Herefordshire Outcomes Framework: Investment in Primary Care 2018-2021 - Draft Version 0.6: Engagement and Feedback February 2018
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Herefordshire Outcomes Framework:
Investment in Primary Care
2018-2021
Draft Version 0.6: Engagement
and Feedback
February 2018
1
TABLE OF CONTENTS 1.0 Background ………………………………………………………………..3 2.0 Context ……………………………………………………………………..4 National and local Policy Framework Methodology 3.0 Framework Agreement…………………………………………………..7 Principles Contract and funding framework 4.0 Commissioning for Outcomes ………………………………………..10 4.1Framework indicators and measures……………………………..….11 COPD CVD Diabetes Mental Health Cancer Frailty Medicines Optimisation MSK Urgent Care Public Health 5.0 Contract Basis……………………………………………………………16 Contract outline Payment mechanism Payment for delivery Payment for achievement Key Performance Indicators Data Return Manual Data Return Monitoring Non Achievement of KPIs Breach of Contract Termination Disputes Standards of Practice Equality and Diversity 6.0 Appendix………………………………………………………………..…21 Signatory page Read codes/Template Clinical pathways and guidelines Resources 2
1.0 Background Herefordshire is a predominantly rural county, with the 4th lowest population density in England, although the population has risen 8% since the 2001 census from 174,900 to 188,100. Individuals aged 65 and over account for 23% of the population, including 5,900 residents aged 85 plus. By 2020 the 65-84 years old population is expected to increase by 9.4% whilst over 85 year olds population is expected to increase by 13.3%; a 0.4% drop is predicted in the 15-64 year old age group. The life expectancy in Herefordshire is 79.7 years for males and 83.7 years for females both of which are higher than the England average of 79.2 for males and 83.0 for females The highest mortality rates across Herefordshire are from cardiovascular disease, cancers, respiratory diseases and dementia. There are 7,680 years of potential life lost per annum, of which 70% were due to cancers and circulatory diseases; 30% of all mortality in Herefordshire occurs in in people under 75. There are 24 GP practices across Herefordshire with 187,242 registered patients. Over 75% of patients consider the overall service from their practices as very good or fairly good, with 15 practices scoring 90% or more. Patient experience of services in GP practices in Herefordshire as a whole is 91% compared to 85% nationally. The Herefordshire Outcomes Framework: Investment in Primary Care 2018/19 replaces all previous local contracting methods such as previous Local Enhanced Services and the Local Incentive Schemes into an outcome based commissioning framework to enable primary care to utilise innovation and flexibility to meet the health population needs for Herefordshire patients. 3
2.0 Context Primary Care is an essential element of the wider health and social care system, and in developing the Herefordshire Outcomes Framework for Primary Care we have aimed to align priorities to compliment national and local plans and strategies. Key drivers that will influence the CCG and Primary Care over the next few years include: National and Local policy Five Year Forward View NHS England Five Year Forward View was published in October 2014 and sets out a vision for the future of the HHS. Developed through partnership engagement it creates a collective view of how the health service needs to change over the next five years if it is to reduce the inequalities in the health of the population, quality of care and the funding of services. Priority areas include; prevention, self-care, mental health, removing barriers to care (including across organisations), redesign of urgent care and an acknowledgement that England is too diverse for a ‘one size fits all’ solution. GP Forward View NHS England is investing £500 million in a national sustainability and transformation package to support GP practices, which includes additional funds from the clinical commissioning group (CCGs). It includes help for struggling practices, plans to reduce workload, expansion of a wider workforce, investment in technology and estates and a national development programme to speed up transformation of services. They have committed to an increase in investment to support general practice over the next five years. 4
The plan was developed with the Royal College of General Practitioners (RCGP) and Health
Education England (HEE) and contains over 80 specific, practical and funded steps to:
channel investment
grow and develop the workforce
streamline the workload
improve infrastructure
and support practices to redesign their services to patients
GPFV Funding:
It is estimated, the additional investment in respect of the GPFV Programme across
Herefordshire will be circa £6.8m over a three year period which commenced April 2016.
This represents an additional £36 per head of population investment.
In Summary:
Herefordshire and Worcestershire Sustainability and Transformation Plan
The Herefordshire and Worcestershire Transformation Partnership published the STP plan in
July 2017 following a period of consultation detailing how healthcare services would need to be
delivered over the next five years.
