Recommendation 107

Public Health England sharing information

Accepted
If the Health Protection Agency or its successor, or the relevant local director of public health or equivalent official, becomes concerned that a provider’s management of healthcare associated infections is or may be inadequate to provide sufficient protection of patients or public safety, they should immediately inform all responsible commissioners, including the relevant regional office of the NHS Commissioning Board, the Care Quality Commission and, where relevant, Monitor, of those concerns. Sharing of such information should not be regarded as an action of last resort. It should review its procedures to ensure clarity of responsibility for taking this action.

Public Health England is reviewing its governance framework which underpins its responsibilities (in partnership with local, regional and national partners) for sharing and escalating concerns. As part of this work and as new structures emerge, Public Health England is revisiting and updating its internal operational guidelines, which provide a standardised risk-based approach within the framework, for its regional centres. This work formalises the process whereby Public Health England internally escalates, and informs local and national commissioners and regulators about, any concerns they might have regarding the management of Healthcare Associated Infection-related risks linked with health and adult social care providers (e.g. during outbreaks and incidents of infectious diseases).

A peer support toolkit, previously developed by the Health Protection Agency (whose functions were transferred into Public Health England from 1 April 2013), is also under review. The toolkit clarifies the process whereby expert and peer support might be offered to, or requested by, healthcare providers. It includes recommended timelines, and the format the advice might take, as deemed appropriate for the situation.

Following discussions with the key parties outlined in this recommendation, joint draft proposals are being developed to share expertise across all the key stakeholders in relation to infection, including those that are healthcare associated. These stakeholders include the Care Quality Commission, Monitor, NHS England and the NHS Trust Development Authority.  The draft proposals strengthen current practices on information sharing among these organisations and will also establish an agreed set of principles and information flows setting out the lines of communication for sharing information where there are concerns that may require further investigation. The overarching principles and lines of communication were established in July 2013.

Update

Public Health England has been undertaking work to review and revise arrangements for the sharing of information and escalation of concerns relating to the management of healthcare associated infections by health and adult social care providers. This includes procedures for internal escalation within Public Health England and escalation to relevant external bodies, such as commissioners and regulators, both locally and nationally. This work is being undertaken within the context of an organisation-wide strategic review, which includes consideration of the management of public health priorities to ensure Public Health England can fulfil its role of leading the public health system and deliver its responsibilities in the most efficient and effective way.

Set in this context, escalation procedures have been updated and will be finally outlined within updated operational guidance for Public Health England Centres, aimed at improving the quality and consistency of the advice and support Public Health England Centres offer to provider organisations in relation to healthcare associated infections. Public Health England’s operational guidance has been re-written to reflect the changes to structures within the health and social care sector in England and to outline the requirements relating to the Antimicrobial Resistance agenda. It is currently being prepared for internal consultation with a view to publication before the end of march 2015. Public Health England’s work to update this operational guidance will be further finessed by the recommendations resulting from its own internal strategic review. This document encompasses the updated escalation algorithm and is scheduled for publication by end of March 2015. Public Health England is also considering how it will integrate proportionate expert support into the escalation process as requested or deemed necessary according to the level of concern.

Additionally, Public Health England is working to integrate this approach into a high-level overview of the escalation steps in relation to sharing concerns about healthcare associated infections aligned to incident levels within Public Health England’s National Incident Response Plan. This work is being undertaken with partners, including the Department of Health, NHS England, the Care Quality Commission, Monitor and the NHS Trust Development Authority. Public Health England will continue to monitor the agreed ways of working between the organisations and undertake work to strengthen, these informed by any changes or recommendations arising from its strategic review.