A meeting of the Governing Body of NHS Bromley Clinical Commissioning Group - NHS Bromley CCG

Page created by Shirley Hamilton
                          A meeting of the Governing Body   East London Sector
                       NHS Bromley Clinical Commissioning Group
                                      March 2018
                                              ENCLOSURE 7


On Monday 16th - 20th October 2017 the Care Quality Commission (CQC) undertook a full Safeguarding
and Children Looked-after Review of Bromley health services. The Care Quality Commission (CQC) has a
legal requirement to make sure that health and social care services provide people with safe, effective,
compassionate and high-quality care. A rolling programme of reviews is undertaken to fulfil this role.

The week started with a strategic Bromley overview for the lead inspector Liz Fox and her team, staff from
across the health system and the London Borough of Bromley Children’s Services, including Public
Health. The CQC also reviews health services commissioned by Public Health as these services have a
significant role in safeguarding and promoting the welfare of children and young people e.g. school
nurses, health visitors and contraceptive services (Section 48 of the Health and Social Care Act, 2008). In
addition, ‘Change Grow Lives,’ the Drug and Alcohol Service for Children and adults commissioned by
Public Health was also reviewed, similarly due to the significant risks drug and alcohol issues can impact
on families. The organisations visited are listed in Appendix 1.

Broadly, the review found that across the health economy they found committed professionals and staff
with good examples of partnership working and innovative working where staff improved outcomes
through service development. The report also identified areas that needed continued development such
as improving information sharing and information technology across services so that vulnerable children
are highly visible within the health system and can be safeguarded.


The central purpose of this inspection was to undertake a targeted review of how well local health
services – whether commissioned by Bromley Clinical Commissioning (BCCG), NHS England or London
Borough of Bromley (LBB) - identify, help, protect and provide child-centred care, whilst ensuring that
children’s health needs are effectively met. Inspectors evaluated the quality and impact of local health
arrangements for safeguarding children and improving health outcomes for children who are looked after.
This included mapping the child’s journey at all stages – from pre- birth through to their transition to
adulthood, and from the point of their entering to leaving care.
Inspectors visited services, spoke with children and their families, staff, clinicians and safeguarding leads
as they evaluated safeguarding practice, service provision and governance arrangements whilst tracking
a child or young person’s journey through services. They also observed how IT systems worked. The
inspection framework is based on the following key lines of enquiry:

       Clinical Chair: Dr Andrew Parson               1                      Chief Officer: Dr Angela Bhan
   The experiences and views of children and their families.
      The quality and effectiveness of safeguarding arrangements in health services
      The quality of health services and outcomes for children who are looked after and care leavers.
      Health leadership and assurance of local safeguarding and looked after children arrangements

Nine cases were selected by provider organisations (three from each) (Midwifery, Health Visiting and
Child & Adolescent Mental Health Services (CAMHs) that met the criteria provided and each case had to
include multi-disciplinary involvement and had to have been referred to the Multiagency Safeguarding Hub
(MASH); chronologies were created for each case. In total the inspectors reviewed 90 case records. Any
issues identified during the inspection were shared during the morning ‘Keeping in Touch’ (KIT) meetings
between the lead inspector and Head/Designated Nurse Safeguarding Children (SGC). These issues
were shared with providers who responded immediately by troubleshooting, providing risk assessments
and trajectories.


Examples of ‘What People Told Us’

      Parents spoke very positively about the care received. “We felt cared for …the staff go above and
       beyond”. They described how the midwives had explained risk and benefits to help them make
      “CAMHS have done a significant piece of work with her and it has taken over a year for them to get
       her to a place where she is ready for the service to be effective.”
      Bromley Changes received a referral from children’s social care in relation to a young person’s
       alcohol use and binge drinking. The young person was autistic so the worker looked at the best
       way to adapt the sessions to meet the young person needs, such as delivering very short focused
       sessions. There has been a very positive outcome for this young person with greatly reduced binge
       drinking. The worker is now supporting the young person as they prepare to apply for a job.
      Although there were no direct quotes from children and young people, inspectors scanned records
       and identified best practice which led to improved health outcomes for some of the most vulnerable
       children and young people.

Across the health system they found committed professionals and staff with good examples of partnership
working and innovative working where staff improved outcomes through service development. The areas
reviewed included:

      Early Help
      Child in Need
      Child Protection
      Looked-after Children
      Leadership and Management
      Governance
      Training and supervision

       Clinical Chair: Dr Andrew Parson             2                     Chief Officer: Dr Angela Bhan
Summary of key themes:

     Children and young people benefit from timely assessments of their clinical needs when attending
      urgent or emergency care at Princess Royal University Hospital (PRUH).
     Bromley Healthcare provides a comprehensive and flexible service which includes a Young Person
      Clinic (under 25yrs).
     Perinatal Mental Health Service was well developed with a rigorous removal-in process and risk
     Midwifery services – safeguarding leadership strong, good links to specialist midwives (Mental
      Health, Drug and Alcohol); women seen alone for domestic abuse mandatory questions (though
      need to ask more than once).
     Bromley Changes is working successfully with primary care; schools and ED at PRUH to ensure
      the service supports professionals and have strengthened referral pathways are in place to help
      ensure effective early and robust assessments.
     Assessments of a child’s home environment and their safety by health visitors are not always
      robust. This was reflected in case records seen and included a lack of chronologies or genograms.
     Inspectors were not assured the health needs of electively home educated children were being
      effectively overseen and met.
     Children presenting to the PRUH in severe mental health crises often wait too long for a CAMHs
      assessment and subsequent discharge or transfer to a specialist setting.

      Admin and IT processes
     The identification of vulnerable CYP at the Urgent Care Centre (UCC) and Emergency Department
      (ED) is not robust. Currently the IT systems for these services at the PRUH do not communicate
      with each other. A paper-based system is in place between the two services.
     Lack of shared IT between midwives and adult mental health services
     Recruitment and resources - a longstanding vacancy for a Bromley HealthCare liaison health visitor
      has limited information sharing between PRUH and health visitors about children’s attendances.