The Primary Care priorities in the plan are:
5 Prioritise investment to ensure delivery of the General Practice Forward View –
developing primary care at scale “bottom-up” with practices, community pharmacy, third
sector and health and care services.
Redesign the primary care workforce, sharing resources across primary and secondary
care to provide resilience and sustainability as well as capacity.
Adopt an anticipatory model of provision – with proactive identification, case
management and an MDT approach for those at risk of ill-health.
Share information across practices and other providers to enable seamless care.
Move to “big system management” – with real time data collection and analysis
providing the intelligence to support continuous quality improvement and demand
management.
The Strategy for Primary Care and the implementation plan for the STP Primary Care work
stream will be delivered through the GP Forward view plans which have been assured by NHS
England.
Framework Methodology
In understanding how to improve the health outcomes of Herefordshire residents, the CCG
uses a range of data sources to give an idea of where the opportunities may be.
NHS Right Care is a national NHS England supported programme committed to delivering the
best care to patients, making the NHS’s money go as far as possible and improving patient
outcomes. The aim is to ensure the best possible care is delivered as efficiently as possible,
which is essential for both patients and the NHS.
Ensuring people access the right care, in the right place at the right time means the NHS can
treat more people effectively, now and in the future. It’s unacceptable to see inconsistent
differences across the country around the type of care patients receive. NHS Right Care’s work
is core to ensuring the best possible care is delivered everywhere.
Using leading edge medical evidence and practical support helps local health economies
understand how money is spent to deliver the best care in different parts of the country.
NHS Right Care advises local health economies to:
Make the best use of their resources – by tackling over use and underuse of resources.
Understand their performance – by identifying variation between demographically
similar populations so they can adopt and implement optimal care pathways more
efficiently and effectively.
Talk together about the same things – about population healthcare rather than
organisations and encouraging joint decision-making.
Focus on areas of greatest opportunity by identifying priority programmes which offer
the best opportunities to improve healthcare for people and ensuring taxpayer money
goes as far as possible.
Use tried and tested evidence based processes to make sustainable improvement to
reduce unwarranted variation.
The CCG will use the findings of the NHS Right Care data to determine its key priorities and
areas identified for improvement for delivery through this Framework.
63.0 Framework agreement
The objectives of this framework:
To support primary care through investment to secure the sustainability of General
Practice.
Provide an opportunity for General Practice to deliver new models of patient care.
Support primary care in the delivery CCG strategic priorities.
To ensure that there is the best use of all available resources.
To reduce bureaucracy around the commissioning, service delivery, monitoring and
payment functions.
Principles
1. The Framework outcomes and measures are evidence based from sources such as,
but not exclusively to:
NICE
Quality and Outcomes Framework
Right Care
NHS Benchmarking
NHS Digital
2. The Framework is designed to be delivered by one or more of the Primary Care Home
localities.
3. The framework builds on the work already being undertaken in the Primary Care Home
localities.
4. Delivery of the outcomes should encompass a multi-disciplinary team. It is expected
that a common set of competencies and skills will be in place across the Primary Care
and Community workforce to enable the delivery of the indicators at a locality level.
5. All practices/localities will deliver services according to national and locally agreed
guidelines and policies.
6. All practices/localities will ensure that there is attendance by clinical and managerial
staff at GP/Nurse education sessions which may be held on a locality or CCG basis.
7. All future investment in Primary Care will be through the Herefordshire Outcomes
Framework for Primary Care in conjunction with the HCCG Investment Policy.
Funding and Contract Framework Funding Source
The framework agreement will run for a period of three years from April 2018 – March 2021.
The Herefordshire Outcomes Framework (HOF) will see total investment into primary care
through the HOF in 2018/19 of £1,761,230 (£8.80 per head of weighted population as at
January 2018) this includes Primary Care Home investment.
Practices will receive £7.80 per head of weighted population i.e. £1,561,230 excluding Primary
Care Home.
The table below details the sources of this investment:
7All practices will receive a summary of the payments they currently receive for their core
contract and for the HOF Investment in Primary Care funding. This information will also be
shown at locality level. See Appendix (I – to follow).
