategic Objective 6: We will continue to review and develop our internal resources, Risk lead: Liz Allen, strategic director of organisation effectiveness structures and processes to ensure that we are able to achieve our strategic objectives Risk owner: Fiona Jeffrey, associate director of organisation effectiveness as our commissioning functions transfer and, thereby, our CCG staff transition to new Integrated Care System (ICS) and Integrated Care Partnership (ICP) arrangements. There is a risk of CCG staff struggling to adapt to revised system- and Specific outcomes: Risk partnership-focussed roles as we move towards the new ICS and ICP  develop our inclusion and diversity as a team to better reflect and rating operating model by 1 April 2022 due to the need for different organisational understand our communities 12 forms and individual CCG staff role flexibility and the normal factors  improve our skills and knowledge to increase our personal value associated with change, exacerbated by the impact of the Covid pandemic  be responsible, holding ourselves and each other to account upon ways of working, resulting in failure to successfully transition our CCG staff.  Documentation and guidance provided to line managers and staff to support  Provision of equality, diversity and inclusion (EDI) specialist support still to effective annual appraisals, mid-year reviews and regular one-to-one conversations be confirmed following the retirement of the current post-holder at end of (including personal and career development, flexible working and wellbeing) Feb 2021  Support for on-line access to training is available  Engagement sessions (mandatory for all managers) focussed on  Workforce Race Equality Standard (WRES) action plan agreed by SLT and in place new/revised recruitment, selection and promotion policy, flexible working  Black, Asian and minority ethnic (BAME) and WellbeingandAble (WAA) staff procedures and home-based working policy needed to ensure fair and networks in place, representatives attending SLT, bringing items on a monthly basis. consistent implementation and using case studies from staff’s lived Both networks have governing body, strategic clinical director and associate director experience sponsors.  Leads for each section of workforce equality plan need to be confirmed  Workforce equality plan (developed by the BAME and WAA staff networks) agreed  Mapping and audit of total wellbeing offer to staff – including gap analysis – by SLT and in place required  New recruitment, selection and promotion policy developed in conjunction with BAME staff network, including a strengthened recruitment checklist mandated for use in all relevant processes  Member of BAME network to be involved throughout recruitment processes for senior (band 8a and above) posts, and other posts (where their capacity allows)  CCG staff taking part in the West Yorkshire ICS BAME fellowship as mentors and mentees  Wellbeing task and finish group formed with input from range of staff including network representatives Controls action plan Implementation Progress to date what actions are being taken to address gaps in control? date 1. CCG People Plan - action plan due to be finalised March 2021 Plans in place for update meeting March 2021 2. Workforce development framework to be launched at staff 23 February Plans in place for staff engagement event February 2021 engagement event 2021 3. Workforce development action plan to expand offer of blended Working with BDCFT colleagues to expand L&D offers April 2021 learning and development opportunities for all staff Page | 26

131 Strategic Risk Log – Risk 6.1 our People a skilled, motivated workforce with a culture of continuous improvement Strategic Objective 6: We will continue to review and develop our internal resources, Risk lead: Liz Allen, strategic director of organisation effectiveness structures and processes to ensure that we are able to achieve our strategic objectives Risk owner: Fiona Jeffrey, associate director of organisation effectiveness as our commissioning functions transfer and, thereby, our CCG staff transition to new Integrated Care System (ICS) and Integrated Care Partnership (ICP) arrangements. There is a risk of CCG staff struggling to adapt to revised system- and Specific outcomes: Risk partnership-focussed roles as we move towards the new ICS and ICP  develop our inclusion and diversity as a team to better reflect and rating operating model by 1 April 2022 due to the need for different organisational understand our communities 12 forms and individual CCG staff role flexibility and the normal factors  improve our skills and knowledge to increase our personal value associated with change, exacerbated by the impact of the Covid pandemic  be responsible, holding ourselves and each other to account upon ways of working, resulting in failure to successfully transition our CCG staff. 4. Develop common process for L&D applications including return Draft process being considered and revised February 2021 for self, team, hub, organisation 5. Revise HR and L&D service specification to address priorities for Service specification and key performance indicators are being reviewed April 2021 the transition period 6. Discussion required with ICP partners to consider provision of Meeting arranged with ICP partners March 2021 equality, diversity and inclusion specialist support 7. Mandatory manager engagement sessions concerning March/April Content of engagement sessions being developed using case studies from new/revised HR policies and procedures to be rolled out 2021 lived experience of staff (informed by BAME and WAA staff networks) 8. Allocation of leads for workforce equality plans being finalised March 2021 Most leads now allocated, still some elements to confirm 9. Mapping and audit of total wellbeing offer to staff required April 2021 Mapping and audit to be included in remit of wellbeing task and finish group Assurance mechanisms Assurance details where / how do we get assurance that the existing controls are working effectively? specific evidence of positive or negative assurances Internal  Senior leadership team (SLT) and associate leadership team (ALT) members NHS staff survey results are still largely positive provide management, leadership and direction within and across the hubs and share issues, concerns, successes in CCG business and/or development meetings  Workforce development group action plan reviewing progress at 3,6 and 12 months  1:1 calls between staff and managers  Development review meetings  Workforce reporting to ALT including HR metrics  Annual workforce report to Governing Body  Reporting against WRES action plan to ALT  EDI reporting in the CCG annual report  Feedback from staff networks to extended SLT (includes ALT members) External  National NHS staff survey  WRES national comparators Page | 27

132 Strategic Risk Log – Risk 6.1 our People a skilled, motivated workforce with a culture of continuous improvement Strategic Objective 6: We will continue to review and develop our internal resources, Risk lead: Liz Allen, strategic director of organisation effectiveness structures and processes to ensure that we are able to achieve our strategic objectives Risk owner: Fiona Jeffrey, associate director of organisation effectiveness as our commissioning functions transfer and, thereby, our CCG staff transition to new Integrated Care System (ICS) and Integrated Care Partnership (ICP) arrangements. There is a risk of CCG staff struggling to adapt to revised system- and Specific outcomes: Risk partnership-focussed roles as we move towards the new ICS and ICP  develop our inclusion and diversity as a team to better reflect and rating operating model by 1 April 2022 due to the need for different organisational understand our communities 12 forms and individual CCG staff role flexibility and the normal factors  improve our skills and knowledge to increase our personal value associated with change, exacerbated by the impact of the Covid pandemic  be responsible, holding ourselves and each other to account upon ways of working, resulting in failure to successfully transition our CCG staff. Gaps in assurance and action plan where are we failing to gain Implementation Progress to date evidence that our controls are effective and how can we address this? date 1. Actions required in response to any negative NHS staff survey NHS staff survey results received February but embargoed until March 2021 April 2021 results Key changes since last review of 3xCCGs’ GBAF (now re-named CAF) Related risks on the Risk Register number, brief description, current score 1.1 Workforce plans following the establishment in April 2020 of the new Bradford District Risk 1587 (Covid risk log): There is a risk to staff wellbeing, morale and and Craven CCG did not have the opportunity to develop and embed before the impact motivation due to the pandemic and related working environment, i.e. physical of the COVID pandemic. The announcement of new legislation that will abolish CCGs isolation from colleagues, childcare issues, working in home space, etc. The has provided an additional layer of uncertainty. It will be important to support the impact is personal impact on staff and organisational impact in terms of wellbeing and resilience of our CCG staff throughout the transition period to April 2022. performance. (12)

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133 Strategic Risk Log – 7.1 our Leadership assuring the sustainability of our health and care system Strategic Objective 7: Working at Bradford district and Craven place, we will maximise Risk Lead: Robert Maden, Chief Finance Officer value for money in the use of healthcare services to ensure we can make shared Risk Owner: Diane Lawlor, Strategic Head of Finance for corporate reporting decisions on how to use our resources to improve population health. and financial control and Amy Paffett, Strategic Head of Finance for planning and transformation Risk There is a risk that we do not address the underlying financial deficit and Specific outcome: rating establish a financially sustainable position over the medium term as we exit  make shared decisions on how to use our resources to improve population 16 the pandemic health Risk Rating Rationale for current score: (Likelihood x The financial regime around the pandemic has limited the CCG’s ability to Impact) improve the underlying financial deficient in 2020/21. Still need to understand the longer term impacts of COVID on services and also how the system will Initial 4 x 4 = 16 address the backlog of activity created. (Sept 2017) Rationale for target score (risk appetite): Current 4 x 4 =16 The impact of not closing the financial gap will always remain high but we want (Feb 2021) to lower the likelihood

Target 2 x4 = 8 Partners / stakeholders involved: Health and Care Partnership stakeholders Demand needs to be owned by all stakeholders in the footprint NHS England

Existing Controls Gaps in Control where are we failing to put effective controls in place and what more what are the key controls in place to prevent this risk occurring? should be done to manage the risk  Joint planning process established across the Bradford place  Waste reduction / savings programme not in place due to diversion of  Business case process to support shared decision making on the use of resources resources to support the pandemic  Expenditure controls in place to limit new expenditure commitments  Prioritisation framework to support the use of resources to be finalised  System transformation programmes established to support demand management  Uncertainty over financial resources available in 2021/22  Bradford Place financial risk share arrangements  Lack of understanding over local Place based approvals processes  System Finance & Performance Committee established  Fixed income contracts with main local providers implemented from 2019/20.  Demand management initiatives (e.g. GP streaming, pathway adherence, evidence based interventions, etc.) Page | 29

134 Strategic Risk Log – 7.1 our Leadership assuring the sustainability of our health and care system Strategic Objective 7: Working at Bradford district and Craven place, we will maximise Risk Lead: Robert Maden, Chief Finance Officer value for money in the use of healthcare services to ensure we can make shared Risk Owner: Diane Lawlor, Strategic Head of Finance for corporate reporting decisions on how to use our resources to improve population health. and financial control and Amy Paffett, Strategic Head of Finance for planning and transformation Risk There is a risk that we do not address the underlying financial deficit and Specific outcome: rating establish a financially sustainable position over the medium term as we exit  make shared decisions on how to use our resources to improve population 16 the pandemic health Controls Action Plan (what actions are being taken to address gaps in Implementation Progress to date control) date 1. Establish underlying financial position and 2020/21 exit ICS level run-rate template has been issued to identify the underlying financial expenditure runs rates to inform resource requirement for Q1 position. This is due to be completed at the beginning of March. March 2021 2021/22

2. Model expenditure forecasts for Q2 to Q4 2021/22 based on 2 scenarios;  return to business as usual trajectories April 2021  the capacity and resource required to address the backlog of activity

3. Utilise prioritisation framework to clarify investment priorities and Prioritisation framework is currently being designed. Expect a draft version to cost pressures for inclusion in the 21/22 plan be shared at next QIPP working group meeting in March. May 21 One system list being collated around all known cost pressures and requests

for investment to ensure a systematic approach to prioritisation. To be presented to March System Finance and Performance Deputies meeting. 4. Scope efficiency opportunities and expected implementation Re-establishment of QIPP working group meeting including representatives timescales in light of impact of the pandemic; June 2021 from System Transformation Programme. Remit of meeting to be agreed but expectation is that this will oversee the efficiency programme of work. 5. Confirm local Place based approvals processes Status

6. Target dates for the above to be confirmed after a place-wide discussion

status

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135 Strategic Risk Log – 7.1 our Leadership assuring the sustainability of our health and care system Strategic Objective 7: Working at Bradford district and Craven place, we will maximise Risk Lead: Robert Maden, Chief Finance Officer value for money in the use of healthcare services to ensure we can make shared Risk Owner: Diane Lawlor, Strategic Head of Finance for corporate reporting decisions on how to use our resources to improve population health. and financial control and Amy Paffett, Strategic Head of Finance for planning and transformation Risk There is a risk that we do not address the underlying financial deficit and Specific outcome: rating establish a financially sustainable position over the medium term as we exit  make shared decisions on how to use our resources to improve population 16 the pandemic health Assurance Mechanisms (where / how do we get assurance that the existing controls are Assurance Details (specific evidence of positive or negative assurances) working effectively) Internal  Link to NHS Oversight Framework indicator 141a (in-year financial  Involvement of SLT and Governing Body members in development of plans performance) Q4 19/20 – BC rated AMBER, with AWC and BDs rated RED  Sign-off of plans by F&P Committee and Governing Body  Monthly non-ISFE submission to NHSE on year to date and forecast  Monthly financial reporting to SLT, CCG F&P, System F&P and Bradford Place financial position Forums and Health and Care Executive Board  Annual accounts submission  Reporting to Finance and Performance Committee, SLT, Governing Body  External audit opinion External  Financial Plan sign off by NHSE&I  Collaborative agreement of plans by the WY&H ICS  Reporting to System Finance & Performance Committee, Health and Care Partnership Boards and West Yorkshire & Harrogate ICS  Role of NHS England/Improvement as regulators  Act as One system programme boards and WYH ICS 10 ambitions Gaps in Assurance & Action Plan (where are we failing to gain Implementation Progress to date evidence that our controls are effective and how can we address this?) date No gaps in assurance currently. Not applicable Not applicable Key changes since last review of 3x CCGs’ GBAF (now named CAF) Related risks on the Risk Register number, brief description, current score 1.1  Development of system-wide savings schemes. Not applicable  Nationally mandated block contracts with Trusts and the removal of non-contracted activity charges  Development of system wide prioritisation matrix for investments

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136 Strategic Risk Log – Risk 7.2 our Leadership assuring the sustainability of our health and care system Strategic Objective 7: Working at Bradford district and Craven place, we will maximise Risk Lead: Robert Maden, Chief Finance Officer value for money in the use of healthcare services to ensure we can make shared Risk Owner: Diane Lawlor, Strategic Head of Finance for corporate reporting decisions on how to use our resources to improve population health. and financial control and Amy Paffett, Strategic Head of Finance for planning and transformation Risk Recommend close (superceded by 7.1): There is a risk that the two Specific outcome: Rating Health and Care Partnerships are not financially sustainable due to the  make shared decisions on how to use our resources to improve population 16 system financial gap not being closed resulting in action from the regulators health Risk Rating Rationale for current score: the financial regime around the pandemic has (Likelihood x limited the CCG’s ability to improve the underlying financial deficit in 20/21. Still Impact) need to understand the longer term impacts of COVID on services and also how the system will address the backlog of activity created. Initial 4 x 4 = 16 (Sept 2017) Rationale for target score (risk appetite): The impact of not closing the financial gap will always remain high but we want Current 4 x 4 =16 to lower the likelihood (Feb 2021) Partners / stakeholders involved: Target 2 x 4 = 8 Health and Care Partnership stakeholders Demand needs to be owned by all stakeholders in the footprint NHS England

Existing Controls what are the key controls in place to prevent this risk occurring? Gaps in Control where are we failing to put effective controls in place and what more should be done to manage the risk  Health and Wellbeing plan includes a financial plan  Fully developed system recovery plan  Local financial plan is part of the WY financial plans  Operational plans for 20/21.  Programme boards/work-streams exist under both health and care partnerships board governance structures tasked with improving quality and making our system sustainable  Monthly meeting of local DOFs/CFOs  Participating in the WY finance group  System Finance & Performance Committee established. Controls Action Plan (what actions are being taken to address gaps in Implementation Progress to date control) date 1. Prioritising resources for key Planned Care and Urgent & Ongoing Page | 32

137 Strategic Risk Log – Risk 7.2 our Leadership assuring the sustainability of our health and care system Strategic Objective 7: Working at Bradford district and Craven place, we will maximise Risk Lead: Robert Maden, Chief Finance Officer value for money in the use of healthcare services to ensure we can make shared Risk Owner: Diane Lawlor, Strategic Head of Finance for corporate reporting decisions on how to use our resources to improve population health. and financial control and Amy Paffett, Strategic Head of Finance for planning and transformation Risk Recommend close (superceded by 7.1): There is a risk that the two Specific outcome: Rating Health and Care Partnerships are not financially sustainable due to the  make shared decisions on how to use our resources to improve population 16 system financial gap not being closed resulting in action from the regulators health Emergency Care initiatives in order to manage demand. 2. Reviewing potential savings opportunities via external Ongoing support (such as NHS Futures Platform). 3. Contract agreement and detailed budget setting for 2020/21. March 2020 Assurance Mechanisms where / how do we get assurance that the existing controls are Assurance Details specific evidence of positive or negative assurances working effectively Internal  System Finance Report presented to System Finance and Performance  Monthly financial reporting to SLT, CCG F&P, System F&P and Bradford Place Committee and shared with Health and Care Partnership Boards Forums and Health and Care Executive Board  West Yorkshire ICS Financial position shared  Reporting to Finance and Performance Committee, SLT, Governing Body

External  Financial Plan sign off by NHSE&I  Collaborative agreement of plans by the WY&H ICS  Reporting to System Finance & Performance Committee, Health and Care Partnership Boards and West Yorkshire & Harrogate ICS  Role of NHS England/Improvement as regulators  Act as One system programme boards and WYH ICS 10 ambitions Gaps in Assurance & Action Plan (where are we failing to gain evidence Implementation Progress to date that our controls are effective and how can we address this?) date No gaps in assurance currently. Not applicable Key changes since last review of 3x CCGs’ GBAF (now named CAF) Related risks on the Risk Register number, brief description, current score 1.1  Nationally mandated block contracts with Trusts and the removal of non-contracted Risk 930: BI service issues and ability to analyse data (12) activity charges Risk 931: Mental health data access issues (9) Risk 934: New care models data access issues (12)  Development of system wide prioritisation matrix for investments Risk 963: Estates Strategy risk (9) Risk 1098: Poor performance against constitutional standards (9)

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138 Agenda item 13

Name of meeting Governing Body Meeting date 9 March 2021 Review of Policies:  Policy on Receipt of Gifts, Sue Baxter, Strategic Title of report Hospitality & Sponsorship Report author(s) Head of Assurance  Conflicts of Interest & Business Conduct Policy Sue Baxter, Strategic Lead(s) / SRO Helen Hirst, Chief Officer Report lead(s) Head of Assurance

Paper summary and/or key discussion points The Policy on Receipt of Gifts, Hospitality & Sponsorship and the Conflicts of Interest & Business Conduct Policy were reviewed by the Audit & Governance Committee on 1 March 2021. The key proposed amendments are as follows:

Policy on Receipt of Gifts, Hospitality & Sponsorship  Amendment to new CCG and accessibility standards compliance, approved by the Audit & Governance Committee Conflicts of Interest & Business Conduct Policy  Changes for the new CCG and accessibility standards compliance  Version submitted to Governing Body for approval Outline how this will help us to achieve our vision through our strategic ambitions:  Our population – improving health and equity for local people, and/or  Our partnerships – as the vehicle for enabling people to take more responsibility for their health, and/or  Our people – a skilled, motivated workforce with a culture of continuous improvement, and/or  Our leadership – assuring sustainability of our health and care system.

Our leadership - A robust approach to corporate governance is essential to supporting the delivery of the CCG strategy. These policies are required by statutory guidance and support the CCG’s approach to conflicts of interest management and the robustness of our decision making processes.

Purpose assurance information decision action

approve / recommend / review / consider / support / ratify comment / discuss Recommendation(s)

Following the recommendation of the Audit & Governance Committee, the Governing Body is asked to review and approve the updates to the following policies:  Note the approval by the Audit & Governance Committee of the Policy on Receipt of Gifts, Hospitality & Sponsorship  Approve the Conflicts of Interest & Business Conduct Policy

Appendices (or other supporting papers)  Policy on Receipt of Gifts, Hospitality & Sponsorship  Conflicts of Interest & Business Conduct Policy Page 1 of 1 139

POLICY ON OFFER OR RECEIPT OF GIFTS, HOSPITALITY and SPONSORSHIP

NHS Bradford District and Craven Clinical Commissioning Group (CCG) must demonstrate that it has open and transparent decision making processes which are not influenced by inducements of inappropriate offers of gifts, hospitality or sponsorship.

Key information

Responsible director: Helen Hirst – Chief Officer

Author: Sarah Dick – head of governance

Approval body: Audit and Governance Committee

Date approved:

Version: V4.1

Review date: 1 April 2023

140

Version control

Version Date Author Description Circulation no. 0.1 MAY 2017 Sarah Based on the AWC CCG policy SMT Dick/Phil amended in light of the Garnett collaborative governance structure of the three CCGs working together 0.2 June 2017 Sarah Updated as per SMT comments Audit and Dick/Phil Governance Garnett Committees 1.0 June 2017 Sarah Approved by 12th June Audit & Limited Dick/Phil Governance Committees circulation Garnett whilst revised CCG guidance awaited 1.1 August Sarah Dick Minor revisions following issue of Governing 2017 revised CCG guidance – Bodies for clarification that requirements approval related to CCG members only in relation to their connection with the CCG (and not more widely). 2.0 Sept 2017 Sarah Dick Version approved by Governing CCG wide and Bodies website 2.1 Dec 2018 Sarah Dick Scheduled review – amendment A&G to Declaration Form (Appendix Committee A) in light of GDPR requirements members (by email), Chief Officer 2.2 Feb 2019 Sarah Dick Clarification of the applicability of Audit & the policy to CCG members (see Governance Scope and Section 6. Update of Committees training section. Addition of Appendix B. Revision of approving body to Governing Bodies (so this policy is considered in conjunction with the CoI and Standards of Business Conduct Policy). 2.3 April 2019 Sarah Dick Amendment to Appendix A and Governing Section 6 to clarify timescales for Bodies declaration as per audit recommendation 3.0 May 2019 Sarah Dick Approved by Governing Bodies CCG wide and website 4.0 March Sarah Dick Amendment to new CCG and Audit & 2021 accessibility standard, approved Governance by the Audit & Governance Committee 1 Committee March 4.1 March Sarah Dick Provided for information to 9 Governing 2021 March 2021 Governing Body Body, CCG wide and website

141 Contents

Key information ...... 1

Version control ...... 2

1 Introduction ...... 5

2 Scope of the policy ...... 5

3 Associated documentation ...... 5

4 Policy statement...... 5

5 Aims and objectives ...... 6

5.1 Accountability: ...... 6

5.2 Probity: ...... 6

5.3 Transparency: ...... 6

6 Definitions / explanation of terms ...... 6

6.1 The definition of ‘Gifts’ is ...... 6

6.2 The definition of ‘Hospitality’ is: ...... 6

6.3 The definition of ‘Sponsorship’ is: ...... 6

7 Duties, accountabilities, roles and responsibilities ...... 7

7.1 Audit and Governance Committee ...... 7

7.2 The CCG’s conflicts of interest guardian ...... 7

7.3 Chief officer (accountable officer) ...... 7

7.4 CCG chairs ...... 7

7.5 Line managers ...... 7

7.6 Head of governance ...... 8

7.7 Governance and Corporate Managers ...... 8

7.8 All Individuals ...... 8

8 Policy and procedure details ...... 8

8.1 Gifts ...... 8

8.2 Hospitality ...... 9

8.3 Hospitality ...... 9

8.4 Sponsorship...... 9

9 Dissemination, implementation and training ...... 10

10 Review and monitoring ...... 11

11 Public sector equality duty ...... 11

142 12 References ...... 12

13 Appendices ...... 12

APPENDIX A: Declaration of Gifts, Hospitality & Sponsorship Form ...... 13

APPENDIX B New Starter Policy Declaration Form ...... 16

143 1 Introduction

The purpose of this policy is to set out the standards and procedures which must be followed in respect of gifts, hospitality and sponsorship. It is intended to help individuals understand their responsibilities in protecting themselves and the CCG or their GP practice against any suggestion of inappropriate behaviour.

The Bribery Act 2010 revised the legal framework to combat bribery in the public and private sectors. It makes it an offence to receive a financial or other advantage as a reward for an improper act such as the award of a contract. A gifts, hospitality and sponsorship policy is a key tool for organisation to demonstrate they have arrangements in place to discourage the offer or acceptance of such rewards.

2 Scope of the policy

This policy applies to:

 the CCG’s employees and individuals working for the CCG under a contract for services  members of the governing body and their committee and sub-committees, members of the executive and members of the CCG’s other committees and sub- committees (excluding CCG council)  the CCG’s members: GP partners (or directors where the practice is a company) and any other practice staff involved with the CCG.

3 Associated documentation

The policy should be read in conjunction with the following documents:

 the CCG’s standing orders and prime financial policies  the CCG’s policy on business conduct and management of conflicts of interest  the CCG’s anti-bribery, fraud and corruption policy  the CCG’s whistleblowing and raising concerns policy  the CCG’s disciplinary policy and procedure  the CCG’s policy on joint working with the pharmaceutical and related industries

Staff should also refer to their respective professional body codes of conduct relating to acceptance of gifts, hospitality and sponsorship.

4 Policy statement

As a statutory NHS body, the CCG will embody public service values and principles in all business the organisation conduct. High standards of corporate and personal conduct based on the principle that patients come first, is a requirement for all members and employees of the CCG.

144 5 Aims and objectives

This policy supports a culture of accountability, probity and transparency in the CCG’s business transactions. All CCG decision-making will be undertaken without being influenced by inappropriate inducements of gifts, hospitality or sponsorship.

The following principles will govern the activities of the CCG:

5.1 Accountability

Everything done by members and employees of the CCG must be able to stand the test of parliamentary scrutiny, public judgements on propriety and professional codes of conduct.

5.2 Probity

There should be an absolute standard of honesty in dealing with the assets of the NHS and the CCG. Integrity should be the hallmark of all personal conduct in decisions affecting patients, staff and suppliers, and in the use of information acquired in the course of the CCG business.

5.3 Transparency

There should be sufficient transparency about the CCG’s activities to promote confidence between the CCG and their staff, patients and the public.

The CCG will view instances where this policy is not followed as serious and may take disciplinary action against individuals as a result, which may result in dismissal. The CCG will refer cases of potential fraud to the local counter fraud specialist for investigation.

If there is any doubt about whether gifts, hospitality or sponsorship should be accepted, advice should be sought in advance of receipt from the head of governance, who will take further advice as required from the accountable officer, clinical chair or conflicts of interest guardian.

6 Definitions / explanation of terms

6.1 The definition of ‘Gifts’ is

Any item of cash, goods or any service provided for personal benefit free of charge or at less than its commercial value. 6.2 The definition of ‘Hospitality’ is

Offers of meals, refreshments, travel, accommodation and other expenses, in relation to attendance at meetings, conferences, education and training or any other event. 6.3 The definition of ‘Sponsorship’ is

Commercial funding for courses, conferences, post/project funding, meetings, publications, etc. in connection with CCG or GP practice activities.

145 7 Duties, accountabilities, roles and responsibilities 7.1 Audit and Governance Committee

The audit and governance committee of the CCG is responsible for reviewing and approving this policy.

The audit and governance committee will seek assurance that there are systems and processes in place to manage offers of gifts, hospitality or sponsorship appropriately and to declare these in accordance with this policy.

The audit and governance committee will receive reporting on all gifts, hospitality or sponsorship declared on the CCG’s register of gifts, hospitality & sponsorship.

7.2 The CCG’s conflicts of interest guardian

The chair of the audit and governance committee acts as the CCG’s conflicts of interest guardian and has a lead role in ensuring that the governing body and wider CCG behave with the utmost probity at all times. The chair of the audit and governance committee oversees key elements of governance including the appropriate management of conflicts of interest in line with national guidance.

The conflicts of interest guardian in collaboration with the CCG’s head of governance will:

 act as a conduit for GP practice staff, members of the public and healthcare professionals who have any concerns with regards to conflicts of interest (including in relation to gifts, hospitality or sponsorship)  be a safe point of contact for employees or workers of the CCG to raise any concerns in relation to this policy  support the rigorous application of conflicts of interest principles and policies  provide independent advice and judgement where there is any doubt about how to apply conflicts of interest policies and principles in an individual situation  provide advice on minimising the risks of conflicts of interest

The CCG’s conflicts of interest guardian is responsible for reviewing and authorising declaration of gifts, hospitality or sponsorship forms (see Appendix 1) for the CCG Chair

7.3 Chief officer (accountable officer)

The accountable officer will ensure that there are systems and processes in place to support the implementation of this policy. 7.4 CCG chair

The CCG chair is responsible for reviewing and authorising declaration of gifts, hospitality or sponsorship forms (see Appendix 1) for executive members, non-staff members of the governing body and the accountable officer. 7.5 Line managers

Line managers must ensure members of staff and contractors are aware of the existence of this policy and the process to be followed.

146 Line managers are responsible for reviewing and authorising declaration of gifts, hospitality or sponsorship forms (see Appendix 1) for members of staff and contractors. 7.6 Head of governance

The head of governance is responsible for supporting individuals and advising on the application of this policy. Where required, the head of governance will seek further advice on behalf of the CCG (e.g. from legal advisors, local counter fraud specialist, etc.).

The head of governance will ensure all entries on the CCG’s register of gifts, hospitality & sponsorship are reported to the audit and governance committee.

7.7 Governance and Corporate Managers

The governance and corporate managers are responsible for ensuring that all declaration forms received are transferred to the register of gifts, hospitality or sponsorship on a timely basis and that the version of the register held on the CCG’s websites is up-to-date.

7.8 All Individuals

It is the responsibility of all individuals to familiarise themselves with this policy and comply with the provisions set out in it.

‘All individuals’ refers to:

 CCG employees and individuals working for the CCG under a contract for services  members of the governing body and the CCG’s committees and sub-committees  the CCG’s members: GP partners (or directors where the practice is a company) and any other practice staff involved with the CCG

8 Policy and procedure details

8.1 Gifts

The overarching principle applying in all circumstances is that individuals should not accept gifts that may affect, or be seen to affect, their professional judgement.

Other gifts from suppliers or contractors linked (currently or prospectively) to the CCG’s business:

 should be declined. The person to whom the gift(s) were offered should complete a gifts, hospitality or sponsorship form (see Appendix 1) in order that the declined offer can be recorded on the register of gifts, hospitality & sponsorship

 the exception to the above is low-cost branded promotional aids (stationery, calendars, pens, etc.) which may be accepted if they are under the value of the common industry standard (as per the Association of the British Pharmaceutical Industry), which is currently £6. Such gifts do not need to be declared

147 Gifts offered from other sources (e.g. patients, families, service users, etc.)

 gifts of cash or cash equivalents (e.g. vouchers, offers of remuneration for services) to individuals should always be declined

 gifts valued at over £50 should be treated with caution and only accepted on behalf of an organisation, not in a personal capacity. These gifts should be declared

 modest gifts under a value of £50 can be accepted and do not need to be declared

 multiple gifts from the same source over a 12 months period should be treated in the same way as a single gift over £50, where the cumulative value exceeds £50 8.2 Hospitality

Overarching principles applying in all circumstances:

 individuals should not ask for or accept hospitality that may affect, or be seen to affect, their professional judgement

 hospitality must only be accepted when there is a legitimate business reason and it is proportionate to the nature and purpose of the event

 particular caution should be exercised when hospitality is offered by actual or potential supplies or contractors – these can be accepted if modest and reasonable but individuals should always obtain senior approval and declare these. Care should be taken to consider any particular sensitivities, for example if a contract re-tender is imminent 8.3 Hospitality

 under a value of £25 – may be accepted and need not be declared

 of a value between £25 and £75 – may be accepted and must be declared

 over a value of £75 – should be refused unless (in exceptional circumstances) senior approval is given in advance; a clear reason should be recorded on the register of gifts, hospitality & sponsorship as to why it was permissible to accept 8.4 Sponsorship

Consideration should be given to the implications of any proposed sponsorship deal as high ethical standards must be adhered to at all times. Staff should consider the deal’s cost and benefits and an awareness of bias generated through sponsorship and where this might impinge on professional judgement and impartiality.

CCG staff, governing body and committee members and GP member practices may be offered commercial sponsorship for courses, conferences, project funding, meetings and publications in connection with the activities which they carry out for or on behalf of the CCG or their GP practice. All such offers (whether accepted or declined) must be declared so that they can be included on the CCG’s register of gifts, hospitality & sponsorship (where appropriate, consideration should also be given to recording such offers on the register of interests).

If such offers of sponsorship are reasonably justifiable and otherwise in accordance with this policy, then they may be accepted, subject to senior approval in advance.

148 The following principles apply to sponsorship:

 sponsorship by external bodies should only be approved if a reasonable person would conclude that the event will result in clear benefit for the organisation and the NHS

 during dealings with sponsors there must be no breach of patient or individual confidentiality or data protection rules and legislation

 no information should be supplied to the sponsor from which they could gain a commercial advantage and information which is not in the public domain should not be supplied.

 at the CCG’s discretion, sponsors or their representatives may attend or take part in the event, but they should not have dominant influence over the content or the main purpose of the event

 the involvement of a sponsor in an event should always be clearly identified in the interests of transparency

 sponsorship does not equate to endorsement of a company or its products and this should be made visibly clear on any promotional or other materials relating to the event staff should declare their involvement with arranging sponsored events to the CCG

9 Dissemination, implementation and training

This policy is available to the public and all relevant individuals and organisations via the CCG’s website.

Notification that the policy has been updated and a summary of the key changes made will be sent to all those to whom this policy applies.

The following will be undertaken to ensure awareness:

 introduction to the policy during local induction for new starters to the organisation. (See Appendix B for the new starter policy declaration form)  annual reminder of the existence and importance of the policy via internal communication methods and the GP practice bulletin

NHS England has developed an on-line training package on conflicts of interest. Three levels of training are available relating to an individual’s role and the extent of their involvement with conflicts of interest management. Only the first module is mandatory and only for those deemed as ‘decision-taking*’; this training must be repeated on an annual basis compliance with the uptake of module one of the training will form part of the CCG’s performance assessment by NHS England.

Any individuals who consider themselves in need of immediate training or further guidance should contact the head of governance.

*’Decision-taking staff’ have been defined by the CCG as: staff Band 8A and above, governing body and senior leadership team, executive members, associate clinical directors, associate leadership team and chair of the CCG council.

149 10 Review and monitoring

This policy will be reviewed every two years. Earlier review may be required in response to exceptional circumstances, organisational change or relevant changes in legislation or guidance. Any changes to the policy will be approved by the audit and governance committee.

The audit and governance committee will receive reporting on all gifts, hospitality or sponsorship declared on the CCG’s register of gifts, hospitality & sponsorship.

The audit and governance committee will also receive reporting on the outcome of the CCG’s annual audit of the publication of member practice registers of gifts, hospitality & sponsorship. This report will also be shared with the primary care contracting team.

The CCG monitor and review their performance in relation to the policy through a programme of internal and external audit work and through the oversight of the CCG audit and governance committee. Monitoring of the implementation of and compliance with this policy will be monitored as follows:

Monitoring Methodology Frequency of Responsible OfficerReporting Criteria Monitoring Committee All new gifts and Annually head of audit and declarations of hospitality governance governance gifts, register to be committee hospitality and checked sponsorship to against reports be reported to to audit and the audit and governance governance committee committee

11 Public sector equality duty

The Equality Act 2010, available on the GOV.UK website, includes a general legal duty to:  eliminate unlawful discrimination, harassment, victimisation and any other conduct prohibited by the Act  advance equality of opportunity between people who share a protected characteristic and people who do not share it  foster good relations between people who share a protected characteristic and people who do not share it

The protected characteristics are:  age  disability  gender reassignment  marriage or civil partnership (only in respect of eliminating discrimination)  pregnancy and maternity  race  religion or belief  sex  sexual orientation

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Public bodies have to demonstrate due regard to the general duty. This means active consideration of equality must influence the decisions reached that will impact on patients, carers, communities and staff.

It is no longer a specific legal requirement to carry out an equality impact assessment on all policies, procedures, practices and plans but, as described above, the CCG do need to be able to demonstrate they have paid due regard to the general duty.

The policy establishes how the CCG will ensure best practice is followed in managing offers and receipt of gifts, hospitality or sponsorship and sets out the safeguards that will be put in place to ensure transparency, fairness and probity in decision-making. It is not believed that this policy will impact on or affect differently or adversely any of the groups with protected characteristics.

12 References

The following key documents informed the content of this policy:

 NHS England, Managing Conflicts of Interest in the NHS, Guidance for Staff & Organisations, February 2017

 NHS England, Managing Conflicts of Interest: Revised Statutory Guidance for CCGs, June 2017

13 Appendices

Appendix A – Declaration of Gifts and Hospitality and Sponsorship Form Appendix B – New Starter Policy Declaration Form

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APPENDIX A: Declaration of Gifts, Hospitality & Sponsorship Form

All offers of Gifts, Hospitality & Sponsorship must be notified to the CCG as soon as practicable and no later than 28 days after the offer was made. Any changes to the original offer must also be notified within the same timescales.

Recipient Position Date Date of Details of Estimated Supplier / Details of Declined Reason Name of Receipt (if Gift / Value Offeror Previous or for Offer applicable) Hospitality / Name and Offers or Accepted? Accepting Sponsorship Nature of Acceptance or Business by this Declining Offeror/ Supplier

Decision taking staff (defined as: staff Band 8A and above, Governing Body and Executive Members, Clinical Speciality Leads and Chairs of Councils of Members / Representatives) should be aware that the information provided in this form will be added to the CCG’s registers which are held in hardcopy for inspection by the public and published on the CCG’s website. Decision taking staff must make any third party whose personal data they are providing in this form aware that the personal data will held in hardcopy for inspection by the public and published on the CCG’s website and must inform the third party that the CCG’s privacy information notice is available on the CCG’s website. If you are not sure whether you are a ‘decision taking’ member of staff, please speak to your line manager before completing this form.

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I confirm that the information provided above is complete and correct. I am aware that if I do not make full, accurate and timely declarations then civil, criminal, professional regulatory or internal disciplinary action may result.

I do / do not (delete as applicable) give my consent for this information to published on registers that the CCG holds (see note below). If consent is NOT given please give reasons:

Note: In exceptional circumstances, where the public disclosure of information could give rise to a real risk of harm or is prohibited by law, an individual’s name and / or other information may be redacted from the publicly available registers. Where an individual believes that substantial damage or distress may be caused to him / herself or somebody else by the publication of information about them, they are entitled to request that the information is not published. Such requests must be made in writing (via this form). Decisions not to publish information must be made by the CCG’s Conflicts of Interest Guardian who will seek appropriate legal advice where required and the CCG will retain a confidential, un-redacted version of the register. Person offered gift / hospitality / sponsorship

I confirm that I have read the CCG’s Policy on Receipt of Gifts, Hospitality and Sponsorship and have complied with its requirements.

Signed: ______

Dated: ______

Name (printed): ______

Role: ______

Line Manager

I confirm that I have read the CCG’s Policy on Receipt of Gifts, Hospitality and Sponsorship and have approved / not approved (please delete as appropriate) the acceptance of this gift / hospitality / sponsorship.

