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Annual Report and Accounts 2018/19 NHS Hammersmith and Fulham Clinical Commissioning Group

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Page 1: Annual Report and Accounts 2018/19...Annual Report and Accounts 2018/19 NHS Hammersmith and Fulham Clinical Commissioning Group 1 Performance Report ..... 4 1 Performance 1.1 Statement

Annual Report and Accounts 2018/19

NHS Hammersmith and Fulham Clinical Commissioning Group

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Performance Report ..................................................................................... 4

1 Performance overview ........................................................................................... 6 1.1 Statement from the Chair and Accountable Officer ................................................... 6

1.2 Our vision and who we are ....................................................................................... 8 1.3 How the CCG works and its activities ....................................................................... 8 1.3.1 Working in partnership with North West London CCGs ............................................ 9 1.3.2 North West London Health and Care Partnership ................................................... 9 1.4 Health of the borough ............................................................................................... 9

1.5 Achievements ........................................................................................................ 10 1.6 Priorities ................................................................................................................ 11 1.7 Key issues and risks .............................................................................................. 14

1.7.1 Issues .................................................................................................................... 14 1.7.2 Risks ..................................................................................................................... 14 1.8 Going concern ....................................................................................................... 15 1.9 Performance summary ........................................................................................... 15 1.10 How we spent your money .................................................................................... 16

2 Performance analysis ............................................................................................. 17

2.1 How the CCG measures performance .................................................................... 17 2.2 Development and performance during the year....................................................... 17

2.2.1 Financial targets .................................................................................................... 17 2.2.2 Funding allocations ............................................................................................... 18

2.2.3 Relationship and linkage of information ................................................................ 18 2.2.4 Accident and emergency (A&E) department ........................................................... 19 2.2.5 Referral to treatment (RTT) ................................................................................... 20

2.2.6 Diagnostic waiting times ........................................................................................ 21 2.2.7 Cancer waiting times ............................................................................................. 22

2.2.8 Improved Access to Psychological Therapies (IAPT) ........................................... 23 2.2.9 Dementia diagnosis............................................................................................... 25 2.2.10 Health Care Associated Infections (HCAIs) such as MRSA and C.difficile ........... 26 2.3 Social matters, human rights, anti-corruption and bribery ....................................... 27

2.4 Environmental matters including sustainable development .................................... 28 2.5 Improve quality ...................................................................................................... 28

2.5.1 Continuing Healthcare ........................................................................................... 29 2.5.2 Quality and safety monitoring and assurance ....................................................... 29 2.5.3 Clinical effectiveness ............................................................................................. 30 2.5.4 Quality assurance visits ......................................................................................... 30 2.5.5 Learning from deaths and mortality ........................................................................ 31

2.5.6 Patient safety ......................................................................................................... 31 2.5.7 Safeguarding adults and children ........................................................................... 31 2.5.8 Infection control ..................................................................................................... 32 2.5.9 Patient experience ................................................................................................. 33 2.5.10 Leadership/responsiveness (Well-led) ................................................................... 33

2.6 Patient and public engagement.............................................................................. 34 2.7 Reducing health inequality ..................................................................................... 35

2.8 Health and wellbeing strategy ................................................................................ 36

Accountability Report ................................................................................ 38

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Corporate Governance Report ....................................................................................... 40 3 Members’ Report .................................................................................................. 40 3.1 Member profiles .................................................................................................... 40 3.2 Member practices ................................................................................................. 40 3.3 Composition of Governing Body ........................................................................... 41

3.4 Committees, including Audit Committee ............................................................... 42 3.5 Register of Interests .............................................................................................. 43 3.6 Raising concerns – whistleblowing arrangements ................................................ 43 3.7 Personal data related incidents ............................................................................. 43 3.8 Statement of Disclosure to Auditors ...................................................................... 43

3.9 Modern Slavery Act ............................................................................................... 43

4. Statement of the Accountable Officer’s Responsibilities ................................ 44

5. Governance Statement ...................................................................................... 46 5.1 Introduction and context ....................................................................................... 46 5.2 Scope of responsibility ......................................................................................... 46 5.3 Governance arrangements and effectiveness ...................................................... 46 5.3.1 CCG constitution and structure ............................................................................ 47

5.3.2 Governing Body.................................................................................................... 48 5.3.3 Audit Committee .................................................................................................. 50

5.3.4 Other Governing Body Committees ..................................................................... 53 5.3.5 Joint committees with delegated decision making authority .................................. 60

5.3.6 Other Joint Committees ........................................................................................ 68 5.4 UK Corporate Governance Code ......................................................................... 69

5.5 Discharge of statutory functions ........................................................................... 69 5.6 Risk management arrangements and effectiveness............................................. 69 5.6.1 Risk management strategy ................................................................................... 69

5.6.2 Capacity to handle risk ......................................................................................... 73 5.6.3 Risk assessment .................................................................................................. 73

5.7 Other sources of assurance ................................................................................. 75 5.7.1 Internal Control Framework ................................................................................. 75

5.7.2 Annual audit of conflicts of interest management ................................................ 76 5.7.3 Data quality .......................................................................................................... 77

5.7.4 Information Governance ...................................................................................... 77 5.7.5 Business critical models ....................................................................................... 78 5.7.6 Third party assurances ........................................................................................ 78 5.7.7 Joint Health and Safety Committee ..................................................................... 78 5.7.8 Freedom of Information (FOI) .............................................................................. 79

5.7.9 Emergency preparedness resilience and response .............................................. 79 5.8 Control issues....................................................................................................... 80 5.9 Review of economy, efficiency and effectiveness of the use of resources ........... 80 5.9.1 Financial planning and in-year performance monitoring ...................................... 81 5.9.2 Delegation of functions ........................................................................................ 82

5.9.3 Counter fraud arrangements ................................................................................ 82 5.10 Head of Internal Audit Opinion ............................................................................. 83

5.11 Review of the effectiveness of governance, risk management and internal control .............................................................................................................................. 88

5.12 Conclusion ........................................................................................................... 88

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Remuneration and Staff Report ...................................................................................... 89 6 Remuneration Report ............................................................................................ 89 6.1 Remuneration Committee ..................................................................................... 89 6.2 Policy on the remuneration of senior managers .................................................... 90 6.2.1 Chair and clinical directors .................................................................................... 90

6.2.2 Lay and associate lay members ............................................................................ 91 6.2.3 Executive directors ................................................................................................ 92 6.2.4 Executive directors pay awards ............................................................................ 92 6.3 Remuneration of very senior managers ................................................................ 93 6.4 Senior managers remuneration (salary and pension entitlements) ....................... 93

6.4.1 Senior managers definition ................................................................................... 93

6.4.2 Senior managers: salaries and allowances (has been subject to audit) ................ 94

6.4.3 Senior managers: salaries and allowances – joint appointments (has been subject to audit) ................................................................................................................. 95

6.4.4 Senior managers: pension benefits (has been subject to audit) ............................ 99 6.5 Compensation on early retirement or for loss of office (has been subject to audit)

............................................................................................................................ 101

6.6 Payments to past senior managers (has been subject to audit) .......................... 101 6.7 Fair pay disclosure (has been subject to audit) ................................................... 101

7. Staff Report ........................................................................................................ 102 7.1 Number of senior managers by band .................................................................. 102

7.2 Staff numbers and costs (has been subject to audit) ........................................... 102

7.3 Staff composition ................................................................................................ 104

7.4 Staff sickness absence and ill health requirements............................................. 104 7.5 Staff policies ........................................................................................................ 104

7.5.1 Equality and diversity .......................................................................................... 105 7.6 Other employee matters ...................................................................................... 105 7.7 Expenditure on consultancy ................................................................................ 106

7.8 Off-payroll engagements ..................................................................................... 106 7.9 Exit packages agreed during the year (has been subject to audit) ...................... 108

8. Parliamentary Accountability and Audit Report ............................................. 109

Independent Auditor’s Report and Financial Statements .......................................... 110

9. Independent Auditor’s Report and Financial Statements ............................. 112

10. Financial statements ......................................................................................... 117

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Performance Report The NHS Hammersmith and Fulham Clinical Commissioning Group Performance Report comprises of the:

• Performance overview • Performance analysis

Mark Easton Accountable Officer NHS Brent, Central London, Ealing, Hammersmith and Fulham, Harrow, Hillingdon, Hounslow and West London Clinical Commissioning Groups

Date: 24 May 2019

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1 Performance overview

1.1 Statement from the Chair and Accountable Officer

Introduction 2018/19 has been a year of achievement and challenge for Hammersmith and Fulham Clinical Commissioning Group. Achievement in that we continue to deliver well against all national performance measures and we are making good progress in delivering an ever wider range of services in new and innovate ways. Challenge in that demands on NHS services are continuing to rise against a challenging financial position. The decisions we make about health services are also based on the feedback we get from local people, patient experiences, and the involvement of local people on our committees and on our Governing Body. We want people to feel they are being listened to and that they can make a valuable contribution in setting and meeting the health priorities for Hammersmith and Fulham. Some of these achievements have been delivered locally and some have been delivered in partnership with our colleagues and partners across North West London.

A new Employment and Wellbeing Service for Hammersmith and Fulham launched in October 2018 - this is an exciting new service run by Richmond Fellowship that offers structured employment support, befriending, peer support and signposting and navigation to people with mental health problems in the borough.

We have extended our community respiratory service and re-designed our specialist community heart failure service with Imperial College Healthcare Trust – the community heart failure service is made up of a multi-disciplinary team consisting of psychology, heart failure consultants and specialist heart failure nurses to provide care in the community to patients with heart failure.

The NHS and its partners have a long history of working together in NW London and the eight Clinical Commissioning Groups (CCGs) and this year we progressed this further with a single leadership structure and the development of a Joint Committee on NW London CCGs, as there are some decisions which are better taken together, once. The NHS in NW London wants to reduce variation in patient care and experience no matter where you live in the region. There are some issues and challenges which cross borough and CCG boundaries and which are more effectively planned and commissioned across multiple boroughs. The Joint Committee is held in public so anyone is welcome to attend and there is an opportunity for members of the public to ask questions. The NHS Long Term Plan was published by NHS England on 7 January 2019. The plan describes how it aims to save almost half a million lives, stop 85,000 premature deaths each year, prevent 150,000 heart attacks, strokes and dementia cases, give mental health help to 345,000 more children and young people, and create a “digital front door” into NHS services through cutting edge technology. This aligns with the work we have been doing in North West London to refresh the strategy of the partnership, and to develop integrated ways of working at both borough and STP

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level. All parts of the country are expected to produce a local version of the plan by the autumn of 2019, and we will take the opportunity to ensure our strategy reflects the ambition of the NHS Plan, and to this end we will be engaging with our public and partners over the coming months as we develop the next stage of our thinking. We are looking at an approach based on co-production with Healthwatch, lay partners, NHS providers and local authorities. The NHS Long Term Plan also talks about developing an Integrated Care System (ICS) by April 2021, with typically a single CCG for each ICS area and building on the work we have done developing the Joint Committee, we have agreed to explore the implications of a single CCG, with the aim of coming up with some recommendations that we can test with stakeholders later in the year. We are clear that the issue of CCG configuration cannot be looked at in isolation and in parallel we will need to look at the development of borough-based integrated care partnerships that maintain the relationship between the local NHS (both provider and commissioner) and other important local partners. Most of what we do will continue to be implemented at a borough level and our relationships with local authorities, voluntary sector organisations, Healthwatch and other partners will be as important as ever. This is reinforced by the messages in the new GP contract which describe the development of primary care networks as an essential building block of integrated care. We spend much of our time talking to staff, the GP membership, our partners and the wider community. We continue to be impressed with the commitment shown to the values of the NHS and their wish to deliver the best health services they can for local residents and we thank them for this.

Dr Tim Spicer Chair NHS Hammersmith and Fulham Clinical Commissioning Group

Mark Easton Accountable Officer NHS Brent, Central London, Ealing, Hammersmith and Fulham, Harrow, Hillingdon, Hounslow and West London Clinical Commissioning Groups

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1.2 Our vision and who we are

NHS Hammersmith and Fulham Clinical Commissioning Group (CCG) is a clinically-led organisation. We plan, buy and monitor a range of local health services in Hammersmith and Fulham, a process called commissioning. This involves assessing local needs, deciding priorities and strategies, and then buying services on behalf of the population from providers such as hospitals, clinics and community health bodies. These include:

primary care services

most planned hospital care

rehabilitative care

urgent and emergency care (including out-of-hours)

most community health services

mental health and learning disability services. Patients are at the heart of everything we do in Hammersmith and Fulham CCG. Our vision is to give every child and family the best start and continue to support people to live healthy lives, make sure there is care and support when needed and if you do need to be in hospital, we want patients to receive high quality care and spend the appropriate time there.

1.3 How the CCG works and its activities The CCG brings together 29 local GP practices, other health professionals and serves a registered patient population of 231,004. We make decisions about health services based on the feedback we receive from patients and carers, patient experiences, and the involvement of local people on our committees and Governing Body. This ensures the services we purchase and re-design are those services Hammersmith and Fulham residents tell us they need. Please visit our website for more information about NHS Hammersmith and Fulham CCG and the work it does, including our constitution.

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1.3.1 Working in partnership with North West London CCGs

The eight Clinical Commissioning Groups in NW London (Brent, Harrow, Hillingdon, Central London, West London, Hammersmith and Fulham, Hounslow and Ealing) operate under a single leadership structure and the new Accountable Officer, Mark Easton, took up his post on 1 June 2018. We work together on a range of programmes to improve the quality of health services and share a number of support services to help deliver effective and efficient commissioning. Whilst CCGs will continue as the sovereign statutory body, making decisions and commissioning services which are specific to their local area, we have now taken this further with the development of a Joint Committee of the CCGs that will allow us to look at issues and challenges which cross borough and CCG boundaries and which are more effectively planned and commissioned across a wider area. A good example is acute care, where we are commissioning from hospitals which serve many boroughs.

Find out more about the Joint Committee.

1.3.2 North West London Health and Care Partnership The NW London health and care partnership is made up of over 30 NHS and local authority organisations. Between us, we plan, buy and provide health and care services for more than two million local residents across eight boroughs, spending around £4bn per year and have come together to develop and improve healthcare in NW London through our joint health and care partnership. A joint strategy was published in October 2016 and we continue to work with local people and organisations as we implement those improvements.

1.4 Health of the borough

A comprehensive picture of Hammersmith and Fulham’s health is captured in the Joint Strategic Needs Assessment (JSNA) by Hammersmith and Fulham Council. What follows in this section is based on the highlights of this assessment: The aim of Hammersmith and Fulham’s JSNA is to identify the inequalities in health and wellbeing and other associated factors in Hammersmith and Fulham . Strategies and action plans are aimed at addressing such issues to improve the lives of people who live in the borough.

The estimated Hammersmith and Fulham resident population in 2016 was 180,500.

There is a high proportion of older working age adults (the 6th highest in London) and a smaller proportion of children (the 6th smallest in London).

33.9% of the resident population is from Black, Asian or other minority ethnicity (BAME) groups. The percentage from a white ethnic background is 66.1%.

77.3% of the resident population speak English as their main language compared to 78% in London and 92% in England.

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Hammersmith and Fulham is ranked 84 out of 326 districts in England using the 2015 Index of Multiple Deprivation (IMD), where the first score relates to the most deprived district.

Men living in the least deprived areas live nearly 10 years longer than men living in the most deprived areas. For women this gap is 3 years. About 20% of Hammersmith and Fulham residents are estimated to have a common mental health disorder. 26% of people accessing a substance misuse service are also accessing a mental health service. 4% of people over the age of 65 have a recorded diagnosis of dementia.

1.5 Achievements

In the last year we have been working towards the objectives laid out in our NW London health and care plan as we aim to deliver quality services for our residents in Hammersmith and Fulham. We will now be looking to align our current activity with the new NHS Long Term Plan, continuing to develop integrated ways of working at both borough and CCG level. Start well

The North West London maternity team was shortlisted for ‘Team of the year’ by the Royal College of Midwives (RCM) Awards. The team was recognised for their successes which included the launch of a new app to support pregnant women to make more informed choices about where they give birth. The team has also introduced new information booklets for women during pregnancy, birth and beyond.

The 'Digital Healthy Schools Programme' was launched, a free programme that provides schools with the necessary information, support and guidance to help students and their parents explore and understand digital health. This innovative new programme harnesses the device students use most – their smart phones.

Live well

GP extended access – work continues to ensure that there are appointments available and being utilised from 8am-8pm across NW London. In January, there were over 21,000 appointments available for patients within the extended access hubs.

Diabetes Health App - over 450 patients have enrolled onto the app, supporting patients to manage their condition and a plan is in place to rapidly expand this, with over 7,000 patients being offered the use of this app via email or text message.

Treat Me Right! learning disabilities and autism awareness training programme was praised by Tulip Siddiq MP. Speaking at a Westminster Hall debate on avoiding preventable deaths for people with autism and/or learning disabilities, Tulip Siddiq MP praised the NHS in North West London for our training programme Treat Me Right! and encouraged other areas of the country to learn from our work.

Sleepio, a self-help app based on Cognitive Behavioural Therapy (CBT), launched

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in 2018. The techniques help to reset sleeping patterns naturally, without relying on sleeping pills, helping people to fall asleep faster and stay asleep through the night.

A new Employment and Wellbeing Service for Hammersmith and Fulham launched in October 2018 - this is an exciting new service run by Richmond Fellowship that offers structured employment support, befriending, peer support and signposting and navigation to people with mental health problems in the borough. If you require more information please visit their website here.

Age well

Enhanced care in care homes - ‘Is my resident well?’ - this training empowers care home staff to identify deterioration earlier resulting in residents receiving more timely care within their home. As of 31 January 2019, 853 participants have been trained in 84 care homes. The increased numbers of care home staff receiving training will encourage better care and improve understanding around key pathways between NHS services within the care home workforce.

The Home First programme helps people home form hospital, assessing patients for on-going support in their own home. This scheme has contributed to a reduction in the time older people have spent in hospital by over 5,900 days since April 2018.

We have extended our community respiratory service and re-designed our specialist community heart failure service with Imperial College Healthcare Trust – the community heart failure service is made up of a multi-disciplinary team consisting of psychology, heart failure consultants and specialist heart failure nurses to provide care in the community to patients with heart failure. As part of this work we will continue to look at innovative approaches such as tele-dermatology and using self-care apps such as myCOPD and myHeart.

1.6 Priorities

NHS Long Term Plan The NHS Long Term Plan is a new national plan for the NHS to improve the quality of patient care and health outcomes. The plan focuses on building an NHS fit for the future by:

enabling everyone to get the best start in life

helping communities to live well

helping people to age well.

The plan has been developed in partnership with frontline health and care staff, patients and

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their families will improve outcomes for major diseases, including cancer, heart disease, stroke, respiratory disease and dementia.

North West London

In NW London we work with our health and local authority partners, a collaboration of over 30 organisations. We work together to deliver a shared health and local government ambition across the Health and Care system. Throughout 2019 we will engage with our partners, staff and local communities to develop our Long Term Plan, both locally and across NW London. We are working to develop our plan by Autumn 2019. The development of our plan will be based on seven interconnected priority areas:

We have been working with our providers across NW London for some time to deliver benefits to our population through our STP, including maternity, paediatric transition, home first, and access to primary care. We are now refreshing our areas of focus to ensure it reflects what matters to our patients, and to ensure we are reducing any unnecessary variation in our care across our patch, whilst delivering the priorities set out in the Long Term Plan. Our proposed areas of focus are:

Healthy communities and prevention Maternity, children and young people Primary, social and community care Urgent and emergency care Mental health Cancer care Hospital and specialist care

The national plan is already based on a period of NHS engagement with over 3.5 million people from all around the country. But the engagement with the public isn’t over yet. NHS North West London CCGs will now be having a series of conversations with people who live in North West London about the local detail of our plans, and about how what we’re doing will benefit residents and their families.

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One of the ways people will be able to get involved will be through our soon-to-be-launched Citizens’ Panel, a new democratic platform through which 4,000 members of the public will broadly represent the demographic make-up of our community. The panel can share their view on the local NHS and influence our decision-making. We will also be working closely with Healthwatch and other community and voluntary sector partners as well as, of course, engaging with patients regularly through all our usual channels. It is also our intention to co-produce our engagement plan with Healthwatch, our integrated lay partner group and partners in the NHS and local authorities. We have been working with the five Healthwatch organisations and lay partners to develop an outline approach, which we will work through with these and other partners in immediate future.

Once we’ve heard from residents about how they’d like us to make these plans a reality in North West London we will be publishing our local plan for 2019-20 this year, followed by our full plan covering the next five years. We look forward to hearing not only from our residents, but also from NHS colleagues so that we can all improve our health and social care system together.

However, some of the areas we know we will be focusing on at either a NW London or CCG area include:

Building on the success of the High Intensity User service pilot based at Charing Cross Hospital emergency department, the CCG will fund the Social Prescription Lead to continue to help High Intensity Users to live well, and reduce emergency service attendances. High Intensity Users are those who frequently use urgent and emergency services such as 999 and A&E. The Social Prescription Lead looks at the needs of each person and helps to refer them to a wide range of voluntary and community services, such as gardening support groups, art therapy and befriending. The role will be extended to work more with GP practices.

The CCG will continue to work with its partners in the Integrated Care Partnership to support our frail older people through developing integrated services which are pro-active in their approach. We will also continue to develop services for our patients who live in local care homes.

The CCG intends to work with its partners through the Integrated Care Partnership to improve its local rapid response service (called the Community Independence Service) and to ensure this is working closely with our GP networks.

In 2019/20 we plan to work with other organisations including the Local Authority and West London NHS Trust to design a new accommodation scheme which will offer enhanced housing and clinical support for people with complex needs related to their mental health. It is hoped that this will enable people to remain in Hammersmith and Fulham rather than being placed outside the borough, and will support people to regain independence and have better outcomes after hospital admissions and mental health crises.

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1.7 Key issues and risks

1.7.1 Issues

The CCG continually reviews services and how the system is working to ensure it is maximising the value and patient benefit from the money spent. In 2018/19 this was reflected in a £17.3 million QIPP (Quality, Innovation, Productivity and Prevention) programme with £9.7 million in delivery. The QIPP challenge continues to increase as we move into 2019/20 due to wider NHS financial pressures. The leads of the QIPP programmes across the 8 CCGs in NW London meet regularly to share good practice and identify new opportunities. QIPP is not just about saving money but improving patient care at the same time. For example, this year we have engaged a pharmacist to review patients at risk of undiagnosed atrial fibrillation in GP practices and putting them on anticoagulation therapy. This avoids future stroke risks and saves on the costs of long inpatient admissions for strokes. This is better quality care for patients and saves money for the CCG.

1.7.2 Risks The CCG assessed its key risks and uncertainties throughout the year using the NW London board assurance framework and corporate risk register. The board assurance framework sets out the risks to delivering our strategic objectives and how these risks are managed. The assurance framework is presented to the Governing Body at its meetings in public, so that members can review the risks and mitigations and receive assurances that the risks are being managed. The Board Assurance Framework was also considered by the NW London Joint Committee, in public, on a monthly basis from December 2018 onward from a system perspective, allowing the Governing Body greater focus on the risks to the CCG. Further details on risk are included in the governance statement. The highest scoring risk categories (Areas of Focus) for NW London CCGs at March 2019 were: Area of focus 1: development of general practice at scale to be in a strong position to contribute to integrated care systems. Key risk - if the sustainability issues in primary care are not addressed then we may be less able to deliver quality primary care services at scale across the borough in order to meet patients’ needs. Area of focus 2: to improve outcomes for children and adults with Serious and long- term mental health needs. Key risk - serious long-term mental health needs - If we do not prioritise the spending on mental health then patients’ needs will not be met. Area of focus 3: delivery of financial sustainability. Key risk - our collective financial recovery plans lack deliverability leading to non-achievement of our financial control totals and a major financial challenge in 19/20.

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Area of focus 4: to support the development of a workforce that will deliver the NW London agreed areas of focus towards new models of integrated care. Key risk - there is a system risk around alignment between existing workforce capacity and capability to meet current and future demand to deliver new models of care and work towards integrated care partnerships.

1.8 Going concern These accounts have been prepared on a going concern basis despite the issue of a report to the Secretary of State for Health under Section 30 of the Local Audit and Accountability Act 2014. Public sector bodies are assumed to be going concerns where the continuation of the provision of a service in the future is anticipated, as evidenced by inclusion of financial provision for that service in published documents. NHS England has issued indicative resources allocations for the clinical commissioning group for the next 5 years and as services will continue to be provided the financial statements are prepared on the going concern basis.