Funding the transition
3 Year Contract Year 1 Year 2 Year 3
April - October - March
September
Practice 25% of the total 25% of the total
funding for the funding for the
HOF in 2018/19 HOF in 2018/19
Locality 25% of the total 25% of the total 100% of the 100% of the
funding for the funding for the total funding for total funding for
HOF in 2018/19 HOF in 2018/19 the HOF in the HOF in
2019/20 2020/21
Year 1
The CCG has supported the implementation of the Primary Care Home localities through an
investment of £200k in 2017/18. This has enabled recruitment of key support roles for localities
and the ability to fund the time of the locality leads at key meetings and to develop locality
delivery plans.
In the first year of the framework, £200k will continue to fund Primary Care Home support from
the £3 per head GP Forward View funding that CCGs are required to make available to GP
practices.
The Locality plan
Practices will work within their Primary Care Home localities to develop a locality plan to deliver
services either on an individual practice basis or across more than one practice or on a locality
footprint.
The locality will receive the first payment, on the following basis:
8 An agreed approach as to how the funding should be invoiced – this could be to a host
practice agreed by the locality or on a fair shares basis (per registered patient) or on an
arrangement agreed and signed up to by all practices in the locality
The first payment is to support releasing key clinical and managerial staff to develop the
plan
The locality plan will need to provide detail on:
1.Service Delivery
How priorities for the locality’s population have been identified
How the outcome measures will be delivered
How services will include an integrated multi-disciplinary locality team
How clinical and administrative staff capacity will be released
2.Governance
How decisions in the locality are made
How payments are to be made
3.Planning for Year 2
Developing workforce solutions to delivering services
What could be delivered in Primary Care? Practices/localities to identify opportunities
as a result of releasing capacity through locality working of where services would be
more appropriately delivered in Primary Care
Releasing savings for reinvestment - practices/localities identifying investment through
QIPP initiatives
Years 2 and 3
The CCG will work with practices/localities in Year 1 on the indicator set for Year 2 and once
agreed each locality will be required to prepare a plan to secure the aspiration payment.
When the final framework indicators and locality plans have been agreed a contract variation
will be issued to each practice/locality.
It is expected that the process for year 3 will be the same except where national or local
direction changes. In this instance the contract will be managed in line with the Contract
chapter at 5.0
94.0 Commissioning for outcomes
Locally agreed outcomes have been developed across the Integrated Care Alliance
Patients feel:
The care & support I receive is delivered around my needs
I am entitled to a high quality service– wherever I live
I know where, how and when to access services when I
need them
If I go to the wrong place for help, I’m assisted to the right
place
I feel confident that I know what is available for me to make
the right choices to remain fit and healthy throughout my
life
I tell my story once & I have a single care plan that I own
I’m clear about my responsibilities and the responsibilities
of others
Those who need to, can access up to date information
about me to deliver care based on my preferences and
needs
My carers know where to access the support that they
need to maintain their health and wellbeing
I am happy with the services that I receive and am
confident that those who need to, know my what my care
plan means
GP practice team:
I work with my colleagues & other partners to deliver the
best care & support to the local population
I work within the area I serve, working as part of a team
with other professionals and disciplines
I can access and input into a single care record for the
people we support
I know who to go to for managerial and professional advice
I know where decisions are made about services and am
confident that my views are heard
I can access shared information and learning - to ensure
that the care I provide is safe and best practice
I am trusted and supported to do the job that I am trained
to do
I am able to do today’s work today
I am happy in my work
104.1 Framework Indicators and Measures
Indicator Indicator (and source Links to Measure Achievement Weighting
Ref reference) Outcomes Validation
COPD
1 Increase Case Finding for 1, 2, 6 Improvement Evidence of tbc
Respiratory Diseases in from Qtr. 1 to GRASP
Primary Care – utilisation of Qtr. 4 upload.
the GRASP tool.
Clinical Assessment,
recording and appropriate
management.
CVD
1 Case Finding and 1, 2, 6 Improvement Evidence of tbc
Optimising Management in from Qtr. 1 to GRASP
Atrial Fibrillation and Heart Qtr. 4 upload.
Failure utilising the GRASP
tool.
Clinical Assessment,
recording and appropriate
management
2 Management of DVT 2, 4, 6 100% of suitable Audit tbc
patients are
placed on the
appropriate
pathway
3 Case Finding and 1, 2, 6 Improvement Evidence of tbc
Optimising Management from Qtr. 1 to GRASP
Hypertension utilising the Qtr. 4 upload
GRASP tool.