Signed: ______

Dated: ______

Name (printed): ______

Role: ______

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Please return to this form to:

FAO: Corporate Governance Team

Level 1

Scorex House

West 1 Bolton Rd

Bradford

BD1 4AS

Alternatively email: [email protected] / [email protected] / [email protected]

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APPENDIX B New Starter Policy Declaration Form

New Starter Policy Declaration Form

I declare that I have read and understood the CCG’s:

 Conflicts of Interest & Standards of Business Conduct

 Policy on the Offer and Receipt of Gifts, Hospitality & Sponsorship

Name:

Role:

Signature:

Date:

Please return this form to HR for retention on your personal file: [email protected]

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Conflicts of interest and business conduct policy

The Clinical Commissioning Group (CCG) manage conflicts of interest as part of its day-today activities. Effective handling of such conflicts is crucial for the maintenance of public trust in the healthcare commissioning system. It also serves to give confidence to patients, providers, parliament and tax payers that the CCG commissioning decisions are robust, fair, transparent and offer value for money.

Key information

Responsible director: Liz Allen - strategic director of organisation effectiveness

Author: Sarah Dick, head of governance

Approval body: Governing Body

Date approved:

Version: V3

Review date: 1 April 2022

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Version control

Version Date Author Description Circulation no. 0.1 Oct 17 Sarah First draft of a 3 CCGs joint policy – and Audit and Dick amendments arising from June 2017 revisions Governance to guidance. Committees 0.2 Sarah Version recommended for approval by A&G Governing Dick Committees Bodies 1. Sarah Version approved by Governing Bodies CCG wide and Dick websites 1.1 Dec 18 Sarah Scheduled review, including revisions arising A&G Committee Dick from internal audit recommendations: members, Chief i. new section (7.3.3) on declarations of Officer interest at the outside of any commissioning process ii. rewording to reflect that web-links to registers are included on agenda templates and that registers available on CCG websites are updated monthly iii. specification that visitors participating in meetings must also declare any relevant interests (Section 7.3.4 and Appendix C). iv. addition of suspension of standing orders as an option for alternative quorum arrangements for Governing Bodies (Section 7.3.5) v. inclusion of the CCGs’ definition of ‘decision- taking staff’, replacing NHS England’s suggested definition (Section 7.4) vi. clarification to Section 8.5 (contract management) vii. addition of Section 8.6 (CCG staff transfer following an award of contract recognised as an interest) viii. clarification of mandatory training requirements (Section 10) ix. Declaration of Interests form (Appendix B): amended for GDPR requirements

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1.2 Mar 19 Sarah Amendments following comments from Audit & Dick A&G Committee members, further Governance discussion with the Chief Officer and: Committees  clarification to Section 2 (scope) from guidance in the new CCG model constitution  clarification that individuals outside the scope of the CCGs’ definition of ‘decision-taking’ are expected to register interests and undertake relevant training within their own organisations and to declare these interests as appropriate at CCG and / or partnership meetings (Section 7.4)  addition of Appendix G: New Starter Policy Declaration Form 1.3 April Sarah  definition of an interest added to Governing 19 Dick Appendix Bodies  Chair’s CoI Checklist (audit recommendation) addition of ‘receipt of funding from a pharma or related company as part of a joint working arrangement’ as a type of financial interest 2.0 May 19 Sarah Version approved by Governing Bodies CCG wide and Dick websites 3.0 Mar 21 Sarah  Changes for the new CCG and CCG wide and Dick accessible content standard compliant websites Version submitted to Governing Body for approval

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Contents

Key information ...... 1

Version control ...... 2

1 Introduction ...... 7

Legislative framework ...... 8

2 Scope of the policy and associated documentation ...... 8

3 Associated documentation ...... 9

4 Policy statement on business conduct...... 9

Accountability ...... 10

Probity ...... 10

Transparency ...... 10

5 Aims and objectives ...... 11

6 Definition of conflicts of interest ...... 12

Financial interests:...... 12

Non-financial professional interests: ...... 13

Non-financial personal interests:...... 13

Indirect interests: ...... 13

7 Roles and responsibilities...... 14

7.1 Governing Body ...... 14

7.2 Chair of the Audit and Governance Committee (CCG’s Conflicts of Interest Guardian) ...... 15

7.3 Audit and Governance Committee ...... 15

7.4 Accountable Officer ...... 15

7.5 Meeting chairs ...... 16

7.6 Strategic head of assurance ...... 16

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7.7 Senior Leadership Team ...... 17

7.8 All individuals ...... 17

7.9 Transactions in support of commissioning functions ...... 17

7.10 Privileged information ...... 17

8 Management of conflict of interests ...... 18

8.1 Principles and general safeguards ...... 18

8.2 Secondary employment ...... 19

8.3 Declaration of interests – when to make a declaration and decision-making when a conflict arises ...... 19

8.3.1 Prior to appointment ...... 20

8.3.2 On appointment ...... 20

8.3.3 At the outset of any commissioning process ...... 20

8.3.4 Annually ...... 21

8.3.5 At meetings ...... 21

8.3.6 Minute taking at meetings ...... 22

8.3.8 On any change of circumstances, role or responsibility ...... 23

8.4 Register of interests ...... 23

8.5 Impact of non- compliance ...... 25

8.6 Raising concerns about conflicts of interests ...... 25

8.7 Managing and reporting conflicts of interest breaches ...... 25

8.8 Managing conflict of interest on an ongoing basis ...... 26

9 Transparency in procuring services and awarding grants ...... 26

9.1 Regulatory requirements ...... 26

9.2 Contractors and people who provide services to the CCG ...... 27

9.3 Bidders in procurement processes...... 28

9.4 Register of procurement decisions...... 28

9.5 Contract monitoring and management ...... 29

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9.6 CCG staff transfer following award of contract ...... 29

10 Member practices and conflicts of interests where GP practices are potential providers of CCG commissioned services ...... 29

10.1 Factors to address when commissioning services from GP practices ...... 30

10.2 Providing assurance ...... 30

10.3 Preserving integrity of the decision-making process when all or most GPs have an interest in the decision ...... 30

10.4 Primary Care Co-Commissioning ...... 31

11 Implementation, and dissemination and training ...... 32

12 Review and monitoring ...... 33

13 Public sector equality duty ...... 33

14 References...... 34

15 Appendices ...... 34

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1 Introduction

“If conflicts of interest are not managed effectively by the CCG confidence in the probity of commissioning decisions and the integrity of clinicians involved could be seriously undermined. However, with good planning and governance, the CCG should be able to avoid these risks”.

NHS Commissioning Board - Managing conflicts of interests: Guidance for clinical commissioning groups – March 2013

“If conflicts of interest are not managed effectively by the CCG confidence in the probity of commissioning decisions and the integrity of clinicians involved could be seriously

undermined. However, with good planning and governance, the CCG

NHS Bradford District and Craven Clinical Commissioning Group (hereafter known as the CCG), as commissioners of healthcare, need to manage conflicts of interest in a way that demonstrates transparency, probity and accountability. This is particularly important where commissioning services might be delivered by member practices as providers – ensuring that the approach taken does not affect or appear to affect the integrity of the CCG’s decision making processes. This will enable the CCG to withstand scrutiny and challenge and also protect the CCG, their governing body, senior leadership team, committee members, staff and member practices from any perception of wrong-doing.

“Conflicts of interest are inevitable in commissioning. It is how we manage them that matters”.

Managing Conflicts of Interest: Revised Statutory Guidance for CCGs, June 2017, NHS England

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Legislative framework

There are two separate pieces of legislation that require the CCG to manage conflicts of interest. These are:

Section 140 of the 2006 Act (Health Act 2006), as amended by section 25 of the 2012 Act (Health and Social Care Act 2012). This requires commissioners to:

 maintain appropriate registers of interests  publish or make arrangements for public to access those registers  make arrangements requiring the prompt declaration of any interests and inclusion within the relevant register  make arrangements for managing conflicts of interest and potential conflict of interest  have regard to guidance published by NHS England and Monitor in relation to conflicts of interest

The NHS (Procurement, Patient Choice and Competition) Regulations 2013. This requires commissioners to:

 manage conflicts and potential conflicts of interest when awarding a contract by prohibiting the award of a contract when the integrity of the award has been, or appears to have been, affected by a conflict  keep appropriate records of how they have managed any such conflicts in relation to NHS commissioning contracts it enters into. Details of this should be published by the CCG.

In addition to the legislation outlined above, NHS England has published detailed guidance for CCGs on the discharge of their functions and requires each CCG to have regard to the guidance. The latest version of this guidance is Managing Conflicts of Interest: Revised Statutory Guidance for CCGs, June 2017. This guidance supersedes the previous version (June 2016) and has been fully aligned with the new cross-system guidance on Managing Conflicts of Interest in the NHS which was published in February 2017.

NHS England expects all CCGs to fully implement statutory guidance on conflicts of interest management. Where a CCG has decided not to comply with this guidance, the reasons for doing so must be set out in the annual conflicts of interest self-certification.

2 Scope of the policy and associated documentation

This policy applies to all:

 employees of the CCG (including those on temporary or honorary contracts)  members of senior leadership team, CCG Council and other committees and sub- committees of the CCG  members of the governing body, their committees and sub-committees; and

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 CCG members (partners or directors where the practice is a company) and any other practice staff with involvement in CCG business.

Where any individual directly involved with the business or decision-making of the CCG and not otherwise covered by one of the categories above (for example, a member of a CCG programme board from a provider organisation), has an interest, or becomes aware of an interest which could lead to a conflict of interests in the event of the CCG considering an action or decision in relation to that interest, this must be considered as a potential conflict and declared to the CCG and at all relevant meetings.

Individuals contracted to work for, or on behalf of the CCG or otherwise providing services or facilities to the CCG will be made aware of their obligation with regard to declaring conflicts or potential conflicts of interest. This requirement will be written into their contract for services.

3 Associated documentation

This policy should be read in conjunction with the:  CCG constitution  CCG anti-fraud, bribery and corruption policy  CCG whistleblowing and raising concerns policy  CCG policy on the offer and receipt of gifts, hospitality and sponsorship  CCG procurement policy  CCG disciplinary policy and procedure  CCG policy on joint working arrangements with the pharmaceutical and related industries  code of conduct of NHS managers  general medical council good medical practice.

4 Policy statement on business conduct

As a statutory NHS body, the CCG will embody public service values and principles in all business the organisation conducts. High standards of corporate and personal conduct based on the principle that patients come first, is a requirement for all members and employees of the CCG.

The following principles will govern the activities of the CCG:

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Accountability Everything done by members and employees of the CCG must be able to stand the test of parliamentary scrutiny, public judgements on propriety and professional codes of conduct.

Probity There should be an absolute standard of honesty in dealing with the assets of the NHS and of the CCG. Integrity should be the hallmark of all personal conduct in decisions affecting patients, staff and suppliers, and in the use of information acquired in the course of CCG business.

Transparency There should be sufficient transparency about CCG activities to promote confidence between the CCG and their staff, patients and the public.

All individuals covered by this policy (see Section 2: Scope) should act in the interests of the CCG at all times and should follow the Seven Principles of Public Life (the Nolan Principles) set out by the Committee on Standards in Public Life and detailed in Appendix F of the CCG’s constitution:  selflessness  integrity  objectivity  accountability  openness  honesty  leadership

The CCG will also observe the principles of good governance set out in:

 the Good Governance Standards for Public Services (2004); Office for Public Management (OPM) and Chartered Institute of Public Finance and Accountancy (CIPFA) (2004)  the Equality Act 2010  the UK Corporate Governance Code (2016)  standards for members of NHS boards and CCG governing bodies in England (Nov 2013)

The CCG expects that all employees, members, committee and sub-committee members of the group and members of the governing body (and their committees) to:

 ensure that the interests of the public remain paramount at all times  be impartial and honest in the conduct of its official business  use the public funds entrusted to it to the best advantage of the service, always ensuring value for money

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 comply with the requirements of constitutions, standing orders and prime financial policies and all instructions relating to corporate governance  comply with the department of health code of conduct / code of accountability.

It is also the responsibility of employees, members, committee and sub-committee members of the group and members of the governing body (and their committees) to ensure that they do not:  abuse their official position for personal gain or to benefit their family or friends  seek to advantage or further private business or other interests in the course of their official duties.

5 Aims and objectives

Conflicts of interest are inevitable in public life. This policy provides advice on recognising where and how conflicts of interest arise and management of these within a robust governance framework to ensure that conflicts of interest do not affect, or appear to affect, the integrity of the CCG’s decision-making processes.

This policy sets out how the CCG will ensure best practice is followed in managing actual or potential conflicts of interest. The policy sets out the safeguards which are in place as part of a robust governance framework to ensure transparency, fairness and probity in decision- making, including:

 arrangements for declaring interests  maintaining and publishing registers of interests  managing conflicts of interest proactively or when they arise  keeping a record of the steps taken to manage a conflict  situations where individuals would be excluded from decision-making as a result of an actual or potential conflict of interest  managing situations where a breach of this policy has occurred  engagement with a range of potential providers on service design  maintaining and publishing a register of procurement decisions.

The benefits of managing conflicts of interest are:

 maintaining confidence and trust between patients, the public and GPs  enabling the CCG and member practices to demonstrate that they are acting fairly and transparently and that the members of the CCG will always put their duty to patients before any personal interest  ensuring that the CCG operate in line with legislation and statutory guidance.

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6 Definition of conflicts of interest

NHS England defines a conflict of interest as occurring:

“Where an individual’s ability to exercise judgement or act in a role is, could be, or is seen to be impaired or otherwise influenced by his or her involvement in another role or relationship. In some circumstances, it could be reasonably considered that a conflict of interest exists even when there is no actual conflict” (i.e. a perceived conflict).

The latest version of this guidance is Managing Conflicts of Interest: Revised Statutory Guidance for CCGs, June 2017. This guidance supersedes the previous version (June

2016) and has been fully aligned with the new cross-system guidance on Managing Conflicts of Interest in the NHS which was published in February 2017.

NHS England identifies four categories of conflicts of interest:

Financial interests

This is where an individual may get direct financial benefits from the consequences of a commissioning decision. This could, for example, include being:  a director, including a non-executive director or senior employee in a private company or public limited company or other organisation which is doing, or which is likely, or possibly seeking to do, business with a health or social care organisation  a shareholder (or similar ownership interests), a partner or owner of a private or not-for- profit company, business, partnership or consultancy which is doing, or which is likely, or possibly seeking to do business with a health or social care organisation  a management consultant for a provider.

This could also include an individual (or their practices, in the case of GPs) being:

 in secondary employment (see Section 8.2)  in receipt of secondary income from a provider  in receipt of a grant from a provider  in receipt of payments (for example, honoria, one-off payments, day allowances or travel or subsistence) from a provide

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 in receipt of funding from the pharmaceutical or med-tech industry as part of a joint working arrangement  in receipt of research funding, including grants that may be received by the individual or any organisation in which they have an interest or role; and  having a pension that is funded by a provider (where the value of this might be affected by the success or failure of the provider)

Non-financial professional interests

 an advocate for a particular group of patients  a GP with a special interest(s)  a member of a particular specialist professional body (although routine GP membership of the Royal College of General Practitioners, British Medical Association or a Medical Defence organisation would not usually by itself amount to an interest which needed to be declared);  an advisor for the Care Quality Commission (CQC) or the National Institute for Health and Care Excellence (NICE);  a medical researcher.

Non-financial personal interests

This is where an individual may benefit personally in ways which are not directly linked to their professional career or do not give rise to direct financial benefit. This could include, for example, where the individual is:

 a voluntary sector champion for a provider  a volunteer for a provider  a member of a voluntary sector board or has any other position of authority with a voluntary sector organisation  a member of a lobby or pressure group with an interest in health

Indirect interests

This is where an individual has a close association with an individual who has a financial interest, a non-financial professional interest or a non-financial personal interest in a commissioning decision, for example:  spouse / partner  close relatives e.g. parent, grandparent, child, grandchild or sibling  close friend

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 business partner. A declaration for a “business partner” in a GP partnership should include all relevant collective interests of the partnership and all interests of their fellow GP partners (this could be done by cross-referring to the separate declarations made by those GP partners)

Whether an interest held by another person gives rise to a conflict of interest will depend upon the nature of the relationship between that person and the individual and the role of the individual within the CCG. It is not possible to define all instances in which an interest may be a real or perceived conflict. It is for each individual to exercise their judgement in deciding whether to register any interests that may be construed as a conflict. If an individual is unsure as to whether an interest should be declared then that individual should seek advice from the Associate Director of Corporate Affairs and CCG’s head of governance, committee chairs, accountable officer or the conflicts of interest guardian (chair of audit and governance committee). Where the CCG’s accountable officer wishes to seek advice on their own interests, he / she should consult with the conflicts of interest guardian (chair of audit and governance committee).

If in doubt it is better to assume the existence of a conflict of interest and declare it, rather than ignore it.

NHS England has developed a series of case studies to accompany the revised statutory guidance on managing conflicts of interest for CCGs. The case studies are intended to raise awareness of the different types of conflicts of interest that could arise in CCGs and to support CCGs to robustly and effectively identify and manage them. The case studies can be accessed here: https://www.england.nhs.uk/commissioning/wp-content/uploads/sites/12/2016/06/coi-case- studies-jun16.pdf

7 Roles and responsibilities

7.1 Governing Body

The governing body will oversee this policy and will ensure that there are systems and processes in place to support all members of the governing body, senior leadership team, members of committees, employees and member practices to:

 declare their interests through a Register of Interests which is made available to the public via the CCG’s website or on request to the CCG  declare any interests relevant to discussions and proceedings so that any comments they make are fully understood by all others in that context  ensure that where any conflict which could have an effect on any decision or process the individual concerned will have no part in making or influencing the relevant decision.

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7.2 Chair of the Audit and Governance Committee (CCG’s conflicts of interest guardian)

The chair of the audit and governance committee (the lay member for audit and governance) act as the CCG’s conflicts of interest guardian and have a lead role in ensuring that the governing body and wider CCG behave with the utmost probity at all times. The chair of the audit and governance committee oversees key elements of governance including the appropriate management of conflicts of interest in line with national guidance.

The conflicts of interest guardian will:

 act as a conduit for GP practice staff, members of the public and healthcare professionals who have any concerns with regards to conflicts of interest  be a safe point of contact for employees or workers of the CCG to raise any concerns in relation to this policy  support the rigorous application of conflicts of interest principles and policies provide independent advice and judgement where there is any doubt about how to apply conflicts of interest policies and principles in an individual situation  provide advice on minimising the risks of conflicts of interests  The chair of the audit and governance committee (together with the CCG’s accountable officer) will provide direct attestation to NHS England that the CCG have complied with national guidance on the management of conflict of interest via quarterly and annual self- certifications

7.3 Audit and Governance Committee

The audit and governance committee will receive copies of the registers of interests and of procurement decisions on a regular basis. They will also receive copies of the procurement template when the CCG are potentially procuring services from GP practices. In addition, if any instances of non-compliance with this policy are identified, a lessons learnt review will be reported to the audit and governance committee.

7.4 Accountable officer

The accountable officer has overall responsibility for the implementation of this policy and for ensuring that a robust process for declaring and managing conflicts of interest is in place.

The accountable officer will ensure that for every interest declared, either in writing or by oral declaration, arrangements are put in place to manage the conflict or potential conflict of interest to ensure the integrity of the CCG’s decision making process.

Where appropriate, the accountable officer will put in writing to the relevant individual, arrangements for managing the conflict or potential conflict of interest within a week of declaration. This will confirm the following:

 when an individual should withdraw from a specified activity, on a temporary or permanent basis

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 monitoring of the specified activity undertaken by the individual, either by a line manager, colleague or other designated individual

7.5 Meeting Chairs

Meeting Chairs have particular responsibility for ensuring the appropriate management of conflicts of interest during the course of all of the CCG meetings. They are responsible for ensuring:

 they are familiar with the contents of the registers of interests as pertinent to their groups or committees  they prepare for the meeting mindful of any actual or potential conflicts of interest that may arise relevant to the business of that meeting  that declarations of interest are always an item on the agendas  that the meeting is quorate and that this is recorded in the minutes  that members are asked to declare any interests that are likely to lead to a conflict or potential conflict that could impact (or has the potential to impact) on any items on the agendas. This should be repeated again at individual item(s) where it is considered a conflict is likely to or could potentially arise  any declaration must be clearly noted in the minutes both at the start of the meeting and at the relevant item. If there is any doubt as to whether or not a conflict of interest could arise, a declaration should be made and noted in the minutes  the minutes must specify how the chair decided to manage the declared interest (please see Appendix C for additional guidance) and provide evidence that it was managed accordingly  any declaration arising during the course of a meeting / individual item must be minuted and action how to handle it agreed by the chair and recorded in the minutes  quoracy of the meeting or for individual items must be checked if an interest is declared. If the meeting is no longer quorate (in full or for particular items) or there is insufficient relevant expertise to inform decision-making once those with conflicts of interests are excluded the chair must agree how this should be managed, i.e. defer the item / meeting or refer any decisions for particular items(s) to another committee for consideration and formal approval Please see Appendix C for a conflicts of interest checklist for committee chairs.

7.6 Strategic Head of Assurance

The strategic head of assurance, supported by the CCG head of governance, is responsible for:  ensuring the appropriate maintenance of the registers of interest and the register of procurement decisions and their public availability

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 supporting the conflicts of interest guardian to enable them to carry out their role effectively  providing advice, support and guidance on how conflicts of interest should be managed  ensuring that appropriate administrative processes are in place to support conflicts of interest management

7.7 Senior leadership team

The role of the senior leadership team is to ensure that members of staff and any contractors working on behalf of the CCG are aware of this policy and the processes to be followed.

7.8 All individuals

To ensure openness and transparency in business transactions, all employees, contractors working on behalf of the CCG, members, committees and sub-committee members of the groups and members of the governing body and its committees are required to:  ensure that the interests of the public remain paramount at all times  be impartial and honest in the conduct of their official business  use the public funds entrusted to them to the best advantage of the service, always ensuring value for money  ensure they do not abuse their official position for personal gain of the benefit of family or friends  ensure that they do not seek to advantage or further private or other interests in the course of their official duties  familiarise themselves and comply with the requirements of this policy, including the declaration of any actual or potential conflicts of interest

7.9 Transactions in support of commissioning functions

In any transaction undertaken in support of the CCG’s commissioning functions (including conversations between two or more individuals, emails, correspondence and other communications) individuals must ensure, where they are aware of an interest that they declare it and conform to any arrangements confirmed for the management of that interest.

7.10 Privileged information

No-one should use confidential information acquired in the pursuit of their role within the CCG to benefit themselves or another connected person, or create the impression of having done so.

Members of the CCG, employees, the governing body, senior leadership team and committee / sub-committee members should take care not to provide any third party with a possible advantage by sharing privileged, personal or commercial information, or by

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providing any information that may be commercially useful in advance of that information being available publically (such as by informing a potential supplier of an upcoming procurement in advance of other potential bidders), or any other information that is not otherwise available and in the public domain.

8 Management of conflict of interests

8.1 Principles and general safeguards

The following general principles and safeguards will apply at all stages of the commissioning process and will be particularly pertinent at key decision points:

 doing business appropriately, i.e. appropriate needs assessment, consultation, commissioning strategies and procurement procedures in place, including clear and transparent commissioning specifications that reflect engagement activities and set out the basis on which any contract will be awarded  responsive and best practice, i.e. commissioning intentions are based on local health needs, reflect evidence of best practice and have ‘buy-in’ from local stakeholders on the clinical case for change  being proactive not reactive, minimising the risk of conflict of interests at the earliest possible opportunity e.g. ensuring robust induction and training so that individuals understand their obligations and by being mindful of potential conflicts when appointing / selecting individuals to commissioning roles  assuming that individuals will seek to act ethically and professionally, but may not always be sensitive to conflicts of interests or lack awareness of rules and procedures  being balanced and proportionate, i.e. rules should be clear and robust but not overly prescriptive or restrictive; decision-making processes should be transparent and fair but not constrained by being overly complex or cumbersome  being open and transparent, by ensuring early engagement with all relevant stakeholders in relation to proposed commissioning plans and by clear documenting the approach taken at all stages of the commissioning cycle  securing expert advice, by ensuring that commissioning plans take account of advice from appropriate health and social care professionals  engaging with providers, via early engagement with both incumbent and potential new providers regarding potential changes to services being commissioned and in ensuring equal treatment, non-discrimination and transparency in aspects of engaging with providers

 specifying the outcomes (as far as possible) to be delivered by a new service rather than the process by which it will be delivered  ensuring sound-record keeping, including up-to-date Registers of Interests  a clear, recognised and easily enacted system for dispute resolution, via the Disciplinary and Grievance Policy for staff, the Constitution for member practices, the standard NHS contract for providers and collaborative agreements with partners

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Where the CCG commission services from GP practices, the general safeguards described above will be supplemented by additional safeguards to ensure maximum transparency and probity and provide reassurance that commissioning decisions have been made fairly and in the best interests of patients – please see Section 9 of this policy.

8.2 Secondary employment

All CCG employees, contractors and committee members are required to inform the CCG if they are employed or engaged in, or wish to be employed or engaged in, any employment or consultancy work in addition to their work with the CCG. The purpose of this is to ensure that the CCG are aware of any potential conflicts of interest.

Examples of work which might conflict with the business of the CCG, including part-time, temporary or fixed term contract work, include:

 employment with another NHS body  employment with another organisation which might be in a position to supply goods / services to the CCG  directorship of a GP Federation; and  self-employment, including private practice, in a capacity which might conflict with the work of the CCG or which might be in a position to supply goods / services to the CCG.

All individuals must obtain prior permission to engage in secondary employment and the CCG reserve the right to refuse permission where it is believed that a conflict will arise which cannot be effectively managed.

In particular, it is unacceptable for employees, advisors or consultants to the CCG on matters of procurement to be in receipt of payments from the pharmaceutical or medical devices sector.

8.3 Declaration of interests – when to make a declaration and decision-making when a conflict arises

 Individuals should take all reasonable steps to identify conflicts of interest that arise or may arise in the course of the CCG commissioning any services or the delivery of the CCG business. Individuals are not required to declare all interests they may have outside of the CCG, but rather those interests that could relate to or impact on the CCG’s business.  Declarations of interest must be made either orally or in writing as soon as they are aware of it and in any event no later than 28 days after becoming aware of the conflict. A form to be used for this purpose is included at Appendix B to the policy.  Any declared interest must also be raised verbally when dealing with or discussing a matter to which it is pertinent.

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 Where an individual is unable to provide a declaration in writing, for example, if a conflict becomes apparent in the course of a meeting, they will make an oral declaration at the meeting, and provide a written declaration as soon as possible thereafter.  It must be stressed that, in all instances, whilst advice and guidance is available, the question of whether or not to declare an interest is one which is a matter for the judgement of the individual themselves. In most cases a decision is straightforward but in cases of doubt, the preferred option is to declare the interest.

8.3.1 Prior to appointment

Individuals applying for posts within the CCG or seeking appointment to the governing body or any committees of the CCG will be required to declare any potential conflicts of interest during the appointment process. The materiality and extent of interests / conflicts of interest will be considered as part of the assessment of their suitability for the appointment. Where a question arises as to whether this may impact on the ability to appoint, further guidance should be sought from the CCG chair, chair of the audit and governance committee or accountable officer.

8.3.2 On appointment

All CCG employees and all members of the governing body, senior leadership team and any committees or sub-committees of the governing body or the CCG are required to complete a declaration of interests form (including a “nil return” if there are no interests to declare). The form is attached at Appendix B.

The CCG will assess the materiality of any interests declared, in particular whether the individual (or any person with whom they have a close association) could benefit for any decision the CCG might make, as part of the appointment process. This is particularly relevant for governing body, committees and sub-committee appointments but will also be considered for all employees and especially those operating at a senior level.

Where a position at the CCG requires an individual to refrain from a role with a specified organisation(s) (e.g. the secondary care specialist or the registered nurse undertaking a role at a local healthcare provider), this requirement will be incorporated into the individual’s contract of employment.

8.3.3 At the outset of any commissioning process

At the outset of a commissioning process, the relevant interests of all individuals involved will be identified and clear arrangements put in place to manage any conflicts of interest. This includes consideration as to which stages of the process a conflicted individual should not participate in, and, in some circumstances, whether that individual should be involved in the process at all. The conflicts of interest case studies include examples of this: https://www.england.nhs.uk/commissioning/wp-content/uploads/sites/12/2016/06/coi-case- studies-jun16.pdf

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The CCG will identify and appropriately manage any conflicts of interest that may arise where staff are involved in both the management of existing contracts and the procurement of related / replacement contracts.

8.3.4 Annually

The CCG will contact all individuals to whom this policy applies on an annual basis to request a declaration of interests form (see Appendix B). Where there are no interests or changes to declare, a “nil return” should be returned.

8.3.5 At meetings

Details of declarations of interest already made will be provided to the chair of the governing body and committee meetings when papers are issued (via web-links to the CCG’s published registers of Interests).

Declarations of interest will be an agenda item at each meeting. Visitors in attendance who participate in the meeting must also declare any interests in a timely manner.

In any meeting, where an individual is aware of an interest, previously declared or otherwise, in relation to the scheduled or likely business of the meeting, the individual concerned will bring this to the attention of the chair of the meeting, together with details of any arrangements which have been previously confirmed for the management of the actual or potential conflict of interest. Where no arrangements have been previously been confirmed, the chair of the meeting will determine the action to be taken. The appropriate course of action will depend on the particular circumstances, but could include one or more of the following:

where the chair has a conflict of interest, deciding that the vice chair (or another non- conflicted member of the meeting if the vice chair is also conflicted) should chair all or part of the meeting requiring the individual who has a conflict of interest (including the chair or vice chair if necessary) not to attend the meeting ensuring that the individual concerned does not receive the supporting papers or minutes of the meeting which relate to the matter(s) which give rise to the conflict requiring the individual to leave the discussion when the relevant matter(s) are being discussed and when any decisions are being taken in relation to those matter(s). In private meetings, this could include requiring the individual to leave the room and in public meetings to either leave the room or join the audience in the public gallery allowing the individual to participate in some or all of the discussion when the relevant matter(s) are being discussed but requiring them to leave the meeting when any decisions are being taken in relation to those matter(s)this may be appropriate where, for example, the conflicted individual has important relevant knowledge and experience of the matter(s) under discussion, which it would be of benefit for the meeting to hear, but this will depend on the nature and extent of the interest which has been declared noting the interest and ensuring that all attendees are aware of the nature and extent of the interest, but allowing the individual to remain and participate in both the discussion and in any decisions. This is only likely to be the

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appropriate course of action where it is decided that the interest which has been declared is either immaterial or not relevant to the matter(s) under discussion

The conflicts of interest case studies include examples of material and immaterial conflicts of interest: https://www.england.nhs.uk/commissioning/wp-content/uploads/sites/12/2016/06/coi-case-studies-jun16.pdf

Where the conflict of interest relates to outside employment and an individual continues to participate in meetings (as agreed by the chair), he or she should ensure that the capacity in which they continue to participate in the discussions is made clear and correctly recorded in the meeting minutes. Where it is appropriate for them to participate in decisions they must only do so if they are acting in their CCG role.

8.3.6 Minute taking at meetings  it is imperative that the CCG ensure complete transparency in its decision making processes through robust record-keeping. If any conflicts of interest aredeclared or otherwise arise in a meeting, the chair must ensure the following  information is recorded in the minutes:  who has the interest  the nature of the interest and why it gives rise to a conflict, including  the magnitude of any interest  the items on the agenda to which the interest relates;  how the conflict was agreed to be managed; and  evidence that the conflict was managed as intended (for example recording the points during the meeting when particular individuals left or returned to the meeting).

Further guidance for chairs of meetings is provided at Appendix C: Conflicts of Interest Checklist for Chairs.

8.3.7 Alternative quoracy arrangements

Where more than 50% of the members of a meeting are required to withdraw from a meeting or part of it, owing to the arrangements agreed for the management of conflicts of interests or potential conflicts of interests, the chair (or deputy) will determine whether or not the discussion can proceed.

In making this decision the chair will consider whether the meeting is quorate. Where the meeting is not quorate, owing to the absence of certain members, the discussion will be deferred until such time as a quorum can be convened. Where a quorum cannot be convened from the membership of the meeting, owing to the arrangements for managing conflicts of interest or potential conflicts of interests, the chair of the meeting shall consult with the accountable officer on the action to be taken. This may include: a) requiring another of the group’s committees or sub-committees, the group’s governing body or the governing body committees or sub-committees (as appropriate) which can be quorate to progress the item of business, or if this is not possible,

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b) inviting on a temporary basis one or more of the following to make up the quorum (where these are permitted members of the governing body or committees / sub-committees in question) so that the group can progress the item of business: (i) a member of the group who is an individual (ii) an individual appointed by a member to act on its behalf in the dealings between it and the group (iii) a member of a relevant health and wellbeing board (iv) a member of a governing body of another clinical commissioning group. c) suspension of standing orders: in accordance with the CCG’s constitutions, except where it would contravene any statutory provision or a direction by the secretary of state or by NHS England, any part of standing orders (such as the governing body quorum requirement) may be suspended provided (i) two-thirds of members present at the relevant meeting agree, (ii) a full record of this resolution and the reasons for it are recorded in the minutes and (iii) the suspension of standing orders is reported to the CCG’s audit & governance committee for review of the reasonableness of the decision taken to suspend standing orders.

These arrangements must be recorded in the minutes.

8.3.8 On any change of circumstances, role or responsibility

Where an individual changes role or responsibility within the CCG any change to the individual’s interests should be declared.

Wherever an individual’s circumstances change in a way that affects the individual’s interests (e.g. where an individual takes on a new role outside of the CCG or sets up a new business or relationship), a further declaration should be made to reflect the change in circumstances. This could involve a conflict of interest ceasing to exist or a new one materialising.

Any declaration must be made as soon as possible and no later than 28 days after becoming aware of the actual or potential conflict.

8.4 Register of interests

The CCG will maintain three separate registers for:

 CCG employees (including any temporary, agency or seconded staff), plus any self- employed consultants or other individuals working for the CCG under a contract for services  governing body members and executive and members of committees, sub-committees and sub-groups of the CCG and of the governing body  CCG members (i.e. each practice). Individual declarations should be made by GP partners (or where the practice is a company, each director) and any other individuals directly involved with the business or decision-making of the CCG (e.g., practice

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representatives on the council of members/council of representatives, and/or those who take part in the CCG Task and Finish Groups, etc).

The registers above will specify which committees / sub-committees / working groups an individual is a member of. Details of declarations of interest already made will be provided to the chair of the governing body / committees / sub-committees / sub- groups meetings when papers are issued.

The registers of interests will be updated promptly whenever a new or revised interest is declared. In addition, all interests, including nil declarations, will be confirmed annually.

The registers will be published on the CCG’s website (updated monthly) and also be available for inspection by members of the public at the CCG headquarters. They will also be published as part of the Annual report and annual report statement (a web-link is acceptable).

Whilst all staff are required to declare any relevant interests, only the interests of “decision- taking staff” will be included on the publically available register. The CCG has defined such staff as:

 chairs / deputy chairs of council of members / representatives  governing body members  senior leadership team  public health representatives at governing body and senior leadership team  associate clinical directors  associate leadership team  associate GPs  all staff band 8A and above

Declarations by CCG members will also be included on a publically available register.

In exceptional circumstances, where the public disclosure of information could give rise to a real risk of harm or is prohibited by law, an individual’s name and / or other information may be redacted from the publicly available registers. Where an individual believes that substantial damage or distress may be caused to him / herself or somebody else by the publication of information about them, they are entitled to request that the information is not published. Such requests must be made in writing. Decisions not to publish information must be made by the CCG conflicts of interest guardian who will seek appropriate legal advice where required and the CCG will retain a confidential, un-redacted version of the register.

An interest will remain on the public register for a minimum of six months after the interest has expired. The CCG will also retain a private record of historic interests for a minimum of 6 years after the date on which it expired.

NOTE: for individuals involved with CCG business but not holding a contract for service or employment with the CCG (for example partners in the health & care partnerships or

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involved with CCG programmes / projects), it is expected that that such individuals will register their interests and undertake conflicts of interest training within their own organisations. Where such individuals have an interest, or become aware of an interest which could lead to a conflict of interests in the event of the CCG considering an action or decision in relation to that interest, this must be considered as a potential conflict and declared to the CCG and at all relevant meetings.

8.5 Impact of non-compliance

Where an individual fails to comply with this policy and / or fails to declare an interest disciplinary action will be taken which could lead in extreme circumstances to dismissal or criminal action, for example under the Fraud Act 2006. Please refer also to the CCG’s disciplinary policy and procedure.

Impact and non-compliance relates to a statutorily regulated health professional, the CCG will give consideration to reporting the breach to the relevant regulatory body.

If conflicts of interest are not effectively managed, the CCG could face:  civil challenges to the decisions it makes  criminal charges under the Bribery Act 2010, where failure to prevent bribery and corruption can be brought as a corporate offence

8.6 Raising concerns about conflicts of interests

It is the duty of all those to whom this policy applies to speak up about genuine concerns in relation to the application and administration of the CCG’s policy on conflicts of interest. Any concerns or suspicions should be raised with the associate director of corporate affairs, head of governance or the conflict of interest guardian (chair of the audit and governance committee). If concerns or suspicions relate to the CCG head of governance or conflicts of interest guardian, they should be reported to the CCG’s accountable officer.

CCG employees should refer to the CCG’s whistleblowing and raising concerns policy for further guidance.

Should someone other than a CCG employee wish to report a concern in relation to the CCG conflict of interest management, they are advised to refer also to their own organisation’s whistleblowing policy for guidance.

8.7 Managing and reporting conflicts of interest breaches

Any breaches or potential breaches identified will be immediately notified to the CCG’s conflicts of interest guardian and will be fully investigated by the CCG’s head of governance or, if more appropriate, independently by the CCG’s internal auditors or legal advisors. Full and confidential records of any investigation will be maintained. Reports arising from the

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investigation of breaches or potential breaches of the conflict of interest policy and any resulting actions to be taken will be approved by the CCG’s conflicts of interest guardian.

The CCG’s head of governance will ensure that any breaches of this policy identified are reported to the CCG’s audit and governance committee, along with a lessons learnt review.

All material breaches of this policy identified will also be reported:

 to NHS England (regional director)  anonymously on the CCG website  to the relevant regulator where a breach of this policy relates to a regulated healthcare professional

When determining the materiality of a breach, the following points will be considered:

 the nature, seriousness and consequences of the breach  has anyone gained an unfair advantage as a result of the breach?  has any final decision been made that was contaminated by the breach? When was that decision made? This has a potential impact in relation to time limits for bringing potential judicial review claims  is there any appearance of bias in the decision-making as a result of the breach, in particular were any financial interests not declared/ not dealt with appropriately?  has any legally binding contract been entered into by the CCG as a result of the decision? If so, the following points will be considered: o the length and value of the contract o the consequences of terminating the contract, including considerations of continuity and safety of services to patients and the implications of entering into any interim service provision arrangements

8.8 Managing conflict of interest on an ongoing basis

The CCG will continue to monitor the governance structure and procedures for managing conflicts of interest to ensure that they continue to remain fit for purpose as the organisations develop.

