Draft Healthcare Quality Standard - Assuring Person-Centred, Safe and Effective Care: Clinical Governance and Risk Management

COMMENTS ON
Healthcare Improvement Scotland
Draft Healthcare Quality Standard - Assuring Person-Centred, Safe and Effective Care: Clinical Governance and Risk Management

The Royal College of Physicians of Edinburgh welcomes the opportunity to review this draft healthcare quality standard.  Clinical governance and risk management remain extremely important both internally as drivers of improvement in the quality and safety of clinical services, and externally in providing assurance to patients and the public.  Comments follow:

• The College is particularly pleased to note the inclusion of “effectiveness” in the clinical governance and risk management principles and recommends this is tightened further to encourage the use of “evidence-based best practice” (page 5). 
• This latest iteration of these standards has four significant merits:
  1. it is linked explicitly to the agenda of the NHS as set out in the Quality Strategy;
  2. its emphasis is on self-evaluation, providing HIS scrutiny can be effective and NHS Boards are not allowed to avoid challenging issues;
  3. it seeks to link what takes place at board level on policy and strategy with what happens at the 'sharp-end' of delivering hands-on care and treatment (a particular weakness of previous versions) although the development and use of frontline staff should be given more emphasis; and
  4. it is much shorter and simpler than previous attempts, relying largely on data that is already being collected.
• The detailed self-evaluation questions also seem generally appropriate and comprehensive, with the only significant gap being reference to partnership working with others, such as local authorities and the third sector and which is so important in relation to long-term conditions.  However, these questions might be better phrased “How does …” to avoid the temptation of closed answers.
• The emphasis on clinical audit is most welcome and the College seeks assurance that clinical benchmarks will be selected from Scottish and UK comparators and after specialist advice including from the Medical Royal Colleges. 
• The challenge is to develop robust measures that will enable HIS to assess whether or not NHS Boards are achieving the required standard and target support to those that are not.  Page 10 states that ‘There are effective risk management systems in operation which identify clinical, legislative, finance and other risks and are focused on the safety of patients’.  However, there is no definition of ‘effective’ and how will NHS Boards be held to account for performance?
• The use of a quality risk profile will be helpful for Boards and HIS.  The information examples at the top of page 8 should also include clinical sources such as SASM and other national clinical audits.
• Under the capability and culture domain the omission of a clinical governance committee or equivalent is surprising (page 12, 2a).  Also, in relation to this domain, it would be helpful to remind organisations of the need to integrate the work of quality improvement teams with front line clinical teams.
• It would be reassuring to see explicit reference to feeding back results to clinical teams to encourage sustained change.  This will help secure clinical engagement and avoid the perception of a tick box exercise, especially at a time when the drive for financial balance appears often to frustrate improvement.
• Should there be mention of new ways of involving patients eg self-care or self-management (page 16)?