1.9 Performance summary The CCGs full annual accounts have been prepared under a direction issued by NHS England under the National Health Service Act 2006 (as amended). NHS England has directed that the financial statements of CCGs shall meet the accounting requirements of the Manual for Accounts issued by the Department of Health. The accounting policies contained in the Manual for Accounts follow International Financial Reporting Standards to the extent that they are meaningful and appropriate to the CCG, as determined by HM Treasury, which is advised by the Financial Reporting Advisory Board.

From 1 April 2013, NHS Hammersmith and Fulham CCG has been responsible for commissioning (planning and purchasing) local health services; excluding primary care and specialised services, commissioned by NHS England. Previously primary care trusts (PCTs) had responsibility for the full range of services. From 1 April 2017 NHS Hammersmith and Fulham CCG took full responsibility for the management of its primary care medical services, allowing them to tailor services more effectively to meet local patients’ needs.

Financial position The CCG achieved an in year deficit of £16.9 million in 2018/19, including the benefit of a drawdown of £3.9million. The 2018/19 deficit added to surpluses accumulated from prior years and will be carried forward to future years. This accumulated deficit totals £14.2million and will need to be recovered in future periods. The in-year deficit includes net costs of c£10m related to exceptional, unfunded GP at Hand list growth.

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1.10 How we spent your money

The following chart gives a breakdown by service of the CCGs total net expenditure of £326.3m.

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2 Performance analysis

2.1 How the CCG measures performance Hammersmith and Fulham CCG has a statutory duty to report on the performance of a number of services defined nationally within the NHS Constitution, Everyone Counts Guidance from 2014/15 to 2018/19 (Operating Framework) and the NHS Mandated Outcomes Framework. Performance of the CCG is monitored by the senior management team and is regularly reviewed at key system and operational meetings with providers and other commissioners. Performance of the CCG is also regularly (and as requested) reported to NHS England as part of the quarterly assurance cycle. As part of the Improvement and Assessment Framework CCGs work under, you can keep up to date with the performance of the CCG and the wider local NHS by typing your postcode into the new My NHS website.

2.2 Development and performance during the year

2.2.1 Financial targets (See note 15 in the financial statements) CCGs have a number of financial duties under the National Health Service Act 2006 (as amended) regarding the use of its resources. For 2018/19, NHS Hammersmith and Fulham CCGs performance against each is summarised below:

Expenditure not to exceed its income For 2018/19 NHS Hammersmith and Fulham CCG’s net revenue expenditure of £322.8m exceeded its in year resource allocation of £305.9m by £16.9m.

Capital resource use not to exceed the amount specified in directions For 2018/19 NHS Hammersmith and Fulham CCG did not have a capital allocation.

Revenue resource use not to exceed the amount specified in directions For 2018/19 NHS Hammersmith and Fulham CCG’s net revenue expenditure of £322.8m exceeded its specified allocation of £305.5m by £17.3m.

In addition NHS England has placed the following additional controls on clinical commissioning groups’ use of resources:

Capital resource use on specified matters not to exceed the amount specified in directions For 2018/19 NHS Hammersmith and Fulham CCG did not have a capital allocation.

Revenue resource use on specified matters not to exceed the amount specified in directions

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For 2018/19 NHS Hammersmith and Fulham CCG did not have any resources allocated with specific directions.

Revenue administration resource use not to exceed the amount specified in directions For 2018/19 NHS Hammersmith and Fulham CCG had a target of £3.9m and actual performance of £3.9m and so achieved a break-even position on running costs.

A deficit on programme expenditure of £16.9m and a break even position on running costs together equal Hammersmith and Fulham CCG’s deficit of £16.9m.

2.2.2 Funding allocations Core allocations NHS England published CCG core allocations for 3 years with indicative allocations for the following 2 years in January 2016. These were updated in 2017/18. For 2018/19, the CCG received an increase in allocation of 1.8% on the funding received in 2017/18, equivalent to £4.8m. In 2019/20, the CCG will receive an increase in core allocation of 4.8% above the funding received in 2017/18, equivalent to £12.7m. This allocation level equates to a funding level 3.42% below the target funding level, and is a significant decline from the 4.18% initial over-capitated position of 2017/18. This swing reflects the impact of exceptional list growth at the GP at Hand practice, whose list size of 2,500 pre-launch had increased to 48,935 as at 1 April 2019. Delegated Primary Care 2018/19 marked the second year in which under delegated authority from NHS England, the CCG had responsibility for the commissioning and management of primary care medical services (see section 5.3.6). Allocations in-year for these services amounted to £28.8m, an increase of £1.6m or 5.8%. In 2019/20 this allocation is planned to increase by £1.4m to £30.2m (net of £0.8m of funding retained for indemnity funding to be centrally funded from 2019/20) equivalent to a 4.8% increase. At this level this funding is expected to be 4.99% below the target funding level. Allocations for 2019/20 include additional ‘Pace of Change’ adjustments valued at £0.7m (£0.2m Core and £0.5m Delegated) arising from the application of the NHS allocation formula to partly mitigate the costs of the extra patients now falling to the account of the CCG in full. The costs of that growth, however, are substantially higher than this allocation, and discussions with NHS England continue on this matter.

2.2.3 Relationship and linkage of information The CCG uses information to support the making of better business decisions, by providing insight into the health needs of the local population which then allows us to plan and decide

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what services we need to commission to meet those health needs. We also use information to help us decide if the services we commission are performing well and make any necessary changes to improve performance.

2.2.4 Accident and emergency (A&E) department The A&E four hour waiting time target, means patients should not wait longer than four hours to be seen, treated and either discharged home or moved onto a ward from A&E. For 2018/19 this target was not achieved for Imperial Health Care Trust with a yearend position of 88.2% below the plan of 89.2%. Work is underway on the implementation of the year two Improving Patient Flow program which will focus on emergency department operations and ward flow.

The plan represents the path agreed by the CCG, the Trust and our partners to support consistent achievement of the A&E target.

78%

80%

82%

84%

86%

88%

90%

92%

94%

96%

Apr-18 May-18 Jun-18 Jul-18 Aug-18 Sep-18 Oct-18 Nov-18 Dec-18 Jan-19 Feb-19 Mar-19

A&E - Imperial College

PLAN ACTUAL Standard

A&E - Imperial College(Standard = 95%) Apr-18 May-18 Jun-18 Jul-18 Aug-18 Sep-18 Oct-18 Nov-18 Dec-18 Jan-19 Feb-19 Mar-19 FY

PLAN 85.1% 85.4% 86.1% 87.9% 88.9% 90.2% 90.2% 90.4% 90.2% 90.4% 90.5% 95.0% 89.2%

ACTUAL 84.7% 87.0% 87.6% 88.4% 89.0% 89.0% 90.6% 90.1% 88.4% 86.7% 88.1% 88.4% 88.2%

Difference -0.4% 1.6% 1.5% 0.5% 0.1% -1.2% 0.4% -0.3% -1.8% -3.7% -2.4% -6.6% -1.0%

PLAN 3,591 3,779 3,415 3,082 2,679 2,416 2,480 2,344 2,407 2,407 2,095 1,262 31,957

ACTUAL 3,663 3,279 3,048 2,956 2,573 2,545 2,296 2,329 2,736 3,382 2,713 2,910 34,430

PLAN 24,121 25,950 24,569 25,522 24,157 24,543 25,312 24,322 24,561 25,089 22,158 25,294 295,598

ACTUAL 23,962 25,295 24,584 25,578 23,372 23,126 24,529 23,476 23,543 25,362 22,833 25,015 290,675

Patients waiting >4 hrs

Total A&E attendances

% patients waiting < 4 hrs

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2.2.5 Referral to treatment (RTT)

The referral to treatment (RTT) target is the time it takes from a GP making a referral to a hospital service and treatment being provided by the hospital service. The RTT waiting time incomplete target (percentage of patients seen within 18 weeks) is the main national access performance indicator. NHS Hammersmith and Fulham CCG’s yearend performance is 88.3% above a plan of 87.7%.

The CCG continues to work closely with Imperial College Healthcare NHS Trust to ensure sufficient capacity within specialties with high demand.

84.0%

85.0%

86.0%

87.0%

88.0%

89.0%

90.0%

91.0%

92.0%

93.0%

Apr-18 May-18 Jun-18 Jul-18 Aug-18 Sep-18 Oct-18 Nov-18 Dec-18 Jan-19 Feb-19 Mar-19

NHS Hammersmith and Fulham CCG - RTT performance against plan

PLAN ACTUAL Standard

RTT (Referral to Treatment)(Standard = 92%) Apr-18 May-18 Jun-18 Jul-18 Aug-18 Sep-18 Oct-18 Nov-18 Dec-18 Jan-19 Feb-19 Mar-19 FY

PLAN 87.7% 87.7% 87.7% 87.7% 87.7% 87.7% 87.7% 87.7% 87.7% 87.7% 87.7% 87.7% 87.7%

ACTUAL 87.9% 88.9% 88.7% 88.7% 87.3% 87.0% 87.5% 87.9% 87.6% 88.7% 89.6% 89.7% 88.3%

Difference 0.2% 1.3% 1.0% 1.0% -0.3% -0.6% -0.2% 0.2% -0.1% 1.0% 2.0% 2.0% 0.6%

PLAN 1,975 1,975 1,975 1,975 1,975 1,975 1,975 1,975 1,975 1,975 1,975 1,968 23,693

ACTUAL 2,018 1,866 1,910 1,903 2,094 2,112 2,109 2,005 2,053 1,909 1,739 1,716 23,434

PLAN 16,007 16,007 16,007 16,007 16,007 16,007 16,007 16,007 16,007 16,007 16,007 16,000 192,077

ACTUAL 16,614 16,855 16,915 16,838 16,533 16,271 16,846 16,578 16,542 16,895 16,776 16,679 200,342

Patients waiting >18

weeks

Total waitlist

% patients waiting <18

weeks

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2.2.6 Diagnostic waiting times

The diagnostic waiting times (for 15 key diagnostic tests and procedures) target states that 99% of all patients should wait no more than 6 weeks for their diagnostic test. Yearend performance (patients waiting more than 6 weeks) is 0.8% below the plan of 1.0%.

0.0%

0.2%

0.4%

0.6%

0.8%

1.0%

1.2%

1.4%

1.6%

Apr-18 May-18 Jun-18 Jul-18 Aug-18 Sep-18 Oct-18 Nov-18 Dec-18 Jan-19 Feb-19 Mar-19

NHS Hammersmith and Fulham CCG - Diagnostics performance against plan

PLAN ACTUAL Standard

Diagnostics(Standard = 1.0%) Apr-18 May-18 Jun-18 Jul-18 Aug-18 Sep-18 Oct-18 Nov-18 Dec-18 Jan-19 Feb-19 Mar-19 FY

PLAN 1.0% 1.0% 1.0% 1.0% 1.0% 1.0% 1.0% 1.0% 1.0% 1.0% 1.0% 1.0% 1.0%

ACTUAL 0.6% 1.0% 1.1% 0.8% 0.8% 0.9% 0.5% 0.6% 1.4% 0.9% 0.7% 0.7% 0.8%

Difference -0.4% 0.0% 0.1% -0.2% -0.2% -0.1% -0.5% -0.4% 0.4% -0.1% -0.3% -0.3% -0.2%

PLAN 29 30 29 28 25 29 29 29 28 27 30 30 343

ACTUAL 22 34 37 28 24 27 20 21 50 34 25 27 349

PLAN 2,900 3,000 2,900 2,800 2,500 2,900 2,900 2,900 2,800 2,700 3,000 3,000 34,300

ACTUAL 3,467 3,375 3,445 3,347 3,196 2,854 3,701 3,766 3,611 3,734 3,579 3,737 41,812

% patients waiting >6

weeks

Patients waiting >6 weeks

Total waitlist

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2.2.7 Cancer waiting times NHS Hammersmith and Fulham CCG has achieved eight of the nine cancer waiting time standards. The standard not being achieved is: 62 day – screening.

The 62 day waits for first definitive treatment standard was achieved at 87.1%, above the 85% standard. However, further improvements are being supported thought the NHSE Cancer Taskforce. Initiatives to improve performance in all cancer measurements include; the implementation of surveillance lists, escalation processes to minimise breach numbers, weekly patient list review, and regular review of capacity across high demand specialties

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2.2.8 Improved Access to Psychological Therapies (IAPT) This target is about ensuring residents in Hammersmith and Fulham know that there are psychological services, also known as talking therapies available, to help support the early signs of anxiety or depression. People who are supported early with these conditions benefit from a better recovery. Please note: Q4 ‘freeze’ data not available until 13th June 2019, therefore ‘flex’ data used and is subject to adjustment for both access and recovery measures. IAPT – access NHS Hammersmith and Fulham CCG has seen a steady increase in both access and recovery rates in since the previous financial year. The yearend position for IAPT Access is 17.0% below the plan of 17.5%.

IAPT - access

(Q4 Standard = 4.20%)

18/19 Q1

18/19 Q2

18/19 Q3

18/19 Q4

FY

Access rate

PLAN 4.1% 4.3% 4.4% 4.7%

17.5%

ACTUAL 3.9% 4.0% 4.4% 4.7%

17.0%

Difference -0.2% -0.3% 0.0% -0.1%

-0.5%

Number of people receiving psychological therapies

PLAN 1,154 1,196 1,230 1,331

4,911

ACTUAL 1,102 1,125 1,224 1,316

4,767

Number of people with depression and/or anxiety

28,081

28,081

28,081

28,081

28,081

0.0%

0.5%

1.0%

1.5%

2.0%

2.5%

3.0%

3.5%

4.0%

4.5%

5.0%

18/19 Q1 18/19 Q2 18/19 Q3 18/19 Q4

NHS Hammersmith and Fulham CCG - IAPT Access performance against plan

PLAN ACTUAL Standard

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IAPT – recovery The year end position for IAPT Recovery is 52.2% above the plan of 50.0%.

IAPT - Recovery

(Standard = 50%)

18/19 Q1

18/19 Q2

18/19 Q3

18/19 Q4

FY

Recovery rate

PLAN 50.0% 50.0% 50.0% 50.0%

50.0%

ACTUAL 50.6% 53.7% 50.9% 53.2%

52.2%

Difference 0.6% 3.7% 0.9% 3.2%

2.2%

Number of people completed treatment and moving to recovery

PLAN 257 313 216 255

1,041

ACTUAL 260 336 220 271

1,087

Number of people who have completed treatment and are moving to recovery - the number of people not at clinical caseness at initial assessment

PLAN 514 626 432 509

2,081

ACTUAL 514 626 432 509

2,081

Providers have worked closely with primary care to improve referrals from GPs. In addition, the service has improved outreach in the community by partnering with local voluntary sector organisations. There is also a programme in place to increase numbers of self-referrals which is expected to improve recovery.

48.0%

49.0%

50.0%

51.0%

52.0%

53.0%

54.0%

18/19 Q1 18/19 Q2 18/19 Q3 18/19 Q4

NHS Hammersmith and Fulham CCG - IAPT Recovery Rate performance against plan

PLAN ACTUAL Standard

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2.2.9 Dementia diagnosis Yearend performance (% people diagnosed with dementia 65+) is 67.5% above the plan of 67.0%.

NHS Hammersmith and Fulham CCG is currently performing very well against the NHS England dementia diagnosis standard. Work is ongoing between the CCG and primary care providers to ensure this position is maintained and improved upon.

65.5%

66.0%

66.5%

67.0%

67.5%

68.0%

68.5%

69.0%

Apr-18 May-18 Jun-18 Jul-18 Aug-18 Sep-18 Oct-18 Nov-18 Dec-18 Jan-19 Feb-19 Mar-19

NHS Hammersmith and Fulham CCG - Dementia diagnosis performance against plan

PLAN ACTUAL Standard

Dementia diagnosis(Standard = 66.7%) Apr-18 May-18 Jun-18 Jul-18 Aug-18 Sep-18 Oct-18 Nov-18 Dec-18 Jan-19 Feb-19 Mar-19 FY

PLAN 67.0% 67.0% 67.0% 67.0% 67.0% 67.0% 67.0% 67.0% 67.0% 67.0% 67.0% 67.0% 67.0%

ACTUAL 67.5% 67.0% 67.3% 66.8% 67.3% 68.0% 68.4% 68.6% 68.0% 67.6% 66.9% 67.0% 67.5%

Difference 0.5% -0.1% 0.3% -0.2% 0.3% 1.0% 1.4% 1.6% 1.0% 0.6% -0.1% 0.0% 0.5%

PLAN 821 821 821 821 821 821 821 821 821 821 821 821 9,852

ACTUAL 840 838 843 839 848 861 868 870 868 863 854 859 10,251

PLAN 1,225 1,225 1,225 1,225 1,225 1,225 1,225 1,225 1,225 1,225 1,225 1,225 14,700

ACTUAL 1,245 1,252 1,252 1,256 1,260 1,267 1,269 1,268 1,277 1,276 1,277 1,281 15,178Estimated dementia prevalence

% people diagnosed with

dementia (65+)

Number of people

diagnosed (65+)

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2.2.10 Health Care Associated Infections (HCAIs) such as MRSA and C.difficile

Ensuring patients don’t pick-up an infection while in hospital is very important. We have strict infection control targets to keep our hospitals safe. The target for C.difficile cases is currently being met for NHS Hammersmith and Fulham CCG, with the cumulative yearend position at 23, below a target of 34. The MRSA target of 0 cases throughout the year is not being met.

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The CCG Quality Team is undertaking a review of HCAI cases across providers including a full post-infection review specifically for MRSA cases. A revised assessment form has also been developed to help support the identification of areas of improvement in C.difficile lapses of care.

2.3 Social matters, human rights, anti-corruption and bribery Social matters Hammersmith and Fulham CCG is committed to making a positive contribution on social and environmental matters, human rights and reducing the level of fraud, bribery and corruption within the NHS to an absolute minimum. Hammersmith and Fulham CCG is a GP-led organisation, responsible for planning, buying (commissioning) and designing many of the health services needed by the approximately 231,004 people registered with GPs in Hammersmith and Fulham . The CCG makes decisions about health services based on the feedback we receive from patients and carers. This ensures the services we purchase and re-design are those services local residents tell us they need and are able to access. Hammersmith and Fulham CCG is committed to embedding equality and inclusion in everything that we do, but more specifically:

How we commission services on behalf of our residents How we recruit and support the development of our staff How we proactively engage and support all our residents particularly given the

diversity of our population and service users Our work on embedding equality into the commissioning of health services is underpinned by engagement with our stakeholders. We believe that engagement with and drawing on the expertise of residents, patients, services providers and third sector organisations, is critical in shaping services that are of high quality, value for money and reflect the needs of our diverse populations. Environmental matters Hammersmith and Fulham CCG is committed taking into account environmental matters in the course of its work. See section 2.4 for further details. Anti-corruption and bribery Hammersmith and Fulham CCG is committed to reducing the level of fraud, bribery and corruption within the NHS to an absolute minimum and keeping it at that level, freeing up public resources for better patient care. The CCG does not tolerate fraud, bribery and corruption and aims to eliminate all such activity as far as possible.

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2.4 Environmental matters including sustainable development As an NHS organisation and spender of public funds, we have an obligation to work in a way that has a positive effect on the communities for which we commission and procure healthcare services. Sustainability means spending public money well, the smart and efficient use of natural resources and building healthy, resilient communities. By making the most of social, environmental and economic assets, we can improve health both in the immediate and long term even in the context of the rising cost of natural resources. We acknowledge this responsibility to our patients, local communities and the environment by working hard to minimise our carbon footprint. As a part of the NHS, public health and social care system, it is our duty to contribute towards the level of ambition set in 2014 of reducing the carbon footprint of the NHS, public health and social care system by 34% (from a 1990 baseline). The majority of the environmental and social impacts are through the services we commission. We work with our providers through the contracting process to make sure sustainability is factored into the services they offer local people.

2.5 Improve quality

Hammersmith and Fulham CCG has a statutory duty under section 14R of the National Health Service Act 2006 (as amended) to report on the performance of the number of services defined nationally within the NHS Constitution, Everyone Counts Guidance for 2015/16 to 2018/19 (Operating Framework) and the NHS Mandated Outcomes Framework. There are a number of ways in which the CCG fulfils this duty as previously outlined in relation to quality where the CCG’s remit is to improve quality and commission service that provide quality of care to the patient population. This applies to all commissioned services both NHS provided, NHS funded care and includes primary care.

The CCG uses the three domains to monitor the services commissioned the CCGs: patient safety

Clinical effectiveness

Patient experience

In addition to this the CCG has a responsibility to ensure that it meets its public sector equality duties and to ensure that equalities and health inequalities impact assessments are undertaken as a routine component of commissioning decisions ensuring that the particular nuances of the population are taken into consideration to inform the commissioning process alongside evidence of engagement with the community.

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2.5.1 Continuing Healthcare

Adult Continuing Healthcare (CHC) is provided when an individual has been assessed by a multi-disciplinary team (MDT) and been deemed to have a ‘primary health need’. After this has been agreed, the CCG will commission a package of care accordingly. This is predominantly for individuals outside of hospital who require continuous on-going healthcare provision to meet their needs. Individuals can receive continuing healthcare in any setting, inclusive of their own home or a care home. In 2018/19 the service continued reporting on the Quality Premium which supports the national and local plans to improve the NHS continuing healthcare assessment processes and reduce unnecessary delays in transfers of care. The two key continuing healthcare standards defined in the Quality Premium 2018/19 are as follows:

CCGs must ensure that less than 15% of all full NHS CHC assessments take place in an acute hospital setting.

CCGs must ensure that in more than 80% of cases with a positive NHS CHC checklist, the NHS CHC eligibility decision is made by the CCG within 28 days from receipt of the checklist (or other notification of potential eligibility).

There are action plans in place that are shared with NHS England to provide assurance in relation to measures taken, to ensure delivery against national targets can be achieved.

2.5.2 Quality and safety monitoring and assurance

The CCG uses information from a variety of sources to understand patient experience of the services patient experience, patient safety and safeguarding information, complaints, staff surveys, the Care Quality Commission (CQC), local Healthwatch site visits, GP alerts and national data, as well as key quality and performance information to develop a programme of targeted clinical visits where assurance is sought from patients using the service embedded and develop an improvement programme to ensure all issues are addressed and any learning is embedded. The team also:

Undertake quality assurance visits these afford the CCGs opportunity to

observe care delivery and review the quality of care provided. The CCGs visits are usually announced to ensure providers are fully aware of the standard expected during the visit

Supports contract leads within the CCG to undertake quality impact assessment (QIA) to ensure that possible or actual plans or changes in commissioned services are assessed and the potential risks and consequences on quality are considered

Links with the CQC to discuss providers where there are concerns and also

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areas of good practice. There are more formal meetings with NHS England and NHS Improvement as regulators where providers causing concerns in the health care system will be discussed at North West London, regional or national level

Requires provider organisations to produce a Quality Account each year reviewing priorities set the previous year and looking ahead to priorities for the coming year.

Primary Care

A standardised quality reporting dashboard has been rolled out to primary care committees for use across North West London. The dashboard includes information available in the public domain and from submissions to made to primary care at NHS England. The dashboard’s primary remit is that of quality improvement tool for primary care services to assist NW London CCGs to target and support general practice more effectively.

2.5.3 Clinical effectiveness Clinical effectiveness is defined as "the application of the best knowledge, derived from research, clinical experience, and patient preferences to achieve optimum processes and outcomes of care for patients.” The process involves a framework of informing, changing, and monitoring practice. The providers report on clinical effectiveness at the Clinical Quality Group meetings against local and national audit participation and learning ensuring relevant policies and procedures are updated. The Quality team across NW London CCGs has supported provider organisations in the development of provider annual quality accounts including local quality priorities in line with the NHS Standard Contract. Quality performance indicators from these priorities are reviewed by the CCGs’ quality team in conjunction with the contracting team. Any deviations are appropriately addressed at the providers Clinical Quality Group meetings on a monthly basis.

2.5.4 Quality assurance visits Hammersmith and Fulham CCG are committed to ensuring high quality service within all commissioned services and carry out announced or unannounced quality assurance visits to providers that allow the CCGs first hand to witness and review the care being delivered. These visits provide assurance to the CCG that national and local indicators set within the contract and key outcomes are being met. The CCG also conducts assurance visits within primary and secondary settings including contracted services with non NHS providers. Joint visits also take place in partnership with the Local Authority conducting assurance visits to care homes as required.