9 Transparency in procuring services and awarding grants

9.1 Regulatory requirements

The CCG recognises the importance of making decisions about the services it procures or the grants it awards in a way that does not call in to question the motives behind the procurement decision that has been made. The CCG will procure services and award grants in a manner that is open, transparent, non-discriminatory and fair to all providers and is compliant with the principles of procurement law and guidance.

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The procurement, patient choice and competition regulations 2013 place requirements on commissioners to ensure that they adhere to good practice in relation to procurement, do not engage in anti-competitive behavior that is against the interests of patients and protect the right of patients to make choices about their healthcare.

The Regulations requires commissioners to:  Manage conflicts and potential conflicts of interest when awarding contracts by prohibiting the award of contracts when the integrity of the award has been, or appears to have been, affected by a conflict.  Keep appropriate records of how they have managed any such conflicts in relation to NHS commissioning contracts it enters into. Details of this should be published by the CCG.

Conflicts that affect or appear to affect the integrity of a contract award; examples of factors that a commissioner is likely to need to consider in deciding whether or not it can award a contract

 the nature of the individual’s interest in the provision of services, including whether the

interest is direct or indirect, financial or personal and the magnitude of that interest.

 whether and how the interest is declared, at what stage of the process and to whom.  the extent of the individual’s involvement in the procurement process, including, for example, whether the individual has had significant influence on the service specification / design, has played a key role in setting award criteria, has been involved in deliberations about which provider or providers to award the contract to and / or has voted on the decision to award the contract.

 what steps have been taken to manage the actual or potential conflict of interest?

Monitor, Substantive Guidance on the Procurement, Patient Choice and Competition Regulations, 2013

9.2 Contractors and people who provide services to the CCG

Anyone contracted to provide services or facilities directly to the CCG will be subject to the same provisions of this policy in relation to managing conflicts of interests. This requirement will be set out in the contract for their services.

Commissioning support units (CSUs) and other service providers

The CCG have contracts and service level agreements in place for commissioning support for a number of the CCG functions. Members of staff from the CSU, Bradford District Care Foundation Trust or The Health Informatics Service are often in a position to influence the decisions of the CCG. As such, the CCG will require the CSU and other service providers,

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to provide on a regular basis, a register of interests for senior members of staff supporting the CCG.

Where a CSU and other service providers support the CCG in undertaking procurement, they will help to demonstrate that the CCG are acting fairly and transparently by assessing whether providers meet pre-qualifying criteria and which provider provides best value for money against the specification and evaluation criteria. However, the CCG will:

 determine and sign-off the specification and evaluation criteria  decide and sign-off decision on which providers to invite to tender and  make the final decision on the selection of the provider

9.3 Bidders in procurement processes

Bidders will be asked to complete a formal declaration at the invitation to tender stage of the procurement process. This form is enclosed as Appendix D.

9.4 Register of procurement decisions

The CCG will maintain a register of procurement decisions taken, either for the procurement of a new service or any extension or material variation of a current contract. The register of procurement decisions will be maintained by the CCG’s governance team.

“Procurement” relates to the purchase of any goods, services or works and the term “procurement decision” should be understood in a wide sense to ensure transparency of decision-making on spending public funds. For example, the decision to use a single tender action is a procurement decision and if it results in the CCG entering into a new contract, extending an existing contract or materially altering the terms of an existing contract, the decision should be recorded on the register. The registers will include, as a minimum:

 the details of the decision  who was involved in the decision (for example, governing Body, senior leadership team, committee members or other with decision-making responsibility)?  A summary of conflicts of interest in relation to the decision and how this was managed by the CCG.

In the interests of transparency, the value of all contracts will be published following the agreement of the contract. Where it is decided to commission services through Any Qualified Provider (AQP), the type of services being commissioned and the agreed price for each service will also be included. Such details will also be set out in the annual report.

The register will be updated whenever a procurement decision is taken and will be available on the CCG website and on request for inspection at the CCG’s headquarters. Updated copies will be presented to the audit and governance committee on a regular basis.

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Whilst there is no requirement to keep a register of services that may be procured in the future, it is considered good practice to ensured planned service developments and proposed procurements are transparent and available for the public to see. The CCG will include planned procurements on the register once these have been clearly determined.

9.5 Contract monitoring and management

The management of conflicts of interest applies to all aspects of the commissioning cycle, including contract management.

The individuals involved in the monitoring of a contract should not have any direct or indirect, financial, professional or personal interest in the incumbent provider or in any other provider that could prevent them, or be perceived to prevent them, from carrying out their role in an impartial, fair and transparent manner.

9.6 CCG staff transfer following award of contract

The CCG will also identify as soon as possible where staff might transfer to a provider (or their role may materially change) following the award of a contract. This should be treated as a relevant interest and managed appropriately.

10 Member practices and conflicts of interests where GP practices are potential providers of CCG commissioned services

The British Medical Association (BMA) have identified that a conflict of interest may arise in the following instances:

 where GPs may refer their patients to a provider company in which they have a financial interest  where GPs make decisions regarding the care of their patients to influence the ‘quality premium’ they receive through the CCG  where enhanced services are commissioned that could be provided by member practices

The CCG expect that member practices continue to ensure that patients are referred to the service that they in their professional opinion believe is most appropriate for that patient’s condition, whilst responding to the wishes and choices of that patient. Where the most appropriate service to which the patient is referred is also one in which the GP has a vested

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interest, the GP must inform them of this fact, in line with paragraph 76 of the General Medical Council Guidelines “Good Medical Practice”, 2006.

10.1 Factors to address when commissioning services from GP practices

Conflicts can arise where the CCG commission (or continues to commission by contract extension) healthcare services, including primary medical services, in which a member / advisor of the governing body or senior leadership team, their sub-committees or committees of the CCG or an employee has a financial or other interest.

This is likely to arise most often in the context of co-commissioning of primary medical care but it should also be considered in respect of any commissioning issue where GPs are current or possible providers. These factors will be addressed in a consistent and transparent manner by the use of the Procurement Template (see Appendix E).

10.2 Providing assurance

The CCG will address the factors set out in the procurement template when drawing up plans to commission a service for which GP practices may be potential providers.

This will provide appropriate assurance:

 to the health and wellbeing boards and to local communities that the proposed services meet local needs and priorities and has included appropriate public engagement  to the audit and governance committee and, where necessary, the external auditors that a robust process has been followed in deciding to commission the service, in selecting the appropriate procurement route and in addressing actual or potential conflicts of interest.

Completed procurement templates will be made available to the public upon request.

10.3 Preserving integrity of the decision-making process when all or most GPs have an interest in the decision

Where individuals on the governing body or one of its committees or sub-committees have a material interest, they should either be excluded from relevant parts of meetings, or join in the discussion but not participate in the decision-making itself (i.e. not have a vote).

Where a limited number of GPs have an interest, it should be straightforward for relevant individuals to be excluded from decision-making. Decisions as to whether an individual declares an interest and:  leaves the meeting for the whole of the item

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 takes part in the discussions but not in the decision-making; this may be appropriate where the conflicted individual has important relevant knowledge and  takes part in the discussions but not in the decision-making; this may be appropriate where the conflicted individual has important relevant knowledge and experience of the matter under discussion, which it would be of benefit for the meeting to hear  remains and participates in the discussions and any decisions; this is only likely to the appropriate course of action where it is decided that the interest which has been declared is either immaterial or not relevant to the matter under discussion  will be made by the chair of the meeting and the action taken recorded in the minutes.  Where all the GPs or practice representatives on the governing body or one of its committees or sub-committees could have a material interest in the decisions, particularly where it is proposed to commission services on a single tender basis to all GP practices in the area, or where it is likely that all or most practices would wish to be qualified providers for a service under any qualified provider (AQP), the decision will be undertaken by the remainder of the governing body (or by a specific committee established for this purpose). In such circumstances, the quorum for the governing body / specific committee will be four to include: o either the registered nurse or the secondary care consultant o either of the lay member for governance or the lay member for patient and public involvement o either the chief officer, chief operating officer or chief finance officer

10.4 Primary Care Co-Commissioning

Where the CCG undertake joint or delegated co-commissioning, procurement decisions relating to primary care will be undertaken by sub-committees of each governing body (the primary care commissioning committees). This will:  take the form of a joint committee established between the CCG and NHS England in the case of joint commissioning  take the form of a committee established by the CCG in the case of delegated co- commissioning

In either case, the membership of the committee will ensure that the majority is held by lay and executive members (provided they are not GPs or have any other related conflicts of interests). The chair and deputy chair of the committee will be lay members, however, the chair of the audit and governance committee / CCG’s conflicts of interest guardian is excluded from being appointed as the chair of these committees.

Provision will be made for the committee to have the ability to call on additional lay or CCG members when required (e.g. to remain quorate). The committee could also include GP representatives from other CCG areas and non-GP clinical representatives.

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There will be a standing invitation for (as a minimum) representatives of the CCG’s local Healthwatch and Health and Wellbeing Boards to attend committee meetings, although they will not form part of the membership of the committee. As the CCG cover two local authority areas, the CCG will agree with them which Healthwatch and Health and Wellbeing board will be represented. As a general rule, meetings of the committee, including the decision-making and the deliberations leading up to the decision, will be held in public (unless the CCG have concluded it is appropriate to exclude the public).

The CCG may wish to include decisions on other commissioning matters within the remit of the committee. They may also wish to designate an existing committee to incorporate these responsibilities within their remit, provided the membership and chairing arrangements comply with the requirements outlined above or that when dealing with primary care procurement issues, the participating membership and chairing arrangements are adjusted to meet these requirements.

The CCG may establish sub-committees or sub-groups of the primary care commissioning committee (or equivalent body). However, ultimate decision-making responsibility for primary medical services functions must remain with the primary Care commissioning committee.

The arrangements for primary medical care decision-making do not preclude GP participation in strategic discussions on primary care issues, subject to appropriate management of conflicts of interest. Rather these arrangements apply to decision-making on procurement issues and the deliberations leading up to the decision.

11 Implementation, and dissemination and training

Once approved by the governing body, this policy will be available to the public and all relevant individuals and organisations via the CCG website.

Once approved, notification that the policy has been updated and a summary of the key changes made will be sent to all employees, governing body members, members of governing body and CCG committees and sub-committees and to member practices. The policy will be provided to new appointees as part of the CCG’s induction process, who will also confirm in writing that they have read and understood its requirements (see Appendix F for the Policy Declaration Form).

NHS England has developed an on-line training package on conflicts of interest. Three levels of training are available relating to an individual’s role and the extent of their involvement with conflicts of interest management. Only the first module is mandatory and only for those deemed as ‘decision-taking’ (see Section 7.4 for the CCG’s definition of ‘decision-making staff’); this training must be repeated on an annual basis compliance with the uptake of module one of the training will form part of the CCG’s performance assessment by NHS England.

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Any individuals who consider themselves in need of immediate training or further guidance should contact the head of governance for assistance.

12 Review and monitoring

The CCG monitor and review their performance in relation to the policy through a programme of internal and external audit work and through the oversight of the CCG governing body and audit and governance committee.

13 Public sector equality duty

The Equality Act 2010, available on the GOV.UK website, includes a general legal duty to: eliminate unlawful discrimination, harassment victimisation and any other conduct prohibited under the Act advance quality of opportunity between people who share a protected characteristic and people who do not share it foster good relations between people who share a protected characteristic and people who do not have it

The protected characteristics are:  age  disability  gender reassignment  marriage or civil partnership  pregnancy and maternity  race  religion or belief  sex  Sexual orientation

It is no longer a specific legal requirement to carry out an equality impact assessment on all policies, procedures, practices and plan but, as described above, the CCG do need to be able to demonstrate they have paid due regard to the general duty.

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The policy establishes how the CCG will ensure best practice is followed in managing actual or potential conflicts of interest and sets out the safeguards that will put be put in place to ensure transparency, fairness and probity in decision-making. It is not believed that this policy will impact on or affect differently or adversely any of the groups with protected characteristics

14 References

 NHS Bradford District and Craven CCG governing body constitution  West Yorkshire Audit Consortium: Policy on Business Conduct and Management of Conflicts of Interest Template  Managing Conflicts of Interest Statutory Guidance for CCGs NHS England (June 2017)  The UK Corporate Governance Code, Financial Reporting Council (2016)  NHS Clinical Commissioners, Royal College of General Practitioners and British Medical Association – Shared Principles on conflicts of interests when CCGs are commissioning from member practices (2014)  Standards for Members of NHS Boards and CCG Governing Bodies in England, Professional Standards Authority (2013)  Code of Conduct: Managing Conflicts of Interest Where GP Practices are Potential Providers of CCG Commissioned Services , NHS Commissioning Board (2013)  Monitor – Substantive Guidance on the Procurement, Patient Choice and Competition Regulations (2013)  Good Medical Practice, General Medical Committee (2013) (updated April 2014)  Ensuring Transparency and Probity, British Medical Association (2011)  The Good Governance Standards for Public Services, Office for Public Management and Chartered Institute of Public Finance and Accountancy (2004)  Seven Principles of Public Life, Committee on Standards in Public Life, (1995)

15 Appendices

APPENDIX A Nolan Principles of Public Life – The 7 Principles of Public Life APPENDIX B Declaration of Interests Form APPENDIX C Conflicts of Interest Checklist for Chairs APPENDIX D Bidders / Potential Contractors / Service Providers Declaration Form APPENDIX E Procurement Template When Potentially Purchasing From GP Practices APPENDIX F Conflicts of Interest Case Studies APPENDIX G New Starter Policy Declaration

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APPENDIX A Nolan principles – the seven principles of public life

The ‘Nolan Principles’ set out the ways in which holders of public office should behave in discharging their duties. The seven principles are:

1. selflessness – Holders of public office should act solely in terms of the public interest. They should not do so in order to gain financial or other benefits for themselves, their family or their friends.

2. integrity – Holders of public office should not place themselves under any financial or other obligation to outside individuals or organisations that might seek to influence them in the performance of their official duties.

3. objectivity – In carrying out public business, including making public appointments, awarding contracts, or recommending individuals for rewards and benefits, holders of public office should make choices on merit.

4. accountability – Holders of public office are accountable for their decisions and actions to the public and must submit themselves to whatever scrutiny is appropriate to their office.

5. openness – Holders of public office should be as open as possible about all the decisions and actions they take. They should give reasons for their decisions and restrict information only when the wider public interest clearly demands.

6. honesty – Holders of public office have a duty to declare any private interests relating to their public duties and to take steps to resolve any conflicts arising in a way that protects the public interest.

7. leadership – Holders of public office should promote and support these principles by leadership and example.

Source: The First Report of the Committee on Standards in Public Life (1995)

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APPENDIX B

Declaration of interests form

This form is required to be completed in accordance with the CCG’s Constitutions, and s140 of the NHS Act 2006 (as amended by the Health and Social Care Act 2012) and the NHS (Procurement, Patient Choice and Competition) (No2) Regulations 2013 and related guidance.

The information submitted will be held by the CCG for personnel or other reasons specified on this form and to comply with the organisation’s policies. This information may be held in both manual and electronic form in accordance with the Data Protection Act and General Data Protection Regulations. Information may be disclosed to third parties in accordance with the Freedom of Information Act 2000 and, in the case of ‘decision making staff’ (as defined in the statutory guidance on managing conflicts of interest for CCGs) may be published in registers that the CCG holds. All interests will remain on the register for 6 months after the interest has expired. In addition the CCG will retain a private record of all expired interests for a total of 6 years.

‘Decision taking staff’ (see Section 7.4 of the Conflicts of Interest Policy for the definition) and CCG members should be aware that the information provided in this form will be added to the CCG’s registers which are held in hardcopy for inspection by the public and published on the CCG’s website. Decision making staff must make any third party whose personal data they are providing in this form aware that the personal data will held in hardcopy for inspection by the public and published on the CCG’s website and must inform the third party that the CCG’s privacy policy is available on the CCG’s website. If you are not sure whether you are a ‘decision making’ member of staff, please refer to Section 7.4 of the CCG’s Conflicts of Interest Policy or speak to your line manager before completing this form.

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Name:

Position within, or relationship with, the CCG (or NHS England in the event of joint committees):

Detail of interests held (complete all that are applicable):

Type of Description of Interest (including for Date interest Actions to be Interest* indirect Interests, details of the relates taken to relationship with the person who has the mitigate risk *See interest) From and To reverse (to be agreed of form with line for manager or a details senior CCG manager - see Note 1)

Note 1: Where deemed possible and necessary, specific actions to mitigate risks will be agreed between individuals and the CCG and / or their line manager and recorded on this form and on the Register of Interests.

Note 2: Where there are no interests to declare, please record this above and return the form to the CCG.

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I confirm that the information provided above is complete and correct. I acknowledge that any changes in these declarations must be notified to the CCG as soon as practicable and no later than 28 days after the interest arises. I am aware that if I do not make full, accurate and timely declarations then civil, criminal, or internal disciplinary action may result, where an indirect interest has been declared, I will make the relevant individual or organisation (s) aware that the CCG holds this information.

I do / do not [delete as applicable] give my consent for this information to be published on registers that the CCG holds and on the CCG’s website (see Note 3 below for details of exceptions to publication). If consent is NOT given please give reasons:

Signed: ...... Date: ......

Position: ......

(Line manager or senior CCG manager – signature only required if specific actions are agreed to mitigate risks)

Note 3: In exceptional circumstances, where the public disclosure of information could give rise to a real risk of harm or is prohibited by law, an individual’s name and / or other information may be redacted from the publicly available registers. Where an individual believes that substantial damage or distress may be caused to him / herself or somebody else by the publication of information about them, they are entitled to request that the information is not published. Such requests must be made in writing. Decisions not to publish information must be made by the CCG’s Conflicts of Interest Guardian who will seek appropriate legal advice where required and the CCG’s will retain a confidential, un-redacted version of the register.

Please return completed forms to: [email protected] or [email protected] or [email protected] If you have any queries regarding the completion of this form or as to whether or not an interest should be declared, please contact Sarah Dick, Head of Governance for a confidential discussion via [email protected]

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Types of Interest

Type of Description Interest

This is where an individual may get direct financial benefits from the Financial consequences of a commissioning decision. This could, for example, include Interests being:  A director, including a non-executive director or senior employee in a private company or public limited company or other organisation which is doing, or which is likely, or possibly seeking to do, business with a health or social care organisation.  A shareholder (or similar ownership interests), a partner or owner of a private or not-for-profit company, business, partnership or consultancy which is doing, or which is likely, or possibly seeking to do business with a health or social care organisation.  A management consultant for a provider

This could also include an individual (or their practices, in the case of GPs) being:

 In secondary employment (see Section 8.2)  In receipt of secondary income from a provider.  In receipt of a grant from a provider.  In receipt of payments (for example, Honoria, one-off payments, day allowances or travel or subsistence) from a provider.  In receipt of funding from the pharmaceutical or med-tech industry as part of a joint working arrangement.  In receipt of research funding, including grants that may be received by the individual or any organisation in which they have an interest or role; and  Having a pension that is funded by a provider (where the value of this might be affected by the success or failure of the provider).

Non- This is where an individual may obtain a non-financial professional benefit from Financial the consequences of a commissioning decision, such as increasing their Professio professional reputation or status or promoting their professional career. This nal may, for example, include situations where the individual is:An advocate for a Interests particular group of patients;

 A GP with special interests e.g., in dermatology, acupuncture etc.  A member of a particular specialist professional body (although routine GP

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Type of Description Interest

membership of the RCGP, BMA or a medical defence organisation would not usually by itself amount to an interest which needed to be declared);  An advisor for Care Quality Commission (CQC) or National Institute for Health and Care Excellence (NICE);  A medical researcher.

Non- This is where an individual may benefit personally in ways which are not Financial directly linked to their professional career and do not give rise to a direct Personal financial benefit. This could include, for example, where the individual is: Interests  A voluntary sector champion for a provider;  A volunteer for a provider;  A member of a voluntary sector board or has any other position of authority in or connection with a voluntary sector organisation;  Suffering from a particular condition requiring individually funded treatment;  A member of a lobby or pressure groups with an interest in health. This is where an individual has a close association with an individual who has a Indirect financial interest, a non-financial professional interest or a non-financial Interests personal interest in a commissioning decision (as those categories are described above). For example, this should include:  Spouse / partner;  Close relative e.g., parent, grandparent, child, grandchild or sibling;  Close friend;  Business partner.

If there is any doubt as to whether or not an interest is relevant, a declaration of the interest should be made

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APPENDIX C

Conflicts of interests check list for meeting chairs

Meeting chairs have responsibility for ensuring the appropriate management of conflicts of interest during the course of CCG meetings (see below for a definition and examples of ‘interests’). In particular they must ensure:

 They are familiar with the contents of the Registers of Interests as pertinent to their Group or Committee. The CCG’s Registers of Interests can be accessed here: https://www.bradfordcravenccg.nhs.uk/ccg-information/publication-scheme/lists-and-registers/  They prepare for the meeting mindful of any actual or potential conflicts of interest that may arise relevant to the business of that meeting. Where conflicts of interest are known in advance, the individual concerned must not receive the supporting papers or minutes of the meeting which relate to the matter(s) which give rise to the conflict.  That declarations of interest are always an item on the agenda.  That the meeting is quorate and that this is recorded in the minutes.  That members are asked to declare any interests that are likely to lead to a conflict or potential conflict that could impact (or has the potential to impact) on any items on the agenda. This should be repeated again at individual item(s) where it is considered a conflict is likely to or could potentially arise.  Any declaration must be made clearly noted in the minutes both at the start of the meeting and at the relevant item. If there is any doubt as to whether or not a conflict of interest could arise, a declaration should be made and noted in the minutes.

 Where the Chair has a conflict of interest, deciding that the vice Chair (or another non- conflicted member of the meeting if the vice Chair is also conflicted) should chair all or part of the meeting;  Requiring the individual who has a conflict of interest (including the Chair or vice Chair if necessary) not to attend the meeting;  Ensuring that the individual concerned does not receive the supporting papers or minutes of the meeting which relate to the matter(s) which give rise to the conflict;  Requiring the individual to leave the discussion when the relevant matter(s) are being discussed and when any decisions are being taken in relation to those matter(s). In private meetings, this could include requiring the individual to leave the room and in public meetings to either leave the room or join the audience in the public gallery;

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 Allowing the individual to participate in some or all of the discussion when the relevant matter(s) are being discussed but requiring them to leave the meeting when any decisions are being taken in relation to those matter(s). This may be appropriate where, for example, the conflicted individual has important relevant knowledge and experience of the matter(s) under discussion, which it would be of benefit for the meeting to hear, but this will depend on the nature and extent of the interest which has been declared;  Noting the interest and ensuring that all attendees are aware of the nature and extent of the interest, but allowing the individual to remain and participate in both the discussion and in any decisions. This is only likely to be the appropriate course of action where it is decided that the interest which has been declared is either immaterial or not relevant to the matter(s) under discussion. The conflicts of interest case studies include examples of material and immaterial conflicts of interest.  In making this decision the Chairs will need to consider the following points:

o the nature and materiality of the decision o the nature and materiality of the declared interest(s) o the availability of relevant expertise o as a general rule (and subject to the judgement of the Chairs), if an interest involves a financial interest or a significant non-financial interest, the individual should be asked to leave the meeting for the whole item

 Any declaration arising during the course of a meeting / individual item must be minuted and action how to handle it agreed by the Chair and recorded in the minutes It is imperative that CCGs ensure complete transparency in their decision making processes through robust record-keeping. If any conflicts of interest are declared or otherwise arise in a meeting, the Chair must ensure the following information is recorded in the minutes:  Who has the interest;  The nature of the interest and why it gives rise to a conflict, including the magnitude of any interest;  The items on the agenda to which the interest relates;  How the conflict was agreed to be managed; and  Evidence that the conflict was managed as intended (for example

recording the points during the meeting when particular individuals left or returned to the meeting).  Quoracy of the meeting or for individual items must be checked if an interest is declared. If the meeting is no longer quorate (in full or for particular items) or there is insufficient relevant expertise to inform decision-making once those with conflicts of interests are excluded, the Chairs must agree how this should be managed, i.e. defer the item / meeting or refer any decisions for particular items(s) to another Committee for consideration and formal approval.  Refer to Standard Financial Instructions for Delegated Limits

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Definition of conflicts of interest (Section 5 of the CCG conflicts of interest policy)

Conflicts of interest may arise where personal interests or loyalties conflict with those of the CCGs. Such conflicts may create problems such as inhibiting free discussions which could result in decisions or actions that are not in the best interests of the CCGs, patients or the public and risk creating the impression that the CCGs have acted improperly.

NHS England defines a conflict of interest as occurring:

“Where an individual’s ability to exercise judgement or act in a role is, could be, or is seen to be impaired or otherwise influenced by his or her involvement in another role or relationship.

In some circumstances, it could be reasonably considered that a conflict of interest exists even when there is no actual conflict” (i.e. a perceived conflict).

NHS England identifies four categories of conflicts of interest:

Financial interests

This is where an individual may get direct financial benefits from the consequences of a commissioning decision. This could, for example, include being:  A director, including a non-executive director or senior employee in a private company or public limited company or other organisation which is doing, or which is likely, or possibly seeking to do, business with a health or social care organisation.  A shareholder (or similar ownership interests), a partner or owner of a private or not-for- profit company, business, partnership or consultancy which is doing, or which is likely, or possibly seeking to do business with a health or social care organisation.  A management consultant for a provider

This could also include an individual (or their practices, in the case of GPs) being:

 In secondary employment (see Section 8.2)  In receipt of secondary income from a provider.

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 In receipt of a grant from a provider.  In receipt of payments (for example, Honoria, one-off payments, day allowances or travel or subsistence) from a provider.  In receipt of funding from the pharmaceutical or med-tech industry as part of a joint working arrangement.  In receipt of research funding, including grants that may be received by the individual or any organisation in which they have an interest or role; and  Having a pension that is funded by a provider (where the value of this might be affected by the success or failure of the provider).

Non-financial professional interests

This is where an individual may obtain a non-financial professional benefit from the consequences of a commissioning decision, such as increasing their professional reputation or status or promoting their professional career. This may, for example, include situations where the individual is:  An advocate for a particular group of patients;  A GP with a special interest(s);  A member of a particular specialist professional body (although routine GP membership of the Royal College of General Practitioners, British Medical Association or a medical defence organisation would not usually by itself amount to an interest which needed to be declared);  An advisor for the Care Quality Commission (CQC) or the National Institute for Health and Care Excellence (NICE);  A medical researcher.

Non-financial personal interests

Indirect interests

This is where an individual has a close association with an individual who has a financial interest, a non-financial professional interest or a non-financial personal interest in a commissioning decision, for example:  Spouse / partner  Close relatives e.g. parent, grandparent, child, grandchild or sibling;

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 Close friend;  Business partner. A declaration for a “business partner” in a GP partnership should include all relevant collective interests of the partnership and all interests of their fellow GP partners (this could be done by cross-referring to the separate declarations made by those GP partners).

It is not possible to define all instances in which an interest may be a real or perceived conflict.

If in doubt it is better to assume the existence of a conflict of interest and declare it, rather than ignore it.

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APPENDIX D

Bidders / Potential Contractors / Service Providers Declaration Form

This form is required to be completed in accordance with the individual CCG’s Constitution, and s140 of the Act 2006 (Health Act 2006) (as amended by section 25 of the Health and Social Care Act 2012) and the NHS (Procurement, Patient Choice and Competition) (No2) Regulations 2013 and related guidance.

Notes

 All potential bidders / contractors / service providers, including sub-contractors, members of a consortium, advisers or other associated parties (the Relevant Organisation) are required to identify any potential conflicts of interest that could arise if the Relevant Organisation were to take part in any procurement process and / or provide services under or otherwise enter into any contract with the CCG.  If any assistance is required in order to complete this form, then the Relevant Organisation should contact CCG’s Corporate Governance Team.  The completed form should be sent to the CCG’s Corporate Governance Team.  Any changes to interests declared either during the procurement process or during the terms of any contract subsequently entered into by the Relevant Organisation and the CCG must be notified to the CCG by completing a new declaration form and submitting it to the CCG Corporate Governance Team.  Relevant organisations completing this declaration from must provide sufficient detail of each interest so that a member of the public would be able to understand clearly the interest the organisation and any Relevant Person within it has and the circumstances in which a conflict of interest with the business or running of the CCG might arise.  If in doubt as to whether a conflict of interest could arise, a declaration of the interest should be made.

Interests must be declared (whether such interests are those of the Relevant Person themselves or of a family member, close friend or other acquaintance of the Relevant Person), including the following:  The Relevant Organisation or any person employed or engaged with a Relevant Organisation (Relevant Person) has provided or is providing services or other work to the CCG.  A Relevant Organisation or Relevant Person is providing services or other work for any other potential bidder in respect of this project or procurement process  The Relevant Organisation or any Relevant Person has any other connect with the CCG whether personal or professional, which the public could perceive may impair or otherwise influence the CCG or an any of its member’ or employees’ judgements, decisions or actions

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Name of Relevant

Organisation

Interests

Type of Interest Details

Provision of services or other work for the CCG

Provision of services or other work for any other potential bidder in respect of this project or procurement process

Any other connection with the CCG, whether personal or professional, which the public could perceive may impair or otherwise influence the CCG’s or any of its members’ or employees’ judgements, decisions or actions.

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Complete for all relevant Name of Relevant Person Persons

Interests

Type of Interest Details Personal interest or that of a family member, close friend or other acquaintance

Provision of services or other work for the CCG

Provision of services or other work for any other potential bidder in respect of this project or procurement process

To the best of my knowledge and belief, the above information is complete and correct. I undertake to update as necessary the information.

Signed: ......

Print Name ......

On behalf of ......

Date ......

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APPENDIX E

Procurement Template When Potentially Purchasing From GP Practices

To be used when commissioning services from GP practices, including provider consortia or organisations in which GPs have a financial interest.

Service:

Question Comment/Evidence

Questions for all three procurement routes (Competitive Tender, AQP, Single Tender)

How does the proposal deliver good or improved outcomes and value for money – what are the estimated costs and the estimated benefits? How does it reflect the CCG’s proposed commissioning priorities? How does it comply with the CCG’s commissioning obligations?

How have you involved the public in the decision to commission this service?

What range of health professionals have been involved in designing the proposed service?

204

Service:

Question Comment/Evidence

What range of potential providers have been involved in considering the proposals?

How have you involved your Health and Wellbeing Board(s)? How does the proposal support the priorities in the relevant joint health and wellbeing strategy (or strategies)?

What are the proposals for monitoring the quality of the service?

What systems will there be to monitor and publish data on referral patterns?

Have all conflicts and potential conflicts of interests been appropriately declared and entered in registers which are publicly available?

205

Service:

Question Comment/Evidence

In respect of every conflict or potential conflict, you must record how you have managed that conflict or potential conflict. Has this management of all conflicts been recorded with a brief explanation of how they have been managed?

Why have you chosen this procurement route?1

What additional external involvement will there be in scrutinising the proposed decisions?

How will the CCG make its final commissioning decision in ways that preserve the integrity of the decision-making process?

Additional question when qualifying a provider on a list or framework or pre-selection for tender (including but not limited to any qualified provider) or direct aware (for services where national tariffs do not apply)

How have you determined a fair price for the service?

1 Taking into account all relevant regulations (e.g. the NHS Procurement, Patient Choice and Competition Regulation 2013 and guidance (e.g. that of Monitor)

206

Additional questions when qualifying a provider on a list or framework or pre- selection for tender (including but not limited to any qualified provider) where GP practices are likely to be qualified providers

How will you ensure that patients are aware of the full range of qualified providers from whom they can choose?

Additional questions for proposed direct awards (i.e. single tender actions) to GP providers

Question Comment/Evidence

What steps have been taken to demonstrate that there are no other providers that could deliver this service?

In what ways does the proposed service go above and beyond what GP practices should be expected to provide under the GP contract?

What assurances will there be that a GP practice is providing high-quality services under the GP contract before it has the opportunity to provide any new services?

207

APPENDIX F

Conflicts of Interest Case Studies

https://www.england.nhs.uk/commissioning/wp-content/uploads/sites/12/2016/06/coi-case- studies-jun16.pdf

208

APPENDIX G

New Starter Policy Declaration Form

I declare that I have read and understood the CCG’s:

 Conflicts of Interest & Standards of Business Conduct

 Policy on the Offer and Receipt of Gifts, Hospitality & Sponsorship

Name: ______

Role: ______

Signature: ______

Date: ______

Please return this form to HR for retention on your personal file: [email protected]

209 Agenda item 14

Name of meeting Governing Body Meeting date 9 March 2021

Risk Register Report: Cycle 5 Stacey Fleming, Senior Title of report Report author(s) 2020-21 (January - February) Governance and Resilience Manager Sue Baxter, Strategic Lead(s) / SRO Helen Hirst, Chief Officer Report lead(s) Head of Assurance

Paper summary and/or key discussion points

The purpose of the paper is to provide the Governing Body with details of ‘high level risks’ (those scoring 15 or more), new risks identified and risks closed during the current risk review cycle.

Corporate risk register (updated bi-monthly)

 There is one risk at the ‘critical’ level (scoring 20 or 25) relating to the COVID pandemic. This risk is underpinned by the detailed COVID risk register.  There are 12 risks classed as ‘serious’ (scoring 15 or 16).  Two new risks have been added to the risk register in the current cycle; one of these relates to unidentified carers (scoring 20), another relates to designated doctor provision for children in care (scoring 12).  One risk relating to compliance with website and apps accessibility regulations increased in score this cycle (current score is now 5 whereas previously this was a 4).  Two risks have decreased in score this cycle. The risks relate to member engagement in a larger CCG and post pandemic (current score is now 6, previously this scored 12) and IG processes and handling of personal data (current score is 6 but previously this scored 9).  No risks are marked for closure.

COVID risk register (currently updated monthly)

 There are four risks at the ‘critical’ level, three of which are scored at 20. One critical risk (relating to demand for mental health services) increased in score this cycle from 20 to 25.  There are three risks at the serious level (scoring 15 or 16).  One new risk was added during this cycle relating to delays in 3 & 12 month CHC reviews, appeals and retrospective CHC reviews (scoring 9).  One risk relating to complaints/legal challenges due to suspending means testing during Covid-19 has decreased in score from 9 to 4.

[Note: please outline the key factors within this paper that will help us achieve one or more of our strategic ambitions for our population, our partnerships, our people, our leadership and what are the associated consequences and/or potential risks]

Page 1 of 2 210 A robust risk management framework is essential to supporting the delivery of the CCG strategy. The CCG’s new assurance framework is in the early stages of development. This will set out the higher- level and longer-term risks to achievement of the CCG strategy. The assurance framework is underpinned by the corporate and Covid-19 risk registers which set out the CCG’s more operational risks and their management. See the Covid-19 and corporate risk logs.

Purpose assurance information decision action

approve / recommend / review / consider / support / ratify comment / discuss Recommendation(s)

The governing body is asked to receive and note the risk report and high level risk logs.

Appendices (or other supporting papers) Appendix 1: Risk report including scoring matrices and risk overview diagram Appendix 2: Corporate risk register; high level risk log Appendix 3: Covid-19 risk register; high level risk log

Page 2 of 2 211

Risk Register Report: Cycle 5 2020-21 (January 2021 – February 2021)

1.0 Purpose of the Report

1.1 To provide the Governing Body with details as at the end of Risk Cycle 5 2020-21, of:

 ‘high level risks’ (those scoring 15 or more)  new risks added to the risk register during the current risk cycle  risks closed during the current risk cycle.

2.0 Risk Review and Reporting Process

2.1 There are normally six risk review cycles per annum. The process for the review and reporting of the CCGs’ corporate risk register is as follows:

 Review of individual risks by Risk Owners  Review of individual risks by allocated Senior Managers  Review of all risks by the Senior Leadership Team (SLT)  Review of all risks by either the Finance and Performance Committee (FPC) or Quality Committee (QC)  Further report to SLT prior to Governing Body reporting by exception.  Reporting of risks scoring 15 or more, plus new and closed risks, to the Governing Body.

2.2 In addition, the corporate risk register is a standing item on the agenda of standard Audit and Governance committee meetings in order to provide assurance on the risk management process.

3.0 Corporate Risk Cycle 5 January – February 2021

3.1 Please see Appendix 2 for the CCG risk overview diagram.

3.2 Numbers of risks and average risk scores are shown in the table below:

212 Numbers of risks and average risk scores

Total number of open risks 32 Number of open risks aligned to Finance and Performance Committee (FPC) 15

Number of open risks aligned to Quality Committee (QC) 17

CCG average risk score 12.44

FPC average risk score 11.33

QC average risk score 13.41

3.3 Two new risks were added to the risk register in the current risk cycle, details of which can be found in the table below:

Details of new risks

Risk scores are calculated by multiplying the impact by the likelihood.

Risk reference Risk summary Current risk score number 1726 UNIDENTIFIED CARERS Overall score is 20 Impact score is 5 There is a risk that unpaid carers are not identified as carers Likelihood score is 4 and are therefore not offered assessment and support, resulting in worse mental and physical health and increased acute care needs for both the carer and the person they look after. 1712 DESIGNATED DOCTOR PROVISION FOR CHILDREN IN Overall score is 12 CARE Impact score is 3 Likelihood score is 4 The CCG does not effectively fulfil its statutory duties due to the resignation of Designated Doctors for Children in care with a resultant gap in the strategic designated health leadership of Children in Care services .

3.4 There are two risks currently classed as ‘critical’ (scoring 20 to 25) one of which is new and detailed above. The other critical risk is details below.

Details of critical risk

Risk scores are calculated by multiplying the impact by the likelihood. Risk Risk summary Current risk score reference number

1495 COVID-19 PANDEMIC Overall score is 25

There is a risk of a COVID-19 pandemic resulting in an Impact score is 5 enormous public health impact with substantial fatal outcomes in high-risk groups and economic and social Likelihood score is 5 disruption. Latest risk assessments by the European Centre for Disease

213 Risk Risk summary Current risk score reference number Prevention and Control (ECDPC) (which includes a risk assessment for the UK) available at www.ecdc.europa.eu. The risk associated with COVID-19 infection for people in the EU/EEA and UK is currently considered to be as follows as at 22 April 2020 (latest risk assessment available at 22 May 2020):  low/moderate risk of severe COVID-19 disease for the general population if social distancing measures are met.  moderate / very high risk of severe COVID-19 for older adults and individuals with chronic underlying conditions.

3.5 ‘Serious’ risks are those scoring 15 or 16. The current number of ‘serious’ risks is 12 in total. Two risks will be reported in private and the remaining ‘serious’ risks are noted below:

Details of serious risks Risk scores are calculated by multiplying the impact by the likelihood.

Risk Risk summary Current risk Previous Cycle 5 update reference score risk score number Risk not reviewed. 1694 Underlying financial position Overall score Risk has risk is 16 been static in (FPC) score for one Impact is 4 cycle.

