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The Civil Contingencies Act (2004) requires NHS organisations and providers of NHS-funded care to prepare for, be able to respond to and recover from, a wide range of incidents and emergencies that could affect health or patient care while maintaining services for patients.
This could be anything from extreme weather conditions to an outbreak of an infectious disease or a major transport accident. This programme of work is referred to in the health community as ‘emergency preparedness, resilience and response’ (EPRR).
In April 2013, the changes to the NHS brought about by the Health and Social Care Act 2012 saw Clinical Commissioning Groups (CCGs) taking on responsibility for the majority of healthcare commissioning in their areas. Alongside this, CCGs were identified as Category 2 responders under the Civil Contingencies Act. As well as the duties placed upon CCGs by the Civil Contingencies Act, the Health and Social Care Act identified a role for CCGs in respect of emergencies, including a duty to be properly prepared for dealing with an emergency. The specific requirements in relation to EPRR that CCGs, and other NHS organisations, are expected to achieve are set out within the Core Standards for EPRR
The Core Standards are a national framework for NHS EPRR and form the basis of assurance processes monitored by NHS England and the recently established Local Health Resilience Partnerships, which provide a strategic (typically county level) forum for health EPRR matters.
Wigan Borough CCG took a proactive approach to its new responsibilities and began to work closely with Greater Manchester Commissioning Support Unit (GMCSU) on EPRR.
GMCSU provides core resilience services to the
12 CCGs in Greater Manchester, with each CCG having a named Resilience Manager working
on their behalf. With valuable knowledge, skills and relationships from legacy PCT
organisations, GMCSU’s Resilience team was well equipped to assist the CCG
navigate EPRR requirements and processes.
As ‘Category 2 responders’, CCGs have a duty to share information and cooperate with Category 1 responders. Category 1 responders are those organisations, such as acute and ambulance NHS trusts, Public Health England and NHS England, that have a greater number of duties under the Civil Contingencies Act and which are likely to play a leading or hands on role in emergency response; Category 2 responders are typically supporting organisations.
As Category 2 responders, CCGs are less likely to be involved in the heart of incident response, but they are expected to contribute towards and be engaged with emergency preparedness within their sector. Although Category 2 responders have a lesser set of duties, it is vital that they share relevant information with other responders so that EPRR arrangements are robust and coordinated.
Category 1 and 2 responders come together to form a multi-agency local resilience forum based on police areas. These forums help to co-ordinate activities and foster co-operation between local responders.
The NHS England Core Standards for EPRR state that NHS organisations and providers of NHS funded care must:
NHS organisations are also expected to have suitable, up-to-date plans for service resilience, which set out how they will:
This planning should follow the principles of ISO 22301 and PAS
2015.
Through its Resilience Team, GMCSU provides Wigan Borough CCG with advice and
support for resilience on an ongoing basis. The knowledge and skills within the
Resilience team means the CCG has access to the expert guidance required to
help it navigate the EPRR process and allow it to be an informed partner in
matters relating to civil emergencies.
GMCSU’s Resilience manager for Wigan worked closely with the CCG to:
GMCSU assessed the CCG’s alignment to the national Core Standards and provided the CCG with a compliance score that was reported back to NHS England.
As part of its support to the CCG, the Resilience team reviewed and updated the local health economy incident response plan, which describes arrangements for incident management, communication and coordination during a significant incident or emergency within the locality. The plan also ensures that one recognised management framework is used by all health commissioners and providers across the health economy.
The Resilience team also reviewed arrangements for an Incident Coordination Centre, or control room that may be activated in the event of a major incident or emergency, and developed a guide for setting up and operating this facility.
As previous training needed to be refreshed in light of the significant organisational changes to the NHS, GMCSU initiated the development of a new EPRR training programme in alignment with the Core Standards, collaborating with NHS England on the design and delivery of this training, which initially focused on preparing on-call managers.
GMCSU’s Resilience team also worked with the CCG
to ensure that plans were in place to test local EPRR. This involved ensuring
that a schedule was developed for the EPRR testing arrangements required by NHS
England; namely a live exercise to take place every three years, a desktop
exercise every year, and communications exercise every six months.
The outcome of Wigan Borough CCG’s first annual EPRR compliance review was an outstanding score of 95 per cent. The assessment was based on the CCG incident response plan and supporting documents, the CCG incident coordination centre guide, training of all on-call staff, and business continuity work.
Local health economy incident response plans have been signed off by the CCG and shared with the local health economy resilience group.
The Business Continuity Management Policy and Business Continuity Plan have both been approved and an impacts and strategies toolkit was completed.
All on-call members of staff have been
trained to National Occupational Standards. GMCSU is continuing to deliver
resilience awareness training to new members of staff as well as ongoing refresher
training courses.
GMCSU’s Resilience Manager for Wigan has
built a good working relationship with the CCG’s Risk and Governance Director
and Accountable Executive Officer.
As part of the ongoing resilience service, GMCSU
will continue to work with the CCG to ensure that EPRR plans remain up-to-date
with the latest guidance, that new staff are trained, and that participation in
relevant EPRR tests and exercises is maintained.
Graham Coxon, Head of Integrated Governance at GMCSU, who has accountability for the Resilience team said:
“This excellent score reflects the good practice adopted by Wigan Borough CCG. It is a testament to effective partnership working between GMCSU and the CCG, and the commitment from the CCG to the EPRR process. It is particularly impressive given that we only had 12 months to develop all the necessary structures and processes involved.”