      Leadership, management and governance
     Good commitment by CCG to working with the local authority to improve outcomes for children and
      young people.
     BCCG designated professionals offer strong leadership within the organisation and robust
      governance oversight across the health economy. Their profile is high with senior partner agencies.
     development of the GP Services Safeguarding Children Local Enhanced Services template and the
      Health Economy Safeguarding/Children Looked-after dataset led by the Designated Nurse
      Safeguarding Children.
     Named nurse and specialist midwives at the PRUH lead on promoting good safeguarding practice
      and have well developed multiagency working relationships.
     The safeguarding lead practitioners within both the adult and young people’s substance misuse
      services provide robust oversight of each service.
     The changes in commissioning arrangements for the five to-19 year service has reduced the
      opportunity for the sexual health advisors to refer young people to a ‘school nurse’ for more
      universal focused health advice or ongoing support within the school setting. It is too early to say if
      this will have any longer term impact on the interdisciplinary working and supporting young people
      with their health needs.

      Clinical Chair: Dr Andrew Parson                3                      Chief Officer: Dr Angela Bhan
   The Bromley Healthcare Children Looked-after Team is well led. Initial Health Assessments are not
       always completed within statutory timescales. Review Health Assessments were seen to be
       particularly strong.

Training and supervision
    Most provider organisations, (with the exception of King’s College NHS Trust) evidenced their
      workforce were appropriately trained in safeguarding. The oversight of exceptions takes place
      within the BCCG Safeguarding Executive Group.
    Further clarity and evidence needed to provide assurance that midwives and other clinical staff
      comply with statutory guidance on number of hours multi-disciplinary and interagency training
      required three yearly.

A number of recommendations were made and Bromley CCG and health providers are already making
improvements in many of these areas.

Next steps

A combined Health System SMARTER Action Plan and separate Public Health Action Plan were collated
and shared with the CQC and signed off on by the CQC on the 12th March 2018. The CQC governance
and quality assurance of the action plan will be overseen by the local area team going forward. Our efforts
are now focused on delivering these recommended improvements.


The combined Health Action Plan will be overseen and monitored via the following governance

      BCCG Governing Body – six monthly.
      BCCG Safeguarding Executive Group – strategic oversight quarterly. Recommendations and
       actions integrated into the BCCG Safeguarding Children/Children Looked-after Strategic and
       Operational Work Plan.
      BCCG Quality Assurance Sub-committee – quarterly Safeguarding Children/Children Looked-after
      Operational oversight of action plan via the Safeguarding Children Health Economy Forum; bi-
      BCCG Contract and Mobilisation meetings for contractual escalation and monitoring.
      Bromley Safeguarding Children Board (BSCB) Quality Assurance Performance Management
       Subgroup – bi-monthly.
      Supervision of named safeguarding professionals by designated professionals.

The committees or working groups (with dates) that have discussed this report or issues prior to
submission to the GB:
    Discussed at the Quality Assurance Subcommittee on 26th October 2017 and 22nd February 2018.
    Discussed at the Senior Management Team meeting

       Clinical Chair: Dr Andrew Parson              4                      Chief Officer: Dr Angela Bhan
   London Borough of Bromley Children’s Services Improvement Board – 23.02.18

The Governing Body is asked: To Discuss and note this report and action plan.

                                              APPENDIX 1

  Services visited as part of the CQC Bromley Safeguarding and Children Looked-after Services

    Children Looked-after Service - Bromley Healthcare

    Bromley Multiagency Safeguarding Hub (MASH)

    Greenbrook Urgent Care Centre - Princess Royal University Hospital

    Emergency Department at Princess Royal University Hospital (incl. children’s ward)

    Maternity at Princess Royal University Hospital

    Contraceptive Services - Bromley Healthcare (Beckenham Beacon)

    Sexual Health & Genitourinary Medicine (GUM) (Beckenham Beacon)

       King’s College NHS Foundation Trust)

    Child & Adolescent Mental Health Services - Oxleas NHS Foundation Trust

    Bromley Adult and Children’s Substance Misuse Services (Change Grow Live)

    Health Visiting and Health Support to Schools Service 0 – 19 service Bromley Healthcare and
     Oxleas NHS Foundation Trust

    Adult Mental Health Services – Oxleas NHS Foundation Trust

    GP Practices x3.

AUTHOR CONTACT:                                        DIRECTOR CONTACT:
Name:     Sadie McClue                                 Name: Sonia Colwill
Position: Designated Nurse Safeguarding                Position: Director of Governance, Quality and
Children                                               Patient Safety
E-Mail:   BROCCG.ContactUs@nhs.net                     E-Mail: BROCCG.ContactUs@nhs.net

       Clinical Chair: Dr Andrew Parson            5                       Chief Officer: Dr Angela Bhan
Bromley CCG Health Systems Action Plan for the Care Quality Commission

Report Title                CQC Review of Health Services for Children Looked After and Safeguarding in Bromley

Date of Publication of      29 January 2018

Ref.    Organisation/       Recommendation                Actions                            Lead            Outcomes                         Completion Date   RAG
        Service                                                                                                                                                 rating

1.1     Bromley CCG         GPs are supported to          •   Enhanced Community             Named GP        Audit of case conference            April 2018
                            effectively share                 Service to continue in                         reports to include quality
                            information about                 2018/19 with coding                            and use of correct Emis
                            parent/carer and children         recommendations and audit                      template.
                            held in their records that        of annual self-assessments
                            impacts on the child’s            by Named GP                                    Enhanced Community                  April 2018
                            wellbeing. This will inform                                                      Service document for
                            child protection reports      •   Training on referrals and                      2018/19 to be rolled out
                            and multiagency decision          reports to GPs at Academic
                            making.                           Half Day in January 2018                       Named GP to audit use of            April 2019
                                                                                                             Enhanced Community
                                                          •   Ensure use of correct Emis                     Service via the self-
                                                              template for case conference                   assessment questionnaire.
                                                              report is fully embedded                                                         January 2018
                                                                                                             Academic Half day
1.2     Bromley CCG         CCG safeguarding leads        • New health professional role     Designated      Single robust multiagency        September 2018
                            should review and             in development. To be co-located   Professionals   CSE risk assessment tool
                            maintain oversight of the     with Bromley Local Authority                       which addresses the health
                            consistency and quality of    Atlas team to scope and evaluate                   needs of children who are
                            CSE risk assessment tools     the interface between health and                   at risk of sexual exploitation
                            in use in the health          other agencies around CSE                          to be developed and
                            economy, benchmarking         agenda                                             ratified.
                            against the LSCB CSE

       CQC Action Plan v6

tools.                                                                           Staff will be trained in how     October 2018
                                                                                                            to use this across the
                                                                                                            health economy