Likelihood is 4 . 1693 Financial Position Risk Overall score Risk has Risk not reviewed. 2020/21 (M7 to M12). is 16 been static in (FPC) score for one Impact is 4 cycle.

Likelihood is 4

1135 Adult Autism and/or ADHD Overall score Risk has We continue to work with Assessment and Diagnosis is 16 been static the provider and there is (QC) for 10 cycles. to be a sub group looking Impact is 4 at neurodiversity as part of the newly developed Likelihood is Mental health, LD and 4 Neurodiversity HCPB.

A systems senior 1134 Health outcomes for children Overall score Risk has leadership group has looked after. is 16 been static been established to (QC) for 18 cycles. oversee the Impact is 4 implementation of the Likelihood is clinical model which will 3

214 Risk Risk summary Current risk Previous Cycle 5 update reference score risk score number 4 be in place and operational by 1 April 2021. We have identified a cohort of GPs who are interested in supporting this model and BDCFT have agreed to offer the GPs honorary contracts of employment. A training package is currently in development. Interim Designated Dr support has been identified.

The waiting list has 1094 Child autism and/or ADHD Overall score Risk has decreased from 1854 assessment and diagnosis is 16 been static in (Aug) to 1798 (Oct). (QC) score for 18 Despite COVID, referrals Impact is 4 cycles. remain consistent with 829 referrals in the last 11 Likelihood is 4 months, projection of 904 referrals per year. All services including external providers have resumed face to face assessments. Some parents have raised concern in relation to the COVID impact on the autism assessment waiting times. A communication is being compiled will be circulated widely across the system to update parents regarding the autism service and waiting times. As a result of funding identified to utilise external providers 45 children have received their outcomes. A further 151 children are awaiting their outcomes from external providers – assessments were delayed due to COVID restrictions. Additional funding for a further 60 referrals to an external provider has been identified and the transfer process has commenced. A patient feedback survey has been completed with 4

215 Risk Risk summary Current risk Previous Cycle 5 update reference score risk score number the first cohort of families referred to Helios where a remote assessment was completed. This provided positive feedback on the Helios process and some constructive feedback on the District Neuro Development Assessment Services. An action plan has been developed to act upon issues raised. 940 BTHFT maternity services Response to Ockenden Overall score Static – 4 report - BTHFT complaint (QC) is 16 cycles with first stage of recommendation. Impact is 4 Evidence submitted to

Likelihood is LMS and regional HOM 4

1549 There is a risk that local Overall score Risk has New expenditure financial control will be lost and is 15 been static in approvals reported to (FPC) replaced by national directives score for four the Finance & Impact is 3 over the use of CCG resources cycles. Performance in 2020/21 due to the COVID- Committee. 19 pandemic. This may mean Likelihood is 5 that planned investments are COVID-19 expenditure put on hold. reported to SLT and the Finance & Performance Committee.

Assurance received via 1404 0-19 Services impact on CCG Overall score Risk has Partnership Group that commissioned services is 15 been static in BDCFT are progressing (QC) score for the implementation of the Impact is 3 eight cycles. agreed contract. Likelihood is 5 Performance against System F&P Committee 1098 constitutional standards Overall score Static – 5 meets monthly and is 15 cycles planning now undertaken (FPC) on a system footprint. Impact is 3 System performance and Likelihood is recovery dashboards in 5 place

964 Vulnerability to cyber attack Overall score Risk has Risk not reviewed is 15 been static in (FPC) score for four Impact is 3 cycles. Likelihood is 5 5

216

3.6 One risk has increased in score during the current risk cycle:

Risk Risk summary Current risk Previous Cycle 5 update reference score risk score number Score adjusted to reflect 1681 Compliance with website and Overall score Overall score current position regarding apps accessibility regulations is 5 was 4 meeting the accessibility (FPC) regulations. Impact is 1 Impact was 2

Likelihood is Likelihood 5 was 2

3.7 Two risks have decreased in score during the current risk cycle:

Risk Risk summary Current risk Previous Cycle 5 update reference score risk score number Risk score reduced 1546 Member engagement in a Overall score Overall score (likelihood down from 3 to larger CCG and post pandemic is 6 was 12 2) as the plan has been (FPC) agreed and is now moving Impact is 3 Impact was 4 to implementation The Likelihood is Likelihood reduced funding has also 2 was 3 been accepted.

Last significant CCG IG 1397 IG processes and handling of Overall score Overall score incident was summer personal data is 6 was 9 2019 and BD&C IG work- (FPC) stream now meeting Impact is 3 Impact was 3 regularly - score reduced Likelihood is Likelihood from L3xI3 = 9 to L2xI3 = 2 was 3 6

3.8 No risks have been marked for closure during the current review cycle.

4.0 Covid-19 Risk log update

4.1 Please see Appendix 4 Covid-19 risk log for further details.

4.2 The Covid-19 risk log has been moved on to the on-line risk register system. The Covid-19 risk log will be reviewed on a monthly basis and the CCG corporate risk register will continue to be reviewed bi-monthly.

217 4.3 There are a total of 15 open risks on the Covid-19 risk log, of these:

 seven risks align for assurance purposes with the Quality Committee  six risks align with the Finance and Performance Committee  two risks align with both FPC and QC

4.4 Following the latest updates provided to SLT on 23 February 2021 and F&P Committee and Quality Committee on 4 February 2021:

 One new risk was added to the COVID risk log:

Risk reference Risk summary Current risk score number 1727 There is a risk of delayed 3 & 12 month CHC reviews, CHC Overall score is 9 appeals and retrospective CHC reviews which are a result of Impact score is 3 (QC) the NHSE direction to complete the C-19 CHC backlog Likelihood score is 3 caseload by 31st March 2021.

 One risk has increased in score relating to the demand for Mental Health services has increased from 20 (I5xL4) to 25 (I5xL5)

Risk Risk summary Current risk Previous Cycle 5 update reference score risk score number The increases in referrals 1613 Demand for mental health Overall score Overall score and non-elective services is 25 was 20 admissions via AED and (QC) crisis service has seen a Impact is 5 Impact was 5 significant increase Likelihood is Likelihood particularly for children. 5 was 4 We have made adjustments and changes to how current services and staffing is delivered to manage demand but pressures on service continue.

 One risk has decreased in score:

Risk Risk summary Current risk Previous Cycle 5 update reference score risk score number Position remains the 1575 Complaints/Legal challenges Overall score Overall score same with regard to no due to suspending means is 4 was 9 increase in complaints (QC) testing during COVID and risk scores have been Impact is 2 Impact was 3 reduced. New process Likelihood is Likelihood has been agreed and 2 was 3 implemented with regard to managing providers who requests 'top up' payments from families.

218  No risks have been closed.

4.5 There are four risks at the ‘critical’ level (scoring 20 or 25) aligned to the Quality Committee. Details of risk 1613 can be found above, details of the remaining risks can found in the table below:

219 Details of critical risks on the COVID-19 risk log

Risk scores are calculated by multiplying the impact by the likelihood.

Risk Risk summary Current Score Update for Governing Body reference number

1590 Outcomes for population negatively impacted due to lack of Overall score is COVID activity increasing in secondary care but urgent clear prioritisation of restarting service. 20 services such as cancer referrals continuing as normal. In (QC) terms. Restart prioritisation managed via access program There is a risk that outcomes for our population are negatively Impact is 5 (system group). No current issues with PPE via national impacted due to: portal. No change to risk.  lack of clear prioritisation of re-starting urgent and non- Likelihood is 4 urgent services (partly due to lack of information to enable this)  limiting factors such as PPE supplies, staff testing, staff sickness, bed availability and access to equipment  the impact is patients who need access to services are unable to access them / not delivering on CCG objectives such as reducing health inequalities. Priority for January is to develop comms tools for the RIC 1582 Increased health inequalities due to socio-economic and Overall score is programme and individual projects to support the launch and ethnicity factors. 20 (QC) wider promotion of RIC services to referrers. Launch is There is a risk of increased health inequalities due to socio- Impact is 5 scheduled for 4 Feb. CLICS facilitator is in post and economic and ethnicity factors during the pandemic (evidence supporting practices with embedding the service (which to date is that the pandemic is impacting on deprived and BAME Likelihood is 4 focusses on multiple covid risk factors). We will continue to groups more than average). monitor impact of covid on service delivery to determine if The impact is failure to meet statutory duties relating to adjustments are required. reduction of health inequalities / disproportionate suffering for certain groups.

220 Risk Risk summary Current Score Update for Governing Body reference number

943 COVID Impact on Care Homes Overall score is As of 5/2/2021 COVID Outbreaks 20 • Bradford Increase in numbers of COVID positive cases in the (QC) There is an increased risk that quality of health care in care Care Homes doubled since Christmas. Currently 34 providers homes is reduced due to COVID- 19 and response required to Impact is 4 have a current outbreak within 0-28 day cycle (major outbreak at prevent and manage infections. This may result in an adverse the Beeches) Likelihood is 5 impact on the quality of care provided and the increased risk of • Currently 5 homes and 1 ECH have a current outbreak within the service user harm. 0-28 day cycle • The current number of people on the Super Rota caseload stands at 61 • COVID support Team and NYCC and partners via Care@home system group continue to support in areas such as IPC, vaccinations and testing. • Care@Home key messages • Vaccinations - 100% Care Homes offered and a few to be completed shortly.(exception beeches due to current outbreak) • Oximetry@Home - Progressing well, 18 referrals to date and best across WY&H. Three patients admitted to hospital and the rest being managed at home • Designated Beds - Troutbeck home available from this week thus increasing capacity • West Yorkshire and Harrogate funding secured, this is being utilised for 3 projects to include continuation of the Super Rota until the end of March 2021, • Bring Back Scheme –Lead for this scheme has transferred to WYICS who will do a stock take of all nurses returners and look to redirect them to local ‘nurse banks ‘ that are already established. No further action required by CCG at this point Care Home Quality As reported last month continuing to see an increase in homes that require improvements with 23 homes rated RI and 4 homes rated as inadequate with CQC. All four homes have been placed in special measures, embargo in place and are on enhanced surveillance supported by BMDC/CCG.

221

4.6 There are three risks at the ‘serious’ level (scoring 15 or 16) active on the COVID-19 risk log, of these:

 One is aligned to the Quality Committee  One are aligned to the F&P Committee  One is aligned to both committees.

Details of serious risks on the COVID-19 risk log

Risk scores are calculated by multiplying the impact by the likelihood.

Risk Risk Summary Current Score Update for Governing Body reference number

1574 End of life experience Overall score is 16 Risk remains high as we await a post holiday period analysis of pandemic increase in R rate. (QC) Impact is 4

Likelihood is 4

1713 COVID Vaccinations Overall score is 15 Continues to be a section of our community who are not confident to accept the vaccine. National and local work underway to target specific communities. (FPC & Impact is 3 Vaccine flows are stable currently, but guidance on delivery of 2nd vaccine yet QC) to be received. Likelihood is 5 Following discussion at FPC - decision made to align to both FPC & QC due to performance element of risk.

1594 Financial sustainability of the Overall score is 15 The CCG is liaising with local care home providers regarding payments for care home market services and an analysis of the how the pandemic has impacted on their (FPC) Impact is 5 capacity and resilience. Likelihood is 3

222 5.0 Recommendation

The Governing Body is asked to receive and note the High Level Risk Report and COVID-19 Risk Log. Appendices

Appendix 1: Risk Scoring Matrices (from the Integrated Risk Management Framework) Appendix 2: Risk Overview Diagram Appendix 3: High Level Risk Log Appendix 4: COVID-19 Risk Log

223 Appendix 1: Risk Scoring Matrices and Risk Grading

Impact 1. Insignificant 2. Minor 3. Moderate 4. Major 5. Catastrophic Impact

Financial £1k - £10k Up to £50k Up to £250k Up to £1M Over £1M

Some minor injuries/ Many minor injuries/ Minor bruises/ Some major injuries/ ill- Multiple Harm discomfort/ ill-health - minor. ill-health – temporarily health - permanently injuries/infections incapacitating. affects wellbeing. incapacitating Unexpected Death <3 days absence RIDDOR reportable.

No significant effect on Noticeable effect on Significant effect on Patient care Clinical care Patient care impossible quality of care provided quality of care provided quality of care provided significantly impaired

Negligible negative Minor negative impact Moderate negative Major negative impact Catastrophic negative impact on access, on access, experience impact on access, on access, experience impact on access, experience and /or and /or outcomes for experience and /or and /or outcomes for experience and /or outcomes for people people with this outcomes for people people with this outcomes for people with this protected protected with this protected protected with this protected characteristic. characteristic. Minor characteristic. characteristic. Major characteristic. Negligible increase in increase in health Moderate increase in increase in health Catastrophic increase in health inequalities by inequalities by health inequalities by inequalities by health inequalities by widening the gap in widening the gap in widening the gap in widening the gap in widening the gap in Quality access, experience and access, experience access, experience and access, experience and access, experience and /or outcomes between and /or outcomes /or outcomes between /or outcomes between /or outcomes between people with this between people with people with this people with this people with this protected characteristic this protected protected characteristic protected characteristic protected characteristic and the general characteristic and the and the general and the general and the general population. general population. population. Potential to population. population. Potential to result in result in moderate Potential to lead to Potential to result in minimal injury requiring Potential to result in injury requiring major injury leading to incident leading to no/minimal intervention minor injury or illness, professional long-term death, multiple or treatment, peripheral requiring minor intervention. incapacity/disability permanent injuries or

224 1. Insignificant 2. Minor 3. Moderate 4. Major 5. Catastrophic Impact element of treatment intervention and overall irreversible health suboptimal and/or treatment suboptimal" effects, an event which informal impacts on a large complaint/inquiry number of patients, totally unacceptable level or effectiveness of treatment, gross failure of experience and does not meet required standards

National Performance National Performance Internal Standards not Repeated failure to Performance not achievable not achievable achievable meet internal standards (Intermittent) (Continuous)

Audit non- Breach of procedure/ Government Enforcing action conformance/advice Directive from Improvement Notice. Prohibition Notice. Investigation. from enforcers. enforcers.

Likelihood

Level Descriptor Description

1 Rare The event may occur only in exceptional circumstances

2 Unlikely The event could occur at some time

3 Possible The event should occur at some time.

4 Likely The event will probably occur in most circumstances.

5 Almost Certain The event is expected to occur.

225 Score and risk level

Score Risk Level

1-3 Low risk

4-6 Moderate risk

8-12 High risk

15-16 Serious risk

20-25 Critical risk

226

Appendix 2: Risk Overview Diagram

227 Corporate Risk Log for Governing Body as at 2.02.21 Principal Risk Key Controls Key Control Gaps Assurance Controls Positive Assurance Assurance Gaps GBAF Entry Description(s) Risk Risk Risk Risk Risk Risk Risk Date Date No(s) Status Rating Target Senior Risk ID Risk Owner Created Category Manager GBAF Ref Risk Type Risk

25 COVID-19 PANDEMIC - Full gold, silver and bronze command structure in - Rapidly changing nature of the prevalence of COVID- UPDATE FOR SLT: - Local arrangements have been established in line with - Unknown how high compliance is with social QC

1495 place in the CCG and across Bradford district and 19 means that actions and arrangements required are national guidance. distancing measures. (I5xL5)

Liz Allen Liz There is a risk that the COVID-19 pandemic will result Craven. constantly changing. - Local and national intelligence suggests that we are - Daily SITREPs by acute trusts to NHSE. - Unknown numbers of people who are COVID-19 12 (I3xL4)

03/03/2020 in substantial fatal outcomes in high-risk groups and - Once a week regional teleconference calls for the - Public compliance with social distancing is a key past the peak of the current wave. As of 1 Feb 2021, in - Assurance returns by the CCG to NHSE on positive but are asymptomatic or have very mild Laura Siddall

Our Population Our economic and societal disruption. The demand for NHS emergency planners. component of transmission Bradford district, the number of patients admitted to arrangements. symptoms.

health services may outstrip resources available, - Weekly videoconferences for Bradford district and - If current national lockdown restrictions are eased, hospital is down 17.6% on the previous week. The - Twice-weekly dashboard produced by Bradford - Potential for people to decline Covid testing in order Static - 5 Archive(s) particularly if and/or when we experience a second Craven health and care partners infection rates could increase further if the public does positivity rate is down 12% on the previous week. Council Public Health team. to avoid the requirement to self isolate (if test positive) wave. - Swab testing established and antigen testing being not abide by the relevant law and/or guidance - Cases per 100k people (all ages) are stable, but cases - Daily health and care system dashboard produced by offered to NHS staff and partner organisations. summarised as 'wash hands, cover face, make space'. among those aged 60+ years are down 10% on the CCG - Outbreak Control Board established. Led by BMDC previous week. and with senior system leaders on membership. - BTHFT and ANHSFT have reported at the health and National lockdown began on 26 Dec 2020 and will last care silver meeting on 4 Feb 2021, that COVID activity for at least six weeks. COVID vaccine delivery has is reducing this week, although activity related to started and is focused on care home workers and general winter pressures is increasing. Other services residents and NHS staff. Activity at the hospital has report high, but manageable demand. stabilized from the second peak, but a third peak is expected due to increased mixing at Christmas. The new variant of COVID is circulating predominantly in the south of England and is more transmissible than the previous variant. (13/01/2021- Siddall, Laura)

20 There is a risk that unpaid carers are not identified as SystmOne template available to primary care staff Communications for SystmOne template may not have SystmOne extracts with numbers of carers recorded SystmOne template reviewed December 2020 to In October 2020 GP practices in Bradford district and There is a risk that we fail to gain sufficient QC 2.1

1726 carers and are therefore not offered assessment and including prompts to follow up health needs and reached all practice staff. on clinical system. include LTC follow up, Safeguarding and referral to Craven identified 19,280 people as carers on organisational traction towards integrated (I5xL4) support, resulting in worse mental and physical health identify Safeguarding concerns SystmOne template does not include prompt to refer social prescribers. SystmOne. The true number is estimated as more commissioning of health and social care, due to a 10 (I5xL2) Our People Our Anna Smith New - Open - New 02/02/2021 and increased acute care needs for both the carer and for statutory carer's assessment. than 50,000. range of factors, including ‘programme creep’ and Alijan Haider the person they look after. leadership challenges, resulting in failure to achieve the strategic objective

16 12 UNDERLYING FINANCIAL POSITION RISK. - Place based integrated planning approach for - Prioritisation framework for Bradford Place to be - Involvement of and reporting to SLT and Governing - Integrated planning approach used effectively in N/A FPC

1694 There is is risk that the CCG will take an underlying 2021/22; and developed; and Body members on the development of the plan for 2020/21. (I4xL4) (I3xL4) financial deficit into 2021/22 due to the inability to - Identification of savings schemes that can be - Clarity on financial framework for 2021/22. 2021/22.

25/11/2020 deliver the original planned savings of £13.8m as a progressed when it is possible to do so. - Confirmation of savings schemes for 2021/22. Robert MadenRobert MadenRobert Our Leadership Our result of the disruption of activities caused by the

pandemic. Static - 1 Archive(s) 8

16 FINANCIAL POSITION RISK 2020/21 (M7 to M12). - Continue to liaise with NHSE/I to correct the CCG's - £1.2m of cost savings to be confirmed. Monthly reporting of financial performance to Finance N/A N/A FPC

1693 There is a risk that the CCG will not achieve its in-year resource baseline shortfall (£4.9m); & Performance Committee, SLT and Governing Body (I4xl4) (I2xL4) break-even target for the period October to March - Identify cost savings to at least meet the in-year (bi-monthly);

25/11/2020 2021 due principally to a reduction in the CCG's savings target of £1.2m; Monthly reporting of financial performance to System Robert MadenRobert MadenRobert Our Leadership Our resource baseline compared to the first 6 months of - Only approve new expenditure commitments on an Finance & Performance Committee and WY ICS.

the year. exceptions basis; Static - 1 Archive(s) - Defer new development expenditure where possible; and - Use the agreed financial risk share principles to manage financial risk across the Bradford Place and the WY ICS. 9

16 ADULT AUTISM and/or ADHD ASSESSMENT and CCG SLT and system Finance and Performance Formal contractual routes are used but the service is Minutes of the CCG SLT where regular updates are August 2020 - No change to service restrictions at August 2020 - The service has been closed due to the 1.1 Unwarranted variations in quality and care and QC

1135 DIAGNOSIS Committee. not a priority against the other service pressures submitted. present, the service completes as much work as is safe impact on the diagnostic process of social distancing increase in demand (I4xL4) (I3xL3) where there is greater risk. Minutes of the system Finance and Performance to do but face to face work is suspended. Clinicians enforced by COVID 19. We will be working with BDCFT 1.1 2.2; 2.2 Risk of fractured relationships due to system

03/01/2018 There is a risk of further deterioration in the service Committee. continue to have a route via the IFR process for those to review progress and assess the impact of C-19 on financial pressures Alijan Haider Karren JolaosoKarren Our Population Our offer for adults waiting for assessment, diagnosis and Attendance at BMDC Health Overview and Scrutiny referrals considered urgent or for exceptional the waiting list. We will be also developing a service immediate post-diagnostic support due to the limited and Chair's briefing. individual circumstances. specification to update the contractual agreement. capacity to address the demand for referrals. The 28/10/20 Static - 10 Archive(s) waiting times for initial assessment and completion of 28/08/20 All referrals into the service are being triaged Increased demand resulting in longer time frame for the diagnostic process are lengthening. by the service. There is no-one waiting to access the assessment and diagnosis, now 12 to 14 months service, the issue is the length of time for a diagnosis. Service spec still being developed, by the end of March This is related to the no of sub-assessments required 2021 trajectory of 95 ongoing cases, commissioned for for an accurate diagnosis to be made. This can take up- 40/50 only across both Autism and ADHD to 6/12 months because of limitation in scheduled appointments and capacity. From referral / triage there 29/12/20 no change in concerning situation. is a 40-50% conversion rate. Draft service spec being worked on with service manager. The service has 27/01/2021 We continue to work with the provider limited funding and the demand outstretches the and there is to be a sub group looking at capacity to meet the on average 10 GP referrals per neurodiversity as part of the newly developed Mental month, as well as the ongoing assessment and health, LD and Neurodiversity HCPB. diagnosis of people altered in the service. GP assist referral pathways, e-consult will help to stem some of the demand. (28/08/2020- Jolaoso, Karren)

28/10/20 paper to SLT updating concerning picture

228 940 1094 1134 Risk ID

Date 17/01/2017 14/09/2017 03/01/2018 Created

QC QC QC Risk Type Risk Our Population Our Population Category

16 16 16 Risk (I4xL4) (I4xL4) (I4xL4) Rating

9 6 2 Target (I3xL3) (I3xL2) (I1xL2) Risk Risk Kate Varley Ruth Shaw Ruth Shaw Owner Senior Michelle Turner Alijan Haider Michelle Turner Manager surgical checklist. highlighted over concerns compliance with WHO embedded remains outstanding. CQC report 2020 assurance that learning form these events is retainedThird swab Never event (December 2019) the highest still birth rate level an LMS on consistentlyBTHFT report (historically and currently) maternity records clinical information. Primary Care cannot access online each other-risk delaying in the obtaining/sharing of Maternity Services- and Medway EPR not 'speak' do to clinicalTwo systems in operation (EPR, Medway for improvement’ the maternity rating remained the same as ‘requires improvement’ and the caring domain as ‘good’. Overall safety and effective domains remained as ‘requires (previously ‘requires improvement’ The in 2018). and the Well- led domain was rated as ‘inadequate’ ‘requires improvement’ (previously ‘good’ in 2018) theof domains – Responsive domain was rated as ‘requirements improvement’. Ratings went in 2 down The maternity services was rated overall as CQC (published) inspection2020 outcome Maternity: inequalities,diabetes and obesity. has higher levelsLMS)Bradford health of In comparison to other areas the of (and country patient harm. serious incidents and the potential avoidable of receive unsatisfactory care this may result in increased there is a potential risk that women and babies will SERVICES- QUALITY MATERNITY OF AND SAFETY BTHFT post-diagnostic support. months, delaying any appropriately identified formal mandatory) standard for first appointment by 3 results in with non-compliance the NICE (non- diagnosis and immediate post-diagnostic support. This duty service offer for children waiting for assessment, There is a risk further of deterioration in the statutory DIAGNOSIS. and AUTISMCHILD ADHD and/or ASSESSMENT this risk. and furthercommenced updates will be provided on led review ofhealth services to CLA has now opportunities in care arrangements for CLA. The CCG- assessments resulting in potential missed failure to meet timescales for statutory health reputational damage to health organisations, dueto outcomes Children of After Looked (CLA), and There is a risk negative of impact the on health LOOKED OUTCOMES OF CHILDREN AFTER HEALTH Principal Risk Principal Committee Collaboration, working as one; System Quality Newly formed Better Births Programme 2020) (July monthly West Yorkshire Quality bi- Surveillance (WSQSG) Group currently dueto hold COVID on Patient safety note and quality (PSQSG)- group sub maternityand Humber dashboard. Maternity services are reported quarterly to Yorkshire CCG) Process for Unit to Notifications Suspension (BTHFT CQC Inspections CQC to andsupport ongoing the Trust August 2020) program(OMS) me (monthly meet, commenced membership the on Outstanding Maternity Services Quality team member and CCG Clinical lead have CYP Autism Project Board. System Finance and Performance Committee. Regular updates at CCG SLT. development. hasgroup been held and terms reference of are under Update -The first 03/07/18 meeting theof review children looked after continues toin Bradford rise teamnursing and paediatricians. The number of agreed to maximise the capacity the of specialist the steering Immediategroup. actions have been Colleagues from the local authority are members of -The Sept TOR for 18 the review are agreed. now AfterLooked is progressing -The review 19 Jan ofhealth services for Children duplication is development. under aimed at reducing missed appointments and A new cross-health /Children's Social Care pathway requested. A CCG-led review ofhealth provision to CLA has been situation and risk health this, of sub-group are aware the of current Multi-agency Care Through Strategy and the Group, Key Controls Key timeliness autism assessments moving forward. Any reduction in previous capacity will impact the on organisations. deployed to COVID-19 support responses within their We areBDCFT. aware that clinical staff are being COVID-19 service on and provision across AFT, BTHFT We are currently working to understand the impact of post COVID-19. all the currently identified has been funding utilised front theyup will continue to provide the service until and appropriate. As the providers have been funded service where face non to face options are available The three external providers continue to provide their monthly project team meetings across partners. Comprehensive reporting takes place the through near future identified and it is the hoped review will start in the Update -A CCG lead 07/03/18 reviewer has been now Update -The review 04/04/18 has started. now currently development under hasgroup been held, and terms reference of are Update -The first 03/07/18 meeting theof review initial health assessments and adoption medicals. guidance target in respect timescales of for completing rise and we are to continuing fail in meeting statutory Update: -The CLA number of continues to 28/08/19 her clinical inputwill be reallocated. retirement the one of of Designated Doctors, and how There is uncertainty about the impact the of The CLA number of in the district is increasing moving forward. adoption medical and review health assessments impact the on timeliness initial of health assessment, medicals.. Any reduction in previous capacity will urgent initial health assessments and adoption meet the COVID-19 guidance in respect access of to with the service providers to agree toapproach our assessments and adoption medicals. We are working undertake initial health assessments, review health advised they have redeployed staff would who Update as to at SLT All 31/03 three providers initially measures toOMS establish maternity strategy and outcome requires improvement Compliance with local and national maternity audits CQC inspection, learning not embedded) improvement action plan marked as complete, 2020 Maternity improvement action plans (2018 Key Control Gaps Control Key Progress against Ockenden report links to Better Births program CQC regulatory and monitoring support Quality Committee Exceptions and Serious Incidents escalated to the CCG progress access to regular updates measures, on outcomes and provides OMS CCG timely membership BTHFT of Maternity Improvement Action Plan group reportsOMS directly alongside board to the the BTHFT 26.08.2020) Outstanding MaternityBTHFT Services (lauched OMS asWork programmes throughout one approach System working together and leadership CYP Autism Project reporting. Committee. Minutes the of System Finance and Performance Minutes the of CCG SLT. services for the time being in light COVID of impact -Weekly 2020 March Children's reporting on to SLT responsibilities. for safeguarding, as part their of corporate parenting and the BMDC isof who councillor the portfolio holder requirements. This is shared with the Chief Executive local authority, as part national of reporting assessments is monitored a on monthly basis by the to The CLA number dateof up with statutory health Assurance Controls Assurance 229 Planned BTHFT to CCG qualityPlanned BTHFT to quality committee the CTGrelated number of SIs (since 2018) CTG training package in place, subsequent reduction in exception still of births. Maternal outcomes are otherwise with good the collaboratively Programme provide an opportunity to work CCG membership OMS and Systems Better Births report. Progress is reported to the Governing Bodies update CCG staff are members the of project board. is keptThe CCG SLT informed progress. of A business continuity plan to provide IHAs, adoption trajectory to delivery compliance as requested by JQC. available finances will impact the on update the of This delay BTHFT). inBDCFT, confirmation the of awaiting responses from provider finance teams (AFT, arrangementsfunding for IHAs. CCG colleagues are the CLA business case with an initial the on focus tocontinue review and refine the financial elements of 04/05/2020 Finance and contracting colleagues be reviewed and next steps agreed. meeting is planned September for 24 at progress will identify and address wins quick and a cross systems hasWork across begun the provider organisations to CLA has been developed and shared with partners. within the report the of review ofhealth provision for implementation the of recommendations contained paediatric capacity. The action plan to support the system with a view to identifying additional 4wte We continue discussions across2019/20. during to increaseproposing their CLA nursing capacity by capacity CLA within nursing team. the BTHFT are BDCFT for a 4rolenon-recurrent Band funding to increase in April the strategic partnerships team have identified Update: -Following the presentation28/06/19 to JCC identified. development. Interim Designated Dr hassupport been employment. A training package is currently in have agreed to offer the GPs honorary contracts of are interested in supporting this model and BDCFT April1 We 2021. have identified a GPs of cohort who clinical model will which be in place and operational by established to oversee the implementation the of A 2021: Jan systems senior leadership has group been New pathway in development, as described above. resources and provide data for the review. proposed reviewing working practices and priorities to maximise The specialist CLA health team, in provider services, are PositiveAssurance and with communities our standards in the both hospital, between hospitals both an opportunity to work collaboratively to improve programme (with recent CCG membership provides Programme and the Trusts internal operational 08/07/2020 the systems newly formed Better Births remained the same as ‘requires improvement’. ‘requires improvement’, Overall the maternity rating The safety and effective domains remained as ‘requires improvement’ in 2018). Well- led domain was rated as ‘inadequate’ (previously ‘requires improvement CQC outcome Responsive domain was rated as departments use who SystmOne system is not visible to GP's orother BTHFT Interoperability clinical of systems- current Medway embedded retained swabs Serious Incident investigations are 2019)limited assurance that the actions the of first retainedThird swab Never event (December in CQC Report & Never Events compliance withNon Surgical WHO Checklist a theme referrals and completed activity. allow us to have a comprehensive oversight of organisations. toWork refine the continues PTL to waiting lists will be held by the current host fit in with the newyear) school although existing new pathway ‘front doors’ from September (to 2020 services continue to work towards the introductionof necessary, to deliver face to face assessments. The virtualof assessments and the ability, where pandemic and are currently exploring implementation to face elements the of service the throughout Service providers have to face continued provide non August -The waiting 2020 list continues to rise. named roles doctor at a place’ level rather than per model to implement the designated and doctor was made to look at the system resource to agree a sustainable to the in October SQC 2020. A decision next version the of model to make delivery more task has and finish group been asked to present the along with a revised trajectory for the Sept. 29th The single integrated narrative will be prepared for the CIB resource from a nursing and admin perspective. A current backlog and BDCTwill review its current more doing joint work to the support and BTHFT assessments.. Decisions were also made about ANHSFT more children to complete some the of health remotely and face to face and has already seen 80 current resource to enable more children to be seen hase.g. reprioritisedlockdown) BTHFT it how uses its IHAs took which place F2F COVID during non long waits for IHAsthe (including completion the of impact, serviceby providers to address the back log of have already been undertaken together, and their to understand the 24/09/20 on short term actions that A meeting seniorof system leaders and leads was held Systems and Finance Committee. case and advise it is planned to be discussed at the July colleagues continue to review and refine the business will need IHAs at some point. Finance and contracting they have a backlog casesof in pre-proceedings who adoption medicals. Social care colleagues have advised timeliness and capacity to deliver health reviews and social care and health will impact the both on aware that changes to service delivery across both torespond any urgent requests we for support are to deliver a service COVID-19 throughout and to Althoughhealth our service providers have continued commissioned. Uncertainty re clinic capacity and service Current lack data of from provider services Assurance Gaps Assurance

GBAF Ref 1.1; 6.1; 6.2; 6.3 2.2 1.1 No(s) instability. compromised resulting in clinical and financial 6.3 Risk that the transformation required is goals. services result would in the failure the of programme's 6.2 Risk dueto changes to acute and mental health effectiveness the of collaboration programme 6.1 Risk dueto cultures and behaviours risking the 1.1 Variations in quality and care pressures. Pressures arising from Local Authority Budget financial pressures 2.2 Risk fractured of relationships dueto system 2.2 Pressures arising budget cuts from council increase in demand 1.1 Unwarranted variations in quality and care and GBAF Entry Description(s) GBAF Entry

Risk Static - 4 Archive(s) Static - 19 Archive(s) Static - 18 Archive(s) Status 1098 1404 1549 1558 1559 Risk ID

Date 19/09/2017 25/09/2019 11/05/2020 21/05/2020 21/05/2020 Created

FPC QC FPC FPC FPC Risk Type Risk Our Population Our Population Our Leadership Our People Our People Category

15 15 15 15 Risk 15 (I3xL5) (I3xL5) (I3xL5) (I3xL5) (I3xL5) Rating

5 10 10 Target (I3xL3) 9 (I1xL5) (I2xL5) (I2xL5) Risk Risk Kerry Weir Ruth Shaw Robert Maden Robert Maden Robert Maden Owner Senior Robert Maden Alijan Haider Robert Maden Robert Maden Robert Maden Manager alongside reducedpatient care. may face financial both and reputational impact ratings and quality premium achievement. The CCGs annual Improvement and Assessment Framework CCG national performance assessments the including constitutional standards will impact a number of upon There is a risk that performance poor against the key STANDARDS AGAINST CONSTITUTIONALPERFORMANCE other health services. significantly reducedbudget), resulting in pressure on oral health services (commissioned by CBMDC with a todue redesigned health visitor, nursing and school There is a risk impact of CCG commissioned on services SERVICES IMPACT SERVICES: ON0-19 CCG COMMISSIONED may hold. be puton pandemic.. This may mean that planned investments CCG resources dueto the in 2020/21 COVID and replaced by national directives over the use of There is a risk that local financial control will be lost OF LOCAL FINANCIAL CONTROL LOSS structure. exceeds the vacancies number of in the CCG's staffing costsredundancy as the staff number of transferring eMBED, there is a risk that the CCG will incur Following the completion the of transfer staffof from BI REDUNDANCY COST compensation. liable costs for redundancy and financial tribunal against finds the CCG, then the CCGbe would from eMBED. If claims are made and an employment staffof that the CCG not did accept transfer should employment claims will be made by the two members relation to the eMBED contract, there is a risk that Following the completion the of TUPE process in POST TUPE CLAIM BI EMPLOYMENT Principal Risk Principal System performance and recovery dashboards in place undertakenplanning now a on system footprint. 04/01/21 System F&P Committee meets monthly and monitoring quality concerns. to gain assurance processes for about BTHFT's QualityJoint Committee May in held 2018 with BTHFT timescales for delivery improved of performance. -assurance plans sought on andand BTHFT) performance (QPG) meetings with key providers (AHFT Monthly performance meetings and bi-monthly quality On-going monitoring providerof performance. vulnerable families, and safeguarding. new-borns some face to face for including: the support most element face of to face workcontinue butshould health visiting nursing services and school stopped an national guidance for community services advised that Update We are 31/03/20 aware that COVID-19 the Partnership Group • Service 0-19 Risk Register in place and monitored by Haider Hayward and Ruth provide managerial input. MacDonaldand Jude provide clinical input; Ali Jan • CCG representatives the on Anne group: Connolly implementation process and meeting months • Partnership 0-19 in place Group to oversee the expenditure. Approvals process in place for additional COVID-19 response. investment is not related to supporting the COVID-19 England approval sought /support whereNHS new approval requiredSLT for any new investment. Health Research. possible opportunities with Institute Bradford of employment opportunities, exploring including Review ofsystem wide vacancies for suitable proceeding to external recruitment. that internal requirements are addressed before Vacancy management to ensure SLT control through made against the CCG. Legal advisers be would engaged to defend any claim Key Controls Key development. • Matrix working between still CBMDC and BDCFT in Year in to BDCFT support VCS the of 2 contract. • Additional capacity to be commissioned from the and can only influence direct) (not partners • The CCG neither manages orprovides this service None. None. None. date plans for delivery improved of performance Providerswith NHSI. not consistently do provide up-to- applicable dueto individual provider targets agreed Normal financial contractual levers are not currently Key Control Gaps Control Key Monitoring providerof quality performance at JQC monthly at JFPC Monitoring CCGof constitutional performance Monitoring via performance via groups providers. fora • Regular analysis data of and report updates to key (verbal) • Mobilisation Update Report to Partnership Group • Strategic Partnership Report to Governing Body & Performance Committee. COVID-19 expenditure reported the and to Finance SLT Performance Committee. New expenditure approvals reported to the Finance & updates system on HR wide vacancies. minutes. SLT Updates F&P and Committee to SLT claims on position. Assurance Controls Assurance 230 performance before the 2020/21 endof arebut unlikely to deliver required levels of 08/09/20 - Draft recovery plans have been submitted contract. are progressing the implementation the of agreed • Assurance received via Partnership that Group BDCFT &Finance Performance Committee minutes. minutes. SLT the and to F&P SLT Committee. ina finding Success suitable vacancy be would reported where it has, the outcome the of claim. Confirmation that either claim no has been made, or PositiveAssurance to services and delivery constitutional of standards 04/01/21 - Coronavirus continues to impact on access to services and delivery constitutional of standards 02/11/20 - Coronavirus continues to impact on access to services and delivery constitutional of standards 08/09/20 - Coronavirus continues to impact on access to services and delivery constitutional of standards 13/07/20 - Coronavirus continue to impact on access to services 18/05/20 - Coronavirus continue to impact on access allof constitutional standards 17/03/20 - Coronavirus likely to impact deliveryupon the implementation process. redesign the of services 0-19 are addressed alongside agency team to ensure that raised concerns about the 18/05/2020 The CCG is working closely with a multi- their COVID-19 response. series information of leaflets for families as part of have supported Public Health colleagues to develop a for somesupport the of most vulnerable children. We work the through identification and planning of needs nursing service school have been integral to this to have The CCG occurred. commissioned special their homes where an infection is orsuspected known team is also available to visit children and families in to statutoryup social work services. The Covid-19 receive appropriate early help orare support stepped appropriately managed by the lead agency orthat they additional vulnerabilities and ensure that risk is being hasapproach been developed to identify children with referralsof to children social care a partnership Developed in response to the reduction in the number an Integrated Outreach Covid-19 (ICV19) team. responseour most for our vulnerable children through EarlyCBMDC Help teams to develop and implement 04/05/2020 The 0-19 team have been working with currentlyGroup (waiting times, etc.) • Lack performance of data reporting to Partnership contract to meet demand. • Lack assurance of as to the adequacy the of agreed None. None. None Assurance Gaps Assurance

