The GPhC and seven other health and social care regulators and other bodies have signed a new agreement to help them share concerns with each other more effectively. The regulators have issued a joint statement about the new ‘Emerging Concerns Protocol’ which you can read below:
Joint statement on the Emerging Concerns Protocol
Today, eight health and social care regulators and other bodies have signed a new agreement to help them share concerns with each other more effectively.
The ‘Emerging Concerns Protocol’ seeks to provide a clearly defined mechanism for organisations with a role in quality and safety of care provision to share information and intelligence that may indicate risks to users of services, their carers, families or professionals.
This could include:
- situations that may not be seen as an emergency, but which may indicate future risks;
- cultural issues within health and social care settings that may be noticed, but would not necessarily be raised through alternative formal systems.
An example of the how the protocol might be used can be found in the below annex.
As a group of organisations, we expect providers and professionals to work together collaboratively in order to provide the best possible care. We hold ourselves to the same standards. We know that sharing concerns at the right time can make it easier to make links between pieces of information that tell us that a problem is emerging.
There are numerous bodies working to make sure people receive safe and high quality care across health and social care. The protocol will help ensure regulators are transparent with the public, providers and professionals about the way that we work together.
The protocol is a strengthening and formalisation of existing arrangements for sharing emerging concerns between regulators. However, it is specifically aimed at assisting staff across the signatory organisations in making decisions as to when to escalate information of concern either bilaterally or more widely. It is not intended to work against good working relationships that already exist, but to strengthen and encourage good practice.
We also believe that working together more effectively can reduce unnecessary burden that does not benefit people receiving care, by encouraging our organisations to come up with joint plans when we share similar concerns, for example, or by taking assurance from each other’s actions.
We will work together to review and evaluate the process for sharing emerging concerns to ensure that it works not only for providers and professionals but for the individuals who use services.
Organisations that have signed the protocol include:
- Care Quality Commission
- General Medical Council
- General Pharmaceutical Council
- Health and Care Professions Council
- Health Education England
- Local Government and Social Care Ombudsman
- Nursing and Midwifery Council
- Parliamentary and Health Service Ombudsman
The General Dental Council is supporting our emerging concerns working group for the protocol, and they will look to become a signatory in the coming weeks. The protocol is an evolving agreement which looks to build on strong existing relationships, so will take effect immediately to avoid any delay in the support it offers to those already signed up.
This work was commissioned by the Health and Social Care Regulators’ Forum, which oversees its progress. The protocol has been developed by a working group and was piloted with operational staff from all organisations involved.
The protocol covers England only, the regulators with responsibility for regulating across the UK or Great Britain will continue to work collaboratively with the relevant national organisations in the home countries.
A senior doctor working in the NHS approached a GMC Regional Liaison Adviser (RLA) at a conference and disclosed that they had experienced issues for several months with the quality of surgical equipment used by their organisation.
They stated that the surgical packs were not complete and frequently contained instruments that were poorly assembled and prone to coming apart during surgery. The same supplier provides theatre equipment to other healthcare providers, both public and private. The issue was clearly an urgent patient safety concern and involved doctors, nurses and other healthcare professionals. The organisations’ senior management were aware.
This disclosure was clearly about a live and ongoing patient safety concern that went beyond the GMC’s statutory functions and was potentially affecting at least three professional groups and a number of NHS and private healthcare organisations. It was determined by GMC senior managers that this information had to be shared urgently with CQC and other partners.
- A call between the GMC and CQC took place and agreed that a Regulatory Review Panel (RRP) would be triggered in line with the ‘Emerging Concerns Protocol’.
- A redacted intelligence summary was shared with CQC and NMC.
- All of the potential signatories were contacted by CQC.
- Representatives attended a virtual meeting chaired by CQC.
- Delegates were provided with a verbal synopsis of the GMC intelligence.
- Information that CQC had ascertained between the initial call with the GMC and the RRP was shared.
- The NMC updated the call with what they had ascertained from their own data and intelligence.
- CQC confirmed that they were in the process of inspecting the organisation concerned and would seek additional information.
- It was agreed that the Health and Safety Executive (HSE) and Medicines and Healthcare Products Regulatory Agency (MHRA) should be informed.
- Regulatory action was agreed and taken swiftly by CQC
- Professional regulators shared intelligence and data expeditiously
- HSE and MHRA were briefed within days of the disclosure
- Other signatory organisations were sighted on the issue
- The meeting was over within 45 mins
- Feedback was positive from all attendees.