                                                                                                            Undertake an audit to
                                                                                                            assess staff use of the tool
1.3    Bromley CCG         GPs review IHA and RHA      •   Named GP to liaise with          Designated Dr   Named GP and Designated           March 2018
                           plans to inform their           Designated Dr for CLA in         CLA/ Named      Dr CLA to meet and
                           interactions with CLA and       order to discuss the             GP              discuss
                           CCG processes assess            timeliness of sharing of
                           the impact of the work.         IHA/RHA reports with GPs                         IHA/RHA codes to be                April 2018
                                                                                                            included in 2018/19 ECS
                                                       •   Enhanced Community                                                                 March 2019
                                                           Service for 2018/19 requires                     Named GP to audit usage
                                                           that GPs code IHA/RHA to                         of IHA/RHA codes via the
                                                           facilitate identification of                     self-assessment
                                                           CLA.                                             questionnaire.                     July 2018

                                                       •   CLA workshop at GP                               Audit to be undertaken by
                                                           Academic Half Day 17.1.18                        CLA nurses at RHA,
                                                           to promote understanding of                      exploring experiences of
                                                           the role of the GP with CLA                      CYP and their carers of
                                                           processes and to help GPs                        services received by GP
                                                           to consider the risks to these                   services and about
                                                           vulnerable children during                       ensuring health
                                                           their assessments.                               recommendations have
                                                                                                            been acted upon.

1.4    Bromley CCG         GPs use current and         •   Enhanced Community                               Updates to Enhanced            April 2018
                           relevant coding as              Service (previously known as     Named GP        Community Service
                           recommended in the CCG          Local Enhanced Service) to                       document
                           Local Enhanced Service          continue in 2018/19 with
                           for safeguarding children       coding recommendations                           Named GP to audit usage        April 2019
                           agreement and quality           and audit of annual self                         of codes via the self-
                           assurance processes to          assessments by Named GP                          assessment questionnaire.
      CQC Action Plan v6

support compliance
                                                         •   Explanation of coding for                        Named GP to liaise with
                                                             vulnerable child to be added                     Local Authority Heads of    March 2018
                                                             to Enhanced Community                            Service

                                                         •   Work with Local Authority to
                                                             ensure that notification of
                                                             children no longer subject to
                                                             CLA legislation and children
                                                             no longer subject to a child
                                                             protection plan is shared with
                                                             the GP.

                                                         •   Audit of usage of coding by
                                                             case reviews at practice
                                                             leads ½ days

1.5    Bromley CCG         Record keeping and IT         •   Bromley healthcare and           Designated      Training in use of IT       February 2018
                           systems across Bromley            Oxleas have agreed that the      Professionals   systems provided to
                           Health economy support            safeguarding advisers from                       Bromley Healthcare and to
                           effective information             each organisation will have                      Oxleas safeguarding
                           sharing; appropriate              access to one another’s                          advisers.
                           flagging/ alerts; access to       record keeping systems to
                           safeguarding records and          ensure that appropriate
                           multiagency plans so              information is accessed in a
                           vulnerable children are           timely way across their
                           highly visible and can be         organisations.
                                                         •   The following issues were
                                                             resolved during the CQC
                                                             inspection. Immediate action
                                                             was taken following the
                                                             technical issue with flagging
                                                             during the implementation of
                                                             a new version of Rio in
                                                             Oxleas. Immediate action
      CQC Action Plan v6

was taken in relation to data
                                                             cleansing in Bromley
                                                             Healthcare IT systems. The
                                                             Princess Royal University
                                                             Hospital Safeguarding
                                                             template in A+E was
                                                             amended to ensure that the
                                                             safeguarding section was

2.1    Bromley CCG         Work with NHSE so that        •   New Models of Care              Children &       The enhanced BBG CYP           October 2017
       and Oxleas          children and young people         delivered closer to home,       Young People’s   mental health liaison
                           in Bromley have timely            with improved assessment        Commissioner     service is to be situated
                           access to specialist mental       and bed management                               across the Queen Elizabeth
                           health care close to home.        pathways.                                        and Princess Royal
                                                                                                              University hospital sites
                                                                                                              and will provide support
                                                         •   Increased Out of Hours                           and accept referrals for
                                                             capacity to assess CYP                           CYP presenting with a
                                                             mental health needs through                      mental health crisis at A&E,
                                                             the A&E                                          CDU, UCC, paediatric             Q2 2018
                                                                                                              wards and Health Based
                                                                                                              Places of Safety (HBPoS)
                                                         •   The agreed staffing                              outside of working hours.
                                                             establishment to support the
                                                             service across the three
                                                             boroughs is detailed below:

                                                             Consultant Psychiatrist
                                                             Band 8a Clinical Lead
                                                             (1 wte)
                                                             Band 7 Clinical Staff
                                                             (2.5 wte)

      CQC Action Plan v6

•   The service is to be fully
                                                              operational from the hours of
                                                              4pm to 12midnight Monday
                                                              to Sunday including bank
                                                              holidays, with daytime
                                                              specialist CAMHS team crisis
                                                              response remaining in place
                                                              from Monday to Friday.
2.1    Oxleas              Work with NHSE so that         •   To progress the                 Executive Lead-   Monitoring systems are          The
       CAMHS               children and young people          implementation of the South     Stephen           being set up for the whole      implementation is
                           in Bromley have timely             London Partnership New          Whitmore          CYP population in the SLP       on-going;
                           access to specialist mental        Care Model. Specifically, to    Beverley Mack     area accessing Trier 4          progress to be
                           health care close to their         monitor access to CAMHS         & Jacqui          CAMHS beds. Bromley             reviewed
                           home.                              beds for Bromley CYP to         Pointon           data will be available in due   quarterly.
                                                              ensure there is equitable                         course.
                                                              access to inpatient care.
                           ‘Leadership and                                                                      Since the programme start
                           Management: Access to                                                                (October 2017), there has
                           Tier 4 CAMHS for CYP                                                                 been a 25% increase in
                           who need in-patient or                                                               south London beds being
                           crises care is not meeting                                                           accessed by South London
                           local demand and is an                                                               CYP.
                           area for development. We
                           heard strategic plans are
                           progressing through senior
                           management to strengthen
                           the approach to CAMHS
                           tier 4, bed management
                           and out of hours’ crisis
                           response through a South
                           East London borough
                           approach. It is, however,
                           too early to assess the
                           impact of this collaborative
                           work’ (P 13, para 2.9)

      CQC Action Plan v6

3.1    Bromley CCG/        Consistent and sufficient     See recommendation 5.4
       Bromley             health presence in the
       Healthcare          MASH is available to
                           enable full contribution to
                           multi-agency decision