Clinical Assessment,
recording and appropriately
management.
4 Management of Anti- 2, 4, 6 a.Time in EMIS search tbc
Coagulation Therapeutic
Range rolling 12
months as per
INRstar or
equivalent
equal or above
the national
11average 65%
b.Share the
NPSA warfarin
quality metrics
INRstar for
benchmarking
5 Management of Leg Ulcers 2, 4, 6 80% of patients Audit tbc
with Leg ulcers
will be healed
within 24 weeks
6 Health Checks Follow Up 1, 2, 6 Where people EMIS search tbc
attending for a
healthcheck
have a raised
blood pressure,
they are
followed up
within 4 weeks
Diabetes
1 Hypertension in Diabetes 1, 2, 6 The percentage EMIS tbc
of patients with
diabetes under
age of 60, on
the register, in
whom the last
blood pressure
reading
(measured in
preceding 12
months) is
140/80 mm HG
or less
2 National Diabetes 1, 2, 6 tbc
Prevention Programme
a.Implement processes to a.Increase EMIS
assess and identify percentage of
individuals at increased risk patients on NDH
of developing Type 2 register to meet
Diabetes and where non- local prevalence
diabetic hyperglycaemic (6.3%)
(NDH) add to NDH risk
register for annual review
b.Achieve EMIS
12b. Discuss diabetes practice pro-rata
prevention with at risk target
patients and, where eligible
and medically suitable,
referred to ‘NHS Diabetes
Prevention Programme:
Healthier You’
c.100% patients
c. Demonstrate long term invited for EMIS
decrease in Type 2 annual review
Diabetes patients and health
completing Healthier You outcome data
have annual review of added if
glycaemic status, weight attended
and cardiovascular disease
risk
Mental Health
1 Physical Health Checks for 2, 4, 6 Screening and EMIS search tbc
Severe Mental Illness physical
assessment of
60% of patients
on the SMI
register
Lester tool
assessment
2 Dementia 2, 4, 6 Where there is a EMIS search tbc
diagnosis of
mild cognitive
development –
the patient will
be recalled in 12
months
Cancer
1 Where there is a possible 2, 4, 5, 6 EMIS search tbc
diagnosis of prostate cancer
there is shared decision A reduction in
making with the patient the number of
PSA tests in
new
presentations of
patients in
primary care
Frailty
1 Frailty Management 2, 4, 5, 6 100% of EMIS tbc
patients over the Searches
age of 65 who
have been
13assessed on the
Rockwood frailty
tool.
Answer ‘Yes’ to
the ‘surprise
question’ to
have an ACP
put in place.
Medicines Optimisation
1 Shared Care 2, 4, 6 Prescribing, tbc
recall and
monitoring of Audit
shared care
medicines eg:
DMARDs in
rheumatology,
dementia
medicines
2 Medication Review by a 2, 4, 6 For patients in EMIS search tbc
pharmacist Care Homes
(Nursing)
3 Utilise digital prescribing 2, 4, 6 Utilise Scriptswitch tbc
solutions to support CCG ScriptSwitch benchmarking
Formulary & Treatment prescribing
Policy decisions support system,
working towards
CCG average
acceptance rate
Musculoskeletal
1 All trauma and orthopaedic 1, 2, 4, 6 a.100% of GP EMIS search tbc
patients will follow the MSK referrals for
pathway patients will
follow the MSK
pathway
b.100% of
patient referrals
to have BMI,
Smoking status EMIS search
and BP
embedded into
referral
Urgent Care
141 Implementation of the APEX a.Launch APEX Data tbc
tool to monitor demand and tool extraction
capacity
b.Adopt locally
agreed
measures
c. Increase
number of
appointments by
5% between 21
December 2018
– 7 January
2019
Public Health
1 To ensure that all eligible 1, 2, 6 Minimum Immform tbc
patients and all staff receive threshold 75%
a flu vaccination of all eligible
patients – to be
updated in line
with PHE/NHSE
guidance
155.0 Contract Basis
5.1 Outline
This contract will be mutually dependent upon the ‘core’ contract. This means that only
providers who currently offer services under the General Medical Services (GMS) contracts will
be able to sign up to the Framework agreement. This mutual dependency means that the
Herefordshire Outcomes Framework for Primary Care (HOF) will be exclusively commissioned
from Herefordshire’s general practices.