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2.5.5 Learning from deaths and mortality All NHS providers are required to have a Mortality review group who assess deaths within their organisations – so providers have combined morbidity and mortality review groups who assess both these impacts in one review process. Investigation of deaths should involve family, carers or others who were close to the deceased. The Learning Disabilities Mortality Review (LeDeR) programme was established in 2017 to support local areas to review the deaths of people with learning disabilities (LD), identify learning from those deaths, and take forward the learning into service improvement initiatives. Since the launch of the programme a number of reviews have taken place across NW London and LeDeR steering groups established linking with provider organisations and the CCG LeDeR local area contacts to share learning from these reviews.

2.5.6 Patient safety The population within NW London are entitled to receive care that is of high quality and does not expose them to harm. NW London CCGs hold providers to account for the quality of commissioned care and seek assurance that appropriate mechanisms are place to prevent patient safety incidents from occurring and when they do occur assurance that appropriate actions are taken, lessons learnt and disseminated.

Incidents can be classified in a range of ways but there is national guidance through the Serious Incident Framework (2015). Providers are required to report Serious Incidents as defined by this framework within specified time frames and fully investigate having ensured that the patient or their relatives are made aware of the incident under the Duty of Candour. There are processes in place to enable the CCGs to be assured that actions and lessons learnt are completed within the NHS England timeframe for investigation. The provider organisations are monitored in reporting, investigating and learning from the incident.

The CCG patient safety team also monitors the number and type of incidents within organisations and across the health economy and will undertake thematic reviews of particular incidents to ensure that learning is shared and outcomes improved.

2.5.7 Safeguarding adults and children Ensuring robust systems and processes to fulfil our statutory safeguarding responsibilities are in place is a central component to our role as clinical commissioners. Hammersmith and Fulham CCG has a statutory responsibility to ensure that both they and the organisations that they commission from have systems and processes in place to safeguard children and vulnerable adults. Hammersmith and Fulham CCG is a member of the Local Safeguarding Children Board (LSCB) and Local Safeguarding Adults Boards (LSAB). As a member of these

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Boards, the CCG works in partnership with others to fulfil their safeguarding responsibilities. The CCG works closely with both boards to ensure that there are effective nhs safeguarding arrangements across the local health community. Work is being progressed to ensure that the necessary arrangements are in place to meet the revised statutory guidance Working Together to Safeguard Children (2018) namely that the Safeguarding Partners (the CCG, local authority and the police) have come together to form the Local Safeguarding Children Partnership in place of the previous Local Safeguarding Children Board. We have a CCG safeguarding team that includes a designated nurse and doctor for safeguarding children, a designated nurse and doctor for looked after children and a designated adult safeguarding. the team also includes a named GP for children to support safeguarding in primary care. Further information on the work of the CCG’s safeguarding team can be found on the CCG website.

2.5.8 Infection control North West London CCGs have a responsibility of holding all providers to account for their actions to protect patients from developing healthcare associated infections and monitor and improve rates of infection in primary care. The following actions demonstrate how this was achieved in the past year: The CCG infection prevention and control (IP&C) leads participated in regular

assurance meetings with the Providers. These meeting are used to review cases of health care associated infections, discuss concerns and collaborate on joint projects aimed at improving patient outcomes and reducing risk of infection.

A strategy was developed and a steering group formed to improve rates of

Gram-negative blood stream infections across the health economy in North West London. This includes both primary and acute care apportioned cases. Work streams were developed to focus initiatives.

An improvement plan was developed to reduce rates of Clostridium difficile

infections in North West London. This included developing a robust system to gain assurance from acute providers; that their actions or omissions did not result in a lapse in care. In addition primary care guidance for GPs and community providers were developed to improve primary care apportioned cases.

The CCG IP&C Leads attended provider organisations Infection Control

committee meetings as a means of monitoring and to gain assurance that the all reasonable measures are in place to reduce risk of infection to patients.

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The CCG IP&C Leads monitored rates of healthcare associated infections in primary care and IP&C activity across North West London. Reports were populated and presented on a quarterly basis to CCG boards.

Work continues to develop an overarching Infection Prevention strategy across the North West London health economy.

2.5.9 Patient experience During the year patient stories have been shared at Governing Bodies as a means of understanding real life patient experience of commissioned services. NW London CCGs review patient experience on a quarterly basis from all commissioned providers requesting themes and trends are reported with clear actions taken to improve patient experience and outcomes. Provider patient experience is matched against national benchmarks such as the Friends and Family Test, Cancer services experience and Children and Young People Tests. The CCGs also request that providers report to Clinical Quality Groups on actions taken as a result of Healthwatch ‘enter and view’ reports. Providers are required to produce improvement plans where benchmarked tests fall below national, regional and service specific levels.

Complaints

The CCG receives complaints from patients, carers, family members, and Members of Parliament. Where the complaint relates directly to a provider the permission of the individual is sought to refer to the relevant provider. The CCG will analyse any trends and themes arising from complaints and work with providers to address these. Complaints relating to primary care services are managed by NHS England.

2.5.10 Leadership/responsiveness (Well-led)

The CCG monitors the quality of the leadership and responsiveness of providers to engage with other CCGs and partners to constantly improve services for patients. Intelligence is gathered from the CQC to monitor the progress of improvements of services and respond to clinical risks that could impact on the safety of patients. NW London CCGs participate in region wide quality surveillance meetings led by NHS England with CQC, Health Education England, Healthwatch, Specialist Commissioning and Primary Care where quality and performance of providers is discussed and system wide actions may be initiated.

CQC Assurance

NW London CCGs work collaboratively with NHS England and NHS Improvement with providers to ensure that there is oversight of CQC action plans and to assure CCGs of the delivery of high-quality care for service users. Regular updates of the CQC action plans and improvement plans are discussed at the Clinical Quality Groups and Integrated Governance Committee.

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2.6 Patient and public engagement The CCG's engagement principles were coproduced with patients, Healthwatch CWL and others, and are attached to SMART outcomes which we report against quarterly. You can read the principles on pages 5-6 of our engagement and communications strategy, with corresponding outcomes on pages 10-15. The CCG uses a wide range of ways to involve the public, lay members and Healthwatch Central and West London in planning, decision making and assuring engagement, including via committees and groups. You can read all about these in full, as well as finding links to our quarterly 2018 patient engagement reports, on our website. In 2018-19 the CCG continued to work effectively with our Community Champions on campaigns and our BME Health Forum to ensure we are engaging effectively and in an accessible way with Black and minority ethnic groups around all our planning and decision making. We have also branched out to find new ways of reaching a wider variety of patient, public and community groups this year, including via an innovative new campaign with West London Health Partnership and the Queens Park Rangers Football Club called “RNHS”. GPs, NHS staff, players, legends and supporters of QPR FC have come together to take part in this special new campaign that uses the power of football to educate the public on what NHS services are available to them and how to access the right care in the right place. We recognise that not everyone has access to a computer or the internet, so we also take hard copies of our reports and you said we did activity to a range of meetings, community outreach events and stall-based activities across the borough of Hammersmith and Fulham. We translate a number of our communications and engagement materials into accessible formats, including key information on cervical screening, latent tuberculosis and GP access. In recognition of the diversity of our borough’s population, we have been working on a number of initiatives to address health inequalities and promote equality of opportunity in the borough. We coproduced our 2019-22 equality objectives with local groups, and have already started work in 2018-19 to progress against these objectives. For example, we have managed to get into a position whereby we can roll out an initiative called “Pride in Practice”, a quality assurance and social prescribing programme that strengthens and develops GP practices’ relationship with their lesbian, gay, bisexual and transgender (LGBT) patients within the local community. In 2018, our Patient Reference Group and Healthwatch told us that one of the key areas where we needed to improve was how we fed back to people on what we had done with their feedback. The CCG has been working to improve on how we evaluate and communicate what we have done as a result of local people’s and community and voluntary sector feedback. In addition to publishing our you said we did activity on our website, we have: completed reports every three months which show what we have done with the feedback local people have shared, and discussing these reports with our Patient

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Reference Group and wider stakeholders for comment before taking them to our Governing Body; directed people to the reports and to our You Said We Did page via Twitter; made You Said We Did documents available in hard copy at our Annual General Meeting and a range of our local outreach events in the community; made better use of our GP Numed screens for advertising engagement; set up follow up meetings to inform local community groups of what we did with the feedback they gave us at earlier outreach events; obtained consent from workshop and public meeting attendees to contact them with write ups of what we have done with their feedback; and created write ups reflecting on what worked well and what could work better for next time.

2.7 Reducing health inequality

This section explains how the CCG has discharged its duty under Section 14T of the National Health Service Act (as amended), having regard to the need to reduce inequalities. The CCG also publishes a Public Sector Equality Duty Report annually. The CCG has developed robust governance structures to provide assurance to the Governing Body that, in working within the parameters set nationally and locally, the organisation meets all of its statutory duties including those related to the equality legislation. Hammersmith and Fulham CCG aims to improve health outcomes and reduce inequalities for its patients. This involves ensuring thorough engagement with, and drawing on, the expertise of residents, patients, services providers and third sector organisations. This is critical in shaping services that are high quality, value for money and that reflect the needs of our diverse population. The involvement and active participation of stakeholders helps us to meet our public equality duties by:

Identifying at an early stage in the design and development of services whether the service is free of unlawful discrimination or impacts adversely on any group of service users

Advancing equality by helping to ensure that services are accessible to all who need the service

Fostering good relations by drawing people from different communities to work together collaboratively with commissioners - and the wider health and social care workforce - to identify solutions to local health challenges.

We have developed our equalities objectives through a range of processes that have involved local people, CCG staff, the CCG Governing Body and our neighbouring CCGs in addition to frontline NHS and Local Authority staff, community groups and voluntary sector organisations across Hammersmith and Fulham. Specifically we have reviewed the needs of our local population with specific regards to equality and diversity.

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2.8 Health and wellbeing strategy

Under section 116B(1)(b) of the Local Government and Public Involvement in Health Act 2007, CCGs must, in exercising their functions have regard to the most recent joint Health and Wellbeing Strategy prepared by the local council. The CCG is an active member of Hammersmith and Fulham Health and Wellbeing Board with the vice chair role held by the CCG Chair, Dr Tim Spicer. The board, which meets on a public bi- monthly basis, is the principal forum for organisations in the borough that oversee work to improve health and social care outcomes. Hammersmith and Fulham CCG is also a key member of the adult and children’s safeguarding boards, where decisions are made on how we collectively support vulnerable and ‘at-risk’ people. For the purposes of this report, the bi-monthly meetings focus on progress against Health and Wellbeing priorities and ensuring that other key plans and strategies, such as the CCG’s commissioning plans, the Better Care Fund plan and the Winter Resilience plan complement and add value to health and wellbeing priorities for Hammersmith and Fulham . There is also a process whereby the Health and Wellbeing Board and wider Council staff review the CCG’s commissioning plans and provide detailed comments about their alignment to the Joint Strategic Needs Assessment (JSNA) and wider priorities for the residents of Hammersmith and Fulham . This annual process culminates in a formal statement of support by the Chair of the Health and Wellbeing Board for the annual commissioning intentions. The aim of the Joint Health and Wellbeing Strategy (JHWS) in Hammersmith and Fulham is to improve the health and wellbeing of all residents in Hammersmith and Fulham , in particular, people that are disadvantaged, hard to reach or vulnerable – whether young or old. JHWS aim to reduce health inequalities in the local population through guiding commissioning to improve health and wellbeing in the borough in all age groups. The new JHWS is in the process of being finalised following the update of the Joint Strategic Needs Assessment (JSNA) in 2018 and the new priorities for action will be set out in this. JHWSs are strategies outlining clear outcomes that the Health and Wellbeing Board wants to achieve and will inform local commissioning. As with the previous Health and Wellbeing Strategy, we will continue to work closely with a wide range of partner organisations to achieve this. We will work to prevent ill health and improve wellbeing of residents and where there is ill-health, we will work to detect conditions earlier and treat as effectively as possible. Healthy London Partnership NHS Hammersmith and Fulham CCG, along with all of London’s 32 CCGs, Greater London Authority, London Councils, Public Health England and NHS England (London) contributed funding towards Healthy London Partnership (HLP) in 2018/19.

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The aim was to bring together the NHS and partners in London to work towards the common goals set out in Better Health for London, NHS Five Year Forward View and the devolution agreement.

HLP works as a partnership across London’s health and care system and beyond to achieve these goals. This includes NHS organisations in London, including NHS Hounslow CCG, NHS England, NHS Improvement, hospital trusts and providers, as well as working across health and care with the Greater London Authority (GLA), the Mayor of London, Public Health England and London Councils. Additionally, HLP hosts the London Health and Care Strategic Partnership Board which provides oversight and leadership for devolution plans, working closely with the London Health Board secretariat. HLP is supporting the development of the refreshed shared vision for health and care to ensure all partners are clear about their role in making London the world’s healthiest city.

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Accountability Report The NHS Hammersmith and Fulham Clinical Commissioning Group Accountability Report comprises of the:

• Corporate Governance Report • Remuneration and Staff Report • Parliamentary Accountability and Audit Report

Mark Easton Accountable Officer NHS Brent, Central London, Ealing, Hammersmith and Fulham, Harrow, Hillingdon, Hounslow and West London Clinical Commissioning Groups Date: 24 May 2019

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Corporate Governance Report

The Corporate Governance Report outlines the composition and organisation of the CCGs governance structures and how they support the achievement of the CCGs objectives. The Corporate Governance report comprises of:

Members’ Report

Statement of the Accountable Officer’s Responsibilities

Annual Governance Statement.

3 Members’ Report

NHS Hammersmith and Fulham CCG is responsible for planning and commissioning health services for the people of the London Borough of Hammersmith and Fulham. Set up in 2013, the CCG operates in accordance with its Constitution with a Governing Body made up of lay members, clinicians, co-opted GP member, a practice manager and executive directors.

3.1 Member profiles Full member provides can be found on the NHS Hammersmith and Fulham CCG website.

3.2 Member practices

Our population is served by 29 GP practices that make up the CCG’s membership.

Ashchurch Surgery

Ashville Surgery

Brook Green Medical Centre

Brook Green Surgery

The Bush Doctors

Cassidy Road Medical Centre

Fulham Medical Centre

Fulham Cross Medical Centre

Hammersmith and Fulham Centres for Health (the two sites are Hammersmith Hospital and Charing Cross Hospital)

Hammersmith Bridge Surgery

Lillyville Surgery at Parsons Green

Babylon GP at Hand

The Medical Centre, Dr Kukar

The New Surgery

North End Medical Centre

Palace Surgery

Park Medical Centre

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Richford Gate Medical Centre

Salisbury Surgery

Shepherds Bush Medical Centre

Sterndale Surgery

North Fulham Surgery, 82 Lillie Road

Sands End Health Clinic

Westway Surgery, Dr Dasgupta and Partners

Parkview Practice

Dr. Uppal and Partners, Parkview

Dr Kukar, Parkview

Canberra, Old Oak Surgery

Dr Jefferies and Partners, 292 Munster Road

3.3 Composition of Governing Body

The main function of the Governing Body is to ensure that NHS Hammersmith and Fulham CCG has appropriate arrangements in place to ensure it exercises its functions effectively, efficiently and economically, and in accordance with any generally accepted principles of good governance that are relevant to it. The Governing Body leads on the setting of the CCG’s vision and strategy approves commissioning plans, monitors performance against plan, and provides assurance of strategic risks. Members of the Governing Body are:

Name Role Voting/Non-

voting

Dr Tim Spicer Chair V

Dr James Cavanagh

Vice Chair and GP member V

Vanessa Andreae Vice Chair and Practice Nurse member V

Dr Tony Willis GP member (Left July 2018) V

Dr Paul Skinner GP member V

Trish Longdon Lay member V

Jane Wilmot Lay member V

Philip Young Lay member and Audit Chair V

Nick Martin Lay member V

Dr Amy Wilson GP member V

Clare Parker Accountable Officer (Left 30 April 2018) V

Rob Larkman Interim Accountable Officer, NW London CCGs

(Appointed 1 May 2018 – until 16 June 2018)

V

Mark Easton (1)

Accountable Officer – NW London CCGs

(Appointed 1 June 2018) V

Paul Brown (2) Chief Finance Officer - NW London CCGs (Appointed 19 November 2018)

V

Janet Cree Managing Director V

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Dr Andy Petros Secondary care clinician V

Mary Mullix Director of Quality and Safety (Until 1 July 2018) V

Diane Jones Chief Nurse and Director of Quality, NW London CCGs (From 2 July 2018)

V

Ben Westmancott Director of Compliance NV

Keith Edmunds Chief Finance Officer - CWHHE CCGs (Left 20 April 2018)

V

Neil Ferrelly Chief Finance Officer - NW London CCGs (Left 14 December 2018)

V

Dr Pritpal Ruprai GP member V

Dr Victoria Cooney GP member V

Dr Smitha Addala GP member V

Katie Embleton System and IT manager V

Anita Parkin Interim Director of Public Health NV

Key: V - Voting member NV - Non-voting member

Notes: 1) The Accountable Officer, who sits across the eight CCGs in North West

London (NW London), was appointed from 01 June 2018, replacing Rob Larkman.

2) The Chief Finance Officer, who sits across the eight CCGs in North West London (NW London), was appointed from 16 November 2018, replacing Neil Ferrelly.

3.4 Committees, including Audit Committee

In line with the CCG’s constitution, and in furtherance of the effective discharge of its functions, the Governing Body has established the following Committees:

NW London Audit Committee

NW London Remuneration Committee

CWHHE Investment Committee (an independent Committee of the Governing Bodies for managing issues affected by potential conflicts of interest)

Primary Care Commissioning Committee

Quality Patient Safety and Risk Committee

Finance and Performance Committee

Information Management and Technology (IM&T) Committee

Health & Safety Committee.

NW London Joint Committee

NW London Finance Committee

NW London Shadow Quality and Performance Committee Details of the work of these Committees, their members and levels of attendance are set out in the CCG’s Annual Governance Statement at Section 5 below. The role, membership and activities of the Remuneration Committee are covered in the

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Remuneration Report at section 6.1.

3.5 Register of Interests

NHS Hammersmith and Fulham CCG maintains a Register of Interests that details names of individuals and details of their interest. Individuals will declare any interest that they have, which may lead to a conflict with the interests of the CCG in relation to any decision to be made by the CCG. The Register of Interests is available here.

3.6 Raising concerns – whistleblowing arrangements NHS Hammersmith and Fulham CCG has a policy and procedure in place for staff and external parties to raise concerns without fear of reprisal or victimization which demonstrates the CCG’s commitment and support to those who may need to come forward. Concerns may relate to unlawful conduct, financial malpractice or malpractice related to patients, employees, the public or the environment. Where concerns have been raised, the CCG has carried out an investigation following the due process outlined in our Raising Concerns (Whistleblowing) Policy and reported the outcomes as appropriate.

3.7 Personal data related incidents There were no personal data related incidents reported to the Information Commissioner’s Office during the year.

3.8 Statement of Disclosure to Auditors

Each individual who is a member of the CCG at the time the Members’ Report is approved confirms:

So far as the member is aware, there is no relevant audit information of which the CCG’s auditor is unaware that would be relevant for the purposes of their audit report

The member has taken all the steps that they ought to have taken in order to make him or herself aware of any relevant audit information and to establish that the CCG’s auditor is aware of it.

3.9 Modern Slavery Act

NHS Hammersmith and Fulham CCG fully supports the Government’s objectives to eradicate modern slavery and human trafficking but does not meet the requirements for

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producing an annual Slavery and Human Trafficking Statement as set out in the Modern Slavery Act 2015.

4. Statement of the Accountable Officer’s Responsibilities

The National Health Service Act 2006 (as amended) states that each Clinical Commissioning Group shall have an Accountable Officer and that Officer shall be appointed by the NHS Commissioning Board (NHS England). NHS England has appointed Mark Easton to be the Accountable Officer of NHS Hammersmith and Fulham CCG. The responsibilities of an Accountable Officer are set out under the National Health Service Act 2006 (as amended), Managing Public Money and in the Clinical Commissioning Group Accountable Officer Appointment Letter. They include responsibilities for:

The propriety and regularity of the public finances for which the accountable officer is answerable

For keeping proper accounting records (which disclose with reasonable accuracy at any time the financial position of the Clinical Commissioning Group and enable them to ensure that the accounts comply with the requirements of the Accounts Direction).

For safeguarding the Clinical Commissioning Group’s assets (and hence for taking reasonable steps for the prevention and detection of fraud and other irregularities)

The relevant responsibilities of accounting officers under managing public money

Ensuring the CCG exercises its functions effectively, efficiently and economically (in accordance with Section 14Q of the National Health Service Act 2006 (as amended)) and with a view to securing continuous improvement in the quality of services (in accordance with Section14R of the National Health Service Act 2006 (as amended))

Ensuring that the CCG complies with its financial duties under Sections 223H to 223J of the National Health Service Act 2006 (as amended).

Under the National Health Service Act 2006 (as amended), NHS England has directed each Clinical Commissioning Group to prepare for each financial year a statement of accounts in the form and on the basis set out in the Accounts Direction. The accounts are prepared on an accruals basis and must give a true and fair view of the state of affairs of the Clinical Commissioning Group and of its income and expenditure, Statement of Financial Position and cash flows for the financial year.

In preparing the accounts, the Accountable Officer is required to comply with the requirements of the Government Financial Reporting Manual and in particular to:

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Observe the Accounts Direction issued by NHS England, including the relevant accounting and disclosure requirements, and apply suitable accounting policies on a consistent basis

Make judgements and estimates on a reasonable basis

State whether applicable accounting standards as set out in the Government Financial Reporting Manual have been followed, and disclose and explain any material departures in the accounts; and

Prepare the accounts on a going concern basis; and

Confirm that the Annual Report and Accounts as a whole is fair, balanced and understandable and take personal responsibility for the Annual Report and Accounts and the judgements required for determining that it is fair, balanced and understandable.

As the Accountable Officer, I have taken all the steps that I ought to have taken to make myself aware of any relevant audit information and to establish that NHS Hammersmith and Fulham CCG’s auditors are aware of that information. So far as I am aware, there is no relevant audit information of which the auditors are unaware. I also confirm that:

as far as I am aware, there is no relevant audit information of which the CCG’s auditors are unaware, and that as Accountable Officer, I have taken all the steps that I ought to have taken to make myself aware of any relevant audit information and to establish that the CCG’s auditors are aware of that information.

To the best of my knowledge and belief, and subject to the disclosures set out below, I have properly discharged the responsibilities set out under the National Health Service Act 2006 (as amended), Page 72 Managing Public Money and in my Clinical Commissioning Group Accountable Officer Appointment Letter. Disclosures:

as described in the section 2.2.1 on meeting our financial duties on page 18, and also in note 15 to the Financial Statements, the CCG did not remain within its revenue resources limit in 2018/19 and has reported a deficit position as outlined in the performance report. The CCG has also set a deficit budget for 2019/20

a report under s30 of the Local Audit and Accountability Act 2014 was issued on 21 May 2019 by our external auditors to the Secretary of State for Health and Social Care setting out the breach of financial duties as set out above.

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5. Governance Statement

5.1 Introduction and context

NHS Hammersmith and Fulham CCG is a body corporate established by NHS England on 1 April 2013 under the National Health Service Act 2006 (as amended). The clinical commissioning group’s statutory functions are set out under the National Health Service Act 2006 (as amended). The CCG’s general function is arranging the provision of services for persons for the purposes of the health service in England. The CCG is, in particular, required to arrange for the provision of certain health services to such extent as it considers necessary to meet the reasonable requirements of its local population. These accounts have been prepared on a going concern basis despite the issue of a report to the Secretary of State for Health under Section 30 of the Local Audit and Accountability Act 2014. Public sector bodies are assumed to be going concerns where the continuation of the provision of a service in the future is anticipated, as evidenced by inclusion of financial provision for that service in published documents. NHS England has issued indicative resources allocations for the clinical commissioning group for the next 5 years and as services will continue to be provided the financial statements are prepared on the going concern basis. As at 1 April 2018; the clinical commissioning group was not subject to any directions from NHS England, issued under Section 14Z21 of the National Health Service Act 2006. A full list of formal powers of direction can be viewed on the NHS England website.

5.2 Scope of responsibility

As Accountable Officer, I have responsibility for maintaining a sound system of internal control that supports the achievement of the Clinical Commissioning Group’s policies, aims and objectives, whilst safeguarding the public funds and assets for which I am personally responsible, in accordance with the responsibilities assigned to me in Managing Public Money. I also acknowledge my responsibilities as set out under the National Health Service Act 2006 (as amended) and in my Clinical Commissioning Group Accountable Officer Appointment Letter. I am responsible for ensuring that the clinical commissioning group is administered prudently and economically and that resources are applied efficiently and effectively, safeguarding financial propriety and regularity. I also have responsibility for reviewing the effectiveness of the system of internal control within the clinical commissioning group as set out in this governance statement.

