Health Improvement Scotland
Thursday, 31 October, 2013

The purpose of this document is to engage the public and NHS stakeholders on Healthcare Improvement Scotland’s priorities for scrutiny.
 We welcome input from as wide a range of individuals and organisations as possible to help inform our next Scrutiny and Inspection Plan.
 The key questions we are asking are:

  •  Do we have the right priorities?
  •  Are there any additional areas you consider we should be scrutinising?
  •  Do we need more or less activity in any of the current priorities?

We will use your feedback to inform our 2014–2015 Scrutiny and Inspection Plan and to shape our broader strategy.

Royal College Of Physicians Of Edinburgh Response To Health Improvement Scotland’s Consultation
‘Help Us Shape The Scrutiny Of Your Healthcare’

  1. The Royal College of Physicians of Edinburgh is pleased to comment on priorities for the HIS Scrutiny Plan for 2014-15, and would very much welcome an opportunity to discuss the needs of physicians more fully with the team building the Scrutiny Plan.

General Points

  1. The College applauds the aspiration of HIS to use the integration of evidence, improvement projects and scrutiny to build a cohesive approach to quality improvement. It can be difficult to assess the impact of this overall approach in terms of progress against the 2020 vision for health and social care, and the College strongly recommends the inclusion of patient-centred standards for scrutiny that will demonstrate to patients and the public the value of such activity.

  2. The College also recommends that HIS finds a way of clarifying its role when undertaking scrutiny activity (ie as a scrutineer or regulator) and which may encourage openness and foster quality improvement as a key outcome from analysis and visits.

  3. The College appreciates that the development of integration authorities with joint and equal responsibility for Health Boards and Local Authorities will present a real challenge to a scrutiny body tasked with addressing culture change to improve services and outcomes.  The cultures in these very different bodies will take time to integrate (if ever) and the relationship between HIS and the integration authorities will be critical if scrutiny and inspection programmes are to impact on care.  Addressing this organisational dynamic should perhaps feature as one of the highest scrutiny priorities for HIS in coming years.

Are there any additional areas you consider we should be scrutinising?

  1. Unscheduled medical care is largely missing from the scrutiny programme.  For physicians, there are twin challenges that have their root causes in the year on year increase in acute medical admissions.  Clinical demand is such that consultants experience burn out and training places lie vacant, adding to problems for those who remain in a vicious circle of high activity and inefficient working.  The knock on effect to more elective (often preventative) outpatient and day case work adds to this pressure. Physicians live with the reality that patient care can be compromised with delayed diagnosis and treatment, poor clinical supervision, boarding and delayed discharges. None of this is new and the College would welcome the ability to draw attention to opportunities for quality improvement and monitor progress through the scrutiny activities of HIS.
  2. The complaints levelled at out-of-hours services (across all health sectors) also seems not to feature in scrutiny and should be an urgent candidate for the new integrated authorities.
  3. There are a number of workforce measures that could be the subject of national scrutiny including vacancy levels (numbers and duration), locum use and 9+1 contracts for medical staff.  All could provide useful intelligence on systems under pressure and where patients may be put at risk due to staff shortages and/or a lack of time for professional activities and CPD.  The College strongly supports the move towards 7 day services for acutely unwell patients but, again, delivering this against a background of current staffing gaps will be extremely challenging; detailed scrutiny of health board performance in these areas would be helpful and instructive.
  4. Prescribing errors are a major patient safety and efficiency issue and the College has been leading the work to develop a standardised chart to address both.  Once introduced, it would be helpful to assess the impact of the new chart through national scrutiny.

Do we have the right priorities?

  1. It seems that priorities are often handed to HIS as a result of a process problem or crisis in one or other territorial health board (eg adverse incident reporting, individual patient treatment request or staff confidential alert line) or a new policy initiative (eg revalidation), and it is unclear at what stage HIS can set topics aside.  For example, the College anticipates HIS being asked to review complaints handling systems following recent media interest in the understated complaints data held at ISD, and infection control will become hot news again with the publication of the Vale of Leven Report.

Do we need more or less activity in any of the current priorities?

  1. The College would like to understand how proportionate scrutiny works in practice to make best use of limited resources and minimise disruption to services.  An example of possible duplication is the impact of preparatory/review visits to endoscopy units in advance of JAG accreditation visits, which are themselves designed to identify areas for improvement and provide valuable externality.  Are these pre-accreditation visits strictly necessary?  Also, when scrutiny work has accomplished its aim, how is the focus moved elsewhere?