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Compliance or Defiance?

Compliance or Defiance?. Kevin Thompson. Introductions. Who am I ? What am I doing here?. Who are you?. What’s the aim of the session?. GOS contract compliance The needs and wants of PCTs Requirements of clinical governance in enhanced service provision To deliver a few key messages.

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Compliance or Defiance?

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  1. Compliance or Defiance? Kevin Thompson

  2. Introductions Who am I ? What am I doing here?

  3. Who are you?

  4. What’s the aim of the session? • GOS contract compliance • The needs and wants of PCTs • Requirements of clinical governance in enhanced service provision • To deliver a few key messages

  5. Clinical Governance – Lets take a closer look A systematic approach to maintaining and improving the quality of patient care within a health system

  6. More jargon & blurb • A framework through which NHS organisations are accountable for continually improving the quality of their services and safeguarding high standards of care by creating an environment in which excellence in clinical care will flourish. Three key attributes: • High standards of care • Transparency and accountability and • Continuous improvement.

  7. Performance Management

  8. An NHS Invention – Which has never been a condition of our GOS contracts

  9. Factors that have driven the CG agenda • Secondary Care issues 1995 Bristol Babies Scandal • Social Service Review 2003 Victoria Climbie Report • Infection control MRSA, CjD, Flu Pandemics • protective legislation, health & safety and employment law • Disabilities Act, Discrimination Act, Equalities Act • The right to complain • Ever increasing litigious society • Ever increasing risk averse society

  10. Compare this landscape with Optics • Competitive market place • Comparatively safe • Complaints are negligible • We raise our own standards

  11. GOS is the PCTs square peg GOS

  12. Problem is - Expectations are now higher • Enhanced service development has highlighted this anomaly to PCTs • Some clinical governance MUST be implemented if you are to hold an Enhanced Service contract

  13. Let’s get our ducks in a row • GOS should simply require a list of policies, procedures and protocols • In 3 years time, so long as the same procedures are in place, you are entitled to continue providing GOS services • BUT....Any introduction of CG means demonstrating CONTINUOUS improvement

  14. But why are PCTs so keen on CG ? • As of 1999, Trust Boards assumed a Legal responsibility for quality of care. • Clinical governance is the mechanism by which that responsibility is discharged.

  15. But why are PCTs so keen on CG ? • Trusts must prepare an Annual Review of Clinical Governance to report on quality of care and its maintenance SO IT REALLY IS AN IMPORTANT BOX TICKING EXERCISE

  16. Who sets the standards?

  17. Standards for Better Health • A set of standards set out by the Department of Health in 2004. (Pillars – then Domains) • NHS trusts must declare their level of compliance with these standards as part of their Annual Health Check.

  18. Level 1 Level 2 Level 3 Key issue in L3 is demonstrating compliance

  19. However • Although the Care Quality Commission is the new independent regulator of health and social care in England • The Dept of Health has specifically excluded primary ophthalmic services from the remit of the CQC

  20. So here we go............

  21. Key Message Number 1 • GOS is a centrally negotiated, centrally funded national contract • Compliance should NOT under ANY circumstances be seen as being subject to local conditions at the whim of an individual/PCT • GOS does NOT include payment for Clinical Governance • LOCs MUST be empowered to defend their members right to hold a national contract using nationally agreed guidelines.

  22. Don’t keep stepping back

  23. RememberAs an LOC you have safety in numbers • Please share your issues with others

  24. So what is ?

  25. To achieve any standardSomeone has to set the goalposts

  26. There must be an agreed minimum baseline standard

  27. Why is QiO unique? All about being SAFE !

  28. IT committee

  29. Description of QiO Levels Level 1 • Is a mirror image of the GOS contract monitoring form to enable compliance. • This defines advice on SAFE practice • This is the AGREED baseline

  30. Level 1Safe Practice

  31. What we are supposed to doWhat we say we do What we ACTUALLY do

  32. Level 2Picks up other standardsthat may be required inenhanced service provision

  33. Level 2Good Practice – Enhanced Services

  34. Level 3Deals with more aspirational standards for practice development

  35. Level 3 – Best Practice

  36. What are the interactive audits? Currently 3 Audits • Record keeping • Infection control • Information governance Do I have to complete them for GOS compliance? • NO................BUT.......................

  37. Are we contortionists ?

  38. Beware of Clause 100

  39. The most commonly used clause to over regulate is clause 100

  40. 100. The contractor shall comply with all relevant legislation and have regard to all relevantguidance issued by the PCT, the SHA, or the Sec. of State. • QiO is not just a help tool for contractors • It is intended to help OAs and PCTs understand the environment that we work in and the risks attached • The audits simply highlight aspects of Level 1 GOS compliance that relate to an area of specific subject matter to demonstrate their relevance.

  41. Record Keeping AuditTHIS IS NOT A CLINICAL AUDITIT IS A DATA AUDIT

  42. WARNING • Erroneous clinical findings can lead to complicity • Unless concerns have been raised about performance, there is no reason why you should be scrutinised on your clinical performance and decision making • This measures ability to RECORD only

  43. How’s my driving?

  44. It’s a friendly reminder

  45. Before this...........

  46. Or this..............

  47. Record keeping auditLevel 1 – Q13.5-13.7 • Records should be: • Fully maintained • Accurate • contemporaneous • Informative • legible

  48. Record Audit - Benchmarking An honest account of what people really do

  49. Record Keeping – Key Performance Indicators 6 Key Clinical PIs 7 Other Clinical PIs 3 Occasionals 3 Dispensing 4 Administrative

  50. Top 6 KPIs to remember Why are they here? Are they alive? Can they see? Is it alright in there? Do they need specs? Did I remember to speak at any point? Is anything in life 100% perfect?

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