Title: Performance management of contracting and contractors
1Performance management of contracting and
contractors
- Philip Leech
- consultant adviser for primary care,
- Department of Health
2Performance management
- What is it in the context of today?
- Trying to look ahead what will it deliver
- to patients
- to PCTs
- to providers
3Where are we, where we are going
- Current arrangements
- Defining and measuring performance
- Implementation, accreditation and regulation
- Market driven failure
4What we believe
- the best way of protecting patients is to build
on and strengthen the existing arrangements for
promoting the quality of clinical care,
collectively known as clinical governance -
- the vast majority of healthcare professionals are
already seeking to give high-quality care to
their patients for them, clinical governance
arrangements are intended to provide support,
encouragement and time for reflection on their
clinical practice
5But..
- a small minority exhibit behaviour or clinical
performance which puts patients at risk.
Clinical governance needs to be sufficiently
robust to maximise the chance of identifying
these clinicians so that prompt action can be
taken to protect patients. But no system can
give an absolute guarantee of safety, especially
(as the Shipman Inquiry fully recognised) when
faced with an individual as devious and malign as
Shipman.
6Clinical Governance
- Protected Time for Regular Team Meetings
- Significant Events Premature Deaths New
Cancer Cases Unpleasantness In The Waiting
Room - Summaries to Clinical Governance Team
- Comms
7What Happened
- Focus on the facts
- No blame
- Its the system
- What went well
- What was OK
- What could have gone better
- What should we do next time?
8PCTs do have a range of mechanisms
- for identifying individual GPs whose performance
is of concern. These include - Monitoring of routine data including QOF scores
- Annual clinical governance reviews
- Analysis of complaints
- Concerns from other professionals
9But where are the measures?
- Objective measures are difficult to construct. If
we wish to assess practice performance against
the whole range of functions they perform we will
need indicators that cover - Clinical quality
- Organisational performance
- Patient experience
- Compliance with regulatory requirements
- Resource utilisation
10One PCT approach
11Essential Ingredients
- Clear evidence and clear focus
- Examples From the field
- Time to consider solutions
- Reality of working at street level
- Systematic recording of information
- Rapid feedback
- Appropriate resources
- Skilled management
12Data Used For Prescribing Analysis
- Name of prescriber
- Drug name, formulation and strength
- Quantity prescribed
- Number of items prescribed
- Cost of prescribing
- No patient information is collected - name of
patient, age of patient, diagnosis or dosage
13Method
- Analyse prescribing by practice for Morphine,
Diamorphine and Pethidine injections only. - Compare Cost and Items per 1000 Patient unit
between practices and the PCT average. - Identify practices above the norm (PCT average).
- For these practices identify the injections that
are above average. - Produce a detailed report itemising all
prescriptions prescribed. - Produce a trend graph for the injection(s)
detailing the number of ampoules prescribed in
the past 24 months.
14QOF and Assessment
- http//www.connectingforhealth.nhs.uk/delivery/pro
grammes/qof/docs/establishing_accuracy_in_qof_data
.pdf - QOF blood pressure
- BP CHD, BP LVD, BP Stroke or TIA, and BP
Diabetes. - QOF records
- QOF indicator exceptions
- nww.qmastraining.nhs.uk
- QOF group exceptions
- QOF cytology
15QOF and Assessment
Many indicators can be matched against other hard
data sources, such as PACT. For example, do
cholesterol indicator reports from QMAS match the
extent of prescribing for cholesterol lowering
drugs? Assessors will be able to use hard
information to see patterns of care emerging that
define the ability and intentions of the practice
to managing patient care in the QOF. The factual
way that the QOF Assessor Validation reports
define patient care should be backed up by using
other data within and without the QOF.
16QOF and Assessment
The case for looking at hypertension has been
made in this guidance similar criteria could be
applied to diabetes matching appropriateness of
diagnosis against date of diagnosis, laboratory
test results looking at glycosylated Hb and
blood glucose results. Assessors can also look at
achievement for flu immunisation for the over 65
population. Both a high and low achievement
should be set against high achievement in other
QOF fields, where that achievement has relied on
high exception reporting.
17NCAS
- the model recommended by NCAS involves
investigation by a multi-PCT resource (the
Performance Advisory Group) to establish the
facts and decision by a senior PCT committee (the
Decision Making Group) typically chaired by the
medical director. Options include imposing
restrictions on the practice, removal from the
PCT list, application to the FHSAA for national
disqualification as a GP, and referral to the
GMC for possible erasure from the register. - Shipman 5 has also recommended giving PCTs powers
for some lesser actions e.g. warnings and
requiring remedial action
18Dr v practice
- A similar framework could in principle be adopted
to deal with unacceptable performance by the
practice. However, in this case the action would
have to be taken via the contract, e.g. by
declaring the practice to be in breach of its
contractual obligations and requiring remedial
action.