4.1    PRUH                PRUH IT systems in each       •   Symphony IT system to be        CP-IS project   Symphony is on target to        June 2018
                           clinical area can identify        updated in March 2018 and       lead/CP-IS      be updated in March. There
                           and      flag   vulnerable        CP-IS installed May 2018.       implementati    has been progress with the
                           children on the electronic                                        on group        Trust’s IT suppliers and
                           record.                       •   CP-IS implementation plan                       some of the issues with
                                                             includes training for staff.                    installing CP-IS overcome.
                                                             The ED child review meeting                     Staff training will start the
                                                             will monitor children flagged                   beginning of March.
                                                             by CP-IS.
4.2    PRUH                ED records are completed      •   An anomaly on the IT system
                           and    the   Trust   has          when children had been                          IT has addressed the            February
                           assurance through robust          brought into ED by                              anomaly.                         2018
                           governance arrangements.          ambulance allowed the
                                                             safeguarding screen to
                                                             remain incomplete; the ED IT
                                                             team are addressing this           ED lead
                                                             anomaly.                         Consultant
                                                                                              /Matron ED
                                                         •   The weekly ED meeting is                        The ED safeguarding
                                                             reviewing ED records and                        meeting will continue to
                                                             completing a Datix if a                         monitor the completion of       April 2018
                                                             safeguarding screen is                          records until the Symphony
                                                             incomplete. Staffs have been                    update has been
                                                             sent a reminder to complete                     completed.
4.3    PRUH                Maternity staff routinely     •   Midwives are speaking to        Safeguarding    Changes have been made          February
                           asks questions about              women about domestic              Midwife       to DV risk assessment. A         2018
                           domestic abuse                    abuse at booking, 28 weeks,                     reminder has been sent to
                           throughout the episode of         34 weeks & on completion of                     staff.
                           care and answers are              post-natal care. This will be
                           recorded and subject to           recorded on Badgernet; a red
      CQC Action Plan v6

managerial oversight as         alert will appear on the
                           per NICE guidance.              screen if this is not
                                                           completed. A records audit
                                                           will be completed in June                                                           June 2018
4.4    PRUH                Maternity staffs are        •   Bromley CSE risk
                           competent in identifying,       assessment tool will be                            CSE risk assessment has
                           recording and                   uploaded to Badgernet and                          been updated on                  February
                           safeguarding those              replace the King’s risk                            Badgernet and YP                  2018
                           experiencing or a risk of       assessment form.                                   midwives notified of the
                           CSE, CSE screening and          Completion is mandatory for                        changes.
                           risk assessment tools are       all pregnant young persons
                           on the electronic record.       under 18 years. The Young
                                                           Persons’ midwives have
                                                           been notified of these            Safeguarding
                                                           changes (they have                  Midwife        Midwives are receiving
                                                           previously undertaken                              training during their annual
                                                           enhanced CSE training).                            safeguarding update.

                                                       •   Midwives will be notified
                                                           about the changes and
                                                           training provided by the                                                            December
                                                           specialist midwife for                                                                2018
                                                           safeguarding during the
                                                           midwives annual
                                                           safeguarding update.
4.5    PRUH                Safeguarding referrals to   •   Safeguarding referrals to             Senior       The audit will be carried bi-   March 2018
                           social care are quality         social care will be audited for   clinical nurse   annually and presented to       & October
                           assured.                        quality, including the              specialist     the Trust’s Safeguarding        2018
                                                           application of BSCB               safeguarding     Children Committee.
                                                           thresholds, bi-annually and        March 2018
                                                           presented to the Trust’s            & October
                                                           Safeguarding Children                  2018
4.6    PRUH                Record keeping and IT       •   The Trust will work with the        Named          Work on IT systems and          March 2018
                           systems across Bromley          CCG to examine this                 doctor/        information sharing will be
                           health economy support          recommendation                    Named nurse      addressed with the health
                           information sharing.                                                               economy at the Health
      CQC Action Plan v6


4.7    PRUH                The Trust must ensure          •   The Trust has moved to a                       EDT are developing LEAP        March 2018
                           they       can      identify       new system for statutory and                   with the suppliers to ensure
                           practitioner attendance at         mandatory training system                      that individual practitioner
                           safeguarding        training       ‘LEAP’, the system provides                    attendance is available for
                           through robust training            data by clinical service such     Education,   analysis.
                           needs      analysis     and        as ED, paediatrics, maternity.   Development
                           compliance data.                   Midwives attend a 3 yearly        & Training
                                                              update and an annual              department
                                                              enhanced training session.

                                                          •  EDT is developing LEAP with
                                                             the suppliers to ensure that
                                                             individual practitioner
                                                             attendance is available for
5.1    Bromley             Children and young people      Paediatric liaison to be recruited   Sharon        Completed                      December
       Healthcare          who attend emergency           to                                   Smith/                                         2017
                           and urgent care are                                                 Natalie       Completed                      February
                           enabled by information         •   Access to RIO                    Warman                                         2018
                           sharing to be followed up                                                         Discussed with Sonia           May 2018
                           by the most appropriate        •   Review of the existing model                   Colwell. Individual in post
                           professional.                      to ensure that the current                     and commenced
                                                              provision promotes the most                    employment in January
                                                              effective method of                            2018.
                                                              safeguarding children
                                                                                                             To agree with service
                                                                                                             evaluation model and gap

                                                                                                             Agreed TORs with external
                                                                                                             reviewers that includes
                                                                                                             representative from the

      CQC Action Plan v6

5.4    Bromley             Consistent presence within    •   Ensure effective cover with      Natalie                                     Immediate
       Healthcare          the MASH.                         the safeguarding team            Warman

                                                         •   To Datix and escalate to the                                                 Immediate
                                                             Director if there is a                          No incidents have occurred
                                                             possibility of MASH not
                                                             having presence and monitor
                                                             incidents                                       Completed February 2018      February
                                                         •   Review activity in the MASH
                                                             of the health advisors                          Completed February 2018      February
                                                         •   Business case to be                             External review
                                                             completed for headroom                          commissioned and
                                                                                                             agreeing TORs                April 2018
                                                         •   For external review to include

5.5    Bromley             Safeguarding referrals are    •   Audit of safeguarding            Named nurse                                 April 2018
       Healthcare          quality assured                   referrals to LA                  for
                                                         •   Audit of MASH referrals                         2 audits completed           April 2018