5.3 Governance arrangements and effectiveness

The main function of the governing body is to ensure that the group has made appropriate arrangements for ensuring that it exercises its functions effectively, efficiently and economically and complies with such generally accepted principles of good governance

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as are relevant to it.

5.3.1 CCG constitution and structure

NHS Hammersmith and Fulham CCG maintains a constitution and associated Standing Orders, Prime Financial Policies and Scheme of Delegation. The Constitution sets out the arrangements made by the Clinical Commissioning Group (CCG) to meet its responsibilities for commissioning care for the people for whom it is responsible. The constitution describes the governing principles, rules and procedures that the CCG has established to ensure probity and accountability in the day-to-day running of the CCG. Above all, the constitution exists to ensure that decisions are taken in an open and transparent way and that the interests of patients and the public remain central to all that the CCG does. The Clinical Commissioning Group is accountable to its members, the public, its stakeholders and NHS England for exercising the statutory functions of the CCG. The CCG may delegate the authority to act on its behalf to individuals or other bodies, such as its governing body, any of its members, a committee or sub-committee of the CCG or Governing Body, and also its employees. The CCG’s Scheme of Reservation and Delegation sets out those decisions that are reserved for the membership as a whole, and those decisions that are the responsibilities of its governing body (and its committees and sub-committees), the CCG’s committees and sub-committees, individual members and employees. The Clinical Commissioning Group remains accountable for all of its functions, including those that it has delegated. NHS Hammersmith and Fulham CCG has delegated its decision making and responsibility for the delivery of all of its duties to the Governing Body but has maintained its authority to:

Determine the arrangements by which the members of the CCG approve those decisions that are reserved for the membership

Consider and approve applications to NHS England on any matter concerning changes to the CCG’s constitution

Approve the arrangements for identifying practice members to represent practices in matters concerning the work of the CCG and appointing clinical leaders to represent the CCG’s membership on the CCG’s Governing Body, for example through election

Approve the appointment of Governing Body members, the process for recruiting and removing non-elected members to the Governing Body (subject to any regulatory requirements) and succession planning.

The constitution of NHS Hammersmith and Fulham CCG was amended during 2018/19 to incorporate the changes required to harmonise the constitutions of the eight North West London CCGs (NHS Brent CCG, NHS Central London CCG, NHS Ealing CCG, NHS Hammersmith and Fulham CCG, NHS Harrow CCG, NHS Hillingdon CCG, NHS Hounslow CCG and NHS West London CCG), to allow for a more collaborative approach to ensure that the work of the Clinical Commissioning Groups is clear, consistent and legally compliant.

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The eight North West London CCGs (collectively known as NW London CCGs) have established a joint committee to enable a more coherent response to the challenges and risks faced by the North West London health ‘system’ as a whole.

The NW London CCGs provide the required transparent governance and accountability for joint decision-making amongst the Clinical Commissioning Groups. The local focus and local accountability of the CCGs is maintained in addition to the retention of each individual CCG’s statutory duties.

The amended Constitution was approved by the CCG Members and NHS England.

5.3.2 Governing Body

To undertake and ensure the systematic discharge of its functions and duties, the CCG established a Governing Body and committees. Details of their roles are set out below. The functions of the Governing Body are:

Commissioning primary care, community and secondary healthcare services (including mental health services) for: o All patients registered with its member GP practices. o All individuals who are resident within the London Borough of Hammersmith and

Fulham who are not registered with a member GP practice of any CCG

Commissioning emergency care for anyone present in the London Borough of Hammersmith and Fulham

Paying its employees’ remuneration, fees and allowances in accordance with the determinations made by NHS Hammersmith and Fulham CCG Governing Body and / or it Remuneration Committee, determining any other terms and conditions of service of the CCG’s employees

Determining the remuneration and travelling or other allowance of members of its Governing Body via the Remuneration Committee.

Performance of the Governing Body The Governing Body and its Committees has a membership drawn from a variety of sources, including NHS staff, clinicians and Lay members, to provide an appropriate balance of skills, experience, independence and knowledge to the Clinical Commissioning Group to enable its duties and responsibilities to be discharged effectively. All Governing Body members receive an annual appraisal and agree a personal development plan to review their performance and enable them to identify opportunities to update and refresh their skills and knowledge to support the work of the Clinical Commissioning Group. The CCG’s Governing Body has an ongoing requirement to review the Clinical Commissioning Group’s governance arrangements to ensure they reflect the principles of good governance. The Governing Body closely monitors and reviews the joint working

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arrangements in place within the North West London Clinical Commissioning Groups including:

the functions delegated to the North West London Joint Committee

the processes for the identification and management of Conflicts of Interests

ensuring that decisions made, either by the Governing Body or the North West London Joint Committee have been made in accordance with the agreed Scheme of Reservation and Delegation

Throughout 2018/19 the Governing Body maintained high standards in relation to good meeting attendance, robust management of Conflicts of Interests and high standards of meeting etiquette.

All papers presented at the Governing Body meetings follow a consistent format, with a standard cover sheet, to focus the Governing Body members’ attention to the key issues, risks, assurances and recommendations. The meeting papers and associated documents are received in advance of the meetings in a timely manner. The Audit Committee acknowledges that the CCG did not conduct a self-assessment of the effectiveness of the Governing Body during the financial year. It is planned that a programme of self-assessment will be undertaken during financial year 2019/20.

Name Role Attendance

(attended/total) Notes

Dr Tim Spicer Chair 4/6

Dr James Cavanagh

Vice Chair and GP member 6/6

Vanessa Andreae

Vice Chair and Practice Nurse member

4/6

Dr Tony Willis GP member 1/2

Resigned from the governing body and left the CCG in July 2018

Dr Paul Skinner GP member 6/6

Trish Longdon Lay member 6/6

Jane Wilmot Lay member 5/6

Philip Young Lay member 6/6

Nick Martin Lay member 5/6

Dr Amy Wilson GP member 5/6

Dr Pritpal Ruprai GP member 3/6

Dr Vicki Cooney GP member 6/6

Dr Smitha Addala GP member 6/6

Katie Embleton Site Operations Manager and elected Governing Body member

5/6

Dr Andy Petros Secondary care clinician 4/6

Clare Parker Accountable Officer 0/0 Left the

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CCG on 30 April 2018

Rob Larkman Interim Accountable Officer 1/1 Left the CCG in June 2018

Keith Edmunds Chief Finance Officer 0/0 Left the CCG on 20 April 2018

Neil Ferrelly Chief Finance Officer 4/4

Left the CCG on 14 December 2018

Mark Easton Accountable Officer 5/5 Joined the CCG in July 2018

Paul Brown Chief Finance Officer ½

Joined the CCG in November 2018

Janet Cree Managing Director 6/6

Mary Mullix Director of Quality and Safety 2/2 Until 1 July 2018

Diane Jones Chief Nurse and Director of Quality 4/5 From 2 July 2018

Ben Westmancott

Director of Compliance 6/6

Anita Parkin Interim Director of Public Health 4/6

5.3.3 Audit Committee

The Audit Committee is accountable to the Governing Bodies of the Clinical Commissioning Groups’ to provide independent scrutiny of the Clinical Commissioning Groups’ arrangements for risk management, governance and internal control. The Committee tests the veracity and robustness of all of the CCG’s assurance mechanisms, including those for quality and performance, and supports the maintenance of an appropriate relationship between the CCG and its auditors. To this end, the remit of the Audit Committee includes:

Governance, risk management and internal control

Internal audit

External audit

Other assurance functions (review of other significant assurance functions, and consideration of the implications for the governance of the clinical commissioning groups)

Counter fraud

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Management (Receipt of reports and positive assurances from members of the CCG Governing Body, directors and managers on the overall arrangements for governance, risk management and internal control)

Financial reporting.

The Audit Committee reviews the annual report and financial statements before submission to the Governing Body and the relevant Clinical Commissioning Group, with a particular focus on:

the wording of the Governance Statement and other disclosures relevant to the Terms of Reference of the Committee;

changes in, and compliance with, accounting policies, practices and estimation techniques;

unadjusted misstatements in the financial statements;

significant judgements in the preparation of the financial statements;

significant adjustments resulting from the audit; letter of representation; and qualitative aspects of financial reporting.

The Audit Committee is able to commission professional or expert advice, reports or surveys it deems necessary to conduct its duties.

To discharge these duties, the Audit Committee met in total on five occasions during the year, attendance tables are below for those meetings.

The Audit Committees of Central London, West London, Hammersmith and Fulham, Hounslow and Ealing (CWHHE) CCGs met in common three times prior to October 2018:

Name Role Attendance

(attended/total)

Philip Young

Chair for CWHHE CCGs Audit,

Remuneration and Finance

Committees and Lay member

Ealing CCG (Audit and

Governance Lead)

3/3

Dr Raj Chandok Ealing CCG GP Governing Body

member 3/3

Diana Middleditch Central London CCG Lay member 1/3

Nick Martin Hammersmith and Fulham CCG

Lay member 2/3

Trevor Woolley Hounslow CCG Lay member 3/3

Simon Tucker West London CCG Lay member 1/3

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From October 2018, the Audit Committee’s meetings were held in common, attended by the eight North West London CCGs (which included the five detailed above, and also Brent, Harrow and Hillingdon (BHH) Clinical Commissioning Groups). In this manner, the Audit Committee met twice with attendance as follows:

Name Role Attendance

(attended/total)

Philip Young

Chair for CWHHE CCGs Audit,

Remuneration and Finance

Committees and Lay member

Ealing CCG (Audit and

Governance Lead)

2/2

Lindsey Wishart

Acting Chair of BHH CCGs Audit & Remuneration Committees from 1 August 2018 and Lay Member Brent CCG

2/2

Dr Vidhya Kumaranayakam Brent CCG GP Governing

Body member 2/2

Dr Raj Chandok Ealing CCG GP Governing

Body member 2/2

Andrew McCall Central London CCG Lay

member 1/1

Diana Middleditch Central London CCG Lay

member 1/1

Nick Martin Hammersmith and Fulham

CCG Lay member 2/2

Allison Seidlar Hillingdon CCG Lay member 2/2

Hiten Shah Harrow CCG Lay member 1/1

Richard Smith Harrow CCG Lay member 1/1

Trevor Woolley Hounslow CCG Lay member 2/2

Simon Tucker West London CCG Lay

member 1/2

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5.3.4 Other Governing Body Committees

Primary Care Commissioning Committee

From 1 April 2017, under delegated authority from NHS England, the CCG took on responsibility for the commissioning and management of primary care medical services. To enable the CCG to fulfil these responsibilities appropriately, the Governing Body established a Primary Care Commissioning Committee with a non-conflicted voting membership. The role of the committee is to carry out the functions relating to the commissioning of primary medical services under section 83 of the NHS Act. This includes the following:

GMS, PMS and APMS contracts (including the design of PMS and APMS contracts, monitoring of contracts, taking contractual action such as issuing branch/remedial notices, and removing a contract)

Providing assurance to the Governing Body and NHS England on quality, performance and finance of all services commissioned from primary care which incorporate the delegated funding and funding from the core CCG allocation (for example prescribing, incentive schemes and local primary care contracts)

Newly designed enhanced services (“Local Enhanced Services” and “Directed Enhanced Services”)

Design of local incentive schemes as an alternative to the Quality Outcomes Framework (QOF)

Decision making on whether to establish new GP practices in an area;

Approving practice mergers, and

Making decisions on ‘discretionary’ payment (e.g., returner/retainer schemes)

Agreeing and monitoring a financial plan and budget; risk assessment, performance framework and annual work plan.

The CCG will also carry out the following activities, in collaboration with other NW London CCGs:

To plan, including needs assessment, primary medical care services in the Hammersmith and Fulham area

To undertake reviews of primary medical care services in the Hammersmith and Fulham area

To co-ordinate a common approach to the commissioning of primary care services generally

To manage the budget for commissioning of primary medical care services in the Hammersmith and Fulham area.

The committee is accountable for exercising the agreed delegated functions from NHS England are set out in schedule 2. NHS England retains the responsibility for individual practitioner performance whilst the CCG will have responsibility for practice contract performance. Over the course of the year, the committee met in public eight times. The main areas considered by the committee were:

18-19 Primary Care draft Budgets

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Enhanced Primary Care Contract Update

Primary Care Medical Services, Monthly Financial Report and update

Prescribing Element of Enhanced Primary Care Contract

Enhanced Primary Care (EPC) Business Case

General Practice at Scale

Primary Care Quality Standards

2017-18 Primary Care Investment Programme Update

NW London Primary Care Workforce Strategy update

Primary Care update including an update on estates

Electronic Referral Service (eRS) update

Primary Care Access - Extended Hours & Weekend Plus

Primary Care Risk Register

Out of Hospitals Services Update

NHS England consultations on ‘digital-first Primary Care’ and ‘QOF’

Contract Variations for 4 practices in Hammersmith and Fulham

Next steps for Strategic Commissioning Framework

Digital Development

Enhanced Primary Care Performance Report

111 In-Hours Direct Appointment Booking

Babylon GP at Hand Independent Evaluation

Babylon GP at Hand relocation

Name Role Attendance

(attended/total) Notes

Dr James Cavanagh Vice Chair/GP member 7/8

Vanessa Andreae Vice Chair/Practice Nurse 7/8

Trish Longdon Lay member 8/8

Jane Wilmot Lay member 6/8

Janet Cree Managing Director 7/8

Owen White Interim Deputy Chief Finance Officer

6/8

Dr Andy Petros Secondary care clinician 4/8

Mark Jarvis Head of Governance and Engagement

7/8

Debbie Parkin Head of Primary Care 8/8

Sue Pascoe Deputy Director of Quality Improvement, CWHHE

5/8

Pippa Street Deputy Director for Quality of Care, CWHHE

1/1

Julie Sands Head of Primary Care NW London 7/8

Toby Hyde Assistant Director for Clinical Quality Improvement and Assurance

4/4 Left the CCG in September 2018

Margie O’Connell Assistant Director for Clinical Quality Improvement and

7/8

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Assurance

Dr Catherine Millington-Sanders

Independent GP 6/8

Eva Psychrani Engagement Lead, Healthwatch 6/8

Dr Seth Dassanayake Local Medical Committee representative

2/8

Adam Jenkins Chair of Ealing Local Medical Committee

5/8

Kyla Cranmer Local Medical Committee representative

1/2

Ann Whateley Director of Primary Care Commissioning and Transformation

2/5

Dr Phil Koczan Clinical Safety Officer (London Region)

1/1

Finance and performance committee The purpose of the committee is to provide assurance to the CCG Governing Body that financial plans are robust and that risks to delivering financial obligations are being managed appropriately. The committee is accountable to the Hammersmith and Fulham CCG Governing Body and reports by way of the minutes supported by a written report. The committee has met 12 times during the course of the financial year. Amongst the main areas considered by the committee during the course of the year were:

The consideration of new investment proposals for approval up to £500k such as the NW London diabetes transformation programme business case, Milson Road development in 2018/19, community independence service re-procurement, enhanced primary care contract business case for 2018/19, West London counselling centre contract extension for the provision of Increasing access to psychological therapies (IAPT) and early intervention in psychosis draft business case for delivering EIP to the residents of Ealing, Hammersmith and Fulham , and Hounslow.

The review and in-depth scrutiny of substantial investment proposals over £500k such as the Better Care Plans and Primary Care budgets, for recommendation and Governing Body approval.

Additionally, the committee received and debated reports for the following areas:

Podiatric surgery transformation

Charging rate : ucc utilisation

Hammersmith and Fulham CCG contract register and pipeline

Financial recovery group terms of reference and plans

Monthly CCG finance and activity reports plus the NW London financial position

Primary Care budget reports

Enhanced Primary Care contract

Better Care Fund

Financial governance checklist

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Imperial contract performance and trend analysis

Hammersmith and Fulham CCG five year financial forward view 2019-2024

Hammersmith and Fulham CCG financial recovery programme

The committee considered and recommended CCG budgets, business and operating plans to the Governing Body:

It received QIPP plans for scrutiny and recommendation to the Governing Body

Scrutinised financial risks through the corporate risk register process and advised the Governing Body of any significant risks and controls in place to mitigate these risks

Monitored financial performance alongside quality and agreed remedial action to improve performance where required

Met with the Quality, Patient Safety and Risk Committee to review items of business that overlap in particular the Integrated Quality and Performance Report for our main provider organisations to consider performance and quality against key performance indicators and update on the monthly QIPP Plan and Financial Recovery Plan, and escalate up to the governing body any areas of concern and level of assurance established to reassure governing body and public members

The membership of the group consists of:

CCG Governing Body representatives to include;

One lay member

Managing director or deputy

Chief Finance Officer, or deputy

Senior management representative.

Name Role Attendance

(attended/total) Notes

Nick Martin Lay member 8/12

Dr James Cavanagh

Vice Chair and GP member 11/12

Dr Tony Willis GP member 2/3 Left the CCG in July 2018

Dr Paul Skinner GP member 10/12

Vanessa Andreae Vice Chair and Practice Nurse member

1/1

Janet Cree Managing Director 8/12

Neil Ferrelly Chief Finance Officer, NW London CCGs

2/2

Left the CCG in November 2018

Trish Longdon Lay member 2/2

Pritpal Ruprai GP member 8/9 Pritpal moved to the Quality,

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Patient Safety and Risk Committee in January 2019

Dr Vicki Cooney GP member 8/12

Dr Smitha Addala GP member 9/12

Katie Embleton Site Operations Manager and elected Governing Body member

7/9

Katie moved to the Quality, Patient Safety and Risk Committee in January 2019

Dr Andy Petros Secondary care clinician 9/12

Sue Roostan Deputy Managing Director 11/12

John Lesley Interim Deputy Chief Finance Officer, CWHHE

3/3

Left the CCG in December 2018

Philip Young Lay member 2/2

Sharon Robson Associate Director of Acute Finance

8/12

David Hill Senior Contracts Manager, Imperial Contract

7/10

Owen White Interim Deputy Chief Finance Officer

11/12

Quality patient safety and risk committee The purpose of the committee is:

To assure that systems are in place to manage clinical and quality risk

To assure quality of services, focusing on the three pillars of quality: patient safety, clinical effectiveness and patient experience

To identify and report potential clinical risks, and to escalate as appropriate to the CCG Governing Body.

Over the course of last year, the quality patient safety and risk committee met nine times and scrutinised and monitored a number of routine monthly, quarterly and annual quality reports for areas such as:

Patient safety quarterly report

LCW medial incident

Chelsea and Westminster CQC report

CLCH CQC inspection

Children and family act report and position report with regards to the future

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service

Podiatry surgery transformation briefing

Infection control annual report 17-18

Central contracts quarterly report

Quarterly safeguarding report

CLCH quality account commissioner statement

Imperial commissioner statement

Transforming care briefing update

Corporate quality risks

Mental health placement quarterly report

Update on implementation of the special educational needs and disabilities (send) reforms and quarterly reports

Family support report

Working together briefing to safeguard children 2018 and North West London child death overview panel, rapid response key work project briefing paper

performance review of initial health assessments for looked after children for the Bi-Borough and Hammersmith and Fulham

3 Borough child death overview panel 2017-18 annual report (Tri-Borough LSCB)

Annual report, looked after children 2017/2018 The committee met monthly in conjunction with the finance and performance committee to review and scrutinise items of business that overlap such as the integrated quality and performance report for the CCGs main provider organisations, including the CCGs QIPP plans and financial recovery plans, service changes also local joint quality and financial risks. It provided the governing body with a brief summation of the issues discussed and actions across a wide range of topics. Furthermore, it escalated good news stories, plus areas of concern and level of assurance in place to reassure members of the governing body and public.

Name Role Attendance

(attended/total) Notes

Vanessa Andreae Vice Chair and Practice Nurse Member

8/9

Trish Longdon Lay member 7/9

Jane Wilmot Lay member 7/9

Dr Amy Wilson GP member 8/9

Dr James Cavanagh

Vice Chair and GP member

3/4

Dr Vicki Cooney GP member 3/6 Moved to the F&P

committee from January 2019

Dr Smitha Addala GP member 3/6 Moved to the F&P

committee from January 2019

Katie Embleton Site Operations Manager and elected Governing Body member

7/9

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Mary Mullix Deputy Director of Quality, NW London CCGs

2/3

Mark Jarvis Head of Governance and Engagement

9/9

Sue Roostan Deputy Managing Director 8/9

Dr Pritpal Ruprai GP member 6/9

Dr Andy Petros Secondary care clinician 8/9

Margie O’Connell

Assistant Director for Clinical Quality Improvement and Assurance

7/9

Pippa Street Interim Deputy Director of Quality and Safety

2/2 Moved roles in October 2018

Eva Psychrani Engagement Lead, Healthwatch

2/2

Olivia Clymer Chief Executive Officer, Healthwatch

4/7

Information management and technology (IMT) committee The purpose of the committee is to initiate and manage the IT strategy for the CCG, which contributes to the achievements of the CCGs’ strategic and commissioning objectives The committee:

Provides NHS Hammersmith and Fulham CCG with an expert resource on both the safe and effective use of information technology, information systems and associated medical technology and the collation, dissemination and application of information within NHS Hammersmith and Fulham CCG.

oversees the development and implementation of initiatives to improve the quality, safety and cost effectiveness of applying technology and information systems across the functional areas of NHS Hammersmith and Fulham CCG’s work programme.

enables improved IT access /inter-operability and solutions between health and social care to drive improvements in patient care.

Over the course of the year, the committee met five times. It deliberated a number of areas such as the Estates Technology and Transformation Fund and project update, service desk performance, the local CCG budget and the NHS E-Referral Service (E-RS) and community pathways. It also discussed the assurance of the GP at Hand technical app, focused on the new enhanced data sharing model (eDSM) roll out and the new General Data Protection Regulations (GDPR) requirements and Data Controller role. Additionally it considered the options open to the CCG for practice SystmOne IT training and the new practice website. It deliberated the tele-dermatology project, the Health Help Now App role out and next steps and the NHS Hammersmith and Fulham CCG Annual Informatics Report for 2017-18. Furthermore, the committee monitored the IT local Budget and discussed online consultation and local digital plans. The IM&T committee reports to the Governing Body by means of the approved committee

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minutes supported by a written report to include updates on a number of key activities and work programme.