Participation is on a practice or locality basis and to be accepted onto the scheme it is
expected that any practice participating in the Herefordshire Outcomes Framework for Primary
Care would also be delivering all core GMS services and maintain an open list.
In circumstances where a practice is applying to formally close its list the CCG would need to
be assured, through the application process, that the practice still has capacity to provide
enhanced services and that local patients remain able to have a choice of practices with which
to register and that the application to close the list does not compromise access for patients.
We will arrange a contract with each individual practice who signs up to the framework, which
will replace any previous contractual arrangements for Local Enhanced Services and/or Local
Incentive Schemes (LIS).
We would encourage practices to take the opportunity to work collaboratively with other
practices to deliver the services on a Primary Care Home footprint. This would be entirely at
the practice’s discretion.
The contracting route used to commission these services will be via a Local Incentive Scheme.
Signing up to the contract:
Practices will be asked to opt in or out on an annual basis, with no option to change that
decision part way through the year.
An locality plan will need to be submitted outlining the plan to deliver contract
Electronic templates for practices will be issued for monitoring.
Practices will be required to return all documents to
PrimaryCare.Contracting@herefordshireccg.nhs.uk.
5.2 Payment Mechanism
Payment will be weighted via core contract capitation.
This means that each practice commissioned to provide the HOF could potentially receive the
total of £7.80 per head. These payments will be processed locally by Herefordshire CCG
finance team.
Payments will be based on the list size as of the 1st January in each year of the contract in line
with the table below:
16Payment Month Payment Period Payment To
30th April April - June 25% Practice
31st October July - Sept 25% Locality for onward
payment to practices in
line with locality
31st May Reward – prior 12 months 25% to Practices
25% Locality for onward
payment to practices in
line with locality plan
To participate in the Herefordshire Outcomes Framework practices will be required to sign up
by April 16th 2018 as payments will be made in the first month of the quarter
Payments will be made in three instalments across the year, with the third payment being
reconciliation to the amount due, based on delivery of the standards set in the HOF. This could
result in recovery by the CCG if deliverables are not achieved.
5.3 Payment for Delivery (50% of total payment)
In the first year of contract delivery, 50% of the payments will be paid to the practice/locality for:
Signing up to the HOF contract
Producing an delivery plan, which is to approved by CCG
Implementing all of the delivery requirements in the standards, which will be reviewed
by an appropriate panel to ensure appropriate standards (NOTE: delivery can be
through individual, peer, locality or federative scale).
Agreement to upload templates for collation of activity for monitoring
Agreements for quarterly remote collection of date from templates
Agreement to undertake audit where identified
5.4 Payment for achievement (up to 50% of total payment)
In the first year of contract delivery, measures are worth 50% of the total payment.
The patient list size at the start of the implementation of the framework will be used to calculate
payment
Each measure will be weighted to reflect workload and health outcome priority.
5.5 Key Performance Indicators
Key performance indictors will be assured through quantitative returns from electronic
templates and annual audits, which will be based at individual practice level.
Overall individual practice performance will be reviewed quarterly and any learning will be
feedback to practices to enable a culture of transparency.
175.6 Data Return Practices agree by signing this agreement for the CCG to have remote access to the EMIS system through EMIS enterprise for the purpose of validating payment. Quarterly EMIS enterprise searches will be undertaken remotely for data return sourced from templates. Dates will be set with prior notice for data extraction. Data will be shared quarterly with practices once data has been assured, analysed and benchmarked to highlight practice activity, and learning such as areas of good practice and improvements required. Annual audits will be given with notice and agreed formats. 5.7 Manual Data Returns In the event that the required data cannot be via an automated extraction, a manual return will be required. Practice will be notified of the requirements, and will be provided with the templates to complete. Any data required from practices must be received by the CCG in line with the agreed deadline dates. Submissions will be sense checked for completeness. If there are any omissions, it will be the responsibility of the Practice to correct and resubmit to the data return email PrimaryCare.Contracting@herefordshireccg.nhs.uk within 10 working days. Late submissions may be approved if there are extenuating circumstances. Any requests will be dealt with on an individual practice basis. Requests should be made to the data return email PrimaryCare.Contracting@herefordshireccg.nhs.uk address within one month before the CCG deadline. Late submission will only be accepted if prior approval has been granted. 5.8 Monitoring We will monitor and analyse the quarterly data submitted through EMIS enterprise. An overall report for HOF activity will be produced six monthly and sent to practices to ensure culture of collaboration and transparency. We will take into account data from other sources as part of evaluation for deliverables, such as SUS Data and GP Dashboard. Where this information is used to determine payment, practices will be advised in advance. Individual practices will be benchmarked against peers and previous practice trends. Practices will be required to keep accurate records of all aspects of HOF contract for Post Payment Verification (PPV). 5.9 Non Achievement of delivery of plan and/or KPIs Where the practice/s are deemed not to have delivered their plan or met the KPIs the CCG will seek to recover any over payment. 18
The CCG may recover the money paid by deducting an equivalent amount from any payment
payable to the GP practice.