                                                         •   Learning and outcomes
                                                             feedback to internal                                                         May 2018
                                                             safeguarding children’s
                                                                                                                                          June 2018
                                                         •   Learning and outcomes
                                                             feedback to the executive
                                                             and the board
5.6    Bromley             CLA team to set               •   To continue to work with LA      CLA team       Completed 100% achieved      December
       Healthcare          trajectories for Individual       to identify blockages in                        for Q3                         2017
                           Health Assessment (IHA)           delaying IHA’s achieving

      CQC Action Plan v6

compliance with LA                 performance for IHA

5.7     Bromley             Ensure that physical and       •   Review as part of Training      CLA team       Ongoing                       February
        Healthcare          emotional needs for                Needs Assessment (TNA) for      and learning                                  2018
                            asylum seeking children            the team                        and
                            are fully understood by                                            development
                            practitioners who              •   Source specialist                                                           March 2018
                            undertake IHA and Review           training/provider following
                            Health Assessment (RHA)            TNA                             CCG for
                                                           •   Provide training                doctor                                      March 2018
5.8     Bromley             CLA electronic record          •   For all referrals to be         CLA team       Completed                    December
        Healthcare          contains all information for       uploaded in to the child’s                                                    2017
                            pertaining to the child            record
                                                                                                              Completed                    December
                                                           •   All IHA assessments to be                                                     2017
                                                               uploaded into the child’s

5.9     Bromley             Quality assurance              •   For CLA team to have            Quality team    This will be discussed at   March 2018
        Healthcare          processes to benchmark             records reviewed as part of a                  the BHC CLA team meeting
                            IHA and RHA are                    quality assurance visit from                   on 16.01.2018
                            developed                          Quality team
                                                                                                              Findings from the thematic   March 2018
                                                           •   Audit of assessment both                       dip sampling to be
                                                               IHA and RHA to ensure that                     discussed at the CLA
                                                               quality of records meet                        health forum.
                                                               appropriate safeguarding and
                                                               records standards

5.10    Bromley             Record keeping and IT          •   ISA with Oxleas                 Natalie        Completed                    December
        Healthcare          systems support effective                                          Warman                                        2017
                            information sharing so
                            vulnerable children can be     •   ISA with GPs                                   Completed                    December
                            safeguarded                                                                                                      2017

       CQC Action Plan v6

•   Training for staff to RIO and                    Completed                         February
                                                             EMIS to enable MASH                                                                 2018
                                                             workers to view records

                                                         •   To support the work with the                     Continue to support               Ongoing
                                                             CP-IS however this is co-
                                                             ordinated by the CCG
5.11    Bromley             CLA formal supervision       •   For formal supervision to be      CLA team       Completed                        December
        Healthcare          implemented within the           documented at all times in                                                          2017
                            client records                   the clients records
                                                         •   An audit on all children
                                                             discussed in supervision                         Re-audit in 6 months
                                                             between November 2017 to
                                                             end of February 2018 and
                                                             can confirm that 100% of
                                                             supervision records were
                                                             documented within the child's

6.1     Oxleas              Children in Need             •   All HVs to be introduced to       Executive      Risks to child identified with     March
        0-4 Service         Practitioners records            Oxleas Safeguarding               Lead-          plan of intervention             /April2018
                            clearly reflect how the          Supervision model. The            Stephen        identified.
                            home environment is              child’s case record is            Whitmore
                            impacting on the wellbeing       reviewed routinely by the
                            of the child, quality            Supervisor. The ‘resilience       Jane
                            assurance of this should         model ‘of analysis will include   Downing/
                            form part of supervision         reflection on the impact of       Rachel
                            practice.                        the child’s environment.          Lanlokun
                                                             The standard record               /Annie Still
                                                              proforma to be used for                         The standard record
                                                              recording safeguarding                          proforma is already being        End of July
                                                             supervision                                      used in Safeguarding               2018
                                                                                                              Supervision with HVs. It is
                                                                                                              anticipated that compliance
                                                                                                              figures for HV supervision
                                                                                                              will have reached over 80%
                                                                                                              by end of Q4.
       CQC Action Plan v6

Audit to be undertaken July
6.2    Oxleas               The use of chronologies        •   Findings from CLAS review        Executive   Meeting with each of the 3      End April
       0 – 4 Service       and genograms is routine            to be shared at the 3 locality   Lead -      locality Teams have been         2018
                           within the health visiting.         Team meetings. This will         Stephen     set up for April 3rd 4th and
                                                               include discussion re the use    Whitmore    10th.                           Bromley
                                                               of a chronology to assist                                                     Team
                                                               analysis when there are          Jane        Recording of chronology
                                                               emerging concerns and the        Downing     can be either through be by     Blenheim
                                                               use of the genogram word         /Denise     using the significant event       Team
                                                               proforma.                        Neath       function on RiO or using a
                                                           •   Chronology format to be                      word proforma depending        Beckenham
                                                               discussed and use of the                     on the purpose of the            Team
                                                               genogram guidance.                           chronology

                           ‘Bromley health visitors do     • Genogram template to be            Jane                                       March 2018
                           not routinely use               sent to Operational Leads to         Downing/
                           chronologies or                 share with their teams. Where a      Denise
                           genograms to support their      genogram is required it will be      Neath
                           safeguarding activity. In       completed and uploaded as a
                           Oxleas, there is not a          word document.
                           consistent approach
                           across commissioned
                           health visiting services.
                           Management accept
                           routine use of chronologies
                           is an area for development
                           in health visitor services in
                           order to ensure effective
                           risk assessment and
                           oversight of a child’s

6.3    Oxleas              Children and young people           To complete recruitment and      Executive   Recruitment process is         June 2018
       CAMHS               have increased timely               implement the new CYP MH         lead-       underway and on track
                           access to specialist                Liaison service                  Stephen
                           CAMHS support and care                                               Whitmore
      CQC Action Plan v6

to assess their mental
                           health within the acute                                                 Sheena
                           setting.                                                                Gohal &
                           ‘Arrangements for children
                           presenting to the PRUH in
                           severe mental health
                           crises do not meet the
                           needs of the young
                            Children and young
                           people often wait for too
                           long for a CAMHS
                           assessment and
                           subsequent discharge or
                           transfer to a specialist
                           setting. It is reassuring that
                           the ED and the ward use
                           registered mental health
                           nurse to look after the
                           children and young people
                           when they are at their
                           most vulnerable.
6.4    Oxleas              CAMHS staffs are                 •   Oxleas Risk Assessment             Executive   The work is underway, and    End March
       CAMHS               competent in identifying             Tool and SAFEGUARD                 Lead-       will be fully completed by     2018
                           potential CSE and                    Pneumonic (Pan London              Stephen     the end of March 2018 at
                           articulating risk within             CSE Protocol) to be re-            Whitmore    which point we can agree a
                           records and on referral to           circulated to all clinicians and   Jacqui      way to test the confidence
                           children’s social care so            to be addressed in team            Pointon     of staff in this area.
                           children and young people            meetings.                                      The tool is available for
                           can be effectively                                                                  staff to use on RiO.