Name Role Attendance

(attended/total) Notes

Tony Willis

GM member and Clinical Lead for IT, Diabetes and CKD

1/2 Left the CCG in July 2018

Laurie Slater IT Lead and GP 5/5

Coral McNeilly

Primary Care Commissioning Manager 5/5

Bill Sturman Director of Informatics, NW London CCGs

1/1

Ian Riley

Director of Business Intelligence, NW London CCGs

2/5

Christine Dunne

Deputy Director of Primary Care Systems, NW London CCGs

5/5

John Keating

Deputy Director (IT Programmes), NW London CCGs

2/5

Faisal Siddiqi

Head of Service Delivery and Business IT, NW London CCGs

3/5

Zeba Jamal

Senior Primary Care Systems Facilitator, NW London CCGs

3/5

5.3.5 Joint committees with delegated decision making authority CWHHE Investment Committee Central London, Ealing, Hammersmith and Fulham and Hounslow Clinical Commissioning Groups (CWHHE) have established a joint investment committee which provides a forum for resolving issues and making recommendations to Governing Bodies where the CCG Governing Bodies face conflicts of interest. The committee considers decisions referred to it by the CCG Governing Bodies and makes recommendations on how to proceed or ratifies the processes employed to address conflict of interest issues. The committee can make decisions on behalf of the Governing Body when asked to do so by the Governing Body. Membership consists of:

Lay member for audit, remuneration and conflict of interest matters (Chair)

An additional lay member from each of the CCGs

Secondary care consultant Governing Body member for each CCG

Accountable Officer

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Chief Finance Officer

CCG chairs. Lay members and secondary care consultants are considered independent members (as flagged by ‘*’ below), unless they themselves have a conflict of interest with an item being discussed. The CCG chairs are also members of the committee but are not able to vote when they are conflicted. Their attendance, along with that of the Chair and chief financial officers, does not count towards the quorum. During 2018/19 the CWHHE Investment Committee met on 2 occasions:

Name Role Attendance

(attended/total)

Philip Young*

Chair for CWHHE CCGs Audit, Remuneration and Finance Committees and Lay member Ealing CCG (Audit and Governance Lead)

2/2

Dr Neville Purssell Central London CCG Chair 2/2

Dr Mohini Parmar Ealing CCG Chair and GP Clinical Director 0/2

Dr Tim Spicer Hammersmith and Fulham CCG Chair and GP Clinical Director

2/2

Dr Nicola Burbidge

Hounslow CCG Chair and GP Clinical Director

1/2

Dr Andrew Steeden

West London CCG Chair and GP Clinical Director

0/2

Dr Andy Petros* Secondary care consultant 0/2

Andrew McCall* Lay member for Central London CCG 2/2

Nick Martin* Lay member for Hammersmith and Fulham CCG

2/2

Simon Tucker* Lay member for West London CCG 0/2

Trevor Woolley* Lay member for Hounslow CCG 2/2

Mark Easton Accountable Officer – NW London CCGs (from 1 June 2018)

0/2

Neil Ferrelly Chief Finance Officer – NW London CCGs (until 18 November 2018)

0/2

Note: see section 6.4.3 for start and leave dates. The North West London Joint Committee (Previously the Shadow Joint Committee) The committee began meeting in shadow form in February 2018 to test its approach and areas of focus in preparation of seeking formal delegated authority from the NW London Governing Bodies. Following this, and the approval of the harmonised constitutions by NHS England, the committee became a formal body in late 2018, having its first formal

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meeting – in public - on 6 December 2018 in Westminster University. The committee has authority to take, on behalf of Governing Bodies, decisions on several key areas, largely relating to the collective management of the Health and Care Partnership and also NW London financial matters. To discharge tits duties, the Joint Committee met in total on 10 occasions during the year, attendance tables are below for those meetings. The Shadow Joint Committee met eight times prior to December 2018:

Name Role Attendance

(attended/total)

Marcia

Saunders

Interim Independent Chair of the Shadow

Joint Committee 5/5

Mark Easton Appointed 1

June 2018

Accountable Officer – NW London CCGs

From 1 June 2018 5/5

Rob Larkman Left 16 June

2018

Accountable Officer – NW London CCGs

Until 31 May 2018 5/5

Clare Parker Accountable Officer - CWHHE CCGs

Until 30 April 2018 1/3

Dr Madhukar C Patel

Chair and GP Clinical Director, Brent CCG

From 1 August 2018 2/2

Dr Etheldreda Kong

Chair and GP Clinical Director, Brent CCG

Until 31 August 2018 6/6

Dr Neville

Purssell

Chair and GP Clinical Director, Central

London CCG 7/8

Dr Mohini

Parmar Chair and GP Clinical Director, Ealing CCG 5/8

Dr Tim Spicer Chair and GP Clinical Director, Hammersmith

and Fulham CCG 7/8

Dr Genevieve

Small

Chair and GP Clinical Director, Harrow CCG

From 19 September 2018 1/1

Dr Amol

Kelshiker

Chair and GP Clinical Director, Harrow CCG

Until 18 September 2018 5/7

Dr Ian

Goodman

Chair and GP Clinical Director, Hillingdon

CCG 8/8

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Dr Nicola

Burbidge

Chair and GP Clinical Director, Hounslow

CCG 7/8

Dr Andrew

Steeden

Chair and GP Clinical Director, West London

CCG

Interim Chair 1 May 2018 to 19 February 2019

Chair from 20 February 2019

4/6

Dr Fiona Butler

Chair and GP Clinical Director, West London

CCG

Until 31 January 2019 (On sabbatical from 1

May 2018)

1/2

Dr Martin Lees Secondary care clinician 4/4

Dr Mona Vadiya Vice Chair, Central London CCG (deputy for

Managing Director) 1/1

Dr Raj Chandok Vice Chair, Ealing CCG 1/1

Dr Vijay Tailor Joint Vice Chair and GP member, Ealing CCG 3/3

Dr James

Cavanagh Vice Chair, Hammersmith and Fulham CCG 1/1

Dr Oisin

Brannick

GP Clinical Director, West London CCG

(deputy for Chair and GP Clinical Director) 1/1

Philip Young Lay member Ealing CCG, (audit,

remuneration and finance committee Chair) 5/6

Lindsey Wishart

Brent CCG Lay member and Acting Chair of

BHH Audit & Remuneration Committees from

1 August 2018

5/6

Allison Seidlar Lay member Hillingdon CCG (deputy Lay

member for audit and finance) 2/2

Nicholas Young Lay member Brent CCG (Lead for patient and

public involvement) 5/5

Trish Longdon Lay member Hammersmith and Fulham CCG 1/1

Sanjay Dighe Lay member Harrow CCG, patient

representation 1/1

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Richard Smith Lay member, Harrow CCG (deputy for Dr

Amol Kelshiker) 1/1

Trevor Begg Lay member Hillingdon CCG 1/1

Neil Ferrelly Chief Finance Officer - NW London CCGs 8/8

Sheik Auladin Managing Director, Brent CCG 6/8

Jules Martin Managing Director, Central London CCG 6/8

Tessa Sandall Managing Director, Ealing CCG 8/8

Javina Sehgal Managing Director, Harrow CCG

From 25 April 2018 4/5

Paul Jenkins Managing Director, Harrow CCG

Until 25 April 2018 3/3

Janet Cree Managing Director, Hammersmith and Fulham

CCG 6/8

Caroline

Morison Managing Director, Hillingdon CCG 6/8

Mary Clegg Managing Director, Hounslow CCG 7/8

Louise Proctor Managing Director, West London CCG 6/8

Jonathan

Turner

Deputy Managing Director, Brent CCG

(deputy for Managing Director) 1/1

Sue Roostan Deputy Managing Director, Hammersmith and

Fulham CCG (deputy for Managing Director) 1/8

Alexandra

Kalmis

Deputy Managing Director, Harrow CCG

(deputy for Managing Director) 1/5

Dr Annabel

Crowe

Deputy Managing Director Hounslow CCG,

(deputy for GP Clinical Director) 1/1

Simon Hope Deputy Managing Director, West London

CCG (deputy for Managing Director) 1/1

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Diane Jones

Director of Quality and Safety Chief Nurse and Director of Quality – NW

London CCGs from 2 July 2018 (formerly BHH

CCGs)

4/4

Mary Mullix Acting Director of Quality, Nursing and Patient Safety (With effect from 23 July 2017)

3/3

Melanie Smith Director of Public Health and Community

Wellbeing, Brent Council 2/4

Christine Vigars Healthwatch 7/8

Olivia Clymer Healthwatch (deputy for Christine Vigars) 1/8

Graham

Hawkes

Chief Executive Officer, Healthwatch

Hillingdon 3/4

The North West London CCG’s Joint Committee’ met twice thereafter:

Name Role Attendance

(attended/total)

Alan Wells

OBE FRSA Independent Chair of the Joint Committee 2/2

Mark Easton Accountable Officer, NW London CCGs 2/2

Dr Madhukar C Patel

Chair and GP Clinical Director, Brent CCG 2/2

Dr Neville

Purssell

Chair and GP Clinical Director, Central

London CCG 2/2

Dr Mohini

Parmar Chair and GP Clinical Director, Ealing CCG 2/2

Dr Tim Spicer Chair and GP Clinical Director, Hammersmith

and Fulham CCG 1/2

Dr Genevieve

Small Chair and GP Clinical Director, Harrow CCG 2/2

Dr Ian

Goodman

Chair and GP Clinical Director, Hillingdon

CCG 2/2

Dr Nicola

Burbidge

Chair and GP Clinical Director, Hounslow

CCG 1/2

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Dr Andrew

Steeden

Chair and GP Clinical Director, West London

CCG 2/2

Dr Martin Lees Secondary care clinician 1/2

Dr James

Cavanagh

Vice Chair, Hammersmith and Fulham CCG

(Deputy for Chair and GP Clinical Director) 1/2

Philip Young Lay member Ealing CCG, (audit,

remuneration and finance committee Chair) 2/2

Lindsey

Wishart

Brent CCG Lay member and Acting Chair of

BHH Audit and Remuneration Committees

from 1 August 2018

2/2

Nicholas

Young

Lay member Brent CCG (Lead for patient and

public involvement) 2/2

Paul Brown Chief Finance Officer - NW London CCG 2/2

Sheik Auladin Managing Director, Brent CCG 2/2

Jules Martin Managing Director, Central London CCG 1/2

Tessa Sandall Managing Director, Ealing CCG 2/2

Javina Sehgal Managing Director, Harrow CCG 2/2

Caroline

Morison Managing Director, Hillingdon CCG 2/2

Mary Clegg Managing Director, Hounslow CCG 2/2

Louise Proctor Managing Director, West London CCG 2/2

Diane Jones

Director of Quality and Safety

Chief Nurse and Director of Quality – NW

London CCGs from 2 July 2018 (formerly

BHH CCGs)

2/2

Lynn Hill Chair, Healthwatch Hillingdon 1/2

Christine

Vigars Healthwatch 2/2

North West London Joint Finance Committee

The Joint Finance Committee provides a forum where North West London Clinical Commissioning Groups performance is considered against the delivery of control totals and objectives set out in the strategy. The duties of the committee are:

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Make recommendations on the budget limits required in order to meet control totals

Recommend the financial strategy and framework for approval by statutory bodies

Understand cost variation in each of the CCGs and recommend actions to minimise financial impact; and

Form an NW London position on the financial impacts of joint procurements and business cases affecting multiple CCGs, advising decision-making bodies accordingly

To share and discuss the overall position with the CCGs and develop a deeper appreciation of the system requirements alongside the local pressures

Monitor in year performance against budgets and QIPP delivery and make recommendations on remedial action for local implementation. The Committee will consider regular reports from the Business Planning Recovery Group (BPRG) on its work, progress, risks and issues in this regard

Allow each CCG to account for delivery of our respective contributions to agreed business cases and agreed financial framework

Review the impact of any CCGs’ variance with their control total, highlighting material variances to the NW London Joint Committee for them to hold CCGs to account; and

Oversee the financial management of acute budgets and core mental health budgets.

To discharge its duties, the Joint Finance Committee met in total on six occasions during the year, attendance table for those meetings is below:

Name Role Attendance

(attended/total)

Lindsey Wishart NW London Finance Committee Chair and Chair of Brent CCG Finance Committee (Lay member)

6/6

Dr Mona Vaidya Chair of Central London CCG Finance committee (GP) from November 2018

4/5

Dr Paul O’Reilly Chair of Central London CCG Finance committee (GP) to November 2018

0/1

Philip Young Chair of Ealing CCG Finance Committee (Lay Member)

4/6

Dr Paul Skinner Chair of Hammersmith and Fulham CCG Finance committee (GP)

0/0

Richard Smith Chair of Harrow CCG Finance Committee (Lay member)

5/6

Allison Seidlar Chair of Hillingdon CCG Finance Committee (Lay member)

5/6

Dr Fabio Conti Chair of Hounslow CCG Finance committee (GP)

4/5

Dr Andrew Steeden

Chair of West London CCG Finance committee (GP)

5/6

Dr Vidhya Kumaranayakam

GP member of Brent CCG Finance Committee

2/2

Dr Raj Chandok GP member of Ealing CCG Finance Committee

1/1

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Dr Mohini Parmar GP member of Ealing CCG Finance Committee

1/1

Nick Martin Lay member of Hammersmith and Fulham CCG Finance Committee

5/6

Diana Middleditch Lay member, Central London CCG 1/1

Mark Easton Accountable Officer - NW London CCGs 5/6

Paul Brown Chief Finance Officer - NW London CCGs (from 19 November 2018)

4/4

Neil Ferrelly Chief Finance Officer - NW London CCGs (until 19 November 2018)

2/2

Sheik Auladin Managing Director, Brent CCG 3/6

Jules Martin Managing Director, Central London CCG

5/6

Tessa Sandall Managing Director, Ealing CCG 5/6

Janet Cree Managing Director, Hammersmith and Fulham CCG

4/6

Javina Seghal Managing Director, Harrow CCG 4/6

Caroline Morison Managing Director, Hillingdon CCG 6/6

Mary Clegg Managing Director, Hounslow CCG 5/6

Louise Proctor Managing Director, West London CCG 4/6

Jonathan Turner Deputy Managing Director, Brent CCG 1/1

Jason Antrobus Deputy Managing Director, Ealing CCG 1/1

Susan Roostan Deputy Managing Director, Hammersmith and Fulham CCG

2/2

Ali Kalmis Deputy Managing Director, Harrow CCG 1/1

5.3.6 Other Joint Committees Shadow Quality and Performance Committee The Committee has delegated responsibility to oversee quality and performance issues for the services commissioned by the eight North West London Clinical Commissioning Groups. The main purpose of the Committee is to provide oversight of the following areas:

NHS Constitutional Standards

NHS Improvement and Assessment Framework

Strategic direction and agreeing priorities for quality and performance

Acute/ Mental Health and Learning Disability

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Provider concerns including primary care affecting multiple organisations

Response to national reports/ guidance, and implications for commissioners and providers

Statutory reports: safeguarding/ infection control/ emergency planning/ complaints before presentation to CCGs for ratification.

The Committee currently meets in Shadow Form to test and refine its function and remit before seeking delegated authority to act on behalf of the Governing Body.

5.4 UK Corporate Governance Code NHS Bodies are not required to comply with the UK Code of Corporate Governance. For the financial year ended 31 March 2019, and up to the date of the signing of this Governance statement, the Clinical Commissioning Group has complied with Section 14L (2) (b) of the National Health Service Act 2006 to at all times observe “such generally accepted principles of good governance as are relevant to it” in the way it conducts its business, through:

the highest standards of propriety involving impartiality, integrity and objectivity in relation to the stewardship of public funds, the management of the organisation and the conduct of its business;

The Good Governance Standard for Public Services;

The CCG Governing Body and its committees and sub-committees adopted and practiced the standards of behaviour published by the Committee on Standards in Public Life (1995) known as the ‘Nolan Principles’

the seven key principles of the NHS Constitution; and

the Equality Act 2010.

5.5 Discharge of statutory functions In light of recommendations of the 2013 Harris Review, the clinical commissioning group has reviewed all of the statutory duties and powers conferred on it by the National Health Service Act 2006 (as amended) and other associated legislative and regulations. As a result, I can confirm that the clinical commissioning group is clear about the legislative requirements associated with each of the statutory functions for which it is responsible, including any restrictions on delegation of those functions. Responsibility for each duty and power has been clearly allocated to a lead director. Directorates have confirmed that their structures provide the necessary capability and capacity to undertake all of the clinical commissioning group’s statutory duties.

5.6 Risk management arrangements and effectiveness

5.6.1 Risk management strategy

The risk management strategy published in 2017 outlines NHS Hammersmith and

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Fulham CCG approach to risk management and its vision in relation to assurance systems. The Risk Management Strategy details the CCGs appetite for risk and the methods by which risks are identified and evaluated and how risks are managed using control mechanisms.

NHS Hammersmith and Fulham CCG is committed to having a risk management culture that underpins and supports the business of the CCG’s. It intends to demonstrate an on-going commitment to improving the management of risk throughout the organisation.

Risk management

Risk management by the Governing Body is underpinned by a number of interlocking systems of control:

Board Assurance Framework (BAF) sets out the strategic objectives, identifies risks in relation to each strategic objective along with the controls in place and assurances available on their operation

Corporate Risk Register (informed by Team, Work Stream and Directorate risks) is the corporate high level operational risk register used as a tool for managing risks and monitoring actions and plans against them. Used correctly, it demonstrates that an effective risk management approach is in operation within the organisation

Audit and other committees exist to provide scrutiny and assurance of the robustness of risk processes and to support the Governing Body.

The consequences of some risks, or the action needed to mitigate them, can be such that it is necessary to escalate the risk to a higher management level. For example from a directorate (work-stream) risk register to the corporate register, or from the team risk register to the directorate risk register. Risks are reviewed according to assigned domains by the appropriate CCG committee. Activities will be controlled using the risk management process and staff are empowered to tackle risks. Identifying risks This is about identifying, evaluating and managing changes in the risk environment, preferably before they manifest as a risk or become a threat to the business. This can also be described as horizon scanning. Horizon scanning can identify positive areas for NHS Hammersmith and Fulham CCG to develop its business and services, taking opportunities where these arise. The CCG will work collaboratively with partner organisations and statutory bodies to horizon scan and will be attentive and responsive to change. Horizon scanning should link into and inform the business planning process.

NHS Hammersmith and Fulham CCG uses the following techniques to identify risks:

Internal methods – such as complaints, claims, identification of

trends, audits, QIPP related risks, project risks, patient satisfaction surveys, whistle-blowing and monitoring the quality of commissioned services

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External Methods – HM Coroner reports, media, national reports, new legislation, surveys, reports from assessments/inspections by external bodies (e.g. CQC), reviews of partnership working, horizon scanning

Liaison – through practice visits, locality meetings, GP Forums, patient engagement forums, practice feedback forms and practice manager meetings.

Risk evaluation and response

Once the risk has been identified, the CCG will then decide how likely it is that the event will occur; that is; the level of risk and how to respond to it. When evaluating and planning risk response, the aim is to reduce the impact and chance of negative risks affecting the objectives and enhance the impact and chance of positive risk helping the objectives. Risk control

Responding to risk is about ensuring that there are appropriate controls in place. Controls are preventative measures to lessen or reduce the likelihood or consequence of the risk happening and the severity if it does. The CCG must ensure that each control (or action where a gap in control has been identified) has an owner and target completion date. The action owner should remember to consider the cost associated with managing the risk, as this may have a bearing on the decision. The Governing Body is responsible for determining the nature and extent of the risks that the CCG is willing to take to achieve its strategic objectives. By articulating its appetite for risk, the Governing Body sets a clear process for the management of risk and enhances the reporting of any instances where the appetite and specific risk thresholds are reached. The Governing Body will review its risk appetite on an annual basis or during times of increased uncertainty or adverse changes. The Governing Body makes clear that:

some acceptance of risk is necessary to allow the CCG to seize

important opportunities the level of risk is more acceptable in some areas than in others there is a point at which the management of a risk should be immediately

escalated to the direct oversight of the senior management team. A formal risk appetite statement sets a clear process for the management of risk and enhances the reporting of any instances where the appetite and specific risk thresholds are reached.

Prevention of risk

The CCG has both formal and informal mechanisms for identifying risks which may prevent it from achieving its objectives. One element of this pro-active risk management is prevention. Prevention is embedded within the operation of the CCG through:

an incident reporting policy which recognises that the vast majority of NHS

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patients receive high standards of care but acknowledges that incidents do occur and encourages prompt reporting as a key part of risk management

the risk evaluation of every decision the Governing Body and its committees are asked to make and

the impact assessment of all policies, practices, procedures and decisions to ensure equality and diversity compliance.

Deterrent to risks arising Although internal controls are in place, reliance on external organisations to perform key functions exposes NHS Hammersmith and Fulham CCG to some risk of fraud and bribery. Measures to mitigate these risks are included in the Anti-Fraud and Anti-Bribery Policy and are addressed as part of the annual Local Counter Fraud Specialist Work plan. Control mechanisms There are different operational levels of risk governance in the CCG. Operational risks are recorded and managed through the corporate risk register or through the Board Assurance Framework (BAF), if it is deemed that they could impact on the achievement of the CCGs strategic objectives. The risks in both documents record the risk, its causes and the effects are rated according to potential severity, which is calculated using weighted values for the likelihood of the risk occurring and the consequences if it does occur. Risks are categorised as either low, moderate, high or extreme.

Embedding risk management NHS Hammersmith and Fulham CCG’s processes for embedding risk management include:

Raising awareness Staff will have an awareness and understanding of the risks that affect patients, visitors, and staff.

Competence Staff will be competent at managing risk – through training and leadership culture and behaviours.

Processes and procedures The way we work mandates explicit consideration of risks – for example, all templates used for decision-making (Committee papers etc.) explore the key risks to an issue and link back to the strategic objectives and Board Assurance Framework.

Public stakeholder engagement NHS Hammersmith and Fulham CCG actively promotes patient and public involvement via partnership working and effective external and internal communication, website and intranet. The process for managing risk will be reviewed to continually improve. This will be integrated with our processes for providing assurance, and the processes of our stakeholders and any relevant third parties.

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5.6.2 Capacity to handle risk The Accountable Officer has overall responsibility for risk management and discharges this by:

continually promoting risk management and demonstrating leadership, involvement and support;

ensuring an appropriate committee structure is in place and ensuring each receives regular risk reports; and

ensuring that the Governing Body, management team, clinical directors and senior managers are appointed with managerial responsibility for risk management.

Staff are trained in risk management where required, and are equipped to manage risk appropriate to their authority and duties. This is facilitated through ownership of risks on the risk register which are subject to scrutiny, and being able to access specialist advice through the CCG’s Governance Lead. There are clear processes, as set out in the Risk Management Strategy for the escalation of risks to the BAF if required.

The Governing Body has a duty to assure itself that the organisation has properly identified the risks it faces, and that it has processes and controls in place to mitigate those risks and the impact they have on the organisation and its stakeholders. The Governing Body is responsible for:

identifying risks to the achievement of its strategic objectives as recorded on the BAF;

monitoring the BAF at each Governing Body meeting and to seek assurances from the CCG committees and lead Directors;

ensuring that there is a structure in place for the effective management of risk throughout the CCG; and

approving and reviewing strategies for risk management on an annual basis. The Governing Body is supported in that function in particular, by the Audit Committee which, in line with the NHS Audit Committee Handbook, ensures the CCG has an effective process in place with regards to risk management a n d monitors the quality of the assurance framework, referring significant issues to the Governing Body,

5.6.3 Risk assessment Using the risk and control framework, risk assessment is conducted in a systematic manner across all aspects of the CCG’s strategic and operational goals. The risks and the controls applied to the goals are actively scrutinised throughout the year by the Governing Body, responsible committees and the Senior Management Team. The Governing Body will review its risk appetite on an annual basis or during times of increased uncertainty or adverse changes. The periodic review and arising actions will be informed by an assessment of risk maturity, which in turn enables the Governing Body to determine the organisational capacity to control risk. Each risk is assigned a target risk rating and, if the Governing Body is satisfied that the

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level of risk has reduced to that level and is fully mitigated, it may direct that the risk be removed from the assurance framework.

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Risk Scoring = consequence x likelihood (C x L)

Likelihood

Likelihood score

1 2 3 4 5

Rare Unlikely Possible Likely Almost certain

5 Catastrophic 5 10 15 20 25

4 Major 4 8 12 16 20

3 Moderate 3 6 9 12 15

2 Minor 2 4 6 8 10

1 Negligible 1 2 3 4 5

Risks to governance, risk management and internal control As part of the approved internal audit plan for 2018/19, internal auditors were asked to undertake an audit of the CCG’s Board Assurance Framework and Risk Management. The internal auditors provided a reasonable assurance opinion and did not identify any significant control issues. The internal auditors concluded that the CCG has an adequate and effective framework for risk management, governance, internal control and information governance. They have identified further enhancements to the framework of risk management, governance, internal control and information governance to ensure that it remains adequate and effective. Risks to compliance The CCG’s annual assessment under NHS England’s Improvement and Assessment Framework provides assurance on the effective management of risks to compliance with the CCG’s continued authorisation to operate as a statutory body.

5.7 Other sources of assurance

5.7.1 Internal Control Framework

A system of internal control is the set of processes and procedures in place in the clinical commissioning group to ensure it delivers its policies, aims and objectives. It is designed to identify and prioritise the risks, to evaluate the likelihood of those risks being realised, the impact should they be realised, and to manage them efficiently, effectively and economically. The system of internal control allows risk to be managed to a reasonable level rather than eliminating all risk; it can therefore only provide reasonable and not absolute assurance of effectiveness.

The Governing Body of NHS Hammersmith and Fulham CCG maintains a comprehensive system of internal control through the application of its:

Constitution

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Standing orders Prime financial policies Scheme of reservation and delegation

The NW London Audit Committee considers a series of audits undertaken by both internal and external auditors on a regular basis throughout the financial year to assess the effectiveness of the organisation’s internal control mechanisms. This process provides the Governing Body with independent assurance of the adequacy of the controls in place.

5.7.2 Annual audit of conflicts of interest management

The revised statutory guidance on managing conflicts of interest for CCGs (published June 2016) requires CCGs to undertake an annual internal audit of conflicts of interest management. To support CCGs to undertake this task, NHS England has published a template audit framework. NHS Hammersmith and Fulham Clinical Commissioning Group conducted this Internal Audit in March 2019. The Internal Audit identified three examples of sound control design across the eight North West London CCGs, namely:

Registers of interest

Procurement register and decisions

Conflicts of Interest policy processes and procedures for the management of any breaches of interest.

