This document sets out the proposed areas for scrutiny and assurance in 2014-2015 led by the Scrutiny and Assurance Directorate. We highlight why these are priority areas, how they link to the NHSScotland Quality Strategy Outcomes and how we will go about our work.Over the coming year, we are proposing to:
- further embed the patient and carer experience in our scrutiny and assurance activities to ensure we remain a listening organisation that learns from local feedback
- move towards more comprehensive assessments of the quality of healthcare
- further embed our joint work with the Care Inspectorate and other scrutiny bodies
- continue to work closely with the Evidence and Improvement Directorate to develop measures to support improvement in the quality of clinical care being delivered to patients, and
- use intelligence to determine areas for investigation and review to support improvement.
Consultation detailsWe are seeking the views of a wide range of interested individuals and organisations as possible. We are committed to ensuring that our priorities reflect the things that matter to patients and the public.This consultation document sets out our proposals for scrutiny and assurance and we seek your views on the proposals. After taking into account the views received, we will submit a final version for the approval of Scottish Government Ministers in early 2014.
Comments on Healthcare Improvement Scotland (HIS)
Annual Scrutiny and Inspection Plan: Draft for Consultation - 2014-15
The Royal College of Physicians of Edinburgh offers the following comments to Healthcare Improvement Scotland (HIS) in response to the public consultation on their Annual Scrutiny and Inspection Plan.
The College was disappointed not to have been circulated with the consultation document and found it by chance when searching for another report – we recommend a review of your circulation lists and would expect to see all professional organisations, including Colleges, to be listed in line with your commitment in the HIS strategy for greater transparency in your work streams.
The College recognises that HIS is not a regulator for much of its scrutiny work but we continue to be concerned about the objectivity and feasibility of effective scrutiny when standard setting, implementation and scrutiny are the responsibility of a single organisation. The College notes that in some sections (eg Joint Inspection for Children and Adults) the Scrutiny Plan is more focused on implementation than scrutiny and this further emphasises the confusion of role for a single organisation with mixed responsibilities.
Shaping priorities
The College welcomes the inclusion of investigating workforce levels and skill mix (as these influence the quality of care provided) and also of integrating inspections and reviews. These wide-ranging reviews will be particularly important in addressing the challenges raised by the recent review in Lanarkshire but will require standards to be set in services for acutely unwell patients. This was an area of work identified by the College in response to your scrutiny plans last year and we remain keen to work with HIS over standard setting and monitoring. The College was therefore disappointed to be omitted from those organisations listed for collaboration over these new broad reviews.
However, it is difficult to assess how effective the described wide-ranging reviews will be unless geographically focussed and phased over several years. The College recognises that HIS has a huge and wide-ranging agenda and this is not helped by a lack of exit strategy for established work streams to make way for new projects. There appear to be plans to embark on new areas of work in:
- Standards for screening programmes
- Quality indicators for patients with learning disabilities
- Clinical governance arrangements at Health Boards
- Death certification arrangements
- Systems to screen the effectiveness of Public Concern at Work
- Adverse events monitoring following the test work last year
How is this to be managed within your indicative £3m budget?
Safer Healthcare
With reference to the above point on exit strategies - the College notes the changes in maternal and infant care with a 4-country approach and the demise of existing Scottish-based audits. Is it possible to do more of this cross-UK sharing?
HAI continues to dominate safety work and it would be useful to understand when HIS will feel confident that resources devoted to this area of quality improvement can be diverted to other problems.
Safer Clinical Practice
The College understands that it is early days for revalidation and the newly introduced Scottish appraisal system but would be keen to see plans to scrutinise the quality and effectiveness of appraisal rather than the rates of appraisal and other structural measures. Setting aside time for medical appraisal and revalidation is costly, and it is important it is valued by clinicians and supports professional development and quality improvement.