                           ‘CAMHS professionals
                           have started to use the
                           CSE tool to help inform
                           their assessment of risks

      CQC Action Plan v6

for the safety and
                           wellbeing of children and
                           young people but practice
                           is not yet sufficiently
                           embedded, or effectively
                           used to inform referrals to
                           children’s social care’. This
                           needs to be measurable
                           and some evidence to
                           provide assurance that this
                           is sufficiently embedded
                           and has increased the
                           number of referrals to
                           children's social care.
6.5    Oxleas              Safeguarding referrals to       •   CAMHS to implement a QA         Executive    Template to capture             End April
       CAMHS               children’s social care are          process in Bromley CAMHS        lead –       process has been                 2018
                           quality assured to support          (manager/ supervisor/senior)    Stephen      developed. Plan to
                           organisational learning and         to review all safeguarding      Whitmore     implement within the
                           a consistent standard in            referrals to CSC prior to                    service
                           meeting thresholds.                 being submitted to the MASH     Jacqui
       Oxleas              ‘Quality assurance              •   Discuss referrals at Locality   Tim Sowter   01/03/18 Guidance on how       April 2018
       AMH                 processes are to support            Team meeting with CLAS                       to make a referral to CSC
                           learning and identify trends        feedback. Referrals to be                    re- circulated to Team
                           was variable across                 reviewed by operational                                                     March 2018
                                                                                                            Leads for discussion at
                           provider services. A robust         leads but not if to do so
                           quality assurance process                                                        service meetings. Clinicians
                                                               causes delay.
                           would provide oversight of                                                       to seek advice from Leads
                           referrals and support a                                                          if necessary.
                           consistent standard to
                           better meet thresholds                                                           Existing practice of            Ongoing
                           when considering actions                                                         submitting all referrals to
                           to protect vulnerable                                                            Head of Safeguarding for
                           children and young
                                                                                                            quantitative and qualitative
                                                                                                            monitoring will continue and
                                                                                                            has been reinforced in
                                                                                                            Safeguarding Children

      CQC Action Plan v6

Policy and procedures.

       Oxleas                                             •   Guidance ‘How to make a        Ruth          01/03/18 Guidance sent to       March 2018
       AMH                                                    good referral to CSC’ to be    Ashworth      TS for circulation to Service
                                                              sent to Team managers for                    Leads
                                                              discussion at Team meetings
                                                              and resend to Safeguarding                   08/03/18 Bromley
                                                              Champions.                                   Champions forum to
                                                                                                           discuss findings from CLAS
                                                                                                           review and reinforce
                                                                                                           available help for making
                                                                                                           referrals to CSC.

6.6    Oxleas              Record keeping and IT          •   Key people in BHC and          Executive     ISA agreed and signed             January
       0-4 Service         systems across Bromley             Oxleas to be given access to   Lead -                                           2018
                           health economy support             each other’s electronic        Stephen
                           effective information              record systems EMIS and        Whitmore
                           sharing; appropriate               RIO
                           flagging / alerts; access to   •   Information sharing            Jane
                           safeguarding records and           agreement between Oxleas       Downing
                           multi-agency plans so              and BHC to be agreed and       Julie Lucas                                   March 2018
                           vulnerable children are            signed off by both agencies.   and BHC                                         Training
                           highly visible and can be                                         Natalie                                       dates have
                           safeguarded.                                                      Warman                                        been set up
                                                                                                                                           in February
                           ‘We heard of a number of                                                                                            2018
                           IT systems incompatibility
                           across Bromley. It is
                           recognised through
                           serious case reviews this
                           can lead to barriers in        •   Training on Rio and
                           timely sharing or access to        authorised access to be        Jane          Lawful and timely
                           information.                       completed                      Downing       information sharing BHC         End of March
                           Practitioners who need to      •   BHC access to Rio.             /Lorraine     Safeguarding Team                  2018
                           work together do not have      •   Oxleas access to EMIS.         Thomas        includes LAC and MASH
                           access to the each other’s     •   Complete staff training and    Natalie
                           client record. Examples            documentation.                 Warman,
      CQC Action Plan v6

include urgent care/PRHU,                                            RiO team
                     BHC/Oxleas (MASH).
                     KCFT/Oxleas (perinatal
                     mental health).

 Oxleas              We also identified                •   Screenshots and                Jane        Dates have been agreed       HV teams to
 0-4 Service         inaccuracies in the                   guidance for completion        Downing/    with RiO team to meet with    be trained
                     flagging systems in a                 of Oxleas Safeguarding         Jacqui      HV teams to discuss          during March
                     number of services, which             Children form and              Pointon     Safeguarding forms on            2018
                     reduces practitioner’s                flagging system to be                      RiO
                     abilities to work in                  circulated to all                                                          MASH
                     partnership with statutory            practitioners.                                                             Health
                     agencies in the care of the                                                                                   professional
                     child. The CCG and                                                                                            trained Jan
                     provider organisation                                                                                             2018
                     recognise the challenges
                     and some work has taken
                     place to mitigate risk’.

 CAMHS                                             •   Screenshots and guidance           Jane        The above training package    End March
                                                       for completion of Oxleas           Downing/    to be made available to         2018
                                                       Safeguarding Children form         Jacqui      CAMHS practitioners.
                                                       and flagging system to be          Pointon
                                                       circulated to all practitioners.