Overall, the internal audit on conflict of interest management concluded that NHS Hammersmith and Fulham CCG’s Governing Body could take reasonable assurance that the controls in place to manage this risk are suitably designed and consistently applied. However, the audit has identified issues that need to be addressed in order to ensure that the control framework is effective in managing the identified risk(s).

The key issues noted for the CCG were as follows:

Assessment Area Compliant Action for CCG

Conflicts of Interest Guardian

No There will be a review into whether to adopt a Conflicts of Interest Guardian or to remain an outlier outside of the recommendation from NHS England.

Lay members on the Governing body to support with conflicts of interest management

Yes None

The CCG’s non-compliance with the Conflict of Interest Guardian is a conscious one; the CCG is content that both the spirit and the outcomes of the Conflict of Interest Guardian are met through its current structure and split of responsibilities between the (non-executive) Audit Committee Chair, the (executive) Director of Compliance and the lead

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governance officers. In considering whether to adopt the Conflict of Interest Guardian role into the structure, the CCG’s Audit Committee was concerned that doing so would cut across the established lines of executive accountability. So, whilst the Audit Committee Chair is the independent point of escalation for Conflict of Interest concerns, the title of Conflict of Interest Guardian has not been adopted.

5.7.3 Data quality

The CCG has robust processes and governance arrangements in place to ensure that the quality of data used by the Membership Body and Governing Body is accurate and fit for purpose. All data that is forwarded to the Governing Body has been discussed, and analysed at a minuted committee meeting prior to being submitted for discussion, noting or a formal decision at the Governing Body. The Membership Body and the Governing Body are assured that the data received is of sufficient quality to meet its requirements.

5.7.4 Information Governance The NHS Information Governance Framework sets the processes and procedures by which the NHS handles information about patients and employees, in particular personal identifiable information. The NHS Information Governance Framework is supported by a “Data Security and Protection” (DSP) Toolkit; (formerly known as the Information Governance (IG) Toolkit); and the annual submission process provides assurances to the Clinical Commissioning Groups, other organisations and individuals that personal information is dealt with legally, securely, efficiently and effectively. It also demonstrates the organisations compliance with the Principles of the General Data Protection Regulation (EU GDPR ) and the new Data Protection Act 2018 which both became Law on the 25th May 2018. The Clinical Commissioning Group places high importance on ensuring that there are robust Information Governance systems and processes in place to help protect patient and corporate information. The North West London Clinical Commissioning Groups have established an Information Governance Management Framework (IGMF). We are working through an action plan towards achieving full GDPR compliance which includes the appointment of the Data Protection Officer (DPO); in accordance with the requirements of Article 37(1) of the GDPR. The CCG has policies and controls in place to ensure that it is able to protect and maintain the confidentiality, integrity and availability of its electronic data, physical, and information assets. The CCG will seek assurances from its IT department regarding the robustness of the network infrastructure, data backup and business continuity processes in the event of a loss of service. The CCG ensures that all staff undertakes annual mandatory Information Governance training and that there are processes in place for incident reporting and investigation of serious incidents. The CCG has also developed information risk management procedures, and a programme to fully embed an information risk culture throughout the organisation has been implemented.

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Furthermore, a significant advisory audit is undertaken annually to test the coverage and veracity of the CCG’s Information Governance DSP Toolkit submissions prior to the 31 March deadline. The audit process, which was undertaken across all eight North West London Clinical Commissioning Groups, has enabled the establishment of comprehensive systems and processes that provide robust assurance of Information Governance DSP Toolkit compliance.

5.7.5 Business critical models

NHS Hammersmith and Fulham Clinical Commissioning Group has an appropriate framework and environment in place to provide quality assurance of business critical models, in line with the recommendations in the 2013 MacPherson review into quality assurance of analytical models. The Clinical Commissioning Group has implemented the following quality assurance systems to mitigate business risks:

Reviews of stakeholder experience including patient complaints and serious incident management arrangements

Risk assessment, through the use of a Risk Register and a Board Assurance Framework

An Internal audit programme and external audit review

Public and patient engagement

Business continuity procedures

5.7.6 Third party assurances

NHS Hammersmith and Fulham Clinical Commissioning Group contracts with several external organisations in relation to the provision of support services and functions. Where these contracts are managed nationally by NHS England, Service Auditor’s Reports, conducted by an independent auditor, are made available to the CCG via the NHS England SharePoint site. The CCG requests Service Auditor’s Reports in respect of contracts arranged directly with providers. The mid-year and end of year Service Auditor’s Reports received by the CCG Audit Committee provided assurance to the CCG on the effectiveness of the services and contractual arrangements.

5.7.7 Joint Health and Safety Committee

The North West London CCGs is working to harmonise its systems and processes across all eight clinical commissioning groups. In February 2019, the Health and Safety Committee held its first joint meeting. The terms of reference for the committee will be presented to the CCG Governing Bodies for approval once ready. The committee’s purpose is to ensure that the organisation is aware of, and is compliant with, its obligations under the Health and Safety at Work etc Act 1974 and that it has

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demonstrably effective mechanisms to manage risks and respond to incidents. The committee will provide assurances to the Governing Bodies. Its duties will include:

1. Keeping under review the systems and practices adopted in the CCGs to ensure that the objectives of our health and safety policy are achieved

2. The review of key H&S and staff well-being data and indicators to inform the formation of recommendations for corrective action to practice and / or policy, including (but not limited to):

a) incident and ‘near-miss’ reports b) high level sickness absence trends and the categories thereof,

particularly those which may be classed as ‘work-related’ (eg stress, carpal tunnel etc.) and those which may aid the assessment of the impact of staff well-being initiatives (e.g. ‘flu jabs); and

c) those which flows out of formal assessments, audits and monitoring mechanisms.

3. Consideration of safety audit reports, risk assessments and building statutory requirements

4. Consideration of reports from safety representatives including findings from their inspections.

5. Monitoring the effectiveness of the safety content of employee training and induction

6. Monitoring the adequacy of safety and health communication and publicity across the collaboration

7. Monitoring changes to health and safety legislation likely to impact on the Collaboration

8. Monitoring the development of the management systems, policies including procedures and processes

9. Monitoring the allocation of resources for health and safety.

5.7.8 Freedom of Information (FOI)

NHS Hammersmith and Fulham Clinical Commissioning Group, as a statutory body for the purposes of the Freedom of Information Act 2000, is required to respond to requests for information within 20 working days. It must either confirm that it does not hold the information or provide the information requested. The Act allows the CCG to exempt disclosure of some types of information where it is correct to do so and that it is in the public interest. The requester can refer the case to the ICO which has the regulatory duty to ensure public authorities comply with the Act and can investigate the CCG’s decision and handling of requests. In 2018/19 NHS Hammersmith and Fulham CCG received 277 requests between April 2018 and February 2019. The CCG responded to 87% within the same period. In addition to those requests received by the CCG there were 17 requests received and processed on behalf of the NW London Collaboration of CCGs (for example, requests relating to the NW London Health and Care Plan).

5.7.9 Emergency preparedness resilience and response

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Emergency preparedness, resilience and response is defined by a series of statutory responsibilities under the Civil Contingencies Act 2004 and the Health and Social Care Act 2012 which require NHS organisations to maintain a robust capability to plan for, and respond to incidents or emergencies that could impact on their communities. In accordance with the aforementioned legislation, NHS Hammersmith and Fulham CCG collaborates with the Clinical Commissioning Groups of North West London to develop incident response and threat specific plans, e.g. cold weather plans and severe weather plans to ensure we continue to deliver our critical business operations and support our partners in the event of a major incident or emergency. Furthermore, the CCG operates a robust on-call system 24 hours a day, seven days a week, 365 days a year to further ensure resilience across the local health economy. Our organisation is fully part of the local and regional emergency planning structure with regular representation at borough resilience forums and participates in multi- agency exercises, ensuring a proactive and coordinated approach to emergency preparedness. The North West London CCGs are committed to collaboratively implementing an integrated and dynamic business continuity management system which is aligned to ISO 22301, and an emergency preparedness and response capability to ensure the continued delivery of safe and effective healthcare commissioning and management across outer North West London. We certify that NHS Hammersmith and Fulham CCG has incident response plans and procedures in place, which are fully compliant with NHS England’s Emergency Preparedness 2015 Guidance and the EPRR Core Standards. The CCG regularly reviews and makes improvements to its major incident plan and has a programme for regularly testing and exercising this plan, the results of which are reported to the Governing Body.

5.8 Control issues

Control issues – specifically the in-year deficit position, underlying financial position and mitigating actions – are set out in more detail in section 5.9.1.

5.9 Review of economy, efficiency and effectiveness of the use of resources

The NHS Hammersmith and Fulham CCG Governing Body has overarching responsibility for ensuring the CCG has appropriate arrangements in place to exercise its functions effectively, efficiently and economically and in accordance with the CCG’s principles of good governance, as detailed in the Constitution.

Jointly with seven other NW London CCGs, NHS Hammersmith and Fulham CCG has established a collaborative arrangement to share a leadership team and work together to become effective commissioners. This collaborative agreement enables:

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the joint commissioning of high quality care the CCG to tackle cross borough issues maximum influence in negotiating and managing contracts with key providers shaping of the provider landscape in NW London and economies of scale.

The ratings for the Quality of Leadership Indicator (QLI) of the CCG Improvement and Assessment Framework Annual Assessment are published on MyNHS (www.nhs.uk/servicesearch/ performance/search). The year end results for 2018/19 will be available from approximately July 2019. The CCG is currently rated Requires Improvement. The CCG has developed and continues to refine systems and processes to effectively manage financial risks and to secure a stable financial position. The NW London Finance Committee reports and discusses the CCGs financial position, risks and actions to mitigate risks. In addition to reporting to the Governing Body, the Finance Committee provides monthly financial information to NHS England.

The NW London Audit Committee reports to the CCG’s Governing Body to provide an independent and objective view of the CCG’s efficiency and effectiveness, use of resources financial and control systems, financial and business information. The CCG’s annual report and accounts are reviewed by the Audit Committee prior to formal approval by the Governing Body. CCG is actively engaged in discussions regarding the limitations on resources within the NHS to ensure resources are prioritised in line with its strategic direction, including opportunities for developing new models of care with provider organisations. The CCG also recognises the need to achieve cost reductions through improved efficiency and productivity and work is ongoing to develop schemes to achieve the QIPP targets and savings which will include whole system transformation as part of future financial planning. A defined process is in development to ensure monitoring and oversight of such schemes.

5.9.1 Financial planning and in-year performance monitoring

The CCG’s planned surplus in year for 2018/19 was £0.4 million; the out turn position is a deficit of £16.9m and in the Financial year overspends were seen in all programme areas.

Of the total overspend of £17.3m, £11.6m was related to GP at Hand, and partly offset within North West London by intra-NW London transfers, leaving a residual cost of £10m. The remaining £7m of the variance was driven by a £7m under-delivery of efficiency savings. Underlying financial position The CCG plan for 2018/19 anticipated a closing Underlying Deficit of £4m whereas the actual end of year position is a £31.4m deficit. The £27.4m movement can be attributed to the full year effect of GP at Hand costs (£15.7m) plus the under-delivery of recurrent

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efficiencies (c£4.6m of the £9.7m delivered in 2018/19 was non-recurrent). The £15.5m difference between the in-year deficit of £16.9m and the underlying position of £31.4m is accounted for by a combination of items including: £3.9m of historic surplus drawdown; the £4.1m full year effect of GP at Hand costs; £4.6m of efficiencies delivered non-recurrently in 2018/19 plus c£3m related to non-recurrent in-year allocations, and other non-recurrent items.

5.9.2 Delegation of functions

The NW London Joint Committee was established in December 2018 across the eight North West London CCGs. The committee holds the delegated authority of the Governing Body to undertake decision making in relation to:

The Commissioning of Acute and Core Mental Health Services

Individual Funding Requests

The management of Financial Risks and Financial Strategy

The Governing Body is assured of the work of the Joint Committee through the provision of reports and minutes. The NW London Joint Finance Committee was established in September 2018 with delegated authority to:

hold individual CCGs accountable to each other for the delivery of the sector control total and the objectives set out in the NW London Financial Strategy (agreed in May 2018)

provide clear reporting about the differing elements of the strategy

oversee and approve the application of the risk share set out in the strategy

recommend to the NW London joint committee how the investment fund should be spent, based on detailed review of proposed business cases.

5.9.3 Counter fraud arrangements

NHS Hammersmith and Fulham CCG does not tolerate fraud and bribery within the NHS. The intention is to eliminate all NHS fraud and bribery as far as possible. The aim of the Anti-Fraud and Anti-Bribery Policy is to protect the property and finances of the NHS and of patients in our care. To meet its objectives, NHS Ealing CCG has adopted the seven-stage approach developed by the NHS Counter Fraud Authority (NHSCFA):

1. Creation of an anti-fraud culture. 2. Maximum deterrence of fraud. 3. Successful prevention of fraud which cannot be deterred. 4. Prompt detection of fraud which cannot be prevented. 5. Professional investigation of detected fraud. 6. Effective sanctions, including appropriate legal action against people committing

fraud and bribery.

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7. Effective methods of seeking redress in respect of money defrauded.

NHS Hammersmith and Fulham CCG will take all necessary steps to counter fraud and bribery in accordance with this policy, the NHSCFA Standards for Commissioners, the policy statement, Applying Appropriate Sanctions Consistently, published by the NHSCFA and any other relevant guidance or advice issued by the NHSCFA. NHS Ealing CCG also has a Standards of Business Conduct (gifts, hospitality and commercial sponsorship) Policy. A member of the Clinical Commissioning Group’s executive board is proactively and demonstrably responsible for tackling fraud, bribery and corruption, and appropriate action is taken regarding any NHSCFA quality assurance recommendations.

RSM UK Tax and Accounting Limited provides the counter fraud provision on behalf of the CCG and appoints an Accredited Local Counter Fraud Specialist to undertake the counter fraud work proportionate to identified risks.

The CCG Audit Committee receives a report against each of the Standards for Commissioners on an annual basis demonstrating executive support and direction for a proportionate proactive work plan to address identified risks.

5.10 Head of Internal Audit Opinion

For the 12 months ended 31 March 2019, our head of internal audit opinion for Hammersmith and Fulham Clinical Commissioning Group is as follows:

Head of Internal Audit Opinion 2018/19

Please see appendix A for the full range of annual opinions available to us in preparing this report and opinion.

Scope and limitations of our work The formation of our opinion is achieved through a risk-based plan of work, agreed with management and approved by the audit committee. Our opinion is subject to inherent limitations, as detailed below:

the opinion does not imply that internal audit has reviewed all risks and assurances relating to the organisation;

the opinion is substantially derived from the conduct of risk-based plans generated from a robust and organisation-led assurance framework. As such, the assurance

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framework is one component that the Governing Body takes into account in making its annual governance statement (AGS);

the opinion is based on the findings and conclusions from the work undertaken, the scope of which has been agreed with management / lead individual;

the opinion is based on the testing we have undertaken, which was limited to the area being audited, as detailed in the agreed audit scope;

where strong levels of control have been identified, there are still instances where these may not always be effective. This may be due to human error, incorrect management judgement, management override, controls being by-passed or a reduction in compliance;

due to the limited scope of our audits, there may be weaknesses in the control system which we are not aware of, or which were not brought to our attention; and

it remains management’s responsibility to develop and maintain a sound system of risk management, internal control and governance, and for the prevention and detection of material errors, loss or fraud. The work of internal audit should not be seen as a substitute for management’s responsibilities around the design and effective operation of these systems.

Factors and findings which have informed our opinion Based on the work undertaken in 2018/19, there is a generally effective system of internal control, designed to meet the CCG’s objectives, and controls are generally being applied consistently, although there are some specific areas where improvements can be made, particularly over the design and operation of the systems of control to achieve the intended outcomes. We issued one report with a PARTIAL ASSURANCE opinion relating to Cyber Security Application and Behaviours, where a number of weaknesses were identified, which impact the control environment Cyber Security Application and Behaviours Our review focused on systems within the CCG and CCG staff. One high risk issue was noted regarding Mobile Device Management (MDM). Medium risk issues related to backup documentation, test phishing campaigns, a lack of policy for BYOD (Bring Your Own Devices) and removable media, out of date policies, lack of control over IT assets given out to staff and lack of policy acceptance. We had agreed with management an action plan to correct several of the control gaps identified throughout the review. From the follow up of these actions we confirmed the CCG had progressed with implementing the actions that were due to strengthen the control framework. We will continue to follow up the actions as and when they fall due and report back on progress to the Audit Committee. We have also undertaken a number of NWL CCG Joint reviews where either a substantial or reasonable assurance opinion was provided and have not identified any significant

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control issues. Substantial assurance:

Finance Feeder Systems

IT Expenditure Reasonable assurance:

Payments to Staff

Primary Care Delegated Commissioning

Procurement and Contract Registers & Contract Management

Medicines Management /Prescribing

Conflicts of interest

Financial Planning, Management and Control

QIPP Monitoring and Benefits Realisation

Commissioning and Contract Management

Patient Experience and Population Health

Board Assurance Framework and Risk Management

Continuing Healthcare

There were some control issues identified as part of the abovementioned reviews and we have identified some areas for improvement. Where those were highlighted, we have agreed actions with management with agreed deadlines for implementation. These are followed up on a regular basis and their status reported to each meeting of the Audit Committee. Advisory Data Security Protection Toolkit We issued the Data Security Protection Toolkit which, whilst an advisory review, highlighted several areas where assertions within the toolkit had not been met, in addition to areas where we had unsubstantiated assertions or where we had agreed with exceptions. Management have agreed an action plan to close off these areas by the end of September 2019. STP Governance We also issued one Advisory report on STP Governance at the start of the 2018/19 financial year. Whilst there were STP Governance arrangements in place it was not clear through our review how these were not only put in place but approved by the CCG Governing Bodies, who alongside those other organisations within the STP, remained accountable, for the decision making and delivery of the STP, which in itself is not a statutory body. During the review we also found that the reporting from the STP groups, in particular the main STP monitoring Group (the Joint Health and Care Transformation Group) could have been improved to take into account the time, cost and quality of delivery of the STP projects. Consequently, it was not clear how involved the Governing Bodies had been in the decision making within the STP.

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Finally, it was not sufficiently clear how the system-wide financial control total had been reflected within the STP and the flow of those resources. The CCGs along with other partner organisations and stakeholders however were, at the time of the review, in the process of implementing a new proposed STP governance structure that answers many of the issues of the roles of the various committees and groups and how STP communicates with the statutory bodies with the involvement from lay members/partners. We agreed with management an action plan to remedy several of the areas that required strengthening. From the follow up of the management actions that had fallen due we confirmed considerable progress with the actions had been made and the governance arrangements have further developed. However, the agreed actions are not yet fully implemented at the time of compiling this opinion. There are some actions that were not due. We note that several partners and stakeholders are involved in implementing the management actions raised, and these are not solely within the gift of the CCG to implement. We will continue to follow up on those actions currently being implemented and the remaining actions once they fall due.

Topics judged relevant for consideration as part of the Annual Governance Statement Based on the work we have undertaken on the CCG’s system on internal control, we do not consider that within these areas there are any issues that need to be flagged as significant control issues within the Annual Governance Statement (AGS), although the CCG may wish to consider the implications of the issues identified in the abovementioned partial assurance review. The CCG may wish to consider whether any other issues have arisen, including the results of any external reviews which it might want to consider for inclusion in the Annual Governance Statement, as well as to recognise the challenging financial environment within which the CCG is operating and the ongoing challenges to meet financial targets.

Service Auditor Reports - working with other assurance providers We have reviewed the Service Auditor Report for National Shared Business Services, who provide financial transactional support to the CCG, via its contract with NHS England. For the year ending 31 March 2019 no exceptions were identified. The Service Auditor Report for NHS Digital for the year ending March 2019 did not raise any exceptions. NHS Digital (the trading name of the “Health and Social Care Information Centre”) provides IT services as part of the end to end service alongside other organisations to support processing of NHS payments and deductions to providers of general practice (“GP”) services in England. No exceptions were identified. We considered the Service Auditor Reports for the first half of 2018/19 and second half of 2018/19, from the internal auditors of Capita, who process payments to providers of general practice via a contract with NHS England, from whom the CCG has delegated primary care commissioning responsibilities. We found that improvements had been

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made in the second half of the year and there were fewer exceptions identified, none of which were significant to the CCG’s control environment. We have also liaised with the Local Counter Fraud Specialist and External Audit as appropriate.

APPENDIX A: ANNUAL OPINIONS The following shows the full range of opinions available to us within our internal audit methodology to provide you with context regarding your annual internal audit opinion.

Annual opinions

Factors influencing our opinion The factors which are considered when influencing our opinion are:

Inherent risk in the area being audited

Limitations in the individual audit assignments

The adequacy and effectiveness of the risk management and / or governance control framework

The impact of weakness identified

The level of risk exposure

The response to management actions raised and timeliness of actions taken.

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5.11 Review of the effectiveness of governance, risk management and internal control

My review of the effectiveness of the system of internal control is informed by the work of the internal auditors, executive managers and clinical leads within the Clinical Commissioning Group who have responsibility for the development and maintenance of the internal control framework. I have drawn on performance information available to me. My review is also informed by comments made by the external auditors in their annual audit letter and other reports. Our assurance framework provides me with evidence that the effectiveness of controls that manage risks to the Clinical Commissioning Group achieving its principal objectives have been reviewed. I have been advised on the implications of the result of this review by:

The Governing Body The Audit Committee The NW London Shadow Quality and Performance Committee Internal Audit NHS England Assurance Framework Reviews

The Clinical Commissioning Group has engaged both Internal and External Auditors to provide the Governing Body with independent assurance of its process of internal control and to provide assurance of the validity of this Governance Statement.

5.12 Conclusion

The 2018/19 Head of Internal Audit Opinion concluded with the exception of the internal control issues that have been outlined in this Governance Statement, that the Clinical Commissioning Group has an adequate and effective framework for risk management, governance and internal control which is designed to meet and support the organisation’s objectives. The identified control issues have been or are being addressed and Internal Audit did not report any significant control issues.

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Remuneration and Staff Report

(Certain sections are subject to audit)

6 Remuneration Report

6.1 Remuneration Committee

The remuneration committee is responsible for agreeing, on behalf of the Governing Body, the framework for the remuneration and conditions of service of CCG staff including the Governing Body members, and reviewing the on-going appropriateness and relevance of the remuneration policy. The membership consists of:

Lay member lead for audit, remuneration and conflict of interest matters (Chair);

Secondary care consultant member of the Governing Body; and

(optional) Lay member lead for Patient and Public Participation Matters. The remuneration committee met twice in common with Ealing, Hammersmith and Fulham, Hounslow and West London CCG’s in April 2018 and February 2019 with attendance as follows:

Name Role Attendance (attended/total)

Philip Young Lay member Ealing CCG, (audit, remuneration and finance committee Chair)

2/2

Dr Andy Petros Secondary care consultant member of the Hounslow and Hammersmith and Fulham CCG Governing Bodies (Deputy Chair)

1/2

Dr Jane Hawdon Secondary care consultant member of the Central London and West London CCG Governing Bodies (Deputy Chair)

2/2

Diana Middleditch

Lay member, Central London CCG 1/2

Carmel Cahill Lay member, Ealing CCG 1/2

Jane Wilmot Lay member, Hammersmith and Fulham CCG 2/2

Javed Khan Lay member, Hounslow CCG 1/2

Simon Tucker Lay member, West London CCG 0/2

From May 2018 the remuneration committee has met in common with the aforementioned as well as Brent, Harrow and Hillingdon Ealing CCG’s. The committee

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met once in this manner from May 2018 – March 2019 with attendance as follows:

Name Role Attendance

(attended/total)

Philip Young Lay member Ealing CCG, (audit, remuneration and finance committee Chair)

1/1

Dr Andy Petros Secondary care consultant member of the Hounslow and Hammersmith and Fulham CCG Governing Bodies (Deputy Chair)

1/1

Dr Jane Hawdon Secondary care consultant member of the Central London and West London CCG Governing Bodies (Deputy Chair)

0/1

Diana Middleditch

Lay member, Central London CCG 1/1

Carmel Cahill Lay member, Ealing CCG 1/1

Jane Wilmot Lay member, Hammersmith and Fulham CCG 1/1

Javed Khan Lay member, Hounslow CCG 0/1

Simon Tucker Lay member, West London CCG 1/1

The committee reported the basis for its recommendations to the Governing Body which used the committee’s report as the basis for its decisions on remuneration. However, the board remained accountable for taking final decisions on the remuneration and terms of service for the Accountable Officer and senior managers. The Committee also approved a number of HR-related policies and proposals in correspondence over the course of the year.