The practice/s will be notified of their achievement status within one month of the end of the
contract period.
On notification of non-achievement and details of financial recovery, the practice/s will have 10
working days to appeal the CCG decision.
5.10 Breach of Contract
In most cases, the issue of a breach notice, application of a sanction or a move to terminate a
contract should be considered as the final stages in a process where the CCG and the practice
have endeavoured to resolve matters satisfactorily, without the need to take formal contractual
steps.
There may be occasions when a practice is unable or unwilling to change their behaviour or
remedy a situation which may then result in a direct breach of the contracted terms set out in
this document which requires immediate action.
Where a practice has been found to have breached the HOF scheme and the breach is
determined to be capable of remedy, then the CCG may issue a remedial breach notice to the
practice and the group setting out the actions which must be taken to remedy the breach.
This will include the notice period during which the steps must be taken and identify a defined
date for review.
Where the CCG is satisfied that the practice has taken the required steps to remedy the breach
within the notice period, a letter will be issued to this affect and that no further action will be
taken at this stage.
The consequences of further breaching of the PCCF agreement through repeating the previous
breach or a new breach requiring a breach notice to be issued are the application by the CCG
of certain sanctions.
5.11 Termination
Termination is a significant action to take and the CCG will have exhausted all other possible
routes to resolve the matter before applying this sanction. The following process will be
undertaken prior to moving to terminate the PCCF agreement:
5.11.1 CCG discovers an issue within the practice, such as but not exclusively:
Evidence of inappropriate referring activities or an ineffective review process
Non-compliance with pre-requisites (section xx)
Failure to respond to breach notice
Continued failure to meet requirements of PCCF agreement
5.11.2 CCG to produce report recommending termination to be shared with the practice
requesting comments.
5.11.3 Report plus comments to be presented to the Primary Care Commissioning
Committee for decision.
195.11.4 Decision made at Primary Care Commissioning Committee and termination notice
issued ceasing the agreement which should not be less than 28 days from the date
of the notice.
5.11.5 Should the practice decide to appeal the decision this will be considered via the
local disputes/resolution policy.
5.12 Disputes
Any disputes from reporting will need to be sent within 10 days to
PrimaryCare.Contracting@herefordshireccg.nhs.uk
The CCG will then follow the Local Dispute Resolution Process:
https://www.england.nhs.uk/wp-content/uploads/2015/12/joint-dispute-resolution-process-
1617.pdf
5.13 Standards of Practice
We acknowledge and support the statutory obligations for General Practitioners (GPs) and
Nurses, such as those set out in the NHS Constitution, General Medical Committee, Nursing
and Midwifery Council, Health and Care Professions Council and other regulatory bodies.
5.14 Equality and Diversity
An Equality Impact Assessment screen has been undertaken on this contract.
The CCG maintains the highest level of transparency to demonstrate that conflicts of interest
are managed in a way that cannot undermine the probity and accountability of the CCG.
Our Conflict of Interest policy is available on the CCG website;
http://www.herefordshireccg.nhs.uk/policies
Furthermore the CCG identifies, manages and records any potential or actual conflicts of
interests that may arise as part of the commissioning of healthcare for Herefordshire, which is
held in a register on the CCG website; http://www.herefordshireccg.nhs.uk/register-of-
206.0 Appendix
The final document will include:
Signatory page
HOF investment by practice and locality
EMIS Template with read codes
Clinical Pathways and guidelines
Resources
HCCG Investment Policy
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