                                                   •   Internal changes to CAMHS          Executive   This work is underway and     End March
                                                       pathway so that all referrals      Lead-       on track                        2018
                                                       are accepted and the first         Stephen
                                                       appointment identifies and         Whitmore.
                                                       agrees treatment pathway for       Jacqui
                                                       CYP / family.                      Pointon

CQC Action Plan v6

7.1    Oxleas              Oxleas and Kings College      •   Meeting to be arranged          Estelle Frost   Perinatal Mental Health and   End of March
       AMH                 Hospital                          between Kings College           Tim Sowter      AMH services to review           2018
                           Care records are shared           Midwifery service, Perinatal                    current information sharing
                           appropriately so that             Mental Health and AMH           Specialist      pathways by the
                           practitioners from both           services to review current      Midwife
                           organisations are able to         information sharing             PRUH
                           offer a co-ordinated              pathways.
                           approach to care and
                           management of risk.
                           ‘The lack of shared IT
                           means that midwives and
                           adult mental health
                           practitioners are unable to
                           access patient records of
                           expectant women that both
                           services are working with.
                           It is important that
                           vulnerable expectant
                           women with mental
                           concerns receive a co-
                           ordinated approach to their
                           care and that risk is
                           managed appropriately’.
8.1    Oxleas              CAMHS and Bromley Y           •   Develop with the Wellbeing      Executive       This work is underway and     End March
       CAMHS               ensure the process and            Service and implement a         Lead-           on track                      2018
                           quality of information            shared referral form for CYP    Stephen
                           sharing at point of               progressing from the            Whitmore
                           handover consistently             Wellbeing Service to            Jacqui
                           meets the child’s needs.          Specialist CAMHS                Pointon

                           ‘Care pathways between
                           Bromley Community
                           Health and Wellbeing
                           service (Bromley Y) and
                           CAMHS remain an area
                           for development. Current      •   Internal changes to CAMHS       Executive       This work is underway and     End March
                           arrangements do not               pathway so that all referrals   Lead-           on track                      2018
                           consistently support a            are accepted and the first      Stephen

      CQC Action Plan v6

smooth and timely              appointment identifies and     Whitmore
                     response for children and      agrees treatment pathway for   Jacqui
                     young people with more         CYP / family.                  Pointon
                     complex/longer term
                     needs. New arrangements
                     for strengthening handover
                     to CAMHS tier 3 are still
                     being embedded and
                     referral seen did not
                     demonstrate consistent
                     use of the referral form, or
                     evidence it is being used
                     to best effect. We saw
                     examples of requests for
                     additional information
                     being needed to support
                     decision making and
                     identify the appropriate
                     treatment pathways, this
                     can then impact on the
                     timeliness of the child or
                     young person accessing
                     the right care at the right
                     time’. (Page 14 para 2.11).

CQC Action Plan v6

London Borough of Bromley Public Health Services Combined CQC Action Plan February 2018
Recommendation 6.1 Children in Need
Practitioners records clearly reflect how the home environment is impacting on the wellbeing of the child, quality assurance of this should form part of
supervision practice.
‘Assessments of a child’s home environment and their safety carried out by health visitors are not always robust. Case records seen demonstrated that
practitioners concerns did not always articulate strongly enough the impact of the home environment on the child or reflect the child’s voice. Recording of the
information can assist the practitioner to identify emerging or existing signs of neglect’.
Ref        0-4           Action                                            Executiv     Operatio    Comple Evidence            Progress       Outcome
           Universal                                                       e lead       nal lead    tion
           Service                                                                                  date
6.1        0-4           All HVs to be introduced to Oxleas                Stephen Jane             March Q4 HV
           Service       Safeguarding Supervision model. The               Whitemo Downing          2018   supervision
                         child’s case record is reviewed routinely         re      /Denise                 compliance
                         by Supervisor.The ‘resilience model ‘ of                  Neath                   fiqures.
                         analysis will include reflection on the
                         impact of the child’s environment.
                         Standard record proforma to be used.

                         Sample of records will be audited to                           Denise      July       Record
                         ensure information on home environment                         Neath       2018       keeping
                         is recorded in all records                                                            audit.
Recommendation 6.2
The use of chronologies and genograms is routine within the health visiting
‘Bromley health visitors do not routinely use chronologies or genograms to support their safeguarding activity. In Oxleas, there is not a consistent approach
across commissioned health visiting services. Management accept routine use of chronologies is an area for development in health visitor services in order to
ensure effective risk assessment and oversight of a child’s vulnerability’.
Ref        0-4           Action                                            Executiv     Operatio    Completion           Evidence     Progress     Outcome
           Universal                                                       e lead       nal lead    date
6.2        0-4           Findings from CLAS review to be shared at         Stephen Jane             May 2018             Minutes
           Service       the 3 locality Team meetings. This will           Whitemo Downing                               of
                         include discussion re the use of a                re      /Denise          Bromley team 7th     meetings
                         chronology to assist analysis when there                  Neath            March
                         are emerging concerns.                                    and                                   Genogra
London Borough of Bromley Public Health Services Combined CQC Action Plan February 2018
                         Chronology format to be discussed and                          Operatio Bleinheim Team           m
                         use of the genogram guidance                                   nal Leads 13 March                template

                         Genogram template to be sent to                                             Beckenham
                                                                                                     Team TBC
                         Operational Leads to share with their
                         teams. Where a genogram is required it
                         will be completed and uploaded as a word
Recommendation 6.6
Record keeping and IT systems across Bromley health economy support effective information sharing; appropriate flagging / alerts; access to safeguarding
records and multi-agency plans so vulnerable children are highly visible and can be safeguarded
‘We heard of a number of IT system incompatibility across Bromley. It is recognised through serious case reviews this can lead to barriers in timely sharing or
access to information. Practitioners who need to work together do not have access to the each other’s client record. Examples include urgent care/PRHU,
BHC/Oxleas (MASH). KCFT/Oxleas (perinatal mental health). We also identified inaccuracies in the flagging systems in a number of services, which reduces
practitioner’s abilities to work in partnership with statutory agencies in the care of the child. The CCG and provider organisation recognise the challenges and
some work has taken place to mitigate risk’.
Ref        0-4           Action                                            Executiv     Operational        Completion      Evidence        Progres Outcom
           Universal                                                       e lead       lead               date                            s       e

6.6        0-4           Key people in BHC and Oxleas to be given          Stephen      Maria Tanner       March 2018
           Service       access to each other’s electronic record          Whitemo      /Rachel
                                                                                        Lanlokun/ Jane
                         systems EMIS and RIO                              re           Downing

                         Information Sharing agreement between                          Julie Lucas/Jane   January 2018    ISA             Comple
                         Oxleas and BHC to be agreed and signed                         Downing/ Maria                     Document        te
                         off by both agencies                                           Tanner

                         BHC access to RiO                                              Jane               January 2018    Evidence of     Comple
                                                                                        Downing                            access via
                         Complete staff training and                                                                       sponsorship
                         documentation                                                                                     weekly
London Borough of Bromley Public Health Services Combined CQC Action Plan February 2018
                          Oxleas Access to EMIS                                        Jane             March 2018
                          Training and documentation to be                             Downing          Training dates
                          completed                                                                     set up in
                                                                                                        February 2018
                                                                                                        MASH Health
                                                                                                        Trained Jan

6.6       0-4             Screenshots and guidance for completion                      Jane             March 2018
          service         of Oxleas Safeguarding Children form and                     Downing
          and             flagging system to be circulated to all                      /Jacqui
          CAMHS           practitioners.                                               Pointon/
                                                                                       Denise Neath
Recommendation 6.5
Safeguarding referrals to children’s social care are quality assured to support organisational learning and a consistent standard in meeting thresholds.
‘Quality assurance processes to support learning and identify trends was variable across provider services. A robust quality assurance process would provide
oversight of referrals and support a consistent standard to better meet thresholds when considering actions to protect vulnerable children and young people’.