6.2 Policy on the remuneration of senior managers

This remuneration policy includes Clinicians, Lay and Associate Lay members and Executive Directors.

6.2.1 Chair and clinical directors

The Chair and Clinical Directors have a fixed-term Governing Body contract, and there is a three year rolling programme of elections to the Governing Body. Once elected for a term, they are subject to a three month notice period. There is no provision in their contract for compensation for early termination upon the expiry of the initial period or after re-election. Details of the Chair and Clinical Directors are stated below:

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Name Role Contract start date

Contract end date

Dr Tim Spicer Chair 1 April 2013 31 January 2019

Dr Paul Skinner GP member 1 April 2013 31 January 2019

Dr James Cavanagh Co-Vice Chair 1 April 2013

Vanessa Andreae Co-Vice Chair 1 September 2013

Dr Amy Wilson GP member 1 February 2016 31 January 2019

Dr Pritpal Ruprai GP member 2 April 2017 TBC

Katie Embleton Governing Body member

02 April 2018 02 April 2021

Dr Smitha Addala Governing Body member

02 April 2018 02 April 2021

Dr Victoria Cooney Governing Body member

02 April 2018 02 April 2021

6.2.2 Lay and associate lay members

The lay members listed below have a letter of engagement stating the duties and accountabilities of the organisation and themselves. These members are subject to a four week notice period. On termination of the appointment, they are only entitled to accrued fees as at the date of termination, together with reimbursement of any expenses properly incurred prior to that date. Contracts became effective on the dates shown below:

Name Role Contract start date

Contract end date

Philip Young

Lay member (Audit and Remuneration Committee Chair)

1 April 2013 30 September 2019

Trish Longdon

Lay member 1 April 2013 30 June 2019

Jane Wilmot Lay member 1 April 2013 30 September 2019

Nicholas Martin

Lay member 3 April 2017 30 September 2019

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6.2.3 Executive directors

Executive directors are on the senior managers pay framework, have a permanent contract and are subject to a six month notice period except in the case of summary or immediate dismissal. Compensation for loss of office is based on the terms and conditions laid out under NHS Terms and Conditions of Service. Details of the substantive executive directors are stated below:

Name Role Contract start date

Clare Parker Accountable Officer 5 January 2015 to 30 April 2018

Mark Easton Accountable Officer (Across NW London Collaboration of CCGs)

1 June 2018

Keith Edmunds Chief Finance Officer (CWHHE) 1 September 2015 to 20 April 2018

Janet Cree Managing Director 9 May 2016

Neil Ferrelly Chief Finance Officer (Across NW London Collaboration of CCGs)

Left 14 December 2018

Paul Brown Chief Finance Officer (Across NW London Collaboration of CCGs)

19 November 2018

Ben Westmancott Director of Compliance 1 April 2013

Jonathan Webster Director of Quality, Nursing and Patient Safety (Seconded out 23 July 2017)

1 April 2013 to 1 July 2018

Mary Mullix Acting Director of Quality, Nursing and Patient Safety (With effect from 23 July 2017)

23 July 2017 to 1 July 2018

Diane Jones Chief Nurse and Director of Quality 2 July 2018

6.2.4 Executive directors pay awards

The performance of all CCG staff, including directors and senior managers, is reviewed between April and March of each year in accordance with the CCG’s annual performance review process. The CCG operates a process for a consolidated pay increase, for employees on the senior managers pay framework in line with the Performance and Reward Pay Policy. All pay progression payments for directors and senior managers employed on the senior manager pay framework are linked to annual appraisal of performance and the CCG achieving its strategic objectives in line with the senior manager performance and reward pay policy. Performance awards for 2018/19 will be determined in the first quarter of 2019/20.

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The performance of the Chief Operating Officer/Accountable Officer is appraised by the Chair. The performance of CCG Managing Directors/Directors is appraised by the Accountable Officer.

6.3 Remuneration of very senior managers

The Accountable Officer of NHS Hammersmith and Fulham CCG is paid in excess of £150,000 per annum. However it should be noted that this remuneration is for services provided across the eight NW London CCGs – NHS Brent, Harrow, Hillingdon, Hounslow, Ealing, Central London, Hammersmith and Fulham and West London CCGs. The Remuneration Committee advises the Governing Body of an appropriate remuneration for the Accountable Officer based on services provided to the eight CCGs. In addition, the CCG Chair who are part time, would be paid in excess of £150,000 per annum on a pro rata basis and this remuneration has been advised by the Remuneration Committee to the Governing Body who remain accountable for taking decisions on the remuneration and terms of service for senior managers.

6.4 Senior managers remuneration (salary and pension entitlements)

6.4.1 Senior managers definition

The Department of Health and Social Care Group Manual for Accounts 2018/19 defines “Senior managers” as: “Those persons in senior positions having authority or responsibility for directing or controlling the major activities of the NHS body. This means those who influence the decisions of the entity as a whole rather than the decisions of individual directorates or departments.”

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6.4.2 Senior managers: salaries and allowances (has been subject to audit)

Salary

Expense

payments

(taxable)

Performance

pay and

bonuses

Long- term

performance

pay and

bonuses

All pension-

related

benefits Total Salary

Expense

payments

(taxable)

Performance

pay and

bonuses

Long- term

performance

pay and

bonuses

All pension-

related

benefits Total

(bands of

£5,000)

to nearest

£100*

(bands of

£5,000)

(bands of

£5,000)

(bands of

£2,500)

(bands of

£5,000)

(bands of

£5,000)

to nearest

£100*

(bands of

£5,000)

(bands of

£5,000)

(bands of

£2,500)

(bands of

£5,000)

£000 £ £000 £000 £000 £000 £000 £ £000 £000 £000 £000

Governing Board Members

Mrs Vanessa Andreae - Practice Nurse, Vice Chair 55-60 0 0 0 12.5-15 70-75 55-60 0 0 0 0 55-60

Pritpal Ruprai - Co-opted GP member 10-15 0 0 0 2.5-5 15-20 10-15 0 0 0 2.5-5 15-20

D James Cavanagh - GP Member, Vice Chair 5 0 0 0 0 0 0 55-60 0 0 0 0 55-60

Dr Jane Crane - Lay Member 15-20 0 0 0 0 15-20 15-20 0 0 0 0 15-20

Dr Janet Cree - Managing Director 110-115 0 0 0 0 110-115 105-110 0 0 0 37.5-40 145-150

Mr Nick Martin - Lay Member 10-15 0 0 0 2.5-5 10-15 10-15 0 0 0 2.5-5 10-15

Ms Trish Longdon - Lay Member 15-20 0 0 0 0 15-20 15-20 0 0 0 0 15-20

Dr Paul Skinner - GP Member 35-40 0 0 0 2.5-5 40-45 35-40 0 0 0 7.5-10 45-50

Dr Tim Spicer - Chair 1 100-105 0 0 0 10-12.5 110-115 130-135 0 0 0 20-22.5 155-160

Dr Tony Willis - GP Member 2 10-15 0 0 0 17.5-20 25-30 35-40 0 0 0 0 35-40

Dr Amy Wilson - GP Member, Clinical Quality & Governance Lead 50-55 0 0 0 10-12.5 60-65 45-50 0 0 0 62.5-65 105-110

Dr Smitha Addala-GP Member 10-15 0 0 0 0 10-15 0 0 0 0 0 0

Dr Victoria Cooney GP Member 20-25 0 0 0 5-7.5 25-30 0 0 0 0 0 0

Katie Embleton -System and IT Manager 10-15 0 0 0 30-32.5 35-40 0 0 0 0 0 0

Clare Parker - Accountable Officer (to 30th of April 2018) 3 15-20 0 0 0 0 15-20 15-20 0 0 0 5-7.5 25-30

Keith Edmunds - Chief Finance Officer (to 31st December 2017) 3 0 0 0 0 0 0 10-15 0 0 0 0 10-15

Jonathan Webster - Director of Nursing, Quality & Safety (to 30th June 2017) 4 0 0 0 0 0 0 0-5 0 0 0 10-12.5 10-15

Ben Westmancott - Director of compliance (adviser in attendance) 4 15-20 0 0 0 2.5-5 15-20 10-15 0 0 0 2.5-5 15-20

Philip Young - Lay Member and Audit Chair 4 5-10 0 0 0 0 5-10 5-10 0 0 0 0 5-10

Dr Alan Hakim - Secondary Care Consultant (to 6th of Apr 2017) 4 0 0 0 0 0 0 0-5 0 0 0 7.5-10 10-15

Mary Mullix - Acting Director of Nursing, Quality & Safety (to 31st July 2018) 4 0-5 0 0 0 2.5-5 5-10 5-10 0 0 0 0 5-10

Rob Larkman - Accountable Officer - NWL CCGs (1st May 2018 to 16 June 2018) 15-20 0 0 0 0 15-20 0 0 0 0 0 0

Andy Petros - Secondary Care Consultant (from Sept 2017) 4 5-10 0 0 0 0 5-10 10-15 0 0 0 0 10-15

Mark Easton - Accountable Officer (from 1st June 2018) 3 10-15 0 0 0 0 10-15 0 0 0 0 0 0

Paul Brown - Chief Finance Officer - NWL CCGs (from 19th November 2018) 0-5 0 0 0 0-2.5 5-10 0 0 0 0 0 0

Neil Ferrelly - Chief Finance Officer - NWL CCGs (1st January 2018 to 14 December 2018) 5-10 0 0 0 0 5-10 0-5 0 0 0 7.5-10 10-15

Diane Jones - Chief Nurse and Director of Quality - NWL CCGs (from 2nd July 2018) 5-10 0 0 0 5-7.5 10-15 0 0 0 0 0 0

Notes

1. Dr T Spicers' pay is shown as 60%, as the rest of the 40% relates to his work for Shaping a Healthier Future

2. Dr T Willis' gross pay is shown in full, 33% relates to his role as diabetes lead. This cost is shared equally amongst Central London, West London and Hammersmith & Fulham CCGs.

3. Paid by Central London CCG but their costs have been shared across Central, West, Hammersmith and Fulham, Hounslow, Ealing, Hillingdon, Harrow and Brent CCGs.

The average weighting for each CCG is as follows: Central London CCG 10%, West London CCG 11%, Hammersmith & Fulham CCG 8%, Hounslow CCG 13%, Ealing CCG 18%, Harrow CCG 11%, Brent CCG 15%, Hillingdon CCG 14%

4. Paid by Central London CCG but their costs have been shared across Central, West, Hammersmith and Fulham, Hounslow and Ealing CCGs.

The average weighting for each CCG is as follows: Central London CCG 16%, West London CCG 18%, Hammersmith & Fulham CCG 14%, Hounslow CCG 22%, Ealing CCG 30%

Their full year salary is shown in the table below.

5. Pension figures were not available from NHS Pensions agency at the time of reporting. Therefore disclosed zero for both Salary and Pension’

*Note: Taxable expenses and benefits in kind are expressed to the nearest £100.

Name and Title Notes

2018-19 2017-18

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6.4.3 Senior managers: salaries and allowances – joint appointments (has been subject to audit)

The following Senior Managers either work across the five CCGs (NHS Central London, Ealing, Hammersmith and Fulham, Hounslow and West London) or across the eight North West London CCGs (NHS Brent, Central London, Ealing, Harrow, Hammersmith and Fulham, Hillingdon, Hounslow and West London). The table below gives their total salaries and allowances whilst table 6.4.2 only shows NHS Hammersmith and Fulham CCG’s share of their costs.

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Notes: Senior managers salaries and allowances and joint appointments table

The ‘Senior Managers – salaries and allowances’ table 6.4.2 shows NHS Hammersmith and Fulham CCGs costs or their share of the costs of Joint Appointments and the ‘Senior Managers - Salaries and allowances – Joint appointments’ table 6.4.3 shows their total salaries and allowances

1. Joint Appointments - these Senior Managers work across NHS Central London, Ealing, Hammersmith and Fulham, Hounslow and West London CCGs and their share is calculated on the relative population of each CCG. These costs were shared as follows; 16% Central London, 30% Ealing, 14% Hammersmith and Fulham, 22% Hounslow and 18% West London CCG.

2. Joint Appointments - these Senior Managers work across NHS Brent, Central London, Ealing, Hammersmith and Fulham , Harrow, Hillingdon, Hounslow and West London CCGs and their share is calculated on the relative population of each CCG. These costs were shared as follows; 15% NHS Brent CCG, 10% NHS Central London CCG, 18% NHS Ealing CCG, 8% NHS Hammersmith and Fulham CCG, 11% NHS Harrow CCG, 14% NHS Hillingdon CCG, 13% NHS Hounslow CCG and 11% NHS West London CCG.

3. Following a restructure, costs were apportioned across eight CCGs from 1 May 2018 to 16 June 2018 as per note 2. Salary includes £20k in respect of NHS Hammersmith and Fulham CCG’s share of compulsory redundancy and payment in lieu of notice costs following a restructure to develop a joint management arrangement across the eight North West London CCGs. This is disclosed in the Annual Report '2018/19 and 2017/18 exit packages agreed' (section 7.9). Rob ceased to be Accountable Officer on 31 May 2018, but was employed until 16 June 2018 to handover to the newly appointed Accountable Officer. His salary in table 6.4.2 includes £1k in respect of NHS Hammersmith and Fulham CCG's share of other remuneration for this period. His salary in table 6.4.3 includes £7k in respect of total other remuneration across North West London CCGs for this period.

4. Neil ceased to be Chief Finance Officer on 18 November 2018, but was employed until 14 December 2018 to handover to the newly appointed Chief Finance Officer. His salary in table 6.4.2 includes £9k in respect of NHS Hammersmith and Fulham CCG's share of other remuneration for this period. His salary in table 6.4.3 includes £10k in respect of total other remuneration across NWL CCGs for this period

5. Following a restructure, costs were apportioned across eight CCGs from 2 July 2018 as per note 2

6. Salary includes £209k in respect of total compulsory redundancy and payment in

lieu of notice costs following a restructure to develop a joint management structure across the eight North West London CCGs. See note 2 above for NHS Hammersmith and Fulham CCG's share of these costs

7. Salary includes £17k in respect of NHS Hammersmith and Fulham CCG's share of

compulsory redundancy and payment in lieu of notice costs following a restructure

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to develop a joint management arrangement across the eight North West London CCGs. This is disclosed in the Annual Report '2017/18 exit packages agreed' (section 7.9)

8. Salary includes £170k in respect of total compulsory redundancy and payment in

lieu of notice costs following a restructure to develop a joint management arrangement across the eight North West London CCGs. See note 1 above for NHS Hammersmith and Fulham CCG's share of these costs. £69k of the total costs were shared by NHS Brent, Harrow and Hillingdon CCGs

The pension figures supplied by NHS Pensions Agency are based on their current salary compared to that of their last officer employment (which could have been many years ago) uplifted for inflation. Therefore this does not necessarily reflect the increase in pension benefits during 2018/19 only.

Performance pay and bonuses

There are no “performance pay and bonuses” in operation. The CCG operates a process for consolidated pay increases for employees on the senior managers pay framework.

Long term performance pay and bonuses

There are no "long term performance pay and bonus" in operation.. Definitions

Salary and fees – All amounts paid or payable by the clinical commissioning group, including recharges from any other health body but excludes recharges to other health bodies.

Expense payments (taxable) – This is the gross value of taxable expenses and benefits before tax.

Performance pay and bonuses - These comprise money or other assets received or receivable for the financial year as a result of achieving performance measures and targets relating to a period ending in the relevant financial year.

Long term performance pay and bonuses - These comprise money or other assets received or receivable for periods of more than one year as a result of achievement of performance measures or targets.

All pension related benefits – This figure includes those benefits accruing to Senior Managers from membership of the NHS Pensions Scheme which is a defined benefit scheme (although accounted for by NHS bodies as if it were a defined contribution scheme). In summary, for defined benefit schemes, the amount included here is the annual increase in pension entitlement. Zero amounts are shown for individuals for whom - The CCG does not pay into a pension scheme, or - The all pension benefit figure is a negative number.

The value of pension benefits accrued during the year is calculated as the real increase in pension multiplied by 20, less, the contributions made by the individual. The real increase excludes increases due to inflation or any increase or decrease

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due to a transfer of pension rights. This value does not represent an amount that will be received by the individual. It is a calculation that is intended to convey to the reader of the accounts an estimation of the benefit that being a member of the pension scheme could provide. The pension benefit table provides further information on the pension benefits accruing to the individual." Factors determining the variation in the values recorded between individuals include but is not limited to:

o A change in role with a resulting change in pay and impact on pension benefits

o Changes in the wider remuneration package of an individual.

Total – This is the total of all the above columns and does not necessarily represent the total the individual personally received from the CCG.

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6.4.4 Senior managers: pension benefits (has been subject to audit)

Real Real Total Lump sum Cash Real Cash

increase increase / accrued at pension Equivalent increase in Equivalent

in pension at decrease pension at age related Transfer in Cash Transfer

Note pension age in pension pension age to acrued Value at Equivalent Value at

lump sum at pension Transfer

pension age at 31 March at 31 March 1 April Value 31 March

2018 2018 2017 2018

(bands of (bands of (bands (bands

£2,500) £2,500) of £5,000) of £5,000)

£000 £000 £000 £000 £000 £000 £000 £000

Governing Board Members

Mrs Vanessa Andreae - Practice Nurse, Vice Chair 0-2.5 (0-2.5) 20-25 45-50 295 47 359 0

D James Cavanagh - GP Member, Vice Chair 1 0 0 0 0 0 0 0 0

Dr Janet Cree - Manageing Director 0-2.5 0-2.5 30-35 75-80 561 62 655 0

Dr Paul Skinner - GP Member 0-2.5 (0-2.5) 10-15 25-30 157 21 188 0

Dr Tim Spicer - Chair 0-2.5 5-7.5 20-25 60-65 424 (461) 0 0

Dr Tony Willis - GP Member 0-2.5 (0-2.5) 20-25 50-55 368 14 433 0

Dr Amy Wilson - GP Member, Clinical Quality & Governance Lead 0-2.5 (0-2.5) 15-20 35-40 170 30 213 0

Pritpal Ruprai - Co-opted GP member 0-2.5 0 0-5 0 2 (4) 0 0

Mr Nick Martin - Lay Member 0-2.5 0 0-5 0 3 2 6 0

Dr Smitha Addala-GP Member (2.5-5) 0 10-15 25-30 59 74 137 0

Dr Victoria Cooney GP Member 0-2.5 0 0-5 0 0 0 4 0

Katie Embleton -System and IT Manager 0-2.5 0 0-5 0 12 14 27 0

Ben Westmancott - Director of compliance (adviser in attendance) 0-2.5 0-2.5 30-35 65-70 419 73 519 0

Mary Mullix - Acting Director of Nursing, Quality & Safety (to 31st July 2018) 0-2.5 2.5-5 35-40 105-110 665 46 735 0

Andy Petros - Secondary Care Consultant (from Sept 2017) 2 (2.5-5) 0 20-25 0 62 0 62 0

Neil Ferrelly - Chief Finance Officer - NWL CCGs (to 14 December 2018) (7.5 - 10) (12.5 - 15) 45 - 50 160 - 165 1,269 0 0 0

Diane Jones - Chief Nurse and Director of Quality - NWL CCGs (from 2nd July 2018) 2.5 - 5 2.5 - 5 25 - 30 50 - 55 342 87 456 0

Paul Brown - Chief Finance Officer - NWL CCGs (from 19th November 2018) 0 - 2.5 0 - 2.5 25 - 30 75 - 80 516 17 600 0

1. Pension figures were not available from NHS Pensions agency at the time of reporting. Therefore disclosed zero for both Salary and Pension’

2. Pension related benefit adjusted to zero to avoid mistatement due to 16/17 pension information not available due to new starter.

The pension disclosure is a requirement of the Government Financial Reporting Manual to disclose all benefits in year from participating in pension schemes. These are the aggregate input amounts, calculated using the method set out in the Finance Act

2004. This figure will include those benefits accruing to senior managers from membership of the NHS Pensions Scheme.

The disclosure for these individuals who are shared across organisations is the gross amount and not the individual Clinical Commissioning Groups share.

08C Hammersmith & Fulham Clinical Commissioning Group - Annual Accounts 2018-19

Pension Entitlements

Name and Title

Employer's

contribution

to stakeholder

pension

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Notes to pension benefits table:

1. Figures are supplied by the NHS Pensions Agency and are based on their employment as Governing Body Members of the CCG only. Pension relating to Practitioner employments are not included.

2. The disclosure for these individuals who are shared across Brent, Central London, Ealing, Hammersmith and Fulham , Harrow, Hillingdon, Hounslow and West London CCGs is their total amount and not their share applicable to each individual CCG. * There is no cash equivalent transfer value as at 31 March 2019 as these members have reached normal retirement age. ** There is no cash equivalent transfer value as at 31 March 2019 as this member retired during the year

Certain Members including non-executive directors and interims do not receive pensionable remuneration or have opted out of the pension scheme and therefore there are no entries in respect of pensions for these Members. A cash equivalent transfer value (CETV) is the actuarially assessed capital value of the pension scheme benefits accrued by a member at a particular point in time. The benefits valued are the member’s accrued benefits and any contingent spouse’s (or other allowable beneficiary’s) pension payable from the scheme. A CETV is a payment made by a pension scheme or arrangement to secure pension benefits in another pension scheme or arrangement when the member leaves a scheme and chooses to transfer the benefits accrued in their former scheme. The pension figures shown relate to the benefits that the individual has accrued as a consequence of their total membership of the pension scheme, not just their service in a senior capacity to which disclosure applies. The CETV figures and the other pension details include the value of any pension benefits in another scheme or arrangement which the individual has transferred to the NHS pension scheme. They also include any additional pension benefit accrued to the member as a result of their purchasing additional years of pension service in the scheme at their own cost. CETVs are calculated within the guidelines and framework prescribed by the Institute and Faculty of Actuaries. Real increase in CETV - This reflects the increase in CETV that is funded by the employer. It does not include the increase in accrued pension due to inflation or contributions paid by the employee (including the value of any benefits transferred from another scheme or arrangement).

NHS Pensions are still assessing the impact of the McCloud judgement in relation to changes to benefits in the NHS 2015 Scheme. The benefits and related CETVs disclosed do not allow for any potential future adjustments that may arise from this judgement.

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6.5 Compensation on early retirement or for loss of office (has been subject to audit)

There have been no compensation on early retirement or loss of office payments.

6.6 Payments to past senior managers (has been subject to audit)

There have been no payments made to past senior managers.

6.7 Fair pay disclosure (has been subject to audit)

Reporting bodies are required to disclose the relationship between the remuneration of the highest-paid director in their organisation and the median remuneration of the organisation’s workforce. The banded remuneration of the highest paid Governing Body member in NHS Hammersmith and Fulham CCG during the financial year 2018/19 was £110k – £115k (2017/18: £195k – £200k). This was 1.93 (2017/18: 3.79) times the median remuneration of the workforce, which was £58.8k (2017/18: £52k). Remuneration ranged from £2k to £114k (2017/18 £4k-£168k). Total remuneration includes salary, non-consolidated performance-related pay, benefits-in-kind but not severance payments. It does not include employer pension contributions and the cash equivalent transfer value of pensions.

In 2018/19, no employees received remuneration in excess of the highest-paid Governing Body member.

The workforce median calculation is based on the average cost of staff on the NHS Hammersmith and Fulham CCG payroll. The pay multiples disclosed above relate to those staff who are directly employed by the CCG. The CCG also uses staff recharged from other CCG’s who are not included in the calculations above.

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7. Staff Report

7.1 Number of senior managers by band

Number Band

16 (2017/18:17) VSM

7.2 Staff numbers and costs (has been subject to audit)

The average number of people employed by the CCG is as follows and includes staff recharged to and from the CCG:

Workforce numbers (has been subject to audit) 2018/19 2017/18

No. No.

Permanently Employed 71 69

Other 5 7

Total 76 76

Included within the above whole time equivalent staff numbers are 19.42 (2017/18: 17.46) relating to shared corporate support services. These figures include staff which NHS Central London CCG hosts the employment of but are shared across the CWHHE CCG Collaboration, and commissioning support functions shared across all eight NW London CCGs.