GBAF Ref 3.1; 6.3 1.1 1.2 3.1 3.2 No(s) instability. compromised resulting in clinical and financial 6.3 Risk that the transformation required is 3.1 Medium term financial sustainability arranged. change toNo this risk. BI Discussion re-structure on GBAF Entry Description(s) GBAF Entry

Risk Static - 5 Archive(s) Static - 8 Archive(s) Static - 4 Archive(s) Static - 4 Archive(s) Static - 4 Archive(s) Status 964 Risk ID

Date 26/01/2017 Created

FPC Risk Type Risk Our Leadership Category

15 Risk (I5xL3) Rating

3 Target (I3xL1) Risk Risk Simon Wilson Owner Senior Robert Maden Manager working. theduring pandemic in light reliance of IT on remote / agreed8th April SLT to 2020 raise impact score to 5 House. home network orthe corporate network in Scorex mobile device that is either toconnected the users resulting in access to these apps direct from a laptop / iterated they are not to be used within VMware Teams)MS with a clear message being strongly re- home /remote working for CCG business (e.g. Zoom, However there is an increase in using apps to support – butnot necessarilyTHIS) level our vulnerability. of healthcare institutions internationally – shared with teamFraud about increased in attempted attacks on increases (recent comms from Interpol via the Counter Risk cyber-attack of pandemic during potentially data and diversion resources. of resultcould in disruption to business operations, lost organisations containing viruses /ransomware. This emails/viruses/hacking being received in the sophisticated and seemingly genuine click bait There is a risk vulnerability of to cyber-attack dueto ATTACK CYBER Principal Risk Principal the effect and details to how of deal and report them. Communications contain examples Cyber of Attacks, Security and reports incidents of reported in the press. materials in the form email of reminders about Cyber All staff to continue receive communication ad-hoc receive notification for staff that are not compliant. statutory training monitored via and managers ESR an annual basis. Compliance with mandatory & All staff to complete their mandatory DSPT training on maintained. been applied, virus definitions updated and firewalls willTHIS ensure that all software security patches have will be undertaken annually. undertaken with 2020, highrisk Feb no findings. This Network penetration testing theof CCG network to ensure all standards are met. with 2020 The Healththroughout Informatics Service standards – assurance is high. Workwill continue submitted; compliant mandatory with /106 103 April Data 2020 Security & Protection Toolkit Key Controls Key moderate to high). Moderate (likelihood is low to moderate and impact is The overall IT Cyber Security Threat Level remains 2020. Cyber Awareness session to be arranged in with SLT Key Control Gaps Control Key above. All Cyber IT Incidents reported and monitored by Committee. reported in reports included and to to SLT Audit & Gov Compliance with DSPT training monitored by ALT and Assurance Controls Assurance 231 up to dateup (patched). DataBoth Centre Firewalls are current, in warranty and taken since April (non to present 2020 -Aug 2020) Management meetings and advise action on to be Security breaches to the CCG via monthly Account captureTHIS and escalate any instances Cyber of pattern detected). malware to a individuals number of particular (no made via the receipt emails of containing virus / last 3years although multiple attempts have been reportedNo effects cyber-attacks of within the CCG in PositiveAssurance common threatscommon and real life examples. importance of being vigilant and provide examples of serve as a regular reminder to all staff about the education material to distribute to all users. This would report that from THIS it use as could communication / benefitCCG would from a formal monthly narrative Assurance Gaps Assurance

GBAF Ref No(s) GBAF Entry Description(s) GBAF Entry

Risk Static - 5 Archive(s) Status COVID Risk Log for Governing Body as at 23.02.2021 at as Body Governing Riskfor COVID Log

1613 Risk ID

19/06/2020 Date Created

QC Risk Type 25 (I5xL5) Risk Rating

10 (I5xL2) Target Risk Rating

Sasha Bhat Risk Owner

Alijan Haider Senior Manager would reducewould their healthandwellbeing. appropriate mental supporta in timelywaywhich The impact is inabilityof local people toaccess example PTSD). pandemic,the including key impact onworkers (for forwards due toincreasedneed arising thefrom capacityrequire and/ or a different focus going Riskthat for demand mental healthservices outweighs SERVICES HEALTH MENTAL FOR DEMAND Principal Risk be activated ~ Redeployment processplace in shouldthis needto are pickedup, managed, mitigatedand/or escalated. ~ Weeklycalls place in providers with toensure risks in a timelymanner ~ Additional fundinghas enabledthe above tohappen ensure supportis continued. devices tothoseno means with of communications to ~partnerswith Worked toensure we candeliver anddigitial solutions working todelivertheir services ~ Suportedandenabled all services tohave remote CAMHS and CMHT ~ Newmodels of care beingtried out incrisis, urgent, organisationsandtrust) (community redeployment of resourcescapacity and between ~ toallow swift Provider haveforum MOU andpusblished ~ Communiactionsresource and material developed establishedplan work ~ Taskandfinish overseeing group andhave ~ Lots of supportavailable tocare homes. ~ Nationalstaff NHS traumasupportlines established. operated BDCFTby - thisout of has funding run now front line staffPsychological and support line forstaff ~ Bereavement services set for up public, trainingfor inequalities factors pandemicchanges and tohealthneeds, including "~ Recognition of needto revise strategieslight of in IN PLACECONTROLS Key ControlsKey fortnightlycalls. data monthly and through monitoring On-going locally needs tobe identified. tocontinueFunding Covid griefloss and support ACTIONS REQUIRED FURTHER Key ControlKey Gaps 232 but pressuresbut service on continue. servicesstaffing and is deliveredto manage demand made adjustmentschanges and current tohow significant increase particularly forchildren. We have admissions andcrisis via AED service has seena 08.02.2021 Theincreasesreferrals in non-elective and SLT FOR UPDATE Assurance Controls is placing pressurethe on system. We have a taskand to see a risecrisis in psychosis and presentation which As SLT anupdate, 08/07/2020: SLT we are continuing update tofollow afterthis has takenplace. set22.07.2020:SLT Workshop fortheof - 22nd July updateSLT: No as provided at 31.07.2020 COVIDby andeconomic circumstances that have beenimpacted 26.08.2020:SLT This riskremains giventhe high social emerges. The riskremains as high the full picture of needs to see these increase. help referral haddroppedsignificantly starting now but remains high. Access level tolow support andearly 23.09.2020:SLT Demandonacute crisis and service updated. Riskscore reduced=to I5xL3 15 remain high.Controlswhich Key field has been access;out of to monitor area continuing placements to maintain on-going servicework, work visibility and seeking additional funds tocontinue GriefLoss and additional resource, needs have beenprioritised, - Winterpressures 9/11/2020 provide supportwill service. is further no additional fundingfor grief loss and followingdiscussion atandconfirmation SLT that there - Riskscore 26/11/2020 increasedto I5xL4=20 at fundingsources emergingas nothing but yet. . coverlocal needs.have Command Gold agreedto look developing. West Yorkshire adequate supportnot to exhaustedfor local servicewaiting andlist forsupport - Riskremains 16/12/2020 now high. Funding the riskincreasing atto 20 the last cycle. wellbeingof population our be will significant. Hence, 27.01.2021: Theimpact of the pandemicthe on mental /PREVIOUS UPDATES COMMENTS Positive Assurance Not usedNot for COVID RiskLog Assurance Gaps

GBAF Ref No(s) GBAF Entry N/A Description(s)

Increasing Risk Status 1590 Risk ID

09/06/2020 Date Created

QC Risk Type 20 (I5xL4) Risk Rating

10 (I5xL2) Target Risk Rating

Dave Tatham Risk Owner

Dave Tatham Senior Manager objectives suchas reducinghealth inequalities. unable toaccessnot delivering / them CCG on The impact is patients need who access toservices are - closure of some elective serviceswave 2 during staff sickness, bedavailability andaccess toequipment -factors limiting suchas PPE supplies, staff testing, to enable this) non-urgent services (partlydue tolack of information - lack of clearprioritisation of re-startingurgent and negativelyimpacted due to: There is a riskthat outcomespopulation forour are IMPACTED NEGATIVELY FORPOPULATION OUTCOMES Principal Risk re-start work-stream tomobilise System Executive Board re-startedMay. 15th from meetings forthe time being. 1st meeting of Re-start BD&C 06.05.20 met - weekly lowerthan expected). Stillweek2 doing urgent referrals (butcurrent volume IN PLACECONTROLS Key ControlsKey andrestarting services andthe new capacityavailable whilst COVID managing to understand ongoing andWork waiting list numbers conversation toallowthis prioritisation tohappen. Needto re-start system governance arrangements and ACTIONS REQUIRED FURTHER Key ControlKey Gaps 233 via national portal. change No torisk. (systemprogram group).current issues No PPE with Interms. Restart prioritisation managedvia access services suchas cancerreferrals as continuing normal. COVID activityincreasing in secondary care urgent but SLT FOR UPDATE Assurance Controls Identified06/05/20 SLT Query as appropriate towho is. RO 10.06.2020:SLT Reviewed- score toremain the same. noted consideration toreducingscore issues but data with 24.06.2020, FollowingSLT 08/07/2020: SLT updateSLT: No as provided at 31.07.2020. list. apriority and clinical review of all peoplea on waiting managedas one list andpeople tobe seenin clinical safe. Drive toensure that the elective waitinglists are utilisation of estate toensure that services are covid diagnostics challengingas has a reductionis the particularly aerosol generating procedures and across all sectors has made increasingelective services, service areas.relatively A slow decline Covid in activity 26.08.2020:SLT Activity is increasingacross many planning submissions abilityto maintain target activitytrajectories the in activityin all service areas impact of may the which increasingthereagain in the is community increased 21.10.20 As of numbers COVID positive cases are areas. impactedon the levels of activityundertaken in specific their contingencyplans, some in cases this has thanthey were at peak1. Some sectors have activated significantly, acute COVID inpatients are highernow 25.11.20 COVID activityacross all sectors has increased update23.12.20 No UPDATES COMMENTS/PREVIOUS Positive Assurance Not usedNot for COVID risklog. Assurance Gaps

NA GBAF Ref No(s) GBAF Entry N/A Description(s)

Static - 10 Archive(s) Risk Status 1582 Risk ID

09/06/2020 Date Created

QC Risk Type 20 (I5xL4) Risk Rating

10 (I5xL2) Target Risk Rating

Polly Masson Risk Owner

Sohail Abbas Senior Manager suffering forcertain groups. to reductionof healthinequalities disproportionate / The impact is failure tomeet statutoryduties relating average). than more impactingon deprived groups andBAME pandemic (evidence todate is that the pandemic is socio-economicethnicity and factors the during There is a riskof increasedhealth inequalities due to FACTORS ECONOMIC ETHNICITY & SOCIO- INEQUALITIESTO DUE INCREASED HEALTH Principal Risk caseloads admiralteam) nursing are livebuilding and now projectsTwo led BDCFTby (proactive care team and workforce development. people projects, mental health, CLICS care andprimary particularemphasis VCS on leadprojects, homeless with RIC is slowlygaining momentum programme riskshigh groups. related work support with to vulnerable patients / Recentwork. additional topractices comms offering connectors funded theby RIC monies aregreat doing within Bradfordcentral locality. The community asdoing healthinequalities networkacross and WY Some immediate mitigations arewe the are work pandemicchanges and tohealthneeds. Recognition of needto revise strategieslight of in IN PLACECONTROLS Key ControlsKey communities. (Sasha Bhat) looking at mental healthinequalities support and for The Mental healthteam have a specific workstream BradfordDistrict deprivedarea organisationsparticular with focus Keighley on and inequalityamongst fundinglocal grant VCS VCS alliance is anevent holding toraise awareness for be reviewedat the nextRIC steering group. childrenrelated) arehold at andwill the on moment Projects(mainly maternity and that involve BTHFT is Williams.chair led work Toni PHE andby andBradfordwill report networkthat work toHI I Bird, a public healthregistrar is leadingthe on started public healthby in Bradford andat PHE. Pippa There is alsoto support vulnerable work people ACTIONS REQUIRED FURTHER Key ControlKey Gaps 234 delivery todetermine if adjustments are required Weimpact continueservice of on tomonitor covid asevaluation and intomonitoring we move phase. February toreview format andmembership for21/22, Steering holda will development group session in languages]. community creating on working additional versions of thesekey in to provide a platform forfuture [Note comms. we are brochure) have beencreated, togetherwebwith page, national interest.Three key assets (videos and RIC launchsuccessfully Feb 4 on regionalwith and SLT FOR UPDATE Assurance Controls are beingsubmitted to the RIC steering (meeting group services widely. more will continueandthispromote on tobuild work communications managerstarted October andon 21 was well attendedandreceived. TheRIC to promoteRIC projectsencourage and utilisation.This updateSLT: October2020 healthinequalities project teamlearn and approaches our from totackle CCGs areLondon andNottingham inkeento meet the implementation of the project. provide dedicatedsupport topractices toaid the A CLICS facilitator role isto advert. out This role will commence. todeterminesteeringNov 3 onif group these can Outstanding projects be will reviewedat the RIC HCPlaunch HealthofInequalities the WY&H Academy. the first weekof Feb.This launchwill be linkedto the current approach anddeveloping a planfor launch in RIC managerin place. comms They are reviewing provider. by withdrawn approval RIC by steeringprojects 1/20 has group. been projectsmobilising. 3/20 are beingdeveloped for RIC 16/20 30/11/20: projects aredelivery in or adjustments are required. ofservice on covid delivery todetermine if covid riskfactors). We continue will impact tomonitor embedding the service (whichfocussesmultiple on CLICS facilitator ispost in andpracticessupporting with services toreferrers.Launchis scheduledfor Feb.4 support the launchofandwiderpromotion RIC tools forthe RICindividual and projects programme to 27.01.21: Priority forJanuary is todevelop comms /PREVIOUS UPDATES COMMENTS Positive Assurance Not usedNot for COVID risklog. Assurance Gaps

NA GBAF Ref No(s) GBAF Entry N/A Description(s)

Static - 10 Archive(s) Risk Status 943 Risk ID

17/01/2017 Date Created

QC Risk Type 20 (I4xL5) Risk Rating

2 (I1xL2) Target Risk Rating

Bev Gallagher Risk Owner

Michelle Turner Senior Manager widersystem resilience. the stabilityof the sectorandpotential todestabilise in placements havemortalitywhich and impactedon increasing including 19 voids as a result of reductions risingcosts reported theby sectorof covid- managing * These difficulties are furtherexacerbated due tothe * Maintainingpace changes with toguidance digital record. sharing across the systemaccess and toa shared * Communication andlack ofinformationup joined pandemic; demandscare of the providing support and during * Mental wellbeingof care staff home due tothe care staff –self-isolation and parents impacton across health& andretention, skillstaff mix, isolation andalso schools * Staffworkforce and issues toinclude recruitment ablement); include post COVID infections (rehabandre - * Increasingcomplexity of care residents home to residents; andaccess/provision of healthcare services for betweenquality of lifeterms in of visiting, activities * Tension betweeninfection controlandbalance testing; control measures toinclude PPE, trainingandregular * Requirement forincreased infection prevention and the pandemic include (not anexhaustive list): Care homes challenges that have beenexacerbated by providedandthe increasedrisk of service userharm. result inanadverse the impact on qualityof care requiredto prevent andmanage infections. This may care homes is reduceddue toCOVID-andresponse 19 There is anincreased risk that qualityof healthcare in COVID IMPACT CARE HOMES ON Principal Risk communications referencehome Care@Home forumsand group, NYCCBMDC andzone provider bulletins, provider care h. Comprehensive CommunicationsEngagement via & learning bestinform practice, quality andsharedimprovement g. Business Continuity Guidanceto support and reviewsandspecialist support EOL COVID,rounds for with proplr structuredmedication escalating/enhancedneed. This includes virtual ward 21) superrota forcare residents home with enhanceddigital Care offer(i.e. telemedicine (March risks of infectionpatients For escalating with needs via f. Increasedaccess toremote clinical care toreduce outbreaks andsupport for winter resilience learning and from e. (IPC)sustainability provides Group training, advice COVID relatedareas guidancesupport andongoing tocare sectorfor all d. establishment of BMDC COVID-to provideTeam 19 anddemandcapacity challenges on infection rates, mortality, operational, process, action toaddress challengessupport and Care Homes dashboardtargeted and tosupportdailymonitoring c. Comprehensiveintelligence and monitoring and safe settings discharge NHS from thefrom national portal andarrangements toensure Controlfor Fund care providers, access tofree PPE areasincludes and theextension ofthe Infection organisationsNHS social and care providers across key for actions andwinter 2020-2021 forlocal authorities, elements of national support forthe social care sector b, Social Adult care winterplan sets which key out oversight Command a) Care@Home system strategicSilver and group CONTROLS CURRENT Key ControlsKey anagreed action plan. homessupporting where needed towardsand working CQC.The Local Authoritiespartners and are care homes have beenrated as inadequate the by intervention due toqualityandsafety concerns – Two * Some homes require enhancedsupport and parents- healthcare& staff * Schools - self-isolation of studentsimpact and on workforce staffwhole testing home through the and impact on * Workforce fatigueincreasing and infections care in there are are providers who difficult toengage with. * BCA coverage does include not all providers and out of the controlof local our system; relation tothe national testing is which programme, * riskof On-going capacityandprocess failure in governance the within system; * Maintainingpace of change whilst ensuringgood requirements Care@Home Programme/superrota, IPCother and forCCG andsystem partnersto support the * Resourcein terms gap of staffing both andfunding therapies);MDT, disbandedandneeded for the second wave (i.e. OOH COVID during viaredeployed staff have and * Gaps of a services number that were established up/alternative options; what is the contingencyto step these back rota/telemedicine/discharge toassess/my care24 i.e. * Sustainabilityofmitigating factors ongoing i.e. Super guidance; system governance ongoing and forpathways and * Clarityaroundroles responsibilities and the within REQUIRED ACTONS FURTHER Key ControlKey Gaps 235 supported BMDC/CCG.by embargo inplaceare and enhanced on surveillance All fourhomes have beenplaced in special measures, ratedRI homes4 andrated as inadequateCQC. with in homes that require homes23 improvements with As reportedlast to see continuing month anincrease Care Quality Home action required CCGby at this point ‘nurse banks ‘ that are already established. further No nurses returnerslook andtoredirect tolocal them transferredto WYICSdoastock will who take of all •Back Scheme Bring –Leadfor this scheme has ofthe SuperRota until the endof 2021, March is beingutilised for projects3 toinclude continuation • West YorkshireHarrogate and secured, funding this this weekthus increasingcapacity • DesignatedBeds - available Troutbeck home from to hospital andthe rest beingmanaged at home datebest and across Three patients WY&H. admitted - Progressing• Oximetry@Home well, referrals 18 to current outbreak) to be completedshortly.(exception beeches due to • Vaccinations Care - 100% offered Homes anda few Care@Home key messages areas suchas IPC, vaccinationstesting. and Care@home continue system group tosupportin • COVID supportNYCC Teamand partners and via caseloadstands at 61 •of Thecurrent people number the on SuperRota outbreakwithin the 0-28 day cycle • Currently have homesECH 1 5 anda current 0-28 day cycleoutbreak (major at the Beeches) Currentlyproviders have 34 a current outbreakwithin casesthe in Care doubledsince Homes Christmas. • BradfordIncrease ofnumbers inCOVID positive COVIDAs of 5/2/2021 Outbreaks - SLT FOR UPDATE Assurance Controls three homes have beenplaced in special measures, ratedRI homes3 andrated as inadequateCQC. with All homes that require homes21 improvements with • As reportedlast startingto see month anincrease in Care Quality Home andpositive feedbackreceived carefrom providers Care staff Home residents and some already vaccinated • Vaccinations Each PCN is tovaccinate planning how ratherthan in the care TBC home lateral flowtests tobe completedat staff by home place. BCA toconsidera collective response toenable to supportgovernment funding providers this toput in distribution needwhich to be considered - awaiting andresourcing andIPC/ environmental logistics and ‘ask’ totest perweek 2 x plus PCRterms in of capacity • Some concerns noted careby sectorre lateral testing such as IPC, vaccinationstesting. and Care@home continue systemareas group tosupportin • Covid supportNYCC Teamand partners and via shifts still running. residents28 the on superRota case load hour and12 outbreakwithin the 0-28 day cycle • NYCC homesextra 3 1 and care facilityhave a current 0-28 day cycle • Bradfordproviders15 have a current outbreakwithin - As of 6/1/2021 has remainedfairly static . - of Numbers COVID positive casesthe in Care Homes day staff be will tested – IPC6/1/2021 on PHE aware tookplaceIMT all and - case One Skipton ofin Care TB reported by Home 27.01.21: InfectionsOutbreaks and PREVIOUS /COMMENTS UPDATES Positive Assurance N/A not used not N/A for the COVID risklog Assurance Gaps

GBAF Ref No(s) GBAF Entry N/A GBAF in development for BD&C Description(s)

Static - 2 Archive(s) Risk Status 1713 1574 Risk ID

24/12/2020 08/06/2020 Date Created

Both FPC and QC QC Risk Type 15 16 (I3xL5) (I4xL4) Risk Rating

9 9 (I3xL3) (I3xL3) Target Risk Rating

Vicki Wallace Alijan Haider Risk Owner

Vicki Wallace Alijan Haider Senior Manager sharing of misinformation. availability; workforce todeliver; individual beliefs and due toa varietyof reasons including:vaccine population notreceive will vaccination the covid19 There is a riskthat a large of proportion our COVID VACCINATIONS experience causingupset andadding togrief. The impact of the riskis negative patient andfamily current COVID-19 restrictions. family at bedside, religious ceremonies etc) due tothe have the death experience that theychoose would (i.e. There is a riskthat patientstheir and families not will LIFE OF EXPERIENCE END Principal Risk SRO callsSRO Raisingissues regional colleagues via NHSE Covid and vaccine availabilityandassociated supplyissues. Continue toescalate issues nationally relating to of COVID vaccine steering meets which group weekly. maximised: meetingCDs with a on weeklybasis; part system toensure workforce, vaccineresources and are Regularmeetings place in all with partners across the Governance arrangementsplace in across system out. a varietyof channels communication toget messages messagesright are sharedpopulations.our with Using andteams,faith leaders community to ensure the national with Working andlocal communications vaccines are utilisedandnot wasted. partners with Working toensure that any spare safely. the of most estateworkforce and available todeliver The delivery of the vaccine - ifworking making via hub IN PLACECONTROLS are palliative digital by media. allayed allowingcontactby family with who members not toallow anyvisitorsthe on have ward been - Some of the conerns that related decisionto BTHFT's - tothesupport Comms available public on this managing - has Comms gonetoGPs out in tosupportthem contact as as possible much - providerspatients supporting families / virtual with funeral andcremation arrangements. - BMDC continuepublic tocommunicatearound with cremations. a celebrantreligious or official can attendnow ~ BMDC has changedtheir cremation processes so that circulatedto staff public. and ~ Communicationsnew visiting on rules have been IN PLACECONTROLS Key ControlsKey deliverthe vaccines. services puts which pressureavailability on of staff to There continues tobe a focusdelivery on of all NHS issues tootherdepartments. a timelywayas they are call centres pass which the influence. Thenational helplines are able not tohelp in undernational direction wewhich have on no The vaccineandassociated supply supplies are all misinformation Neednational teams tohelp circulation combat of Neednational teams toactnational on supplyissues ACTIONS REQUIRED FURTHER thento support people. andthis is beingrolled out tofront line staff first and support specifically forfaith communities andminority - Themental healthteam have developedtraining and practicable canbe addressed. concerns local from people so that any issues, where messagesregardingCOVID-19 out also and listens to (Fiona J'steam) that pushes messages positive -whatsapphas A group been formed Saeed by Khan involvement and of comms religious groups. sub-groupthat isinto death looking experience, ~ Fiona Jeffrey, Sue JonesMatt and Walshare part of a ACTIONS REQUIRED FURTHER Key ControlKey Gaps 236 both FPC QC & due toperformance element of risk. Followingdiscussion at FPC - decision made toalign to deliveryvaccine of 2nd yet tobe received. Vaccine flows are stable currently, guidance but on underway totarget work specific communities. not confident toaccept the vaccine. National andlocal Continues tobe a are sectionwho of community our SLT FOR UPDATE analysis of pandemic increaseR rate. in Riskremains as high we await a post holiday period SLT FOR UPDATE Assurance Controls N/A newN/A riskadded 24.12.20 likelihoodchange to3.VW/SD 4 from Discussion Update 28/01/2021 re likelihood.Agreed 27.01.21: new risk N/A added 24.12.20. Risksltered as discussedat SLT PREVIOUS /COMMENTS UPDATES I4= x 20).L5 29.04.2020:SLT agreedto reduce the risk(previously same level. Additional controls addedin. Daily huddle 05.05.2020: Agreedthat riskremains at expandto whole palliative care pathway. riskto remain opento reviewbut and riskwording 10.06.2020: considerSLT To for closure - agreedthat health/safetyrestrictions that apply due toCOVID-19. choosethe given social distancingandother families nothave will the death experience they would Theriskstill 08/07/2020: SLT remains that patients and apply due toCOVID-19. Riskto remain active. distancingandother health/safety restrictions that experience choose they would the given social patientsfamilies and nothave will the death 22.07.2020:SLT There are changes no tothe riskthat updateSLT: No as provided at 31.07.2020. of COVID relatedhealth andsafety measures. to the impact of social restrictions imposedas a result 26.08.2020:SLT This riskcontinues due toremain high their relativeshospital in remains high. regardingendof life experience forfamilies lose who 21.10.20SLT - Giventhe threat of a wave 2; the risk C-19. 25.11.20SLT - Riskremains activethe given increase in 23.12.20 update SLT no UPDATES COMMENTS/PREVIOUS Positive Assurance N/A not used not N/A for COVID log usedNot for the COVID-19 risklog. Assurance Gaps

NA GBAF Ref No(s) GBAF Entry N/A Description(s)

Static - 1 Archive(s) Static - 10 Archive(s) Risk Status 1594 Risk ID

09/06/2020 Date Created

FPC Risk Type 15 (I5xL3) Risk Rating

8 Target Risk Rating

Alijan Haider Risk Owner

Alijan Haider Senior Manager pressureother on parts of the healthandcare system. The impact is reductionin care capacity home / the pandemic. markethome due tothe costsissues and arising from There is a riskto the financial sustainabilityof the care FINANCIALSUSTAINABILITYCARE HOME Principal Risk pay. Furtherconversations taking place regardingrates of principle's linkedto the Section agreement. 75 Conversationsre costs void ongoing funding and consistentresponse. andjoinedup closelyBDMC we and work them toensurewith a Co-ordination of market sustainabilityis assumed by IN PLACECONTROLS Key ControlsKey benchmark against otherCCGs Clarification CHC on feesto - ongoing working ACTIONS REQUIRED FURTHER Key ControlKey Gaps 237 resilience. thehow pandemic has impactedon their capacityand regardingpayments forservices an andanalysis of the TheCCG is liaisinglocalwith care providers home SLT FOR UPDATE Assurance Controls 20.05.2020 - Addedto log. materialisesdemand the in nextfew weeks. inabilityto fill beds etc.A lotwill depend on how :National10.06.2020 SLT risk/ issue costs,void given homes. impact of COVIDthe on financial sustainabilityof care thewith care homeskeeping and a close watchon the Thelocal08/07/2020: authoritySLT are discussion in 22.07.2020:SLT Riskto remain active. sustainabilityandcare capacity. home practicable re: impact of COVIDcare on home the care homes toshareaddress and concerns where (DOF)I and have beenregularholding meetings with 26.08.2020:SLT This riskcontinues; Robert Maden 30.09.20SLT - riskremains at the same level. 25.11.20SLT - Riskremains active. SLT23.12.20 - update no UPDATES COMMENTS/PREVIOUS Positive Assurance Not usedNot for COVID risklog. Assurance Gaps

NA GBAF Ref No(s) GBAF Entry N/A Description(s)

Static - 10 Archive(s) Risk Status APPROVED 12.01.2021

Minutes of the Primary Care Commissioning Committee

Tuesday 10th November 2020, 11:45 – 12:45

Zoom meeting

Present Representing Ruby Bhatti (Chair) Lay Member for Primary Care Commissioning CCG Louise Clarke (non-voting) Strategic Clinical Director of Strategy and Planning CCG (GP) Neil Fell Lay Member for Finance & Performance CCG Ali Jan Haider Strategic Director of Keeping Well at Home CCG Michelle Turner Director of Quality and Nursing CCG Robert Maden Chief Finance Officer CCG Bryan Millar Lay Member for Audit & Governance CCG David Richardson Lay Member for Quality CCG James Thomas (non-voting) Clinical Chair (GP) CCG John Young Secondary Care Consultant CCG

In attendance Neil Coulter NHS England Representative NHSE Steve Patterson YORLMC Ltd Chair (GP) LMC Val Wilson YORLMC Ltd Liaison (GP) LMC Ashley Green CEO Healthwatch NY Sue Wilby Strategy, Change and Delivery Senior Manager CCG Lynne Scrutton Associate Director for Keeping People Well at Home CCG Karen Stothers Senior Head of Strategy, Change and Delivery CCG Vicki Wallace Associate Director, Transformation and Change CCG John Hartley Senior Head of Quality Improvement CCG Sarah Dick Head of Corporate Governance CCG Catherine Smith PA (minutes) CCG

Apologies Helen Hirst, Chief Officer, CCG Lincoln Sargeant, Director of Public Health, North Yorkshire County Council Sarah Muckle, Director of Public Health, Bradford Metropolitan District Council (BMDC)

Members of the public: 0

1. Welcome and Apologies

Ruby Bhatti, Chair of the Primary Care Commissioning Committee (PCCC), welcomed everyone to the meeting of the NHS Bradford District and Craven (BDC) PCCC, and noted apologies. The meeting was noted as quorate.

2. Declarations of Interest

David Richardson declared a financial interest in item 8 (healthcare estate in Keighley and North Street APMS contract) as a non-executive director of the Bradford and Airedale Estates Partnership Ltd who may potentially bid for a development in Keighley or the surrounding area. It was agreed that David would not contribute to the discussion for this item.

James Thomas declared a financial interest as a GP partner in the Modality practice that operates in the AWC area in items 8 (healthcare estate in Keighley and North Street APMS contract) and 10 (GMS and PMS harmonisation in Airedale, Wharfedale and Craven). Louise Clarke declared an financial interest in item 8 as a salaried GP with a practice would could potentially bid for the North

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Street contract. It was agreed that Louise and James (who both have a non-voting role on the committee) would not contribute to the discussion for these items.

3. Minutes of the meeting held on 8th September 2020, and actions arising

The minutes of the meeting held on 8th September 2020 were agreed to be a correct record by the members of the Bradford District and Craven (BD&C) CCG PCCC subject to the following amendment:

Page 2, Declarations of Interest - Val Wilson noted that she confirmed in the previous meeting that she was being employed solely on a locum basis and did not have a financial interest as a partner in a local GP practice. ACTION: September minutes to be amended (actioned).

There was one action arising from the last meeting -

Debbie Oxley to initiate discussion on the process to be implemented to support general practice once the change in CQC processes to be implemented going forwards were known. Karen Stothers confirmed that changes to the CQC processes are being implemented and practices have been informed of the transitional approach that the CQC are taking. More information will be provided in item 4.

4. Update to the Contract and Quality Assurance Process, including PC dashboard and RAIDR

Karen Stothers presented a paper on the review of the Contract and Quality Assurance process which has taken place in order to establish more efficient ways of working and reduce bureaucracy for practices. The paper and presentations describe the proposed changes to the Contract and Quality Assurance process - the first presentation outlines the Quality Assurance process and the second presentation outlines how available information from the Primary Care (PC) dashboard and RAIDR are used to inform the process. Karen explained that the revised process was developed in the context of recovery/restart however suggested that due to current Covid pressures it is paused until March 2021 with the primary care team continuing to liaise with the CQC through this period.

Karen provided some background to the existing process and referred to the intention to develop a risk based approach that is similar to the approach taken by the CQC as part of their Emergency Support Framework. Karen explained that the process will take part in two sections – the first being the contractual requirements of the practice which will involve collating information from within the CCG and focus on key policies and procedures held by the practice, such as infection prevention and control, safeguarding and significant event analysis. It will also look at patient feedback, grassroots information and findings from the national GP survey.

The second section will be the quality element of the process focusing on quality indicators that can found within the PC dashboard. Information from these parts of the process will then be reviewed by the primary care team and a risk assessment developed with next steps being agreed and a rating provided. A deep-dive will continue to be undertaken every three years which is a requirement of delegated commissioning. Karen referred to the existing PC dashboard – there has been agreement with medicines optimisation on which elements can be considered and there will be a new indicator on additional and enhanced services.

David Richardson welcomed the inclusion of patient feedback into the process and queried if this is an opportunity to strengthen contact with the patient participation groups; Karen explained that there is work with the CCG’s engagement team to look at how information from patient participation groups and grassroots can be measured.

Neil Fell queried the thresholds for the outcomes and stated that practices will need to be aware of these; Karen explained that each scenario will be different and how the thresholds are agreed will be

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239 APPROVED 12.01.2021 quantified further. Bryan Millar raised if the revised process does enough to reduce bureaucracy for practices and whether other processes will be stopped in order to benefit practices. John Young suggested that high performing practices could be identified in order to share learning.

John Hartley provided an overview of the available information in the PC dashboard and RAIDR and highlighted that the PC dashboard is a Quality Assurance tool that can provide retrospective information on practice performance and RAIDR is a real-time tool providing information on Quality Improvement. The dashboard is a useful tool to review individual practices and the CCG on high level indicators and it can highlight areas of concern and best practice, and RAIDR can then be used to drill down into patient level data. Both provide an ability to benchmark similar PCNs and CCGs and could be used to highlight best practice and influence quality improvement.

Michelle Turner added that it has been agreed within the CCG that the revised process will be implemented in March 2021 acknowledging the current challenging situation in general practice and asked for the view from NHSE/I on the delay to the implementation in relation to how resource can be best utilised in primary care during Covid. Neil Coulter agreed that he would check this approach with NHSE/I and feedback. ACTION – Neil Coulter to check the proposal to delay the implementation of the revised contract and quality assurance process within NHSE/I and feedback to the CCG.

Karen agreed that whilst the implementation of the revised process is paused oversight of performance in general practice continues and suggested a discussion with the PCNs on a Quality Assurance and Quality Improvement approach rather than contract assurance focus.

The Primary Care Commissioning Committee:

Part one – the Contract and Quality Assurance Process

 Endorsed the proposed changes to the CCG Contract and Quality Assurance Process and agreed with the proposal that the process is paused until March 2021  Noted that some practices have already completed the pre-visit template in anticipation of a PCT visit, those practices will be given the option to progress under the existing process

Part two – PC dashboard/RAIDR overview

 Endorsed the point that the two data/information sources are compatible and supportive of each other  Recognised and agreed the use of RAIDR in identifying and analysing areas of improvement  Recognised and agreed the use of the Primary Care Dashboard as a tool to provide contract and quality assurance subject to the amendments to the content as provided

5. Additional Roles Reimbursement: Under-spend decisions

Vicki Wallace presented a paper to assure the PCCC on the process followed by the CCG to allocate the Additional Roles Reimbursement Scheme Unallocated funding. Vicki summarised the process followed highlighting that following receipt of the workforce plans from the twelve PCNs the Unallocated Funding pot was agreed to be £327,000 and all PCNs were invited to bid for this funding as per the process detailed in the paper. Five bids were received and the Unallocated Funding panel agreed to fund all five. It was noted that the CCG has been given two different total ARRS allocations – one is based on the information set out within the specification (£4.5m) and one based on a letter received from NHSE/I’s finance team (£4.9m) and to date the decisions made as part of this process have been based on the specification allocation however Vicki asked the PCCC to note that amount of £4.9m stated by NHSE/I’s finance team is the correct amount and that this revised allocation will be used going forward. Vicki added that PCNs have been asked to acknowledge that there are not able to make any further requests for funding past April 2021. Page 3 of 7

240 APPROVED 12.01.2021

The Primary Care Commissioning Committee

 Noted the process followed by the CCG to allocate the Unclaimed Funding pot for 2020/21  Were assured that the commitments agreed have been based on the original allocation set out within the specification  Noted that if the ARRS allocation for the CCG is the increased amount moving forward, this information will be shared with the PCNs to enable them to plan their future recruitment appropriately

6. Primary Medical Care: Service Provision during Covid-19

Karen Stothers talked through the paper which provided an update on national contract changes including changes to the Quality and Outcomes Framework in response to Covid-19 and which asks the PCCC to endorse the requirements of practices in respect of the remaining 310 points that are subject to income protection. It was proposed that the income protection for the 310 points ensures that practices are undertaking risk assessments to ensure that the patient groups that are vulnerable to harm from Covid are supported and clinical assessments are undertaken to alleviate the risk to harm using RAIDR as a tool to support this. The paper also provides an update on work to support GP practices where staff that have tested positive for Covid-19 to ensure that there is a sustainable primary care offer. There has been a discussion with the LMC on business continuity plans if GP practices are unable to remain open due to outbreaks to ensure continuation of primary medical care and what support practices would need. GP practices have received letters with more information on the Covid vaccine DES and the CCG are supporting and facilitating this work.

The Primary Care Commissioning Committee:

 Noted the national guidance and contract regulation changes as a response to Covid- 19  Noted the current number of practices affected by practice staff testing positive of Covid  Noted that the CCG is discussing options for business continuity with the LMC  Noted the update to site closures

7. Contract Assurance and Performance Report

Karen Stothers presented a paper with a summary of discussions and outcomes from the Contract Assurance Group (CAG) meeting held on 13th October, a summary of primary care performance of the primary medical contracts held by the CCG, and a summary of primary medical care risks on the corporate risk register. It was noted that Farrow Medical Practice remain under enhanced surveillance. The CAG discussed the equitable funding review as there is duplicate funding for the diabetes indicator as it is included within the Quality Assurance Framework. The group received two notifications of amendments from PCNs of their payment arrangements.