Ref       0-4 universal      Action                      Executive     Operational          Completion        Evidence        Progress      Outcome
          service                                        lead          lead                 date

6.5       0 – 4 Service      Discuss referrals at        Stephen       Denise Neath         End March
                             Locality Team meeting       Whitmore                           2018
                             with CLAS feedback.                                            Dates as per
                             Referrals to be                                                R6.6
                             reviewed by
                             operational leads but
                             not if to do so causes
London Borough of Bromley Public Health Services Combined CQC Action Plan February 2018
BHC CQC Action Plan for safeguarding February 2018

Recommendation           Actions                                               Person responsible   Time frame      Updated progress
BHC work with the LA      To continue to work with LA and The Home             Felicity Akers and   March 2018
to ensure that the       Educated Team, identifying home educated              Sharon Smith
Health Support for       children.
Schools Service (HSSS)
have access to data on   Named safeguarding nurse to work with LA with                              Ongoing         Continue to support
home educated            currently known children.
                         Once data is identified, work on a joint process in                        March 2018
                         which this data is shared monthly and monitor
                         the number of children.

                        A business case model has evolved from LA.                                  March 2018
                        Waiting approval from CCG to recruit staff to
                        support home educated children until March
                        2019 when the contract ends.
BHC work with the LA Work with LA to inform processes implemented              Felicity Akers and   March 2018
to ensure that Health   through our Care                                       Sharon Smith
support for schools are Co-ordination Centre, to ensure input from all
able to input into      relevant children’s service into EHCP. This will
children’s EHCP         include HSSS.
The HSSS are routinely Ensure schools and social care are informed of          Felicity Akers and   March 2018
informed of children    the criteria to refer to HSSS where children have a    Sharon Smith
and young people with known, unmet health need.
additional needs and
vulnerability so any    This has been discussed with David Dare, Head of
on-going care and       Safeguarding and the Children’s Disability Service                          February 2018   Completed
safeguarding concerns at LBB.
can be addressed by
the HSSS                It is suggested that Social Workers allocated to                            Ongoing
London Borough of Bromley Public Health Services Combined CQC Action Plan February 2018
                       the families, would send invitations to the HSSS
                       safeguarding email
                       address, BROMH.SNSafeguarding@nhs.net which
                       would identify the families to the service.

                       Referral rates to be measured.

                       Liaise with safeguarding advisors, to identify
                       possible cases where children may have required                    March 2018
                       HSSS and were missed and lessons learnt from
                       cases missed.                                                      Ongoing
London Borough of Bromley Public Health Services Combined CQC Action Plan February 2018
CGL Action Plan

Recommendation        Action                                                  Exec    Operati    Completion    Evidence                    Outcome
                                                                              utive   onal       date
                                                                              lead    lead
9.1 Work with the     9.1 CGL services are arranging to meet with             Servi David        Currently     Contract monitoring         Recomme
local authority MAP   Beverley Brown (Chair of the MAP) by end Feb 18,        ce    Dunkle       ongoing       report                      ndations
to enhance            to discuss partnership work - including attending       Man y              with                                      will be
information sharing   the MAPs in 2018. CGL will attend the MAP to do a       ager               completion                                shared
for young people      presentation on the service to further strengthen                          date by end                               with the
who are at risk by    the knowledge and understanding of the service                             of April                                  teams and
developing and        with other professionals who attend the MAP. Will                                                                    incorporat
embedding a formal    also set up a referral pathway between the                                                                           ed into
communication         services.                                                                                                            this plan
pathway                                                                                                                                    as well as
                      The YP and adults service are linked with local                                                                      our
                      authority safeguarding services. To re-enforce                                                                       safeguardi
                      referral pathways the following actions will take                                                                    ng
                      place:                                                                                                               procedure
                      Presentations to the local safeguarding teams to
                      take place with follow up meetings annually.

                      An initial meeting and presentation has been
                      delivered to the ATLAS team by DD. A follow up
                      meeting to discuss partnership working and
                      referral pathways with both YP and Adults service
                      to be arranged within 12 weeks.
Safeguarding          9.2 All referrals to social care are to be checked by   Servi   DD         Currently     To be discussed in
referrals to          the services’ Safeguarding Leads to make sure they      ce      (Bromley   ongoing       IGTM within both
children’s social     are consistent and they are quality assured in          Man     Changes)   within        services to highlight the
care are quality      meeting current thresholds.                             ager    and AL     service.      good practice currently
assured to support                                                                                             taking place between
London Borough of Bromley Public Health Services Combined CQC Action Plan February 2018
organisational                                                                Drug and                 both services.
learning and a                                                                Alcohol
consistent standard                                                                                    Quarterly audit by
in meeting                                                                                             safeguarding leads to
thresholds.                                                                                            monitor compliance
The electronic        9.3 All BDAS staff will be informed to upload    Servi Service      Within two   Team meeting minutes,
record is a           documents and cross reference to corresponding   ce    manag        weeks of     supervisions, Inter-
comprehensive         case notes onto the CRIIS case management        Man er             CQC report   Governance meeting.
composite of          system; this will be communicated to the staff   ager               receipt.     An audit will take place
information           through team meetings, individual supervision                                    by the Safeguarding
including             sessions and Information Governance Team                                         Lead (quarterly) to
documents that        Meeting.                                                                         make sure staff are
relate to the                                                                                          keeping an electronic
persons care.                                                                                          record which is a
                                                                                                       composite of
                                                                                                       information including
                                                                                                       documents that relate
                                                                                                       to the persons care. l
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