19NPSA
- . The key insights from An Organisation with a
Memory are that - clinical error usually results from human error
provoked by underlying system weaknesses - the NHS has traditionally been weak in learning
collectively from errors some serious clinical
errors are repeated time and time again in
different parts of the NHS - promoting active learning from mistakes requires
- moving from a blame culture to a safety
culture in which clinical staff are encouraged
to report errors and near misses so that learning
can take place - systematic processes for reporting and analysing
errors, establishing the underlying causes, and
ensuring that lessons are put into practice.
20A system model of accident causation (after
James Reason)
Some holes due to active failures
Hazards
Other holes due to latent conditions
Losses
Successive layers of defences, barriers,
safeguards
21The National Health Service (General Medical
Services) Amendment (No. 4) Regulations 2001 (the
2001 Amendment Regulations) (1)
- obligatory for a PCO (then the HA) to carry out
certain checks before admitting a doctor to its
list. HAs were required to check, as far as
practicable - references provided by the applicant
- information given by the applicant relating to
his/her medical qualifications and his/her
registration
22The National Health Service (General Medical
Services) Amendment (No. 4) Regulations 2001 (the
2001 Amendment Regulations) (2)
- contents of his/her declaration about any past
criminal or disciplinary record. - This declaration was now required to be
significantly fuller than previously whether
there was any past or ongoing fraud investigation
involving the doctor.
23The Health and Social Care Act 2001 powers (and
obligations) on HAs to remove a doctor from their
list on the grounds that
- the doctors continued presence on the list would
be prejudicial to the efficiency of the medical
services which doctors on the list undertook to
provide (an efficiency case) - the doctor had been involved in an incident of
fraud or attempted fraud (a fraud case) - the doctor was unsuitable to remain on the list
(an unsuitability case).
24Issues for the future
- The number of providers
- there are over 8.500 practices. The practical
challenges of regulating and inspecting such a
large number of providers are clearly
significant. - To some extent, the provider is also an
individual, the GP. Clearly this is the case for
all single-handed GPs but more generally reflects
the fact that most providers in primary care
are small independent partnerships. - determining a practice is failing will
sometimes be equivalent to asserting the
clinician is failing as well (with the
implications this has for their employment in the
NHS).
25The old story, new twists
- variations in the quality of primary care
providers. - introduction of a wider set of providers
competing for patients (along with increased
incentives on existing providers) increases the
need to provide assurance that performance
standards are high. - market led approaches to primary care are also
likely to increase the number of business
failures and voluntary exits (e.g. retirement)
that will require handling.
26strong need for a clear accreditation process
- Given the number of primary care providers there
are also issues around the capacity to undertake
regulation. The Healthcare Commission cannot
feasibly investigate all practices on any
meaningful basis. As a result we will need to
consider options for implementation. These could
include - A new peer review process building on the RCGPs
existing practice accreditation scheme - Assessment by PCTs operating under license from
the RCGP or Healthcare Commission
27Subtle ways patient empowerment
- an increasing recognition of the importance of
information to enable patients to make informed
choices in dialogue with clinicians and to take
better control of their own health see for
instance the Departments three-year information
strategy Better information, better choices,
better health - the development and roll-out of Expert patient
programmes for patients with longer-term
conditions such as asthma and diabetes to help
them to take active control of their own
treatment - a systematic approach to the use of information
from patient satisfaction surveys, involving all
hospital trusts and administered by the
Healthcare Commission, to assess and improve
services over one million patients have taken
part in the surveys so far - a specific duty on all organisations to involve
patients and the general public in the planning
and development of services
28Subtle ways patient empowerment
- the development of Patient Liaison Services
(PALS) and the Independent Complaints Advocacy
Service (ICAS) to help patients, their carers and
families to navigate services, find solutions
when things go wrong and (where necessary) raise
a formal complaint about services. Both these
services act as a powerful lever for change by
providing feedback and highlighting best
practice - the provision of direct mechanisms to enable
patients to report patient safety episodes
directly to the NPSA and adverse drug reactions
to the Medicines and Healthcare Products
Regulatory Agency (MHRA) - the proposed provisions in the NHS Redress Bill
for financial recompense to those who suffer as a
result of avoidable errors in the NHSiv. This
places the emphasis on putting things right for
patients as a matter of course, provides an
alternative to litigation, and will contribute to
the culture of learning in the NHS.
29Performance management of contracting and
contractors
- Philip_at_primarycareleads.com