The Primary Care Commissioning Committee:

 Noted the actions taken by the Primary Care Contracting and Quality Team (PCT) in the management of the contract assurance process  Noted the primary care risks within the CCG corporate risk register

8. Healthcare Estate in Keighley and General Practice APMS Contract for North Street Surgery

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241 APPROVED 12.01.2021

As declared at Item 2:

 David Richardson has a financial interest in this item as a non-executive director of Bradford & Airedale Estates Partnership Ltd, who would potentially bid for a development project in Keighley  James Thomas has a financial interest in this item as a GP partner in the Modality practice which operates in the Keighley and AWC areas.  Louise Clarke has a financial interest in this item as a salaried GP with a practice who could potentially bid for the North Street contract.

It was agreed that David, James and Louise would not contribute to the discussions for this agenda item.

Lynne Scrutton presented a paper to update the PCCC on the Keighley estate development and outline the requirement to understand the approach to re-provision of primary medical services for patients registered at North Street surgery following the expiry of the APMS contract in November 2021. The paper also provides members with an engagement approach for the healthcare estate development in Keighley and makes a recommendation for the re-procurement of the North Street contract. The paper refers to the process for the market testing exercise which concluded that there is currently market interest in the service and the PCCC were asked to approve the re-procurement of an APMS contract and to seek approval from NHS England for a 10 + 5 year contract term. Lynne referred to the second part of the paper which focuses on a proposed engagement approach for the provision of an estates solution for two practices including North Street, community services and dental services commissioned by NHS England and noted the engagement activities that are in progress regarding the APMS contract at North Street surgery.

Bryan Millar raised financial assumptions; Robert Maden explained that the CCG has a fixed financial envelope but there is an issue with the capital funding – there are a range of funding sources but the scope or value of the development has not changed. More information on the financial plan will follow with a recommendation for the preferred site. The range of languages covered in the engagement process was raised; Lynne explained that an Equality Impact Assessment is being undertaken and a profile of the population will be developed which can guide the appropriate range of options for engagement available.

It was noted that Robert Maden is a director on the Bradford and Airedale Estates Partnership and Lynne explained that the paper acknowledges that there are conflicts of interest within the project team and membership of the team is being reviewed. Ashley Green queried if the development will include new dental practices; Lynne confirmed that it will be a community dental service that is currently in an existing healthcare site in Keighley that provides dental services to vulnerable patients or those who struggle to access routine dental care. Ashley offered support from Healthwatch on the engagement work.

The Primary Care Commissioning Committee:

 Noted the outcome of the Market Testing Exercise and conclusion that there is market interest in this service  Approved the re-procurement of an APMS contract for the delivery of primary medical services for the 6.5k patients registered at North Street Surgery  Approved the contract term of 10 + 5 years and noted the requirement to receive authorisation for this from NHS England  Confirmed support for the engagement activities with the registered population of the North Street Surgery  Confirmed support for engagement with the broader population of Keighley, noting the need for assurance on financial model prior to activities commencing.

9. Special Allocation Service (Safe Haven); Market Engagement Exercise

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242 APPROVED 12.01.2021

Karen Stothers presented a paper which describes a market engagement exercise for the Safe Haven Service that has taken place and the next steps to be taken. The CCG offered the service to current holders of primary medical care contracts however this failed to create any interest and work continues with Local Care Direct who will continue to provide the service until 31st March 2021.The CCG is now working with other CCGs across the ICS to look at commissioning options for this service and a further market engagement exercise has taken place to test the wider market. The exercise has confirmed that there is market interest and the specification will be refreshed and will go out to procurement across the interested CCGs. In response to a question regarding location Karen confirmed that the service will take place within the locality and video consultations might also be used. As the service is currently for acute conditions there is an aim to broaden this into long term management of conditions.

The Primary Care Commissioning Committee:

 Noted the paper and the requirement to canvas interest from local practices and other providers for the service, where a contract is coming to an end.  Noted the opportunity to work with ICS local partners on a procurement exercise for the Safe Haven service.

10. GMS and PMS Harmonisation in AWC

As noted at item 2, James Thomas had declared a financial interest in a GP practice operating in the AWC area (Modality). It was agreed that James would not contribute to the discussion about this item.

Lynne Scrutton presented a paper which advised the PCCC of the intended approach to completing the NHS England Equitable Funding review which is a national approach to ‘harmonising’ GMS and PMS per head contract values. The CCG agreed to move towards harmonisation on behalf of NHS England by redistributing the PMS premium value incrementally over five years. Work to move towards full harmonisation of core contract value is still to be completed. NHS England expect that this work will be completed by April 2021. In March 2020 financial information was shared with the two AWC PCNs and the LMC however this work was paused at the request of the PCNs due to Covid-19. The CCG have decided that a phased approach would mitigate the financial impact on practices and propose applying 50% of overall change by April 2021 and the remaining 50% by April 2022 so practices can undertake financial planning and mitigate the impact of any reduction in funding. The overall value of the adjustment is £213k.

Lynne noted that there will still be disparity in PMS/GMS core contract values between Bradford practices and AWC PMS/GMS practices however noted the condition of financial protection of primary care funding with no movement across the former CCGs unless agreed by the membership and that the value of the AWC LES will remain intact. Discussion will continue with LMC and the two AWC PCNs in order to understand the financial impact and NHS England have acknowledged the intended approach.

The Primary Care Commissioning Committee:

 Noted the intended phased approach to redistributing the ‘PMS Premium’ over a two year period with harmonisation achieved by April 2022.  Noted that a further paper with more detail will be presented to the PCCC meeting in January seeking approval of the financial adjustments (ACTION)

11. Any other business: tabled paper on ‘draft principles for income protection for general practice’

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243 APPROVED 12.01.2021

Ali Jan Haider tabled an urgent paper on draft principles for income protection for general practice and requested support from the PCCC for these. He noted that they were aimed at ensuring general practice was not destabilised financially as a result of COVID and that this was a conversation that was happening across West Yorkshire currently. Ali Jan outlined the individual draft principles.

The timeframe for the application of the principles was queried and Ali Jan explained these were to be in place during the pandemic period. Robert Maden confirmed that they would apply until at least March 2021 and that this was a collective approach across West Yorkshire and Harrogate. He noted that the principles were not a requirement of national guidance but something that was considered important at ICS level to implement.

Steve Patterson noted that tabling the paper meant that members and attendees had insufficient time to digest the content and that there were some contractual elements to the principles that would require discussion with LMCs. Ali Jan explained that Ruby Bhatti had pushed back strongly on tabling the paper for the same reason but following discussion with himself had allowed it for reasons of timing and urgency. He noted that Helen Hirst had been keen that the PCCC was sighed on the draft principles and had a general conversation about them at this point in time.

ACTIONS:

 A copy of the draft principles to be circulated to members and attendees of the PCCC (Ali Jan Haider) [Actioned 11th November 2020]

 The draft principles for income protection for general practice to be added to the agenda of the LMC liaison meeting week commencing 16th November (Ali Jan Haider)

 Update to be provided to the January 2021 PCCC meeting (Ali Jan Haider)

The Primary Care Commissioning Committee resolved to support in principle and subject to discussion with the LMC, the draft principles for income protection for general practice.

12. Key messages for the Governing Body

Due to time constraints, the Chair to identify key messages for reporting to the governing body that afternoon (ACTION: Ruby Bhatti).

13. Questions from the Public on Agenda Items

There were no questions from the public.

14. Date and time of next meeting

The next meeting of the Bradford District & Craven CCG PCCC will take place on: 12th January. 10.30am to 12.45pm, VENUE: To be confirmed but likely to be a Zoom meeting held in public.

Ruby thanked Lynne for her hard work and support to the CCG as it was Lynne’s last meeting before she retires in December.

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244 NHS Bradford District & Craven CCG

Minutes of the Finance and Performance Committee Meeting Thursday 3rd December, 11.00am – 1pm, via Zoom

Present: Neil Fell (Chair) Lay Member for Finance BD&C CCG & Performance Bryan Millar Lay Member for Audit BD&C CCG & Governance Robert Maden Chief Finance Officer BD&C CCG

In Attendance Amy Paffett Strategic Head of Finance BD&C CCG for agenda item 7 only Chris Balson Senior Head of Strategy BD&C CCG Change Delivery

Kerry Weir Associate Director, BD&C CCG Population Health & Wellbeing Sarah Dick Head of Corporate BD&C CCG for agenda item 10 only Governance Sharon Wood (minutes) PA to Chief Finance BD&C CCG Officer Walter O’Neill Strategic Head of Keeping BD&C CCG Well

Louise Clarke Strategic Clinical Director BD&C CCG Apologies Strategy & Planning

1. Apologies Apologies were noted as above. 2. Declarations of Interest There were no declarations of interest. The register of interests records all interests declared and is available at: www.bradforddistrictandcravenccg. 3. Minutes of the Meeting held on 5th November 2020 The minutes of the Joint Finance and Performance Committee meeting held on the 5th November 2020 were agreed to be an accurate record. 4. Action Log EU Directives Governing Public Procurement. – is this still relevant given the Brexit transition arrangements. Robert confirmed as CCGs are in a transitional period this will be in place until December 2020, but agreed to make some enquiries re how long the transitional period is for and how long those particular requirements are with us. - Robert confirmed he hasn’t seen anything new on the EU Brexit in relation to procurement. There is a self-assessment return due this week in terms of whether there are any issues and there is a finance question quantifying the financial impact on Brexit. Robert gave assurance the CCG didn’t anticipate any financial impact however, there might be an impact on Prescribing but is too early to tell. Keep on the action log.

245 Helen to follow up with the team as CCGs have advised North Yorkshire they don’t want to continue with that contract and they want to bring into one Bradford District & Craven Contract instead. – This is on the agenda. Action complete

Covid Expenditure report. The need to focus on breaking down the £12m and looking at it in more detail to be included in the report at the next meeting. This is on the agenda. Action complete

Robert to set out budget proposal issues for the Governing Body to consider and share with Neil & Bryan before the Governing Body meeting. Robert summarised the budget proposal for Governing Body and shared with Neil & Bryan prior to the meeting. Action complete.

Robert to have a conversation with Michelle Turner re care home complaints. Robert had a conversation with Michelle who confirmed there have been no formal complaints re the CHC backlog cohort. There has been 2 issues raised from providers with regard to the lower rate paid since 1 September, however, the PCD has resolved both cases through the usual process, i.e. the provider is required to set out the care needs to justify a higher rate for the care package. 5. Performance Report Kerry Weir gave an update. The report presents performance against the key national performance indicators and ‘must dos’ which reflect delivery of both the national Five Year Forward View (FYFV), the NHS Constitution standards and the NHS Mandate, which the CCGs have to deliver as part of their operational plans. Also included is delivery against the recent recovery plan submissions and the Covid-19 system dashboard (the latest version will be shared prior to the meeting for discussion). Key points to note are: • Both Trusts have seen increased demand on A&E over recent weeks and rising Covid admissions, which has impacted upon bed occupancy and flow and resulted in the Trusts having to reduce non-urgent activity in the past couple of weeks. This will impact the ability of both Trusts to deliver their recovery plans; • 18 week and diagnostic performance continues to improve as activity increased in October, but there were significant increases in 52+ week breaches; • There is an ongoing impact of Covid on inpatient mental health acuity, occupancy, staffing and increased out of area requirements, with inappropriate out of area bed days (adult acute and PICU) remaining high; • Improving Access to Psychological Therapies (IAPT) recovery performance has been on or over target all year and waiting times has been maintained. The numbers entering therapy has been increasing, although this has now flattened off. Suppressed referral activity during the first Covid wave will impact on future demand and acuity and the prevalence (of population with common mental health problems) is estimated to have increased by 6% creating a risk of backlog surge and associated waits. • The number of reported cases of Covid reached an all-time high at the beginning of November, but are starting to see a decrease; and • Delivery of this year's flu vaccination campaign continues with almost 75% of the first priority cohort (65 years and above) now vaccinated and roll out of the new 50-64 not at risk cohort now having commenced. • Continuing Health Care is now in the recovery plan and the CCG are in line with the trajectory given in terms of getting the backlog cleared. Bryan asked was there anything the CCG can do about performance to improve it that they’re not doing at the moment and if there isn’t do they know any more about the consequences of the performance dashboard as it is which has lots of reds. Kerry confirmed there isn’t anything the CCG can do that isn’t already been done by their provider organisations to try and manage performance. When it comes to 18 weeks the focus is not just about how long you’ve been

246 waiting it’s about how urgent you are and what your clinical need is which is required nationally. Clearly there is a push nationally to get some of the lower elective activity done using the Independent sector and the CCGs are working in partnership with the Yorkshire Clinic and Yorkshire eye. In terms of how they will be assessed CCGs recently received their IAF national assessment framework scores which weren’t good due to the CCGs’ financial performance. At present there is no information to indicate how or whether the impact Covid will be taken into account in any future performance assessments. Pre covid they were looking at re-addressing how they measured some of the access information rather than hard numbers. Robert asked if there was any sense of the scale of the recovery that the Trusts will be able to achieve in relation to elective activity, noting that in terms of the ICS plans most providers underspend as a result of the lower levels of elective activity. The Bradford place in terms of balancing at a place is relying on an underspend appearing in local Trusts to help contribute to achieving a balanced position. Kerry confirmed during the first peak referrals were suspended but haven’t suspended referrals this time so the backlog is going to be increasing and will clearly have to be addressed and the recovery plans (formulated before the second wave) will need to be re-looked at. Neil highlighted the IAF requires improvement grading and asked whether the CCG is under any pressure to come up with action plans on this from the centre? Kerry confirmed she hadn’t seen what the CCGs received from NHSE and had not had the detail breakdown the CCG would normally get showing where they are an outlier against each of the indicators and are having to use the base data and get someone in the team to create a dashboard so they can see the hotspots and the need to understand how they did the assessment. The action plan has always been something the CCG has chosen to do rather than you must do. Robert confirmed the main driver of the performance rating was QIPP performance, the CCG reported a maximum level they felt they could in terms of what had happened and if you were below 85% you got a red rating. Planning for the place financial sustainability piece will be picked up as this is the only way to address it. Neil highlighted the Mental Health section of the report where the narrative states that “we are not getting increased referrals now but they will come”. Kerry confirmed national research is saying that clearly Covid itself and the way it is being managed with the lockdowns and the restrictions is impacting upon people’s Mental Health. Robert confirmed within the financial settlement that came out of the spending review there is a lot of money in for mental health, so there are some good opportunities to use this to address some of the pressures that will come through. Neil highlighted A&E and reference to people presenting with winter problems and as there hasn’t been a cold snap how do they explain it. Kerry confirmed Airedale have seen an increase in fractures. Walter confirmed Dr Sara Humphrey responded in the increase in falls highlighting where people are frail and during lockdown the opportunity to be ambulant had been significantly reduced over a long period of time. As a result to potential for falls is increased and suggested this was a key factor. Kerry confirmed as the CCG and providers are working together as a system they are starting to get the Trusts forecast of where they would be and some of the trajectories might go up to Q3 and are trying to build that in, in terms of seeing what they think the position is before it becomes a national position.

Recommendations; The Finance and Performance Committee: • Noted the update on performance. 6 Contracting Report Chris Balson gave an update.

Key points to note. • Continued apparent large under trades within acute trust activity (Bradford teaching hospital and Airedale NHS trust) but these don’t reflect the cost of COVID delivery

247 • Yorkshire Clinic continue to support system through National Contract, but have been given notice by NHSE/I that this will terminate 24th December 2020 • New IS Framework to replace National contract • Local discussions to reach and agree these “new” framework contracts underway Yorkshire Clinic Yorkshire Clinic are operating under a national IS framework contract. Under the terms of this framework they are undertaking activity at the behest of the system, to help alleviate covid pressures. As such they are not fulfilling work under the existing contract with them and therefore are not reporting activity to us directly. During the current period senior operational and management staff have maintained regular contact with the CCG, a YC specific local system capacity update was received from Hospital Director Debbie Craven on 1st December 2020 with particular emphasis regarding future planning and contractual arrangements:

YAS The YAS position will be replicated across the region due to the reduction in the number of people conveyed to hospital throughout the COVID period.

Patient transport will have seen a similar reduction and YAS have become a coordination service for all patient transport services during the COVID period. A number of restrictions have been placed on bringing people in to healthcare appointments with all routine PTS cancelled. Other measures have also been put in place, for example those patients in receipt of renal dialysis can no longer travel together and each has to have their own vehicle provided.

Enable 2 Contract update 2020/21 – Enable 2 is now operating under a framework agreement awarded by the North of England Collaborative, who is the authority for establishing an agreement for the provision of interpreting and Translation services. The framework agreement provides face to face interpreting, telephone and video interpreting services. Enable 2 has been assessed for mandatory requirements, key provisions, quality and price.

Due to COVID-19, all face to face interpreting sessions have been moved to telephone interpreting or have been cancelled from 23rd March 2020.

Neil highlighted if services were functioning well without face to face sessions and the CCG were saving money, is this something the CCG would continue post covid. Chris confirmed work that has worked well wouldn’t be reverted back to pre covid.

MEDEQUIP (AWC patients only)

The contract allows for a 2 year extension, commissioners are keen to look at this option. Each Commissioner is required to gain formal agreement following their own governance arrangements. NYCC and CCGs have begun conversation with the lead contract manager. The conversations need to be continued to reach a decision.

Independent Sector National contract arrangements with Independent Sector (IS) providers are set to expire.

As part of the Revised arrangements for NHS contracting and payment during the COVID-19 pandemic national arrangements for purchasing capacity and support from Independent Sector acute hospitals were put in place so that staff and facilities could be used for urgent surgery, as well as repurposing beds, operating theatres and recovery facilities to provide respiratory support for COVID-19.

These national arrangements were put in place for an initial period from 23 March 2020 for at least 14 weeks and were subsequently re-negotiated, after the initial wave of COVID-19, to reflect that IS providers could undertake 25% of private work and 75% of NHS work until such a

248 point that surge would be triggered to revert back to 100% NHS work. NHS activity is funded directly to the IS via HM Treasury on a full cost recovery basis.

These national arrangements have an expiry date of 31 December 2020 at the latest and cannot be extended past this date. A notice period of one month could be given to terminate the contract prior to this date.

Locally the acute trust has been working with Ramsay Yorkshire Clinic and Optegra Eye Hospital to support the continuation of cancer pathways as well as outpatient and elective pathways based on an agreed set of principles and in line with the national clinical guide to surgical prioritisation.

Neil asked what happened with patient choice, Chris confirmed that patient choice is still operative and if you are referred today the principle is if they sign the contract with the Yorkshire Clinic as the lead commissioner they will sign up all the other West Yorkshire CCGs associates and the principles signed up to are put in the same cohort for prioritisation.

Chris confirmed the complication is how the financial framework and reimbursement works. The elective incentive scheme suggests that if Bradford don’t meet their recovery trajectory they will get a financial hit for that in their allocation, but counter to that they will get reimbursed for every piece of activity they put through their contract in the framework.

Robert asked if Westcliffe were on the framework, Chris confirmed they signed up to the framework and have got a large number of services they haven’t previously offered. Robert asked In terms of the first part of the year when the CCG will have had activity going through Westcliffe, is that activity now on the framework and is it considered as nationally paid for activity. Chris confirmed some of this is on the framework and the CCG had a local agreement around Endoscopy for e.g. which is now on the framework. Robert highlighted this will need to be factored in the financial forecast for M7-M12. Chris confirmed given the demand is likely to come from Bradford the CCG can avoid getting involved in a framework contract with them for their services when there is going to be a specific demand for it.

Neil asked whether the YC continues to deliver activity against the NHSE agreed position. Activity is currently in excess of planned levels across all areas with the exception of MR and CT. BTHFT have relinquished their MRI and CT capacity which will shortly be utilised by Westcliffe Innovations Ltd and Westcliffe are offering to provide services partially through the Yorkshire Clinic. Chris confirmed to some extent yes, some of these services are by default mixed and some services require MRI or CT as part of a diagnostic which Westcliffe don’t have so they will need access to some-ones MRI or CT through the Yorkshire Clinic. Robert asked in terms of the capacity that is on offer is this still at 75% in terms of what providers are required to provide. Chris confirmed there is no definition of what capacity they offer and the ICPs are offering less than 75%.

Robert asked even though Haematolgy is provided out of the Yorkshire Clinic site the staff are BTHFT staff. Chris confirmed it is a mix of Yorkshire Clinic straff with BTHFT staff oversight but clearly when this moves to Eccleshill Hospital this would be all BTHFT resource.

Risks There are a number of risks associated with mobilising the framework. The risk around the lack of clarity in relation to HM Treasury funding flow prior to 31 March 2021 and whether it sufficiently covers the cost that will be incurred is a concern. Robert confirmed this has been raised with NHSE regional finance and everyone is looking at it to get an answer. From an ICS perspective Jonathan Webb asked the direct question above the financial baseline calculation that they share it back with everyone to say this is the financial baseline against which reimbursement claims will be measured.

Robert confirmed if the price being charged for activity is above national tariff what would happen in that instance. Chris confirmed they are not allowed to do that, what is clear within the framework is you are not allowed to charge above national tariff. National tariff is the cap so

249 providers are allowed to offer discount 1% or 2% against national tariff and many offer discounts on volume based on that.

Neil asked whether the finance risks had to be added to the risk register, Robert confirmed the need to confirm what the process is. Once clarified, there is a clear acceptance of the principle of reimbursement against a commonly understood baseline and to that extent feels comfortable there should be no question around not reimbursing as long as it is appropriate framework activity.

Next steps • Initial discussions to take place with YC and YEH to understand the local available service offer and share the proposed approach to contracting • Review and agreement of the proposed approach between CCGs and Trust • Agreement of principles to underpin the required prioritisation of patients to ensure equitable access to services in line with clinical guidance to surgical priorities. • Analysis of current NHS and IS provider waiting lists and clinical priority patients to inform indicative split of capacity at service level • Explore if CCG wants to add any new services made available by IS providers that were not previously available on ERS • Develop a common set of contract schedules for inclusion in the contracts • Potentially run a mini-competition for ‘mixed’ model services • Negotiate contracts with IS providers

Recommendations; The Finance and Performance Committee: • Noted the update 7. Hospital Discharge Scheme Amy Paffett presented to the Committee a deep dive presentation on Hospital Discharge Scheme.

There are 2 schemes in operation: Original Hospital Discharge Programme (HDP) from 19th March to 31st August 2020: • eligibility assessment process suspended from 19th March 2020 • all new or extended out-of-hospital health and social care support packages to be NHS funded • CCG and LA must assess all cases by 31st March 2021

Discharge to Assess Scheme (D2A) from 1st September 2020: • eligibility assessment process deferred for 6 weeks • all new or extended out-of-hospital health and social care support packages to be NHS funded for a maximum of 6 weeks • CCG and LA have 6 weeks from discharge date to assess each case For all cases, the continuing care assessment will determine eligibility and whether the costs will continue to be borne by either the CCG or LA.

Non COVID Costs

The on-going non-COVID costs for continuing care relate to cases that were either already in place at 18th March 2020 or are new HDP and D2A cases found to be eligible for CCG funding following completion of the assessment. For months 7 to 12 non-COVID costs will be funded from within the CCG fixed funding envelope.

As part of the financial planning process for months 7 to 12 a budget was calculated based on: • On-going non-COVID cases at 30th September costed to 31st March 2021. • Application of a conversion rate (estimated at 1/3) to COVID assessed cases costed at average rate to 31st March 2021. • Application of a conversion rate (estimated at 1/3) to the new cases after 6 weeks costed at average to 31st March 2021.

250 Clearance of the backlog at a faster rate than anticipated has resulted in higher non-COVID costs than planned. Similarly, the current conversion rate appears to be above the planned 1/3 level and therefore the non-COVID costs are higher. This may be due to how cases are being prioritised for assessment. Non-COVID costs are currently on-line with budget but if the current speed of backlog clearance and rate of conversion continue, this may lead to an unfunded cost pressure.

Bryan highlighted for all the money the CCG are spending just having a regular update on who they are paying, what for and who’s the budget manager for that and assurance they are getting value for money and managing the resources correctly. It’s good to see the process is working and assured people are being assessed but it’s more about financial governance and control that I am concerned around just seeing their is clear ownership of this within the CCG.

Amy confirmed the whole process is continuing to be managed via the LA team who manage the Continuing Care process., the existing arrangements and controls that are in place regarding CHC and LA placements and putting people within the residential or nursing care placements depending on where they need to be, the team that did this for CHC are still doing that which sits under the process. What they are not doing is the assessment around what levels of need those people have and whether that sits with the CHC criteria or the funded nursing care criteria. In regards to the governance it’s the same governance that sits with the CHC placements if the funding has not being allocated.

Robert confirmed it links to the CHC internal audit report and the issues that are flagged up in there. In terms of the assessment process that is fine but what that report highlights are some financial governance issues that need to be agreed. In terms of ownership it is Adele Thornburn and in terms of budget manager and that team that’s where it sits. Prior to the audit report coming out, there is a joint working group set up to go through the issues. In terms of ownership and timescales most of them fall to Adele to be completed by the end of January.

The CCG are getting assurance it is working and if it’s consuming resource they didn’t expect that some-one is following this up. Bryan highlighted as the CCG are passing resources through the system that are being allocated to them and then re-allocated they need to be comfortable they have a robust system for assuring some form of value for money. Robert highlighted in terms of the cost of the care packages in the main there is a rigorous process in place for either side of the rates but the reconciliation and checking process needs to be strengthened.

Robert highlighted when you look at the elective activity he understood the prioritisation but in relation to this don’t understand why you would prioritise other than by the timing. There is something around a stocktake approach looking at the conversion rates and the average cost of the care package against the assumptions they have put in their forecast model so they can see how they are doing against that estimate.

Neil highlighted does the audit report reference to confusion that the CCG see a lot of cases quicker than others. Robert highlighted the issue is about the Controcc system not holding details of all care packages, whereas SystmOne which the PCD team use, holds the complete PCD caseload. There is more work to do to come up with ideas on how they minimise any differences between the system and link better.

Robert highlighted the backlog will consist of a number of people in care packages as a result of being discharged from hospital and the other part of the backlog is people who were never in hospital that were put into care packages to prevent them going into hospital and more community based that Social care would put forward for a continuing care assessment and the need to understand how both of those cohorts are being tackled.

Robert highlighted in the first half of the year a lot of time and resource that came out of the LA system was right and are aware as they move into the second part of the year they have additional complications which have not been referred to like the beds that are protected in care homes for covid patients (designated setting beds), those beds are paid for through the hospital

251 discharge team and there is a need to make sure the system identifies people in those beds so they seek a re-claim for the right amount which doesn’t end up into normal CHC costs.

Neil highlighted that the audit report states that they stopped having reports at the finance committee as it was too detailed. He recalled that much of the detail was around the CCG risk share process which no longer applies and it would be useful to reinstate a section in future finance reports that charts activity against the budget and any specific risks they are aware of against the budget assumptions to close that off and show they have responded to it. Robert confirmed it is using this to produce a new standard section on this particular budget area.

Recommendations; The Finance and Performance Committee: • Noted the contents of the presentation 8. Finance Report Robert Maden gave an update.

In the first half of the financial year, retrospective resource allocation adjustments were made to bring the CCG’s financial position back to a break-even position.

For the second half of the financial year, this process no longer applies and the CCG needs to manage its expenditure within a fixed resource baseline, with the exception of a small number of items that are funded separately on an actual cost basis. The fixed resource baseline also covers any additional COVID-19 related costs. The items funded on an actual cost basis are Hospital Discharge Scheme costs and local independent sector activity costs in excess of the average run rate over the April to July 2020 period.

This paper provides information on financial performance for the period October 2020 to March 2021 (M7 to M12), with the year to date position reflecting financial performance for October.

Key Points:

• The year to date and forecast positions for costs within the fixed resource baseline show operational budget underspends of £0.6m and £1.3m respectively. These are offset by a corresponding shortfall against the additional savings target of £4.9m resulting in a break- even position (year to date and forecast). Bryan highlighted the report is saying that in relation to the deficit of £4.9m which is called the allocation shortfall, the position remains as it was. However, the CCG is less confident of the recovery of the shortfall, but is more confident it will break-even. Robert confirmed in relation to the additional savings target of £4.9m, a correction of £2.1m to the CCG’s primary care co- commissioning allocation is being pursued with NHS England and Improvement, £1.3m is offset by other budget savings, and £1.5m is expected to be covered by a combination of deferral of development spend and local financial risk share arrangements. When they’ve gone through and looked at the calculation of the local independent sector activity budget at a national level, it had rebased it back to their average spend in M1-M4 and know that the national budget in M1-M4 and then extended to September was a higher value and it had quite a significant underspend against that in the first half of the year by £2.7m. In effect this has been removed from the CCG’s baseline and they will not reinstate that. In terms of moving on, things that have moved since are the forecast budget underspend of £1.3m and a formal proposal to defer development expenditure rather than let’s just wait and see. There is then a quantification of what the CCG would look for from other place partners. Bryan highlighted the need to set this out for GB members. Neil asked in terms of the proposal to defer developments, is that signed off in the organisation or is it still a finance proposal. Robert confirmed that it is an accepted position that the £700k would not go ahead in relation to the RIC schemes that have not yet started. The CCG has said that the schemes will not start in 2020/21 and the position would be kept under review for 2021/22. • The baseline savings target of £1.2m is covered by premises cost and support function

252 savings, and a reduction in forecast prescribing costs.

• Underspends against budgets for which additional funding can be claimed, i.e. the Hospital Discharge Scheme and local Independent Sector activity costs, are offset by a reduction in the value of the reclaim resulting in no impact on the CCG’s financial position.

• The position includes £0.3m and £1.3m for year to date and forecast COVID-19 costs (M7 to M12 budget = £1.3m).

• On the basis of the forecast operational budget performance and the expected mitigation of the £4.9m additional savings target, the CCG expects to meet it break-even financial target for 2020/21.

• The forecast position at Month 9 will be reviewed in order to assess whether the Bradford Place financial position can be managed overall, or whether the wider ICS financial risk management arrangements will need to be invoked to help the CCG meet its break-even target.

Neil highlighted in terms of Mental Health spend the CCG are showing an overspend on M1 and a trajectory one which isn’t 6 times that overspend so suggest they will claw some of that back and the reference to the other risk mitigation as been into the Care Trust in terms of out of area and are they double counting or are there 2 separate issues. Robert confirmed there are 2 separate issues, in terms of the financial position year to date and forecast, this includes an assessment of what the CCG think will happen to mental health placements, whereas the out of area pressures for the CCG relate to psychiatric intensive care unit activity. Whilst psychiatric intensive care activity is within the block arrangement with the Care Trust, that element is still variable. A prudent forecast has been included in the block value with the Care Trust, but we continue to monitor this. There is a risk that it might not be enough and this is a separate issue. Neil asked would there be any issues following the conclusion of the IS process as the CCG can’t legislate for the outcome of that. Robert confirmed for the CCG it is around ensuring they make full use of both national contract and local IS contract capacity. From a financial perspective, there is no financial risk as the activity will either be paid for nationally, or through the local reclaim mechanism for activity above the M1 to M4 baseline. Neil highlighted at system level they are assuming that they are chunking things up through place and then to system is all doable as they said in the assumptions and is there any indication that there will be any blistering anywhere else in terms of the assumptions that partners set off on. Robert confirmed there are 2 levels, in terms of the Bradford place the Trusts are indicating that they are seeing bigger underspends coming through on the non pay at the back of the elective activity reduction and when you play that out across the ICS even though it’s at an early stage, at an ICS level there is a slight underspend emerging so they are not seeing any other areas go the wrong way and are all indicating they will do better than plan. This is helpful in terms of managing the Bradford risk. Robert highlighted that an assessment of management of the Bradford Place financial position will be made at Month 9 to inform the need for any wider ICS support. Recommendations; The Finance and Performance Committee:

• Noted the year to date financial position to the 31st October 2020 and the forecast financial position to March 2021; • Noted the financial risks associated with operating under the new finance regime and the mitigations in place to manage this risk; and • Noted that an assessment of management of the Bradford Place financial position will be made at Month 9 to inform the need for any wider ICS support. 9. COVID Risk Log Sarah Dick gave an update. The purpose of the paper is to provide details of risks allocated to the finance and performance

253 committee (FPC) for review and approval ahead of onward reporting to the governing body.

Corporate risk register (bi-monthly review)

There are currently a total of 14 open FPC risks (one more than the last risk cycle). Of these:

• there are three new FPC risks: • risk 1694 underlying financial position, scoring 16 (I4xL4) • risk 1693 financial position M7-M12 20/21, scoring 16 (I4xL4); this replaces risk 1547 relating to the financial position for M1-M6 (which also scored 16) which has been closed • risk 1681 relating to compliance with accessibility standards regulations, scoring 4 (I4xL2) • there are no FPC risks classed as ‘critical’ (scoring 20 to 25) • there are seven FPC risks classed as ‘serious’ (scoring 15 or 16), the same as at the last risk cycle • no FPC risks have increased or decreased in score

COVID risk register (monthly review)

There are seven COVID risks allocated to FPC (including one relating to PPE that has aspects that align with both FPC and the quality committee):

• no new FPC risks have been added, none have increased in score during this cycle and none are marked for closure. • one risk (relating to PPE availability and use) has reduced in score from I4xI4 = 16 to I5xI3 = 15 • there are no FPC COVID risks at the ‘critical’ level (scoring 20 or 25) • the FPC COVID risks include three at the ‘serious’ level (scoring 15 or 16);

Neil questioned the risk re the compliance of accessibility regulations in terms of what they are not meeting statutory details, Neil highlighted when he tried to log in through webmail he got a message saying it’s an insecure site and is that part of that. Sarah confirmed no, it is around things been accessible visually and to take account of the needs of a diverse audience i.e. people who are colour blind, partially sighted and those papers and documents that are publicly available now have a format for how they should be presented and the communications team have done some templates and training slides. The CCG are not fully compliant, the website itself is ok, it’s the documents that are uploaded as part of that, that is the issue, and the communications team are still liaising with the supplier to see what needs to be done for the intranet.

Bryan highlighted there is some reference around the progress around conflicts of interest with partnership working and how that’s ongoing, and is clearly going to be even more ongoing in the current circumstances and will become more important over the next few months. Sarah confirmed they are re-doing the (SPA) Strategic Partnering Agreement and looking at some conflicts as part of that and a piece of work that needs finishing is the system register of interests which will go on the priority list.

Recommendations; The Finance and Performance Committee: • Reviewed and approved the FPC risk log and COVID FPC risk log for reporting to governing body, subject to any amendments requested. 10. Issues to highlight to SLT & GB • Performance - aware of the potential impact on unravelling of the system approach and the ICS to cover this overlap and the potential need to reset as they move forward. • Contracting – note the under trends, Yorkshire Clinic supporting the national contract and specific areas working through the IS process. 11. Any Other Business There were no items. 12. Date and Time of Next Meeting

254 The next meeting will be held on Thursday 7th January 2021, 11am - 1pm, via Zoom.

255

256 NHS Bradford District & Craven CCG

Minutes of the Finance and Performance Committee Meeting Thursday 7th January 2021, 11.00am – 1pm, via Zoom

Present: Neil Fell (Chair) Lay Member for Finance BD&C CCG & Performance Bryan Millar Lay Member for Audit BD&C CCG & Governance Robert Maden Chief Finance Officer BD&C CCG Louise Clarke Strategic Clinical Director BD&C CCG Strategy & Planning

In Attendance Chris Balson Senior Head of Strategy BD&C CCG Change Delivery Sarah Dick Head of Corporate BD&C CCG (for agenda items 5 & 9 Governance only) Walter O’Neill Strategic Head of Keeping BD&C CCG Well Amy Paffett Strategic Head of Finance BD&C CCG Kerry Weir Associate Director, BD&C CCG Population Health & Wellbeing Sharon Wood (minutes) PA to Chief Finance BD&C CCG Officer

1. Apologies There were no apologies. 2. Declarations of Interest There were no declarations of interest. The register of interests records all interests declared and is available at: www.bradforddistrictandcravenccg. 3. Minutes of the Meeting held on 3rd December 2020 The minutes of the Joint Finance and Performance Committee meeting held on the 3rd December 2020 were agreed to be an accurate record. 4. Action Log EU Directives Governing Public Procurement – Robert confirmed whilst the Brexit deal doesn’t answer the procurement question it gives more assurance around supplies and there will be further guidance coming out on that. Neil highlighted people were concerned around prescribing and drug supply and presumably there have been no issues around that. Robert confirmed the key messages document issued by NHSE covered off things like this so no particular issues, the other issue potentially is around data flows and have done an exercise to look at data flows between us and the EU which wasn’t an issue for us. Chris confirmed the CCG are being asked that if there are any issues they raise those on a daily basis.

Bryan highlighted the other aspect around the ICS consultation or discussion there is a timely sense the new legislation might change procurement rules for the NHS.

257 Hospital Discharge Scheme Update - Now scheduled for the February meeting.

Finance update for GB members - Robert provided a Finance update for GB members. Action complete. 5. Terms of Reference Sarah Dick gave an update with proposed changes for the ToR.

Role and Function It was agreed to add in the following paragraph. Whilst the Finance and Performance Committee is principally concerned with ensuring that the CCG meets its statutory financial and operational plan targets, it discharges its responsibilities recognising the ‘Act as One’ ethos in the Bradford Place that seeks to ensure the most effective management of Place resources in relation to Place priorities. Other Duties Approve arrangements for risk sharing and or risk pooling with other organisations (for example arrangements for pooled funds with other clinical commissioning groups or pooled budget arrangements under section 75 of the NHS Act 2006). Sarah highlighted that Internal Audit have identified that authority for this is allocated to GB or SLT in the SORD and not F&P. Neil noted that if the CCG were separating the executive role from the review function then the setting up risk share arrangements as with joint commissioning arrangements is an executive role and the F&P role would be to review the arrangements that had been established by the executive, in this case the SLT.

Membership • Lay Member for Finance and Performance • Lay Member for Audit & Governance • Strategic Clinical Director of Strategy & Planning (GP) • Chief Finance Officer

Chair The current TOR state that Bryan as Chair for Audit & Governance shouldn’t chair any other Committee to avoid any conflict in case there has to be any scrutiny of the work of the Committee further down the line although it was noted that on other occasions in the absence of the Lay member for Finance and Performance, Bryan had acted as chair. Neil highlighted the process he and Robert went through which was to say; there are 4 members and it is written into these ToR that the Audit Chair can’t chair this committee, which leaves three other members. However in the absence of the chair the other two members may potentially be scrutinising material drawn from operational areas within their particular areas of responsibility and in effect are marking their own homework. As such there might be questions in terms of their objectivity. The proposal recognised that elements of the Quality Committee role draw upon the same information as the Performance committee giving a degree of familiarity with the subject matter. Proposal: To comply with this condition and maintain the independent scrutiny provided by lay members, it is proposed that the Lay Member for Quality is co-opted to chair the meeting if the Lay Member for Finance & Performance is unavailable to attend the meeting. Bryan highlighted concerns re doing the right thing rather than doing the easiest thing around the principle and governance arrangements around quoracy and chairing and what the arrangements are for the Quality Committee? Bryan always favours an arrangement where some-one who is part of the committee and that body chairs it, so there would need to be a debate to be had around either overall membership and or whether it has to be a Lay Member rather than a GP member. Following discussion it was felt that in a normal business meeting which is just receiving papers for assurance it would be fine for Bryan to take the chair, however, if it was a meeting that

258 required a decision or recommending something to the GB to approve then potentially you might want to draft in another lay member to chair. Sarah asked should Ruby’s role as Lay Member for PCCC be on this committee rather than Quality. Bryan highlighted it would be wise to say that in the usual event of the chair not been available they would need to ensure that the meeting was quorate and also need to make appropriate arrangements for chairing it which could include a member of the committee or co- opted Lay or professional member who is not conflicted in terms of the items on the agenda. Neil suggested the need to come up with a paragraph that reflects this. Sarah highlighted there were 2 Lay Members on the F&P Committee and 4 Lay Members on Quality Committee and asked whether one of the Lay Members should join F&P Committee. Bryan highlighted concern that this is based on people’s willingness, preferences and ability rather than what the organisations need and should have a consistent approach across the CCG. In Attendance

• Associate Director of Population Health & Wellbeing • Strategic Head of Keeping Well • Strategic Head of Finance – Financial Planning & Transformation • Senior Head of Keeping Well

On a quarterly basis, attendees will include:

• Associate Director of Quality and Nursing - for Personalised Commissioning update. • Senior Head of Medicines Optimisation - for Prescribing update.

Louise highlighted re the chairing of the committee there is something around the pragmatism if you look at SLT James Thomas chairs but is sometimes conflicted and hands over the passing of the chair to another colleague, so could look at using some of the existing things they do. Although there is the new line in as the Act as one still unsure that if the CCG F&P were seeing things in one way i.e. a set of risks or a decision making process from the CCGs point of view and the system F&P were seeing the same things with a totally different set of risks as that would be a different group of people and how do they reconcile that. There is something around what is the alignment between the System F&P and the CCGs F&P and the need to be really clear about what is on the table for the system decision making process and what still is CCG owned and directed decision making process and how do they explain that alignment. There needs to be something stronger that explains their alignment and the CCG been back stop as essentially the CCG have the legislation and statutory role whereas the System F&P have chosen to delegate that and do it through the system route.

Robert highlighted this would be difficult to do purely because as things stand now the CCG have that statutory identity and set of responsibilities that go with it which is why they almost act and take decisions in the context of knowing they operate as part of a wider system. This committee is around assurance and the back stop bit links with the System F&P committee in relation to the planning round and use of resources. The CCG F&P Committee would need to be assured that the CCG’s financial plan was reasonable taking into account the allocation of resources to Place priorities and the risk that this left for the CCG to manage.

When you look at System F&P then it does have a particular remit around looking at things from a place perspective which is different to the way the CCG look at things here. As we move forward through the transitional ICS/ICP development phase the new operating model should make the Place based arrangements clearer.

Neil highlighted the issue for him was the CCG have got a system F&P committee and 2 Health & Care Partnerships. If you look at the dashboard where it highlights that some of the targets are failing, the question would be under the old CCG arrangements you would know who to contact, however, under the new arrangement it is someone else not of the organisation and haven’t delegated any functions or those targets but the system has that obligation to gear up for each

259 entity to meet its own statutory targets and who is responsible for that.

Kerry highlighted the CCG have a governance role to do as a statutory body, the individual Trusts and council will have their own statutory duties, and is the System F&P there to work collaboratively to come up with plans to address where they have got finance and performance issues and do they need that link. Robert highlighted it is something around knowing that the System F&P are picking that issue up that the CCG are concerned about and there needs to be some feedback mechanism to this committee that gives assurance that the important issues are being looked at. It was proposed the minutes from the System F&P could be shared with this committee to get an understanding of the business of that group.

Quorum Proposed new wording: The committee will be quorate when at least two Lay Members and the CFO are present. Propose current wording above remains unchanged at the moment, but may need to consider a deputy for the Strategic Clinical Director of Strategy and Planning. In discussion it was agreed that quoracy should be 1 Lay Member, the CFO and Strategic Clinical Director of Strategy & Planning (GP) and Robert could have an authorised Deputy to attend on his behalf.

Urgent matters arising between meetings The Chair of the Finance and Performance Committee in consultation with one out of the Chief Officer or the Chief Finance Officer may also act on urgent matters arising between meetings of the Committee. 6. Performance Report Kerry weir gave an update.

The report presents performance against the key national performance indicators and ‘must dos’ which reflect delivery of both the national Five Year Forward View (FYFV), the NHS Constitution standards and the NHS Mandate, which CCGs have to deliver as part of their operational plans. Key points to note are: • Both Trusts have seen increased demand on A&E over recent weeks and rising Covid admissions, which has impacted upon bed occupancy and flow and resulted in the Trusts having to reduce non-urgent activity in the past couple of weeks. This will impact the ability of both Trusts to deliver their recovery plans; • 18 week and diagnostic performance continues to improve as activity increased in November, but there were significant increases in 52+ week breaches; • Improving Access to Psychological Therapies (IAPT) recovery performance has been on or over target all year and waiting times has been maintained. Referrals to the service initially decreased but have now returned to usual levels, though BDCFT are noting later presentations and increasing intensity and complexity; • The CCG remain on trajectory to have managed the backlog of CHC assessments created as a result of the first wave of Covid; • The number of reported cases of Covid reached an all-time high at the beginning of November, but numbers started to decrease mid-November and have plateaued in December at circa 165; • Delivery of this year's flu vaccination campaign continues with almost 80% of the first priority cohort (65 years and above) now vaccinated and roll out of the new 50-64 not at risk cohort at over 20%; • The CCGs first 3 PCN sites commenced delivery of the Covid vaccination programme week commencing 14th December, with a further 4 sites going live before Christmas. The final 3 PCNs were due to commence vaccinations on Monday 4th January, but their vaccine delivery date changed and will not now be until 6th 7th or 8th January. PCNs have been focussing on vaccinating the over 80’s and health and social care staff and first vaccines were delivered and

260 taken into 7 care homes between Christmas and New Year to vaccinate all residents and any staff. Provisional data suggest that as of 2nd January, there have been a total of 11,180 vaccinations of which 7,109 were for the 80+ cohort; • BTHFT are continuing to vaccinate health and social care staff and BDCFT, AHFT and Community Pharmacy in Bradford will also start vaccinations on January 11th. Plans for further community sites are in place and staff are being recruited through multiple routes; • NHS England (NHSE) has published the IAF end of year ratings for 2019/20. NHS Bradford district and Craven was assessed as Requires Improvement overall, with Quality of Leadership rated GREEN and Financial Performance rated RED. The financial challenge for AWC and Districts CCGs had an impact on the IAF Sustainability & Leadership assessments placing them red for the indicator and requiring improvement overall; and • In total, 28/45 of the IAF indicators provided a positive result. The CCG is in the top quartile for the proportion of people on GP severe mental illness register receiving physical health checks, the estimated diagnosis rate for people with dementia as well as Staff Engagement and Effectiveness of working relationships in the local system.

Neil highlighted re vaccination update some PCNs in the South have said they are going to stick to the recommended interval between the first and second doses as opposed to the new arrangement where you have to wait 12 weeks between doses and asked “were there any issues for the CCG? Kerry confirmed the system approach is that they will go with the national dictate of the 12 weeks however, because it came so late in the day and PCNs already had people booked in a couple of sites did go ahead with the second set of vaccinations. Louise confirmed the second set of vaccinations was done at 3 weeks for those who were due to have their second dose from Monday.

Neil highlighted there seems to be more pluses (improvements) than minuses and that all the recovery charts appear to be very close to plan. Kerry confirmed the referrals are back up pre covid levels, the out-patients looks okay which will be down to the way they are now delivering a lot of out-patients through the virtual route, the elective will never be recovered to last year’s level whilst there is covid and capacity in the hospitals to have people in beds and have not recovered to the same level of A&E attendances or non-elective admissions. There is that risk that people are not coming in, but it’s how they are better managing their non-elective work.

Neil highlighted the increasing number of over 52 week waiters was a concern and asked who deals with that in the system, Kerry confirmed it is difficult to predict, when the recovery plans were set, organisations didn’t expect to still be in covid, but the important thing around those 52 week breaches is that all the waiting lists are being assessed for clinical priority and the over 52 weeks waiters will be people that are way down in terms of need / priority / risk etc. There won’t be people who could end up as an emergency admission in the next 4 weeks and there will be people who possibly never needed to be on that elective waiting list. Louise highlighted there are 2 places that are monitoring the situation, there is the system recovery group looking at the targets and the access act as one programme where work is ongoing. For some that have long MSK waits they are looking at what they can do with the VCS, peer support and weight loss programmes to hopefully get people off or help them to manage their pain during the time they are on those waiting list. The ideal position would be that a significant proportion of those at some point would say they no longer need the procedure they are waiting for.

Both Trusts particularly Bradford Hospitals have come under some national scrutiny looking at elective surgery in terms of numbers and how they’ve been low compared to a baseline of last year in comparison to other places across the country. When they looked at that they were confident they were doing the right things. NHSE were saying do as much low acuity high volume procedures as you can and get through numbers, the approach in local Trusts is to utilise theatre capacity on cases that are high priority and procedures that have a significant impact on people’s lives. As a whole system they have committed to doing that but having that National scrutiny has meant they have gone through everything as a system and all signed up to the principles around how they will manage that.

Chris highlighted re the 52 week waiters some are prioritised to be not necessarily urgent but

261 there was a significant number before covid hit, but there is no capacity to do. Within that cohort there are still prioritised numbers that need to be done which can’t be done due to the complexity of the patient it’s not just they have been prioritised out to the end of the waiting list.

Neil highlighted the dip in diagnostics and Yorkshire Clinic losing staff on it. Chris confirmed they have lost staff which has caused an issue with diagnostics but there are things in place. Bradford has the capacity in terms of estate but don’t have the staff and other providers have staff but not capacity in terms of estate. The new IS framework doesn’t allow for us to match those 2 things up easily so can’t bring staff in from those providers into the estate we’ve got and vice versa. During the Christmas period Bradford organised a sub-contract with Westcliffe so they should now start to alleviate some of that endoscopy diagnostic issue and should see an increase in numbers going through rapidly now and are looking to see if there is a need to do more endoscopy and utilise either the Yorkshire Clinic or Living Care at Leeds and will pick up those conversations through January.

Neil highlighted the assessment framework where the committee acknowledged the requires improvement grading at the last meeting and that the CCG would address issues internally without being required to report to NHSE on what actions they were taking.

Neil asked about the Mental Health Investment standard receiving a red grading but the KPMG final accounts audit report signed us off saying they were ok with that. Robert confirmed this is not for 19/20; the 19/20 audit report has still yet to be done. In 19/20 Bradford District and Craven CCG met the standard but as individual CCGs, City didn’t meet the standard. This was something that was flagged up with regional colleagues, and the CCG are not concerned about City having that blip.

Kerry highlighted the next step is to look at some of these to see if they can update the position as to where they are now and whether the issues can be addressed given the current pressures on the system.

Recommendations; The Finance and Performance Committee: • Noted the update. 7. Contracting Report Chris Balson gave an update. Airedale NHS Foundation Trust & Bradford Teaching Hospitals Foundation Trust There continues to be apparent large financial under trades within acute trust activity (Bradford Teaching Hospital and Airedale NHS Trust) but these don’t reflect the cost of COVID delivery. CCGs have block positions with both Trusts this year and mirror what they have previously had, the one altered this month that the CCG are investigating further is the factored costs at Bradford have gone from an under trade to an overtrade on face value. The Covid situation has meant that whilst all material activity streams have been included, there are some activity streams that have not yet been included due to sickness, redeployment etc. resulting in resource limitations and will be updating activity as it becomes available.

Non-elective activity has also been reduced in comparison to previous years, but associated value is relatively high. This represents the high complexity of patients needing to be treated, and the high use of such things as critical care. A&E activity has shown increased levels of activity and is rapidly returning towards pre-covid levels.

Bradford District Care NHS Foundation Trust Main providers across the Bradford District and Craven system for 2020/21 are working under a national framework contract as direct response to the COVID19.

Yorkshire Clinic The provider did receive notice on the original National Contract for 24th December 2021, with the intentetion that they would then move to the IS framework. This notice was rescinded on 8th

262 December and new National Contract Agreement put in place to run from 1st January to 31st March 2021.

Key differences are that this contract is buying activity, not access, and that it includes a 6-week break clause from beginning. If there is not enough activity through the Yorkshire Clinic, or significant enough impacts on waiting list positions, NHSE/I or Tresaury could trigger clause and revert providers to framework.

Neil asked if the volume was done by organisation or speciality, Chris highlighted Airedale have been clear from the start that the only areas they need volume in is TNO and cystoscopy. Bradford have got a much wider range of areas they are interested in, Gynae, breast, general surgery, urology, plastics, TNO and endoscopy.

Oncology and Haematology daycase and outpatients services moved out of Yorkshire Clinic in December and Ward 2 at BTHFT has currently been recommissioned for these services.

Bryan and Neil highlighted it was a useful upate and the CCG are doing everything they can. Chris highlighted the Yorkshire Clinic have been very reasonable throughout this process and are having regular conversations with colleagues and take what they can in terms of the services and specialities that the hospitals need.

Neil highlighted the lack of information from the Care Trust. Chris has requested an update and will circulate to committee members. Robert highlighted the Care Trust is referenced in the finance and risk report that relates to the psychiatric intensive care unit activity where the CCG are normally exposed to that. The Care Trust have agreed with NHSE some additional reource to cover that risk off, and from a contracting review that is a variable element and not expecting any financial costs passed back to the CCG, but still need to understand what is happening on PICU activity and do need that information.

Robert asked about Westcliife Health Innovations, for the first 6 months the CCG had a level of fixed cost support for that provider and asked whether given that they have moved into a slightly different phase whether they have moved onto an activity base or still a mixed bag in terms of still requiring some level of fixed cost support. Chris confirmed it is a mixed bag due to the wide range of services they do and conversations are ongoing, some of those are complicated by Leeds who may have a different view on this and the CCG don’t want to take a view on changing particular services if Leeds have a different view.

Robert highlighted you still need the procurement policy note in the background for 2021 that talked about if you are giving any level of financial support then this is on the basis that essentially it is a no profit year. Amy confirmed the CCGs intention with Westcliffe is that they will move to a activity basis for the last 6 months of the year for all those services, but given where they are whether they will be able to bring their capacity back to what it would have been before to enable them to ensure they are still getting the right level of income, that situation has changed slightly so the CCG need to re-assess. However, with all the work that they are potentially sub-contracting from the Providers, you would think they would be in an ok position income wise, so the CCG won’t be in a position to protect income.

YAS The YAS position has changed slightly as at month 8. The month actual figures are shown to highlight the slight increase in variance across the majority of categories particularly within Urgent and Emergency Care Calls Answered.

YAS have become a coordination service for all patient transport services during the COVID period. A number of restrictions have been placed on bringing people in to healthcare appointments with all routine PTS cancelled. Other measures have also been put in place, for example those patients in receipt of renal dialysis can no longer travel together and each has to have their own vehicle provided

Enable 2

263 Contract update 2020/21 – Enable 2 is now operating under a framework agreement awarded by the North of England Collaborative, who is the authority for establishing an agreement for the provision of interpreting and Translation services. The framework agreement provides face to face interpreting, telephone and video interpreting services. Enable 2 has been assessed for mandatory requirements, key provisions, quality and price.

MEDEQUIP (AWC patients only) This has been ongoing for a number of months now and the decision is still outstanding.

Other Providers/ IS Framework Local agreements have been reached with other IS providers under framework contracts.

Optegra YEH were included in the national contract through 20/21 and like Yorkshire Clinic were given notice that this would terminate at 24th December 2020. They rejected the offer of the new national contract and have now negotiated a framework contract that covers the period 24th December to 31st March 2021.

Westcliffe Health innovations have had a cost recovery model with both BDC and Leeds CCG for 20/21. They now have Framework subcontracts in place with BTHFT for endoscopy and cardiology and are reviewing the option for the CCG model.

Recommendations; The Finance and Performance Committee: • Noted the update. 8. Finance Report Robert Maden gave an update.

This report provides information on the financial position of the CCG as at the 30th November 2020 and the forecast financial performance for the year to March 2021. For the first six months of the financial year the CCG operated within the temporary CCG finance regime established by NHS England and Improvement (NHSE&I) and reported a break-even financial position to the end of September 2020. For the last six months of the financial year (October 2020 to March 2021), the CCG has received a fixed funding envelope which it is expected to manage costs within, except for specific items where additional cost reimbursement will be available. Therefore, this report concentrates on financial performance for the October 2020 to March 2021 (M7 to M12) period with the year to date position reflecting financial performance from October to November 2020.

Key Points:

• The additional savings target of £4.9m has now been reduced to £2.8m following the receipt of £2.1m to correct the CCG’s primary care co-commissioning allocation.

• The year to date and forecast positions for costs within the fixed resource baseline show operational budget underspends of £0.2m and £0.65m respectively. These underspends are net of costs for which additional funding can be claimed.

• The baseline savings target of £1.2m is covered by premises cost and support function savings, and a reduction in forecast prescribing costs.

• The position includes a net £0.46m and £1.37m for year to date and forecast COVID-19 costs (October to March budget of £1.34m).

264

• After allowing for forecast budget underspends, the full year additional savings target of £2.8m is reduced to £2m which is shown as residual financial risk. This represents the additional cost reductions that need to be found in order for the CCG to meet its break- even financial target for 2020/21. The residual financial risk is expected to be covered by a combination of further operational budget underspends, deferral of development spend and local financial risk share arrangements.

• On the basis of the forecast operational budget performance and the expected mitigation of the £2.8m additional savings target, the CCG expects to meet it break-even financial target for 2020/21.

• The forecast position will be reviewed at Month 9 in order to assess whether the Bradford Place financial position can be managed overall, or whether the wider ICS financial risk management arrangements will need to be invoked to ensure that the CCG meets its break-even target.

Bryan highlighted the £1.3m issue will be raised with the GB where they are saying to an extent this is outside of their control and that’s how it is defining itself, if every other assumption is correct which is a big if. Given its January now, there is very little that can be done in terms of decision making or participation in anything else like the change in outcome at this stage. Robert confirmed in terms of taking any further action in-year then there was very limited scope beyond the deferral of the planned development spend already highlighted. In discussions with local Trusts, they felt confident in being able to manage a £2.1m cost pressure. The Care Trust has got some additional resource to cover out of area pressures that gives more assurance re their contribution to that and they were feeling comfortable with their position. Neil highlighted the Primary Care co-commissioning funding where there are lots of additional allocations and was unsure whether that will spend or not. The AARS exercise was recently held around taking up slippage and while they were doing that there was an additional allocation that came out from NHSE that they were not expecting. The question was, does this stay with the CCG if it is not spent in year or if it wasn’t claimed does it stay at the centre. Robert confirmed the initial roles reimbursement scheme is exactly that so they know what the value is that is held at the centre and know what they can claim and locally plans have been put in place to spend that which includes using any slippage in-year. As we have not gone through the reclaim mechanism yet we are unsure how some of that will work, whether they get given a little bit more allocation or whether there may be some things that need to be recharged to NHSE. Bryan highlighted the Psychiatric Intensive Care update was useful which is if the CCG are playing by a set of rules then they need to play out in both directions equally in terms of capping risks for both sides, and the nature of the dialogue with the Finance Directors sounds very similar. Neil asked a question around the HDP staff costs there is an underspend against the zero budget, to clear the backlog, there is no budget but have an underspend of £183,000 forecast underspend, Robert confirmed this is the income adjustment. Neil highlighted the £4.9m, and have £2.1m adjusted in terms of the allocation, the £2.8m that wasn’t adjusted that needs to be addressed, will that be a re-current impact going forward or will it be a case of correcting next year. Robert confirmed it depends on how they are going to set up 21/22. There are two sets of different rules in 20/21 and in the second part of the year the IS budgets were re-based to actual spend levels across April to July. This feels like a one-off as it is a new set of circumstances in the second 6 months. When you move into 21/22 the few details that have been put out seem to indicate that 21/22 start point will be published CCG allocations and won’t be a re-current adjustment and there will be another set of adjustments. Bryan highlighted given the ICS legislation in the pipeline if the fact the second part of the year is playing out like it is gives centrally a national transition path to tell us what they are getting and what to do with it at local level and for us to react to that rather than the relatively free decision making that they have had in the past. Robert confirmed there are 2 additions to this, 1 is impact of the Spending Review and how much of that £3bn finds its way into the ICS and then into

265 Bradford, the other is a continued reference to recognising there will still be additional covid costs in 21/22 and an additional pot of money for that which will then get allocated out to ICS, the value of that is unknown, but in principle they are saying they will recognise something. The other issue that will be recognised is the missed QIPP opportunity in 20/21 and there will be some level of additional resource for this. Bryan highlighted there will be far less freedom around budget setting and far fewer local choices to make in 21/22 than there may have been in 18/19 or 19/20. Robert confirmed that the December letter from NHSE&I had indicated that 19/20 outturn should be used as your starting point for block contract values, but we will need to work through what this means for 2021/22 contract values. Neil highlighted it is looking comfortable in terms of hitting the targets for this year and this will then form part of the GB paper. Recommendations; The Finance and Performance Committee:

• Noted the year to date financial position as at the 30th November 2020 and the forecast financial position to March 2021; • Noted the receipt of £2.1m to correct the CCG’s primary care co-commissioning allocation and the corresponding reduction in the additional savings required to breakeven for the year; and • Noted the level of residual financial risk and how this is expected to be addressed. 9. COVID Risk Log Sarah Dick gave an update. The COVID risk log is currently reviewed on a monthly basis (this has reduced from fortnightly during July and August and weekly during April to June).

As at 22 December, there are a total of 14 open risks on the COVID risk log (the same number as at the last report to the committee). Of these

• Seven risks align for assurance purposes with the finance and performance committee (including one relating to PPE availability and use that aligns to both this committee and the quality committee).

• No risks have increased or decreased in score since the last report to the committee.

• There are four risks at the ‘critical’ level (scoring 20 or 25) on the COVID risk log. All of these are aligned to the quality committee.

• There are four risks at the ‘serious’ level (scoring 15 or 16) on the COVID risk log. Three of these are aligned to the finance and performance committee.

Kerry asked if the PPE risk was really a high level risk. Amy confirmed enhanced PPE is required in schools but not as much as initially thought and is working with the schools to ensure they are getting the PPE they need. There have been no issues with the route through the national ordering system for the GPs, LA or schools etc and are looking at been able to maintain that supply for Personal Health budget clients, personally feel the PPE is stable and not aware of any concerns re the supply of PPE. Sarah highlighted the risk is for both supply and use and the latest version that has been updated is still 15.

Neil highlighted in the context of the third wave of covid and the increase numbers at this point would that not put pressure on it. Chris highlighted this wouldn’t increase the use of PPE beyond what they are already using and the impact risk won’t be any higher than it already is. The only issue not sighted on is any impact from Brexit but have assurances that this won’t affect any of these and there are substantial stocks if there were any immediate Brexit issues with supplies it won’t impact for a few months and is not an immediate issue.

Recommendations; The Finance and Performance Committee:

266 • Reviewed the FPC COVID risk log. 10. Issues to highlight to SLT & GB • Performance – IAF update. • Finance – more comfortable around the outcome than they were a couple of months ago but does still feel that the context of that which is not wholly in their hands where as in previous years they would have taken some of the risk. One feel better re the outcome but secondly this is based on collaboration and partnership rather than self-containment and acknowledge that uncertainty going forward. 11. Any Other Business There were no items. 12. Date and Time of Next Meeting The next meeting will be held on Thursday 4th February 2021, 12pm- 2pm, via Zoom.

267 268

269 Bradford District & Craven CCG Draft Minutes Quality Committee Meeting Thursday 5 November 2020 13:30-16:00 hours Zoom Call

Present:-

David Richardson (Chair) Lay Member for PPI BD&C CCG John Young Secondary Care Consultant BD&C CCG Adele Thornburn Associate Director of Quality & Nursing BD&C CCG Gill Paxton Associate Director of Quality & Nursing BD&C CCG Kate Varley Senior Head of Patient Safety BDC&CCG Michelle Turner Director of Quality & Nursing BD&C CCG Peter Brunskill Secondary Care Consultant BD&C CCG Angie Clegg Independent Registered Nurse BD&C CCG John Hartley Senior Head of Quality Improvement BD&C CCG Ruby Bhatti Lay Member Primary Care Commissioning BD&C CCG Sarah Dick Head of Corporate Governance BD&C CCG Dave Tatham Strategic Clinical Director of Keeping Well in Hospital BD&C CCG James Thomas Clinical Chair BD&C CCG Jackie Haw-Wells Head of Patient Safety & Quality Improvement BD&C CCG Victoria Simmons Head of Engagement BD&C CCG Bev Gallagher Head of Safety and Quality Improvement BD&C CCG Helen Rushworth Manager Healthwatch

Apologies-:

Fiona Jeffrey Associate Director of Organisation BD&C CCG Effectiveness In Attendance:-

Sharonjit Kaur (Minutes) PA to Director of Quality & Nursing BD&C CCG Paul Carder Head of Research BD&C CCG Tracey Gaston Senior Head of Medicines Optimisation BD&C CCG

1. Introductions and Apologies:

No apologies were received for the meeting. The Chair of the meeting introduced Gill Paxton to the committee. Gill Paxton will replace Adele Thornburn as Associate Director of Nursing & Quality from the end of December 2020

270 2. Declarations of Interest:

There were no declarations of interest.

3. Minutes of the previous Meeting:

The minutes of the meeting held on the 5th November 2020 were accepted as a true and accurate record, with one amendment to be made under item 3. Item 3 amended to read: “The committee agreed that in the event of no GP representation, further discussions would take place outside of the meeting and any decisions brought back to Quality Committee for ratification.

4. Action Log:

All actions within the action log noted as completed. The chair of the meeting requested that all actions from the current action log are to be archived following today’s meeting.

Item 6 Ambulatory Care: This item was postponed from the last meeting. The report from H Rushworth (Healthwatch) has been circulated for information as part of the QC meeting documentation and is included on the agenda for today’s meeting.

5. Matters Arising:

The Chair of the committee raised concerns regarding a report which has been received as part of the Audit and Governance Committee. The audit report relates to the recent review of Continuing Healthcare and reported limited assurance, highlighting a number of issues. The committee noted that the findings of the report are being addressed by the team and an action plan is being produced in partnership with partner organisations and stakeholders. . The concerns will be flagged up at a meeting with the Council later this week.

Action: Progress update to be shared by Chair of the Meeting at the next meeting.

6. Quality Update:

K Varley (Senior Head of Patient Safety) and J Hartley (Senior Head of Quality Improvement) presented slides and highlighted key areas for discussion and note by the committee.

BDCFT have reported an increase in the complexity of Serious Incidents, especially suicides. There have been several complex issues with regard to transgender and suicides. M Turner has met with the CQC and discussions have taken place with regard to the progress of BDCFT. It was reported that the CQC will not be conducting a further review until progress is reported with SI’s.

Action: M Turner to follow up conversations with CQC in January 2021.

K Varley shared details of a proposed light touch model for gaining assurance around the quality of service provision with our provider organisations. In summary, the model utilises existing provider frameworks and mechanisms, with colleagues from the

271 Quality Hub as members of the quality groups gaining assurance through their membership, regular attendance at meetings and ongoing relationships with colleagues within the individual organisations.

The suggested way of working has been discussed at the System Quality Committee (SQC) and will be taken forward through a task and finish group containing representatives from across the system.

Action: M Turner to chair Task and Finish Group to discuss the suggested model and agree proposals for the way forward.

Strategic Hospital Discharge Group chaired by M Turner continues to meet on a bi- weekly basis. The group is made up of senior leaders from across the local system (including Dr Sara Humphreys from the CCG) and is providing a focus on patients who are medically fit for discharge from hospital and ensuring that pathways and care packages out of the hospital environment are in place to ensure their discharge is not delayed. A time limited project is in place to identify work which needs to happen and to help to unblock any barriers which may exist across the system. Further linked areas of work within the programme include the availability of resource; including within the BEST (Bradford Enablement Support Team and within Therapy services). M Turner highlighted the impact of workforce sickness on the ability of the system to deliver pathways of care. As an interim solution agreement has been reached for a nurse to support BDCFT from the PCD (Personalised Commissioning Department). In addition, the group has recognised the need to identify requirements and priorities strategically for the medium term in relation to support required by the system to maintain services through the winter period.

Pulse Oximetry is a national virtual ward initiative which has been rolled out locally for service provision with long COVID and multiple needs.

Seasonal Flu work is continuing around the Flu vaccination. As part of the implementation of the vaccination pathway a ‘stress test’ on the process was undertaken (with input from stakeholders across the system and the armed services) to understand the reliability of the service and its ability to react to different circumstances. This testing provided reasonable assurance. Gaps have been noted relating to the reporting of levels of uptake of the vaccinations, however these are being worked through and minimal risk in relation to the systems have been identified. There are currently 2 systems nationally and regionally to determine the level of uptake of the vaccination. IMFORM and System One, which is the clinical system in use.

There has been an issue highlighted within the pregnant women cohort and a significant gap was identified between the 2 systems. On looking at the issue between the 2 systems, the reason for the discrepancy has been identified to be inclusion of pregnant women; women who have recently given birth or miscarried are included within the IMFORM data whereas this was not counted within System One. The data is being circulated via a dashboard which is sent to GP’s on a weekly basis and also shared within the Bradford Flu Board.

272 Data from the systems has enabled identification of practices who are achieving well and areas which may need support and encouragement. The data for patients aged 6months – 64 years is being reviewed with a view to focussing on where further interventions will assist in increasing uptake. This review of the data has identified particular cohorts of patients including those registered with COPD, CVD and diabetes. in addition, the CCG Engagement Team is supporting further work to identify which areas and cohorts have particularly low uptake and to propose interventions which will best engage within these under-served populations and BAME individuals and encourage them to engage with the pathway and take up the vaccination.

Further innovations include, the introduction of a ‘flu bus’ focussing on school age children in areas where parents have refused vaccinations (possibly due to porcine content). This is due to commence within the next week. In addition, there will be a specific focus on providing vaccinations to care home staff in localities where there has been low uptake; this will a concentration of effort around 15 locations across the community.

It is confirmed that the 15-64 year olds will be to be eligible to receive the vaccine from the 1st December onwards.

Hillside Bridge red hub has seen high levels of demand for patient triage following referral from primary care, however the conversion rate to face to face appointment remains low. The resource allocated into the triage service has been increased to cover these requirements. Following the changes in the red hub model (reducing the number of hubs to one), the EQIA has been updated, and an Impact Assessment is underway for the staff testing service also based at Hillside Bridge.

Children Looked After (CLA) - M Turner gave an update on the progress of 2 risks highlighted previously on the Risk Register in relation to Children Looked After (CLA). These related to the lack of Designated Doctor and Named Doctor resources and a backlog in Health Assessments for looked after children. In summary key messages have been sent to the OFSTED Improvement Board. There is now a system integrated dashboard to monitor health assessments which enable regular reporting of the current position. The SQC has signed off a revised model to assist with Health Assessments; urgent Health Assessments were prioritised with a reduction in the backlog.

The revised model includes additional practitioners and capacity. M Turner has requested that the model is in place by March 2021 which will enable sufficient time for recruitment and role planning.

In terms of the requirement for designated and named doctors; intercollegiate guidance notes, the requirement for 24 hours weekly of designated doctor and 10 hours of named doctor resource to be available. Currently, only 10 hours of designated doctor are commissioned and there is no named doctor in place. M Turner has submitted mitigation in the absence of these requirements.

Action: Delivery model and revised timeline to be brought back to SQC and QC

273 in February/March 2021.

Care @ Home Workstream and Care Homes B Gallagher (Head of Safety and Quality Improvement) reported there are 34 homes with a current outbreak and approximately 100 people on the COVID super rota caseload. Within the Craven area, there has been a slight decrease in figures with 5 care homes experiencing an outbreak within the 0-28 day cycle.

A major outbreak has occurred at The Craven Nursing Home where 28 people have tested COVID positive, including 14 residents and 14 staff. The home is under immense pressure regarding workforce and is being supported with wrap around care from the Multi-Disciplinary Team (MDT), the Super rota and North Yorkshire County Council.

The requirements for lateral testing for visitors and residents has been noted and included in the Winter plan. This will impact negatively on staffing resources. Concerns have been raised that Sheffield care homes have advised they will not follow the lateral testing. The MDT team meetings have now been reinstated and are meeting daily to identify any concerns and support required.

Farrow Medical Centre is on enhanced surveillance and is being supported by the contracts team. A follow up visit has been organised for January 2021.

An increase in fractured neck of femur and falls related admissions has been highlighted. This has been recognised and work is ongoing to understand the cause of these issues and to ensure any support required is provided.

B Gallagher gave the following update on homes. Jubilee Lodge, Craven is an operational residential home with wraparound nursing care. The home has no residents as yet with 2 pending admissions.

Within the Bradford area, there is a new 10 bedded unit (Hazelbank) which is now fully operational.

The CQC have given notification of the result of the recent inspection of Greystones Nursing Home which has been rated as inadequate. This now brings a total of 3 providers which have been rated as inadequate within the Bradford area. The CCG continues to work alongside Local Authority colleagues to ensure that action plans are in place to manage the issues raised.

M Turner is on the national board for Cygnet and reported a meeting has taken place to discuss safeguarding concerns within Cygnet Woodside. The safeguarding concerns have been addressed and investigated at Cygnet, Woodside with police involvement. Further discussions will take place regarding all Cygnet sites in Bradford in early 2021.

Action: Safeguarding and Quality concerns regarding Cygnet to be discussed in February 2021.

274 7. LeDeR Report & Sitrep:

J Haw-Wells (Head of Patient Safety and Quality Improvement) shared slides and informed the committee of the position around hosted West Yorkshire LeDeR Service and Bradford, District & Craven. The requirement for the hosted West Yorkshire LeDeR Service is for phase 1 to be completed by 31st December 2020. 66 reviews have been completed out of a total of 124. 50 reviews have been completed since August 2020. NHSE have been cited that the target may not be achieved collectively within the given timescale. 10 reviews were completed in November due to backlog and support to other areas, however LACs are confident that more reviews will be completed in December as they continue to focus resource on reducing backlogs.

Bradford District and Craven originally had 38 reviews to complete. 20 reviews have been completed, 8 reviews have been allocated although again, the target will not be achieved. 7 of the reviews were COVID related and prioritised due to being COVID related. Phase 2 will commence in January 2021.

Concerns have been highlighted regarding Learning Disabilities and Autism. However, discussions are ongoing regarding potential solutions and a further meeting is planned in the coming week across the ICS to take this work forward.

8. Outstanding Maternity Services (OMS) Update:

K Varley (Senior Head of Patient Safety) provided an update on the previous issues raised regarding Maternity Services at BTHFT. A CQC improvement action plan has been agreed, implemented and is being monitored through the System Quality Committee.

There is currently a 2 year work programme in place which includes representation from stakeholders across the system. The work has a focus on engagement and includes a number of key themes, including:

 Workforce  Buildings  Clinical excellence  Streamlining of systems  Digitalisation

It was noted that OMS are currently working in partnership with the provider and linking with the Better Birth Programme and neonatology services. The CCG is retaining an overview of the ongoing work and a meeting is planned for week commencing 14th December to review progress to date. The committee noted the update and highlighted potential gaps within the review including input from and engagement with public health colleagues.

9. COVID 19 Vaccination update:

P Carder (Head of Research) gave an update around the roll out of the COVID vaccination.

275 Ongoing trials are continuing with the Nova Vaccination within the Bradford area. The original ask for trials were for 1000 patients to take part in the trials. A further 700 were recruited. It is reported that BAME representation has now increased.

The Wakefield hub is now open for trials for the vaccine.

The MHRA (Medicines and Healthcare Products Regulatory Agency has announced that the Pfizer vaccine is a 2 dose vaccine and has 90% efficacy. Difficulties have been reported the storing of the vaccine which is brought into the UK from Brussels. The requirement for storing the vaccine is to be stored at -80 degrees. However, the Oxford AstraZeneca can be stored in a normal fridge and the Modernor vaccine will also need to be stored at a low temperature.

Pfizer will initially release 800,000 doses of the vaccine and AstraZeneca will release 4 million doses for distribution before Christmas 2020.

T Gaston (Senior Head of Medicines Optimisation) informed the committee of the issues around the logistics of the vaccine, and its need to be stored at -70C, so at BTHFT in order to receive a delivery of the vaccine, special PPE is required. Because of this currently BTHFT will be the only site where the vaccine will be received. The Oxford vaccine is likely to be administered at 10 PCN sites which have been approved for use. The initial cohort identified for the vaccines is care home staff and over eighties. Mass vaccination sites will support the PCN’s. The Pfizer/BioNTech vaccine has been certified Halal but as yet we don’t know about the Oxford vaccine

10. Serious Incidents:

J Haw-Wells (Head of Patient Safety & Quality Improvement) provided an update on Serious Incidents reported up to and including November 2020.

Airedale (ANHSFT) – 1 reported incident of ED breach although no harm to patient. 4 incidents are currently behind deadline. 1 medication incident has been clustered and is due for submission week. I incident regarding Confidentiality has been delayed due to input from the SI panel

Bradford District Care Foundation Trust (BDCFT) – 4 incidents reported. 3 of which are suspected suicides, 1 incident will have HR involvement, 3 behind deadline.

Bradford Hospitals Trust (BTHFT) – 4 incidents reported. A reported increase from the previous month. 1 incident is behind deadline and will be jointly investigated with BDCFT.

Other Providers – Sheffield Hospital regarding treatment of Bradford patient.

1 incident due to be received from BTHFT Maternity Services – This is still to be reviewed.

JHW informed the QC of the Quarter 2 Quarterly Report which has been reformatted and revised. This has been included within the meeting documentation. The revised version of the report includes additional graphs and highlights peaks and troughs.

276 JHW asked for comments and feedback on the new format of the report. Key messages from the Quarterly report were shared:

 ANHSFT have seen an increase in diagnostic incidents within the last quarter.  BDCFT abuse allegations have increased.  COVID responses have had an effect on action plan evidence due to some meetings being paused.

JH Wells has been involved in discussions and attendance at Governance Meetings with BDCFT to look at ways of streamlining investigations taking place jointly with HR.

Discussions took place around compliance and assurances of recommendations from reports and how these have been embedded. JHW advised that on completion of action plan, the service manager will discuss further at governance meetings prior to implementation.

Action: Comments and feedback on revised format of report to be forwarded to JHW.

11. On the Horizon:

V Simmons (Head of Engagement) shared slides and highlighted key issues from the report. In summary, the update noted:

 A summary of key themes and trends relating to complaints received, including 2 complaints received in relation to the Personalised Commissioning Department and concerns highlighted regarding CCG processes relating to Independent Funding Reviews.  Concerns raised regarding the COVID 19 Pandemic resulting in patients being required to attend sites other than their registered practice, and delays with accessing services.  The BAME Network and Network for People with Long Term Disabilities are now formally established and endorsed by the CCG Senior Leadership Team.  Health Inequalities Training work within the CCG is ongoing.  Engagement with communities regarding accessing services during the pandemic continues alongside system partners including acute providers and primary care colleagues.  Feedback regarding the response to COVID 19 and the public’s view of the vaccine continues to be collected via survey with over 300 responses received in the previous week.  The Communications and Engagement team continue to provide support to general practice especially around the sharing of the message that the NHS is “still here to help”.

12. Risk Register:

S Dick (Head of Corporate Governance) provided an overview of changes to the Risk Register.

Corporate Risk Register:

No new risks have been added for the QC.

277 The COVID risk has been reviewed and is now rated as ‘critical’. The Risk relating to care homes has been reviewed, rescored and reworded to specifically focus on the impact of COVID. The score has now increased from 16 to 20.and has been added to the COVID Risk Register. The risk will be monitored on a monthly basis.

Updates on the risks owned by the committee have been completed in line with the risk management review cycle. The committee was provided with a summary of the risks and amendments to mitigating actions, and assured that there have been no changes to the risk scores allocated

COVID Risk Register:

An update was provided to the committee regarding the COVID specific risks relating to the Quality Committee;

2 risks within the COVID Risk Register have been flagged as critical. These are Outcomes for population being negatively impacted and increased health inequalities. The Care Homes risk has been added to COVID Register

4 risks remain within the serious category although the overall score has reduced. The issue of PPE availability has now reduced from 16 to 15.

The risk regarding demand for Mental Health Services and has been reviewed by the Senior Leadership Team (SLT). Following this discussion, the score for this risk has been increased to 20.

The committee noted a reduction in risk score for risks relating to reduced mortality from non COVID related issues, and the potential for reduced uptake of routine immunisation during COVID

S Dick clarified the risks are managed by Risk Managers and discussed issues relating to CHC.

Action: AT to arrange meeting regarding CHC risks and provide feedback on the outcomes.

13. Healthwatch Report:

The Healthwatch report ‘Experiences of Health & Care in Bradford – During the first phase of COVID-19’ was circulated with meeting documentation for information. . H Rushworth (Healthwatch representative) informed the group of the outcomes of the survey carried out between March and June 2020. The survey findings have been presented to the Health and Scrutiny Committee and Councillors and MPs are also aware of the feedback received. The results of the survey and recommendations will also be shared with Healthwatch England with a view to informing the wider view of the impacts of the pandemic

Recommendations have been shared with the Engagement Team at the CCG, and as a result of the feedback received a number of changes have been implemented, including the provision of new services.

278

The majority of responses relating specifically to local services were positive. J Young queried whether any input regarding the secondary model for Mental Health Care had been included, and a suggestion was made for S Bhatt to be invited to QC to give an overview of Mental Health and transformation of services.

The recommendations within the report will be revisited in January, with a focus on Mental Health Services, Wellbeing Services and suspensions to and delays in accessing healthcare. In addition, H Rushworth informed the committee that as and when the survey is completed again. It is proposed that there will be focus on specific areas such as BAME/Elderly population.

Action: S Bhatt to be invited to present review of Mental Health Services at a future QC meeting.

14. Legislative changes to ICS:

M Turner updated the committee of key messages shared in relation to proposals relating to the way forward by commissioning of services within the NHS published on the 26th November 2020 by NHSE/I.

All staff have been briefed on the proposals and a development session has been arranged to take place for AD’s/SLT/Governing body

The committee noted the ongoing work across the system in Bradford District and Craven, including The Act as One programme which describes a strong emphasis on provider collaboration and the role of partnership working at PLACE which has enabled the CCG to be in a strong position to move forward with any changes to responsibilities regarding commissioning of services.

In summary, the document sets out 4 areas of focus:

 Improving population, health and healthcare  Tackling unequal outcomes and access  Enhancing productivity and value for money  Helping the NHS to support the broader Economic and Social Development

Further details around specific areas such as Finance, Operating model etc. have not yet been received and are the subject of discussion across the Integrated Care Partnership (ICP).

The guidance sets out the potential for providers to become part of the Provider Collaboration by April 2021 and for the Provider Collaboration to be in a position to deliver access to a full range of high quality Acute and Mental Health Services, Ambulance Services and to enable the provision of fair access to care with a focus on Clinical Leadership and Ownership across services.

The document further proposes that the commissioning function is able to provide a more strategic emphasis on population health, with changes in contracting arrangements enabling a focus on population management and addressing health inequalities.

The document gives 2 legislative options for proposed changes:

279 Option 1 – establishing of an ICS board through a joint committee mechanism to allow Commissioners Providers and Local Authorities to take decisions collectively.

Option 2 – Establishing of a statutory ICS body which brings in the current functions of CCGs.

NHSE are currently consulting on the options outlines with a deadline for submissions of feedback by the 8th January 2021, with a view to implementing the preferred model by April 2022.

15. Any Other Business:

M Turner informed the committee of notification received regarding an upcoming Local Authorities inspection which will include CAMHS (Child & Adolescent Mental Health Services). The inspection is due to commence in the next 2 weeks.

16. Date and Time of Next Meeting:

Thursday 7th January 2021 at 1.30pm via Zoom

280

281

Bradford District & Craven CCG Draft Minutes Quality Committee Meeting Thursday 7th January 2021 13:30-16:00 hours Zoom Call

Present:-

David Richardson (Chair) Lay Member, Quality John Young Secondary Care Consultant Michelle Turner Strategic Director of Quality & Nursing Gill Paxton Associate Director of Quality & Nursing Kate Varley Senior Head of Patient Safety Peter Brunskill Secondary Care Consultant Angie Clegg Independent Registered Nurse John Hartley Senior Head of Quality Improvement Ruby Bhatti Lay Member Primary Care Commissioning Dave Tatham Strategic Clinical Director of Keeping Well in Hospital James Thomas Clinical Chair Jackie Haw-Wells Head of Patient Safety & Quality Improvement Bev Gallagher Head of Safety and Quality Improvement Helen Rushworth Manager - Healthwatch Jo Sygrove Manager - Healthwatch Fiona Jeffrey Associate Director of Organisation Effectiveness

Apologies-: Sarah Dick Head of Corporate Governance Victoria Simmons Head of Engagement

In Attendance:-

Elaine Phelps (Minutes) PA to Quality Team Tracey Gaston (Item 7) Senior Head of Medicines Optimisation Liz Moore (Item 8) Senior Head, Quality Team Nadine Cullimore (Item 8) Senior Head of Personalised Commissioning Sasha Bhat (Item 9) Head of Mental Wellbeing Ruth Shaw (Items 9, 10) Senior Head of Strategy, Change and Delivery Helen Hart (Item 10) Designated Nurse, Safeguarding Adults Helen Hyde (Items10, 11) Deputy Designated Nurse, Safeguarding Children Stacey Fleming (item 11) Corporate Governance Manager Bev Denton (item 11) Corporate Governance Manager

1. Introductions and Apologies: Apologies received as noted above.

2. Declarations of Interest: There were no declarations of interest.

3. Presentation - Members and other CCG staff attended to give Adele Thornburn their best wishes for her retirement from the CCG.

4. Minutes of the previous Meeting: The minutes of the meeting held on the 3rd December 2020 are to be ratified at the next meeting as there were a number of amendments to be made.

282 5. Action Log: All actions within the action log were noted as completed. An updated action log is to be shared after the meeting with the revised minutes

6. Matters Arising: There were no matters arising

7. Quality Update: KV and JH provided an overview of work of the quality hub highlighting key areas for discussion and of particular note to the committee. Key points included:

Sentinel Stroke National Audit Programme (SSNAP) data: A number of domains have been impacted by the second Covid peak with wards at BRI closed due to patients presenting with positive Covid test results. Positive Covid patients are sent to red wards thus causing a negative impact on the SSNAP data.

The new Cygnet Woodside CQC report was published on 23rd December 2020 which gave a rating of Inadequate. The facility continues to be subject to an organisational safeguarding enquiry and a Quality Review Group is in place with all partners meeting monthly to review all Cygnet sites in the area.

Covid Vaccine: Roll out began on 4th January, 2021 with BTHFT as the lead provider targeting NHS staff, social care staff and 80yrs+ for wave 1. All 10 PCN designated sites will be operational by Friday 8th January. All 3 acute providers will also be ‘live’ for vaccinations.At least 400 doses of the Oxford vaccine are anticipated to be available at each vaccination site.

Seasonal Flu Vaccination: Data shows there has been an uptake at PCN and practice level and the target vaccination rate has been met with 80% of people in the over 65 cohort vaccinated. In total 5% more people have been vaccinated than last year. Communications are ongoing with key stakeholders who are working to develop wider myth debunking with regards to Flu vaccine, to improve uptake moving forward. Learning Disability (LD) Mortality Review Programme (LeDeR): Phase 1 finished on 31st December 2020 with 98% of reviews completed at West Yorkshire level and 100% completed at Bradford District & Craven level. The team are now looking at phase 2. There are no plans to pause the programme in response to the Covid 19 pandemic. LD Annual Health checks – whilst there has been good progress the 67% contractual requirement has not yet been met due toCovid 19 pandemic pressures on the wider system.

Host Commissioner Responsibilities & Oversight visits: An number of options for a proposed model was taken to SLT in December 2020. The agreement was to explore further a hybrid model of Option 2 to delegate Host to a ‘place provider’ moving towards the goal of Option 3 to delegate host commissioner responsibilities at ICS level. Work is ongoing.

Safeguarding Adults: There are challenges across the system due to sickness and vacancies within providers. The CCG team are supporting providers to ensure services are safe.

RB asked how the CCG workforce were coping with the Covid 19 pressures. MT told the meeting that staff are tired at a system level and there is a lot of work being done to ensure sickness levels are monitored. MOU’s are in place to support staff movement to those areas of highest acuity and need, where appropriate. The CCG huddles are in place to ensure there is awareness of pressures and to promote mental and physical wellbeing. . The Quality team are doing well, coping with a death early in the pandemic. Some are struggling with work/home life balance/looking after children. A prioritisation process has been completed in case there are staff off sick. FJ stated that various things are happening to look at what can be paused/stopped, who can work in other areas and looking at wellbeing. Interventions have been in place for the last 12 months and the leadership team are looking to see if there is anything else that needs to be put in place to support staff.

283 DR asked the meeting if they felt that the Quality report fulfilled the needs of the meeting and was there anything missing. Members are to email Gill Paxton if they feel there is anything they would like adding to the report.

8. CHC Audit: LM reported that the overall objective of the audit was to provide assurance on the arrangements that are in place for meeting the CCGs and LA’s responsibilities in relation to Continuing Health Care and maintaining financial control. This was a joint audit with the internal audit team at BMDC. The review has been given a Limited Assurance opinion, although examples of good practice have been noted, a number of areas for improvement have been identified during the review. These included:  Improvement to the governance framework in which CHC operates  Monitoring and oversight of CHC activity and the reliability of data  Elements of the National CHC Framework that are not being met  IT systems to support the CHC framework and timeliness of invoice checks and payment.

24 recommendations were made overall and of these currently:  10 are for consideration re closure  8 are currently being addressed  6 are awaiting further information from colleagues.

The team are continuing to work on the actions and will take the updated audit response to the CHC Oversight Group for decisions and suggestions re the actions.

9. CAMHs and Autism

CAMHs: Sasha Bhat (SB) updated the meeting on the Independent system review of children and young people’s mental health services undertaken by the Centre for Mental Health. This review aimed to provide a full system overview of children and young people’s mental health provision in Bradford and Craven highlighting strengths and weaknesses, assessing local demand, needs and aspirations and identifying priority areas for improvement.

The report made key recommendations of five areas:  Leadership, commissioning and strategy across our whole system of emotional and mental wellbeing  Understanding the needs, data and insight to inform our planning and service provision  Collaborative model of support - implementing the i-Thrive model across the whole pathway from early help to specialist support  Access and navigation for the whole range of support  Investment and resource prioritisation  SB went on to tell the meeting that the CAMHs waiting list initiative is now underway and counsellors who specialise in working with children and young people are supporting the core and therapy waiting lists. The next steps are to increase the work to include a step down support offer, so that children can be discharged from specialist CAMHs support into peer support or buddy counselling. This will continue to free up capacity in specialist CAMHs to address the waiting list. Parental support sessions are being co-designed to ensure clear information and communications about the mental health offer is available to parents, children, services and communities. Progress has been made in identifying gaps in workforce development and mental health first aid training for all the “Youth In Mind” workforce (working in schools has been set up and delivered since November 2020.

284 Autism: Ruth Shaw (RS) updated the meeting re Autism clients. An overview of the assessment process has taken place which has seen that 10% of reviews for children under 7 take approx. 13 hours. New pathways have been piloted meaning that reviews can now be done within 13 weeks, The CCG commissioned local service providers with a cross agency infrastructure, the impact of this is now being seen and there is a now an increased capacity to close referrals. Covid 19 has impacted on external providers, however ways have been found to work around this and as PPE becomes more widely available the team are managing to deliver clinics. New information leaflets have been developed for families and the team are working with Born In Bradford to identify autism early. Capacity issues are being address with additional funding from WY&H to provide support for families.

10. Designated Doctor/Named Doctor/CLA Health Assessments Ruth Shaw gave an update around the issues for Children Looked After Health Assessments. Local challenges include  The increasing number of children in care and fluctuating demand against capacity  Health service delivery is fragmented across three different providers  A short term reduction in capacity and the impact of a reduction in face-to-face working as a result of Covid-19

On an interim basis the team has:  Increased clinic capacity which has been staffed from within existing resources  Undertaken liaison with families and social workers prior to reduce the number of Do Not Attends/Was Not Brought  Provided additional recurrent funding to increase the Band 4 nursing capacity to support the team  Utilised identified underspend to increase capacity on an interim basis  Worked collaboratively with children’s social care to enable sharing of consent to avoid delays in the Initial Health Assessment

MT told the meeting that the Designated Doctor role is a statutory role and currently we are not meeting Inter Collegiate guidance. An interim arrangement has been set up until March. A different model is to be implemented from April and this will be overseen by the SQC. Helen Hyde is leading on this work and will bring a report back to Quality Committee in March. The new Designated Doctor will report strategically to Michelle Turner and professionally to one of the Chief Nurses or Medical Directors across the system. The Care Trust will employ the GP on an honorary contract.

11. NYSCP Executive Assurance Report Helen Hyde reported that the Safeguarding Team are struggling with capacity. The team have reignited links with the Designated Nurses across West Yorkshire and are hopeful to see more proportionate engagement going forward. The evaluation of the GP assurance tool has not been completed due to Covid.This will continue to be reviewed. Jude MacDonald and Helen Hart are in the process of completing the full Section 11 document which will be brought to a future Quality Committee for approval. This is the wider assurance document around self declaration.

12. Serious Incidents: JHW gave a brief outline of the Serious Incidents currently under review

Airedale (ANHSFT) – There were two new incidents report for December. 1 is a Surgical/invasive procedure and the second is a diagnostic delay incident that has come via the mortality review. There are currently 4 SI’s beyond deadline.

Bradford District Care Foundation Trust (BDCFT) – reported 3 new incidents for December, a medication incident, and 2 apparent/actual/suspected self-inflicted harm incidents resulting in the patient’s death. There are currently 5 SI’s beyond deadline

285 Bradford Hospitals Trust (BTHFT) – 1 incident has been reported; a fracture after a fall. . 2 incidents are beyond deadline.

Independent Providers – Two Serious incidents are currently beyond deadline and awaiting information from Liverpool CCG and Marie Curie Hospice respectively.

13. Risk Register: There are currently 14 open risks on the Covid risk log, of these eight risks align for assurance purposes with the quality committee (including one relating to PPE availability and use. This one aligns to both this committee and the finance and performance committee - Risk 1573). Risk 943 relating to quality in care homes transferred from the corporate risk register to the Covid risk register following discussion at SLT on 25.11.2020. No other new risks were added to the Covid risk log since the last update to Quality Committee. One risk has decreased in score and been marked for closure during this cycle.

Risk 1573 had been previously discussed at Finance and Performance group where it was felt that the score could be reduced due to the availability and supply of PPE. Following a discussion it was felt that as the type of PPE supplied is suitable for use in Primary Care, the risk should be reworded to remove the usage element and the score reduced.

14. Any Other Business An item is to be added to the February agenda to discuss and evaluate the the effectiveness of this committee.

Date and Time of Next Meeting:

Thursday 4th February 2021 at 1.30pm via Zoom

286 DRAFT Minutes of the Audit & Governance Committee 13:00 to 15:30 2 November 2020, held virtually via Zoom

Present Bryan Millar – Lay Member for Audit & Governance (Chair) Ruby Bhatti – Lay Member for Primary Care Commissioning Neil Fell – Lay Member for Finance & Performance David Richardson – Lay Member for Quality

In Attendance Robert Maden – Chief Finance Officer Liz Allen – Strategic Director of Organisation Effectiveness Sue Baxter – Senior Head of Assurance Sarah Dick – Head of Corporate Governance Alison Bullock – Business Manager/PA (Minutes) Sharron Blackburn – Deputy Head of Internal Audit, Audit Yorkshire Lee Swift – Local Counter Fraud Specialist, Audit Yorkshire Rabia Patel – Assistant Internal Audit Manager, Audit Yorkshire Rashpal Khangura – Director – Public Sector Audit, KPMG Helen McNae – Data Protection Officer, The Health Informatics Service (THIS) (left after item 5) Roberto Giedrojt – Health & Safety, BDCFT (joined item 7 and left after item 9)

Apologies Fiona Jeffrey – Associate Director of Organisation Effectiveness

1. Welcome, Apologies for Absence and Quorum

Bryan Millar welcomed everyone to the meeting of the Audit & Governance (A&G) Committee. He drew attention to the statement on the agenda and confirmed that the meeting would be audio recorded to assist with minute-taking.

The meeting was noted as being quorate.

Apologies for the meeting had been received from Fiona Jeffrey.

2. Declarations of Interest

Rashpal Khangura declared an interest relating to item 21 on the agenda Update on the External Audit process. Bryan Millar advised that the members of the A&G Committee had been empowered by the Governing Body to act as the CCG Auditor Panel. It was noted that only the A&G committee members and appropriate CCG support would remain in the meeting to discuss this item.

There were no other declarations of interest.

The CCG’s registers of interests record all interests declared and are available at:

287 https://www.bradfordcravenccg.nhs.uk/ccg-information/publication-scheme/lists-and- registers/

3. Minutes Previous Meetings of the Audit & Governance

The minutes of the Audit & Governance Committees Meeting held 6 July 2020 were agreed to be an accurate record, subject to the following amendments (ACTION: Sarah Dick)

 Add Rob Jones KPMG to the attendance list  Clarify that Robert Maden is not the Deputy Chief Officer

RESOLVED: The Audit & Governance Committees approved the minutes of the meeting held on 6 July 2020.

4. Action Log

The Action Log was reviewed. Actions which were shaded green were complete. Verbal updates were given on the following actions listed as ‘open’:

2019/20- 24: Mapping of functions and responsibilities in the new CCG. Sue advised that the Associate Directors had drafted a document which is predominately around head of service alignment within the Strategy Change and Delivery hub. Bryan Millar advised that the lay and professional healthcare members would be meeting with Helen Hirst and James Thomas prior to the Governing Body on 10/11/20 and James and Helen have been invited to the lay member meeting on 9/12/20 and would provide a further update then. Liz Allen advised that another piece of work the CCG needs to undertake is to look at how we can support and provide resilience to primary care during Covid; this will impact on how staff are working.

2020/2-4: COVID-19 impact to SBS controls, Robert Maden advised that he will update at the risk register at the next risk cycle.

2020/21-7: Assurance to be sought that the fire compartmentalisation issue has been fully resolved at Scorex House. Liz advised this work has been completed and Stacey Fleming is awaiting a certificate, if this has not been received by the end of this week she will escalate to Liz.

2020/21-8: Health and safety service level agreement to be reviewed to ensure it was fit for purpose during response to Covid-19. Liz advised this was complete and there was no further action required.

2020/21-9: Covid-19 specific addendum to be added to Fire Safety Policy and H&S Policy – carried forward as Roberto Giedrojt who was not present to update.

2020/21-10 Response to be circulated providing further information relating to bulk coding through QOF. Lee Swift advised he has contacted NHSE regarding an outcome, he will be arranging a meeting in the coming weeks to understand what the scale of this issue is.

2020/21-13 Appointment of external auditors – to be covered at the private meeting of the Auditor Panel after the committee meeting.

288 RESOLVED: The Audit & Governance Committee noted the assurance provided by the Action Log.

5. Information Governance Update Report (Quarter 2 2020/21 - 15 October 2020)

Helen McNae advised that the NHS Data Security and Protection Toolkit (DSPT) 2020/21 had not yet been finalised but it had been confirmed that the submission date has been extended to 30th June 2020. It was thought there would be only minor wording changes to the toolkit, though there would be more focus on cyber security. It was noted that the mandatory standard relating to IG training was expected to achieve 95% compliance from 1st April – 30th June 2021.

There have been ten information governance /data security related incidents since the last report to the Committee; all these were dealt with internally. One Freedom of Information request breached the required deadline (by close of the 20th working day from receipt of the request). This is the first time an FOI deadline has been breached since June 2016. As a result of this work has been done to review the contact lists to ensure the right people are contacted.

The number of data protection impact screening and assessments (DPIA) has plateaued since the last report to the Committee; Sarah Dick advised that the IG team were currently reviewing the DPIA procedure and form. A new Bradford district and Craven system IG work-stream has been established and is currently looking at ways the system can work better together.

It was noted that compliance with data security awareness training stands at 82.59 % at 8 October 2020, the target is 95%. It was acknowledged that many staff have capacity issues due to the pandemic. Sue Baxter advised that mandatory training was being discussed as part of the current round of objective setting and appraisal meetings and that reminders about training are regularly circulated to staff.

It was noted that there was an issue for lay members around with accessing old emails. Liz advised that there was an ongoing issue around data storage which is being addressed though it was unclear whether this was linked. It was noted best practice is for individuals to delete old emails promptly.

When asked about the achievability of meeting the 2020-21 DSPT, Helen confirmed that no fundamental changes to previous standards were expected and she did not anticipate any significant issues in achieving these.

RESOLVED: The Audit & Governance Committee received and noted the Information Governance Update Report.

6. Information governance policies and procedures

Helen McNae asked committee members to review and approve the following policies and procedures which had been updated for NHS Bradford District and Craven CCG and for accessible content requirements:

 Information governance framework  Internet and social media policy  Destruction of confidential waste procedure  Information governance and data security handbook  Information asset owner handbook

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Robert Maden noted that point 6.9 of the information governance framework referred to an associate director of contracting adding that this was no longer a position in the CCG. ACTION: IG team / Sarah Dick.

Sue commended the team for updating the policies in a timely manner and also suggested that there could be strengthening of the process of how policies are reviewed and approved. In the meantime it was agreed by the committee that approval of policies could be undertaken by email, with an acknowledgement at the next meeting. ACTION: Sue Baxter to look at the process for reviewing and approving policies

RESOLVED: Subject to the amendment to the information governance framework, the Audit & Governance Committee approved all 5 documents.

Helen McNae left the meeting, Roberto Giedrojt joined the meeting

7. Health & Safety (H&S) Update Report (Quarter 2 2019/20)

Roberto Giedrojt joined the meeting via telephone and presented the Health and Safety update report. This report provides assurance to the Audit and Governance Committee that the health and safety work plan is being delivered and that CCG health and safety risks are being adequately managed.

A health and safety inspection took place at Scorex House on 20th October. With regards to arrangements for managing COVID, Robert reported that Scorex House had good signage in place, access to the building was well controlled, the rooms were organised to accommodate the right number of people, a plastic screen was fitted in the reception area, and hand sanitiser was placed all around the building. Robert referenced the storage of PEE on the ground floor noting that this had been done sensibly and was compliant from a fire safety point of view. Robert clarified that if any member of staff was exposed to Covid-19 whilst at work, this would need reporting to the Health & Safety Executive.

Staff could access a wellbeing programme and employee access programme, feedback from staff indicated that they felt valued by the organisation and Scorex provided a Covid safe working environment.

Liz drew attention to the update regarding First Aiders at Scorex House advising that the CCG was looking at reception staff becoming first aiders as they were likely to be in the building the most. Robert advised that the risk to the CCG was low given the size of the organisation and there are very few people currently coming to the building, therefore suggested that the CCG could have an appointed person. In the current situation all CCG staff currently coming into Scorex could be an appointed person, provided they are aware of where the first aid kit and defibrillator are kept.

Action: Liz to update the safe working arrangements document

No health or safety incidents have been reported so far this financial year though it was noted the majority of staff have been working from home during this period.

Robert noted that as Millennium Business Park was closed an inspection of the building was yet to take place and asked that he was informed when a decision was made to open the building.

RESOLVED: The Audit & Governance Committee received and noted the Health and Safety Report Quarter 2 2019/2020

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8. Health & Safety Policies:

The security management policy is reviewed on a 3 yearly basis

Updates had been made to reflect the move to the new CCG. Liz Allen, as Strategic Director of Organisation Effectiveness, was noted as the Responsible Director for the policy.

There were no significant changes to the policy; Laura Siddall had sent further comments in relation to the on call director’s responsibility in section 6.1.5 suggesting that this could be widened out to on call director and any member of the SLT or ALT. This was discussed and it was noted that a change to this would require communication. Laura had also highlighted that reference to the fact that the key holding list is held in the on-call pack should be added to the document. (ACTION: Roberto Giedrojt / Sarah Dick to amend the policy).

RESOLVED: The Audit & Governance Committee approved the security management policy subject to the amendments requested

Roberto Giedrojt left the meeting

9. Internal Audit Progress Report

Sharron Blackburn, Deputy Head of Internal Audit (Audit Yorkshire) presented the item, noting that the report provided an update against the Internal Audit (IA) Plan for 2020/21and also included a section to consider the impact of Covid-19 on the plan.

Sharron reported that work has commenced to progress the 2020/21 internal audit plan and whilst delivery of the plan is currently achievable despite a delayed start, there was a risk that a second wave of Covid-19 could impact on this and any requests to defer audits to Q4 may also have an impact, only one audit has been rescheduled to Q4 to date. In terms of what needs to be delivered against the plan to support the head of audit opinion was, governance, risk management and mandated audits and some work around financial transactions.

One final internal audit report had been issued (Freedom of Information – significant assurance) . The final Continuing Healthcare audit report would be circulated later that week.

There are a number of audit recommendations that are now overdue for implementation; a number of these relate to the Section 117 audit. We are currently waiting sign off of a joint policy agreement (with BMDC): Mental Health Act 1983 - Section 117 Aftercare, which is expected in November.

Concern was raised about the growing list of uncompleted actions and whether there should be a risk assessment undertaken. Robert advised that whilst it would be prudent to follow up on the actions, work was ongoing which was not articulated well in the update. Alongside this Covid was also impacting on progress. It was noted that we need ensure we can get assurance from a value for money perspective. Sharron confirmed that the aim was to deliver the entire internal plan in line with the priorities adding that if at any point the team was struggling to achieve this, the Audit Committee would be informed.

RESOLVED: The Audit & Governance Committee considered the assurance provided in terms of the internal audit reports and progress in implementing internal audit recommendations.

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10. Internal Audit Charter

The Internal Audit Charter sets out the authority of Internal Audit to operate and provide internal audit services to the CCG. It is a requirement of the Public Sector Internal Audit Standards (PSIAS) and is reviewed annually. The Charter has again been recently reviewed and it was confirmed that no further changes have been required since the version was approved in November 2018. The Charter was also independently reviewed as part of the External Quality Assessment in February 2020 and this confirmed that the document meets the requirements of the standards and no further changes are required at this point.

RESOLVED: The Audit & Governance Committee approved the internal audit charter.

11. Audit Yorkshire Annual Report

Sharron presented the Annual Report for Audit Yorkshire for 2019/20 for information, the report summarises Audit Yorkshires performance and developments during 2019/2020 and was presented for information only. It was noted the report had been made more succinct than previous versions. Bryan reminded colleagues that he participates in the Audit Yorkshire Board along with Robert Maden.

RESOLVED: The Audit & Governance Committee noted the Audit Yorkshire Annual Report

12. 2019/20 Counter Fraud Progress Report

Lee Swift presented the item, noting that the purpose of the report was to provide an update on progress against the Counter Fraud work-plan and to also provide an update on the work of the Counter Fraud Authority.

Lee reported that a number of fraud awareness training sessions had taken place virtually with an average of 8/9 people joining each session. There has been an increasing trend of phishing/scam emails circulating; staff are constantly updated on these scams via newsletters and training.

A fraudster has been approaching GP practices using somebody else’s CV to seek employment. Details of this person have been forwarded to GP Practices along with guidance for ensuring that pre-employment checks comply with advice from NHS Employers

An anonymous letter was received by the CCG around how an individual organisation manages the funding it receives from the CCG / NHSE through Primary Care Networks (PCNs); the letter named individuals that may have a conflict of interest. The LCFS has liaised with the Chief Finance Officer regarding the matter and there is no evidence of any fraudulent behaviour at this time and as the complaint was anonymous no further information could be ascertained from the complainant. It was noted that it is within the gift of the PCNs how they spend the money and they do not need to report on this but it could be linked to outcomes. It was noted that we will need to be rigorous with regards to the register of interests for those involved with PCNs, Robert advised that the CCG will look to put stronger processes in but may be constrained by national guidance. Bryan offered support from the committee in terms of an assurance process.

The Counter Fraud team were also asked to establish, following concerns being raised with them, whether the procurement of a contract for the provision of specialised software at the start of the pandemic had been appropriate. Following investigation, the LCFS was satisfied that the correct procedures were followed and the referral was closed.

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Lee also advised that there had been a change in the counter fraud standards which will impact on the CCG; guidance around this will be published in January 2021.

RESOLVED: The Audit & Governance Committee received and noted the Counter Fraud Progress Report.

13. External Audit Progress & Technical Reports

Rashpal Khangura, Director, Public Sector Audit at KPMG, presented the item. Rashpal drew attention to two areas which will impact on the audit approach and audit work.

Rashpal reported that following the publication of the revised Audit Code of Practice by the National Audit Office, there will be no changes from an financial accounts perspective but there will be changes to the requirements for providing assurance over value for money for the 2020-21 accounts and onwards. This will be against three criteria; financial sustainability, governance and improving economy efficiency and effectiveness - more detailed risk assessments will be required around those areas, Rashpal advised that previously reports have been by exception but going forward we will need to specifically report on these three criteria. Rashpal will discuss with Robert Maden and his team in more detail when the guidance has been released. In terms of financial reporting the key changes will be around IFRS 16 relating to leases.

The external audit plan will come to the next Audit Committee. This has been an unusual time with regards to the financial regime and external audit will look at the financial position submitted and what this means in terms of risks. There will be a risk around financial sustainability in the value for money for section; this will apply to the majority of CCGs.

Work has already started on merger of the three trial balances which creates the opening position. Whilst a significant audit risk, external audit are satisfied with the work being done. In response to a question from Neil Fell around what was expected to be seen in the assessment of going concern, Rashpal advised that most of the related accounting standard is not applicable to the NHS.

RESOLVED: The Audit & Governance Committee received and noted the External Audit Progress & Technical Reports.

14. One CCG: Due Diligence Final Report

Sue Baxter, Strategic Head of Assurance presented the item regarding the One CCG Transition Update. Committee members were informed that the undertaking due of diligence was a requirement placed upon the CCG as part of the transfer of undertakings from the three previous CCGs to NHS Bradford District and Craven CCG from 1 April 2020.

The paper described the process followed which has brought the 3 CCGs together. Sue noted that in the main the CCGs were already working as one CCG, the process has allowed us to put things into order and refresh into a one CCG version; it has also enabled us to understand what assets we were transferring. This was a two phased approach undertaken by CCG staff with input from Sharron Blackburn as a critical friend.

During phase 1, internal audit undertook a desktop review of our due diligence approach including the framework, the approach and the content/outputs of the pilot and provided feedback. Phase 2 of the due diligence exercise focussed on the position across all key lines of enquiry and key facts etc. at the point of transfer. The due diligence report was provided and accepted by the Transition Programme Board on the 21 July 2020. Sue advised that the

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end of year assessment ratings, normally due by 30 of June, were still outstanding.

A review of the due diligence exercise was completed by Internal Audit in order to provide assurance on our process.

Bryan and other committee members thanked Sue Baxter and her team for the comprehensive, diligent, and thorough piece of work which was well mapped out in terms of processes and outcomes noting that it provided us with what we need in terms of assurance and a good baseline to let us adapt and evolve as we move forward.

RESOLVED: The Audit & Governance Committee:  received and noted the One CCG Transition Update;  noted the due diligence report was provided and accepted by the Transition Programme Board on the 21 July 2020 and  Noted the Internal Audit Report conclusion which stated that they can confirm that the approach taken to undertake due diligence in preparation for the transfer to the new CCG has been comprehensive and addresses the key areas of concern for the new organisation

15. Corporate Risk & Assurance Report

Sarah Dick presented the Corporate Risk & Assurance (CRA) Report.

It was reported that all governing documents were within their review periods. There have been minor changes to some terms of reference earlier in the year which will be incorporated in the constitution when this document is updated. Due to the impact of the Covid pandemic and their role in response to this, terms of reference for the Associate Leadership Leam have not yet been developed.

Work is ongoing to update policies and procedures for NHS Bradford District and Craven CCG; pre Covid the aim was for all policies to be updated by March 2021, some of this is now at risk due to the impact of the pandemic and the introduction of the new accessibility content template which has proved onerous. It was reported that some of the HR policies would not be ready by the end of the year. Liz advised that priority would be given to documents likely to be used / accessed by members of the public and the most pertinent HR policies e.g. home based working, flexible working, WRES, recruitment and promotion; others may be rolled over for a defined period of time. Neil commented that the whistleblowing and prevent policies should be prioritised and suggested that policies could be circulated via email for comments.

Development of the CCG’s assurance framework will begin shortly following the approval of the CCG strategy at the November Governing Body meeting.

Mandatory training levels are below target for all except one subject. Sarah advised that reminders are sent to staff and mandatory training is included as part of the part of the appraisal process. All face to face training is now being delivered on line.

The quarterly conflicts of interest self-assessment have been suspended during COVID although the statutory requirements remain. The governing body and SLT register of interest has been maintained during the period, as has the staff and contractors register. Sarah advised that the CCG members register of interest had been put in hold until the move to one CCG was completed; this has then be further impacted by Covid and team capacity. It was acknowledged that it was a requirement under statutory guidance to have a CCG

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members register of interest and Bryan requested that we have a plan to take this forward and close the risk. Sarah advised that a discussion on how to take this forward was needed adding that declarations of interest are a standing item at all meetings.

The Covid Risk Register is currently being reviewed monthly, it is not yet known if wave 2 of the pandemic will bring new risks or more impact on the risks already identified. A total of ten incidents (Q2 and Q3 to date) have been reported since the last report to the audit and governance committee, Sarah advised that these were all minor incidents related to information governance and had been included in the IG report.

Bryan acknowledged the difficulty in covering off all areas of corporate governance work during the pandemic and asked if there was a plan to do some prioritisation. Sarah advised that guidance had not yet been released for this year’s annual governance statement but she would be working with Sue Baxter to look at team strategy and determine what should be prioritised for the rest of the year.

Given the lack of guidance available Bryan asked Sharron and Rashpal for advice around what the CCG should do. Rashpal suggested that in absence of guidance the CCG should take good governance principles into account and work to these. Sharron noted she is also undertaking a piece of work around how the CCG has managed its governance arrangements during the Covid pandemic and this will narrative will form part of the Head of Audits opinion.

RESOLVED: The Audit & Governance Committee received and noted the Corporate Risk & Assurance Report.

Sue Baxter left the meeting.

16. Integrated risk management framework

Sarah Dick presented the integrated risk management framework which had been updated for the new CCG and in line with the accessible content requirements.

Sarah reported that the document was slightly overdue for review as it was agreed to wait for the CCG merger, adding that there were no major changes to the framework. The document now reflects that the CCG has a Covid risk register. The reference to links to the risk register on cover papers had been removed from the document; the cover paper template was currently being reviewed and whilst these links provided good evidence for internal audit colleagues, etc. this section of the cover paper template was onerous to complete and often left blank.

In response to a question around why system / programme risk management was not included, it was noted that as we have moved in to a strategic partnering agreement and Act as One, there is more system ownership of programmes and it was not felt appropriate for the CCG to impose our framework on the system. It was noted that we need to be clear this is a risk management framework for the CCG as a separate statutory body with acknowledgement that there is some cross reference/ linkage to the system through programmes/project risk which were previously CCG led.

RESOLVED:

The Audit & Governance Committee approved the CCG’s integrated risk management framework, noting that work is required to develop a risk management framework for the BD&C system.

295 17. Any Other Business

The Committee ratified the following policies which it had approved by email in September following the implementation of the accessible standards regulations:

 Policy for the development and management of policies and;  Content policy and procedure (a new document)

Sarah informed members of the committee that Tracey Gill will be retiring; Tracey finished her governance role at the end of September, but stayed on doing some project work to the end of November. Sarah will circulate a link so members can contribute to a leaving present for Tracey if they wish. Bryan added that Tracey had provided fantastic support to himself and the rest of the committee and wished her well for the future.

Sarah expressed how grateful she was for the support provided from the CCG, Corporate Governance team, and Sue Baxter which had allowed her to take an unplanned career break to allow her to be with her mother at the end of her life, adding that the CCG has been a very compassionate employer in this difficult time.

Sharron introduced Rabia Patel who is the new assistant audit manager; Rabia will be an alternative contact for Sharron.

RESOLVED: The Audit & Governance Committee ratified the approval of the following policies:

 Policy for the development and management of policies and;  Content policy and procedure

18. Key messages for the Governing Body

Bryan Millar would update the Governing Body meeting to be held on 12 January 2021 on the update of the audit appointment process and the One CCG due diligence report and related assurances.

19. A&G Work Programme Key

The committee work plan was reviewed.

With regards to the review of committee effectiveness, it was agreed by the committee to take a light touch approach this year and avoid form filling / questionnaires. As a minimum there should be a discussion between the chair and the executive lead, with other members given the opportunity to contribute if they wish to.

With regards to review of external audit performance, it was agreed not to undertake a separate review this year, acknowledging that this will be done via the appointment process. It was also agreed not to undertake a CCG review of internal audit performance given that Audit Yorkshire have recently had an independent external review of internal audit which was positive and we have also undertaken comprehensive and thorough reviews in the past few years.

20. Date and time of next meeting

The date of the next meeting was confirmed: Monday 1 March 2021, to start at 1pm, via zoom.

296 Meeting closed at 15:30

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