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Workforce benefits

2018/19

Employees Other Total

£000 £000 £000

Employee Benefits

Salaries and wages 3,955 658 4,612

Social security costs 398 1 398

Employer Contributions to NHS Pension scheme 418 - 418

Apprenticeship Levy 8 - 8

Termination benefits 119 - 119

Total workforce benefits expenditure 4,897 658 5,555

2017/18

Employees Other Total

£000 £000 £000

Employee Benefits

Salaries and wages 2,679 661 3,340

Social security costs 319 (1) 319

Employer Contributions to NHS Pension scheme 344 (1) 343

Apprenticeship Levy - - -

Termination benefits 32 - 32

Total workforce benefits expenditure 3,374 659 4,033

Workforce benefits (has been subject to audit)

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7.3 Staff composition

Staff numbers Female Male Governing Body 7 5

Other senior managers and clinical leads (not included in Governing Body figures)

8 7

CCG staff 28 11

These figures show all staff on NHS Hammersmith and Fulham CCG payroll which includes staff shared across the CWHHE Collaboration, and commissioning support functions shared across all eight NW London CCGs.

The membership body of the CCG is made up of the individual member practices whose staff are not employed by the CCG. As such, we do not record information on the gender of staff in general practices.

7.4 Staff sickness absence and ill health requirements

With a relatively small-office based workforce, sickness absence is not a significant issue for the CCGs. The management and reporting of sickness is supported by a comprehensive absence management policy and advice from the Human Resources team that covers the eight NW London CCGs. Human Resources delivers HR Core Training for CCG managers on a rolling basis and this includes the efficient use of the sickness absence management policies and protocols to refresh knowledge and remind managers of their role in the management of absence. The staff sickness absence figures in the table below are provided by the Department of Health and cover the calendar year.

Sickness absence 2018/19 2017/18

No. No.

Total days lost 373 278

Total Staff Years 47 42

Average working days lost 8 7

No employees have retired on the grounds of ill health retirement.

7.5 Staff policies

The CCG has a range of people management policies in place to ensure effective recruitment and employment of its staff. The people management policies promote best practice and a non- discriminatory approach to all aspects of employment within the organisation. These policies recognise the importance of a good employment relationships and commitment to employee engagement. These robust people management policies are reviewed regularly and Equality Health Impact Assessments undertaken. The policies are approved through the CCGs’ Human Resources and Organisational Development (HR & OD) Committee that meets on a monthly basis and thereafter agreed by the Remuneration Committee /Governing Body

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before implementation. All staff policies are accessible to all staff via an internal intranet site and the HR Staff Handbook.

7.5.1 Equality and diversity

The CCG is committed to equality of opportunity in line with the Equality Act 2010 for all employees and is committed to employment practices, policies and procedures which ensure that no employee, or potential employee, receives less favourable treatment on the grounds of sex, race, ethnic or national origin, sexual orientation, marriage and civil partnership, religion or belief, age, pregnancy and maternity, trade union membership, disability, offending background, domestic circumstances, social and employment status, HIV status, gender reassignment, political affiliation or any other personal characteristic. Diversity is viewed positively and, in recognising that everyone is different, the unique contribution that each individual’s experience, knowledge and skills can make is valued equally. The promotion of equality and diversity is actively pursued through policies and ensures that employees receive fair, equitable and consistent treatment. It also ensures that employees, and potential employees, are not subject to direct or indirect discrimination. The CCG works with Access to Work, when appropriate, and abides by the principles of the ‘Disability Confident Scheme’ in relation to recruitment, whereby disabled applicants get a guaranteed interview. It is a condition of employment that all employees respect and act in accordance with our equality and diversity policy. Failure to do so can result in the disciplinary procedure being instigated, which could result in termination of employment.

7.6 Other employee matters The HR & OD Committee has approved Criteria for Establishing a Protected Characteristic Networks under the Equality Act (2010) across the organisation. The objectives of the established networks are aligned to the CCGs corporate objectives and Equality and Diversity plans and the benefits are related to the network and the organisation. The networks also have to demonstrate that membership is open and inclusive for all staff. A Lesbian, Gay, Bisexual and Transgender Network (LGBT) was established across the organisation for all staff in 2017. Progress reports on the work of the networks are presented to the HR & OD Committee on a quarterly basis. The network has developed LGBT awareness training for staff as well as staff events across the organisation. A Black, Asian and Minority Ethnic (BAME) network was launched across the organisation in December 2018. A Diversity Delivery Group was established in January 2019 with representatives from staff across the organisation and the LBGT and BAME networks. The Group is committed to improving workforce equality and treatment of staff that identify themselves to be included in any of the protected characteristics under the Equality Act 2010. It will also help

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develop action plans for the WRES (Workforce Race Equality Standard) and WDES (Workforce Disabilities Equality standards) The purpose of the group is to also to support the CCGs in meeting their responsibilities under the Equality Act 2010, the Health and Social Care Act 2012 and related legislation and guidance. A Joint Consultative Committee (JCC) has been established with recognised trade union representatives and regional officers to further support employee engagement and consultation with staff during any periods of change. The JCC meets on a quarterly basis and reports to the HR & OD Committee. The Trade Union (Facility Time Publication Requirements) regulations 2017 require CCGs to report on trade union facility time. Facility time is paid time off for union representatives to carry out trade union activities. This reporting requirement applies to CCGs who have a full time equivalent employee number of more than 49 through the entirety of any seven month period in the financial year. Whilst NHS Hammersmith and Fulham CCG meets this criteria, it has no facility time costs during 2018/19.

Health and safety

The CCG recognises its responsibility to ensure that reasonable precautions are taken to provide a safe working environment and to prevent or minimise the causes of fires or other health and safety issues, in compliance with relevant statutes and codes of practice. During the year, improvements were implemented following risk assessments with respect to: the working environment; the systems in place including fire precautions and response arrangements; and the information and training provided to staff. The CCG has received professional health and safety and fire safety support to fulfill the role of the competent person throughout 2018/19. Advice, support and training is available for all staff, including those volunteering for specific roles in the event of an emergency. A foundation level of Health and Safety and Fire risks training is mandated for all staff annually. As the CCGs are working more closely as a collaboration, a Joint North West London Health and Safety Committee has been established (see Section 5.7.7). This Committee oversees the CCG’s health and safety arrangements and, alongside senior management, monitors compliance with the established framework, and the response to incidents and near misses.

7.7 Expenditure on consultancy

During the year, NHS Hammersmith and Fulham CCG incurred £200k on consultancy services primarily in respect of Financial Recovery Program, Primary Care Strategy and Sustainability and Transformation Plan support.

7.8 Off-payroll engagements

Table 1 – Off-payroll engagements longer than 6 months For all off-payroll engagements as of 31 March 2019, for more than £245 per day and that last longer than six months are as follows:

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Off-payroll engagements longer than 6 months Number

Number of existing engagements as of 31 March 2019 1 (4)

of which, the number that have existed:

For less than 1 year at the time of reporting 1 (2)

For between 1 and 2 years at the time of reporting 0 -

For between 2 and 3 years at the time of reporting 0 (2)

For between 3 and 4 years at the time of reporting 0 -

For 4 or more years at the time of reporting 0 -

Table 2 – New off-payroll engagements Where the reformed public sector rules apply, for all new off-payroll engagements, or those that reached 6 months in duration, between 1 April 2018 and 31 March 2019, for more than £245 per day and that last for longer than 6 months:

New off-payroll engagements Number

Number of new engagements, or those that reached six months in duration, between 1 April 2018 and 31 March 2019

1

Of which:

Number of new engagements that are within scope of IR35 0 -

Number of new engagements that are outside scope of IR 35 0 -

Number engaged directly (via PSC contracted to department) and are on the departmental payroll

0 -

Number of engagements reassessed for consistency / assurance purposes during the year

0 -

Number of engagements that saw a change to IR35 status following the consistency review

0 -

Table 3 – Off-payroll engagements / senior official engagements For any off-payroll engagements of board members, and/or, senior officials with significant financial responsibility, between 1 April 2018 and 31 March 2019:

Senior official engagements Number

Number of off-payroll engagements of board members, and/or, senior officials with significant financial responsibility, during the financial year

0 -

Total no. of individuals on payroll and off-payroll that have been deemed “board members, and/or, senior officials with significant financial responsibility”, during the financial year. This figure includes both off-payroll and on-payroll engagements

17 (20)

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7.9 Exit packages agreed during the year (has been subject to audit)

The tables above report the number and value of exit packages agreed during the year. Redundancy and other departure costs have been paid in accordance with the provisions of NHS Terms and Conditions of Service. Exit costs in this note are NHS Hammersmith and Fulham CCG’s share of the full costs of departures agreed in the year and are accounted for at the latest in full in the year of departure, and in accordance with relevant accounting standards. The Remuneration Report includes the disclosure of exit payments payable to individuals named in that Report.

2018/19

No. £ No. £ No. £

Less than £10,000 3 7,170 1 4,046 4 11,216

£10,001 to £25,000 2 24,916 - - 2 24,916

£50,001 to £100,000 1 86,647 1 86,647

Total 6 118,732 1 4,046 7 122,778

Analysis of Other Agreed Departures

No. £

Contractual payments in lieu of notice 1 4,046

Compulsory

redundancies

Other agreed

departures

Total

Other agreed

departures

2017/18

No. £ No. £ No. £

Less than £10,000 3 18,400 3 10,262 6 28,662

£10,001 to £25,000 1 13,367 - - 1 13,367

Total 4 31,767 3 10,262 7 42,029

Analysis of Other Agreed Departures

No. £

Contractual payments in lieu of notice 3 10,262

Compulsory

redundancies

Other agreed

departures

Total

Other agreed

departures

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8. Parliamentary Accountability and Audit Report

NHS Hammersmith and Fulham CCG is not required to produce a Parliamentary Accountability and Audit Report. There are no disclosures to report and an audit certificate and report is also included in this Annual Report.

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Independent Auditor’s Report and Financial Statements

Mark Easton Accountable Officer NHS Brent, Central London, Ealing, Hammersmith and Fulham, Harrow, Hillingdon, Hounslow and West London CCGs Date: 24 May 2019

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9. Independent Auditor’s Report and Financial Statements

INDEPENDENT AUDITOR’S REPORT TO THE MEMBERS OF THE GOVERNING BODY OF NHS HAMMERSMITH AND FULHAM CLINICAL COMMISSIONING GROUP Opinion on financial statements We have audited the financial statements of NHS Hammersmith and Fulham Clinical Commissioning Group (the CCG) for the year ended 31 March 2019 which comprise the Statement of Comprehensive Net Expenditure, the Statement of Financial Position, the Statement of Changes in Taxpayers’ Equity, the Statement of Cash Flows and notes to the financial statements, including a summary of significant accounting policies. The financial reporting framework that has been applied in their preparation is applicable law and International Financial Reporting Standards (IFRSs) as adopted by the European Union, and as interpreted and adapted by the 2018-19 Government Financial Reporting Manual as contained in the Department of Health and Social Care’s Group Accounting Manual 2018-19. In our opinion the financial statements:

give a true and fair view of the financial position of the CCG as at 31 March 2019 and of its net expenditure for the year then ended; and

have been properly prepared in accordance with the Department of Health and Social Care’s Group Accounting Manual 2018-19; and

have been prepared in accordance with the Health and Social Care Act 2012. Basis for opinion on financial statements

We conducted our audit in accordance with International Standards on Auditing (UK) (ISAs (UK)) and applicable law. Our responsibilities under those standards are further described in the Auditor’s responsibilities for the audit of the financial statements section of our report. We are independent of the CCG in accordance with the ethical requirements that are relevant to our audit of the financial statements in the UK, including the Financial Reporting Council’s Ethical Standard, and we have fulfilled our other ethical responsibilities in accordance with these requirements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion. Conclusions relating to going concern We have nothing to report in respect of the following matters in relation to which the ISAs (UK) require us to report to you where:

the Accountable Officer’s use of the going concern basis of accounting in the preparation of the financial statements is not appropriate; or

the Accountable Officer has not disclosed in the financial statements any identified material uncertainties that may cast significant doubt about the CCG’s ability to continue to adopt the going concern basis of accounting for a period of at least twelve months from the date when the financial statements are authorised for issue.

Other information The Accountable Officer is responsible for the other information. The other information comprises the information included in the annual report, other than the financial

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statements and our auditor’s report thereon. Our opinion on the financial statements does not cover the other information and, except to the extent otherwise explicitly stated in our report, we do not express any form of assurance conclusion thereon. In connection with our audit of the financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the audit or otherwise appears to be materially misstated. If we identify such material inconsistencies or apparent material misstatements, we are required to determine whether there is a material misstatement in the financial statements or a material misstatement of the other information. If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact. We have nothing to report in this regard. Qualified opinion on regularity In our opinion, except for the matter described in the Basis for qualified opinion on regularity paragraph of our report, in all material respects the expenditure and income recorded in the financial statements have been applied to the purposes intended by Parliament and the financial transactions in the financial statements conform to the authorities which govern them. Basis for qualified opinion on regularity The CCG incurred an in-year deficit of £16.904 million in 2018/19, as reported in its financial performance targets note to the financial statements, thereby indicating a breach of its duty under the National Health Service Act 2006, as amended by paragraphs 223H (1) for expenditure not to exceed income and 223I (3) for revenue resource use not to exceed the amount specific in Directions, of Section 27 of the Health and Social Care Act 2012. Opinion on information in the Remuneration and Staff Report We have also audited the information in the Remuneration and Staff Report that is described in that report as having been audited. In our opinion the parts of the Remuneration and Staff Report to be audited have been properly prepared in accordance with Department of Health and Social Care’s Group Accounting Manual 2018-19. Matters on which we are required to report by exception Qualified conclusion on use of resources On the basis of our work, having regard to the guidance issued by the Comptroller & Auditor General in November 2017, with the exception of the matter reported in the Basis for qualified conclusion on use of resources section of our report, we are satisfied that, in all significant respects, the CCG has put in place proper arrangements to secure economy, efficiency and effectiveness in its use of resources for the year ended 31 March 2019. Basis for qualified conclusion on use of resources The CCG incurred an in-year deficit of £16.904 million in 2018/19, as reported in its financial performance targets note to the financial statements. This is a significant deterioration compared to the planned control total surplus of £6.704 million set by NHS

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England and approved by the Governing Body. The CCG has not yet succeeded in addressing the underlying deficit in its budget and is forecasting a further deficit of £6.704 million for 2019/20. The CCG does not currently have a medium term financial recovery plan to reduce the budget deficit. This is evidence of weaknesses in proper arrangements regarding sustainable resource deployment. Report to the Secretary of State On 21 May 2019 we reported to the Secretary of State under section 30 of the Local Audit and Accountability Act 2014 that the CCG has recorded an in-year deficit of £16.904 million for the 2018/19 financial year and as a result the CCG has incurred unlawful expenditure. We also reported that the CCG has set a budget for 2019/20 indicating a planned deficit of £6.704 million and that as a result the CCG has begun to take a course of action that would be unlawful. Other matters We have nothing to report in respect of the following other matters in relation which the Local Audit and Accountability Act 2014 requires us to report to you if:

in our opinion the Governance statement does not comply with the guidance issued by NHS England; or

except as reported above we refer a matter to the Secretary of State under section 30 of the Local Audit and Accountability Act 2014 because we have reason to believe that the CCG, or an officer of the CCG, is about to make, or has made, a decision which involves or would involve the body incurring unlawful expenditure, or is about to take, or has begun to take a course of action which, if followed to its conclusion, would be unlawful and likely to cause a loss or deficiency; or

we issue a report in the public interest under section 24 of the Local Audit and Accountability Act 2014; or

we make a written recommendation to the CCG under section 24 of the Local Audit and Accountability Act 2014.

Responsibilities of the Accountable Officer As explained more fully in the Statement of Accountable Officer’s Responsibilities, the Accountable Officer is responsible for the preparation of the financial statements and for being satisfied that they give a true and fair view, and for such internal control as the Accountable Officer determines is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error. In preparing the financial statements, the Accountable Officer is responsible for assessing the CCG’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless the Accountable Officer either intends to liquidate the CCG or to cease operations, or have no realistic alternative but to do so. As explained in the Statement of Accountable Officer’s Responsibilities, the Accountable Officer is also responsible for the propriety and regularity of the public finances for which the Accountable Officer is answerable and for ensuring the CCG exercises its functions effectively, efficiently and economically.

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Auditor’s responsibilities for the audit of the financial statements

In respect of our audit of the financial statements our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements. A further description of our responsibilities for the audit of the financial statements is located at the Financial Reporting Council’s website at: https://www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditor’s report. Auditor’s other responsibilities In addition to our audit of the financial statements we are required to obtain evidence sufficient to give reasonable assurance that the expenditure and income recorded in the financial statements have been applied to the purposes intended by Parliament and the financial statements conform to the authorities which govern them. We are also required under section 21(1)(c) of the Local Audit and Accountability Act 2014 to be satisfied that the CCG has made proper arrangements for securing economy, efficiency and effectiveness in its use of resources. Section 21(5)(b) of the Local Audit and Accountability Act 2014 requires that our report must not contain our opinion if we are satisfied that proper arrangements are in place. We are not required to consider, nor have we considered, whether all aspects of the CCG’s arrangements for securing economy, efficiency and effectiveness in its use of resources are operating effectively. As set out in the Matters on which we report by exception section of our report there are certain other matters which we are required to report by exception. Certificate We certify that we have completed the audit of the accounts of the CCG in accordance with the requirements of the Local Audit and Accountability Act 2014 and the Code of Audit Practice issued by the National Audit Office. Use of our report This report is made solely to the Members of the Governing Body of NHS Hammersmith and Fulham Clinical Commissioning Group, as a body, in accordance with part 5 of the Local Audit and Accountability Act 2014 and as set out in paragraph 43 of the Statement of Responsibilities of Auditors and Audited Bodies published by the National Audit Office in April 2015. Our audit work has been undertaken so that we might state to the Members of the Governing Body those matters we are required to state to them in an auditor's report and for no other purpose. To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other than the CCG and the Members of the Governing Body of the CCG, as a body, for our audit work, this report, or for the opinions we have formed.

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Leigh Lloyd-Thomas For and on behalf of BDO LLP, Statutory Auditor

London, UK

24 May 2019

BDO LLP is a limited liability partnership registered in England and Wales (with registered number OC305127).

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117

10. Financial statements

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NHS Hammersmith and Fulham CCG

Audited

Financial Statements

2018/19

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NHS Hammersmith and Fulham CCG - Annual Accounts 2018/19

Contents

Page

Number

The Primary Statements

Statement of Comprehensive Net Expenditure for the year ended 31 March 2019 1

Statement of Financial Position as at 31 March 2019 2

Statement of Changes in Taxpayers' Equity for the year ended 31 March 2019 3

Statement of Cash Flows for the year ended 31 March 2019 4

Notes to the Accounts

1 Accounting policies 5

2 Other operating revenue 9

3 Workforce benefits and pension costs 9

4 Operating expenditure 11

5 Better payment practice code 12

6 Operating leases - as lessee 13

7 Plant and equipment 13

8 Current trade and other receivables 14

9 Current trade and other payables 14

10 Borrowings and finance lease obligations 15

11 Provisions 16

12 Financial instruments 17

13 Joint arrangements - interests in joint operations 18

14 Related party transactions 19

15 Financial performance targets 21

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Statement of Comprehensive Net Expenditure for the Year Ended 31 March 2019

2018/19 2017/18

Note £000 £000

Revenue from sale of services 2 (5,735) (5,172)

Other operating revenue 2 (1) 146

Total operating revenue (5,736) (5,026)

Workforce benefits 3 5,555 4,033

Purchase of services 4 322,552 294,653

Depreciation 4 202 205

Provision expense 4 (473) -

Other operating expenditure 4 642 613

Total operating expenditure 328,478 299,504

Net operating expenditure 322,742 294,478

Finance expense in respect of finance leases 37 39

Total comprehensive expenditure for the year 322,779 294,517

The notes on pages 5 to 21 form part of this statement.

1

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Statement of Financial Position as at 31 March 2019

31 March 2019 31 March 2018

Note £000 £000

Non-current assets

Plant and equipment 7 883 1,085

Total non-current assets 883 1,085

Current assets

Trade and other receivables 8 5,383 6,464

Cash 44 118

Total current assets 5,427 6,582

Total assets 6,310 7,667

Current liabilities

Trade and other payables 9 (35,975) (36,697)

Borrowings 10 (121) (121)

Provisions 11 (594) (983)

Total current liabilities (36,690) (37,801)

Non-current assets less net current liabilities (30,380) (30,134)

Non-current liabilities

Borrowings 10 (828) (917)

Provisions 11 (630) (1,125)

Total non-current liabilities (1,458) (2,042)

Assets less liabilities (31,838) (32,176)

Financed by Taxpayers’ Equity

General fund (31,838) (32,176)

Total taxpayers' equity (31,838) (32,176)

Mark Easton

Accountable Officer

……………………………………………….

The notes on pages 5 to 21 form part of this statement.

The financial statements on pages 1 to 21 were approved by the Audit Committee on 21 May 2019 and

signed on behalf of the CCG by:

The balance sheet movement of £0.3m on the general fund reflects the difference between the cash

funding and net operating costs for the year.

2

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Statement of Changes In Taxpayers Equity for the Year Ended 31 March 2019

Changes in taxpayers’ equity 2018/19

General fund

£000

Balance as at 1 April 2018 (32,176)

Changes in Clinical Commissioning Group taxpayers’ equity 2018/19

Net operating expenditure for the year (322,779)

Cash funding 323,117

Balance as at 31 March 2019 (31,838)

General fund

£000

Changes in taxpayers’ equity 2017/18

Balance as at 1 April 2017 (27,633)

Changes in Clinical Commissioning Group taxpayers’ equity 2017/18

Net operating expenditure for the year (294,517)

Cash funding 289,974

Balance as at 31 March 2018 (32,176)

The cash funding of £323.1m represents the draw down of cash the CCG made during the year from

NHS England.

The notes on pages 5 to 21 form part of this statement.

3

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Statement of Cash Flows for the Year Ended 31 March 2019

2018/19 2017/18

Note £000 £000

Cash flows from operating activities

Net operating expenditure for the year (322,779) (294,517)

Depreciation 7 202 205

Decrease in trade and other receivables 8 1,081 90

(Decrease) / Increase in trade and other payables 9 (722) 4,964

Provisions utilised 11 (412) (555)

Decrease in provisions 11 (473) 0

Net cash outflow from operating activities (323,103) (289,813)

Cash flows from investing activities

Payments for other financial assets (88) (85)

Net cash outflow before financing (323,191) (289,898)

Cash flows from financing activities

Cash funding received 323,117 289,974

Net (decrease) / increase in cash (74) 76

Cash at the beginning of the year 118 42

Cash at the end of the year 44 118

The notes on pages 5 to 21 form part of this statement.

4

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Notes to the financial statements

1 Accounting Policies

NHS England has directed that the financial statements of clinical commissioning groups shall meet the

accounting requirements of the Group Accounting Manual issued by the Department of Health and Social

Care. Consequently, the following financial statements have been prepared in accordance with the Group

Accounting Manual 2018/19 issued by the Department of Health and Social Care. The accounting policies

contained in the Group Accounting Manual follow International Financial Reporting Standards to the

extent that they are meaningful and appropriate to clinical commissioning groups, as determined by HM

Treasury, which is advised by the Financial Reporting Advisory Board. Where the Group Accounting

Manual permits a choice of accounting policy, the accounting policy which is judged to be most

appropriate to the particular circumstances of the clinical commissioning group for the purpose of giving a

true and fair view has been selected. The particular policies adopted by the clinical commissioning group

are described below. They have been applied consistently in dealing with items considered material in

relation to the accounts.

1.1 Going Concern

These accounts have been prepared on a going concern basis despite the issue of a report to the

Secretary of State for Health under Section 30 of the Local Audit and Accountability Act 2014. Public

sector bodies are assumed to be going concerns where the continuation of the provision of a service in

the future is anticipated, as evidenced by inclusion of financial provision for that service in published

documents. NHS England has issued indicative resources allocations for the clinical commissioning

group for the next 5 years and as services will continue to be provided the financial statements are

prepared on the going concern basis.

1.2 Accounting Convention

These accounts have been prepared under the historical cost convention.

1.3 Joint arrangements and Pooled BudgetsArrangements over which the clinical commissioning group has joint control with one or more other

entities are classified as joint arrangements. Joint control is the contractually agreed sharing of control of

an arrangement. A joint arrangement is either a joint operation or a joint venture.

A joint operation exists where the parties that have joint control have rights to the assets and obligations

for the liabilities relating to the arrangement. Where the clinical commissioning group is a joint operator it

recognises its share of assets, liabilities, income and expenses in its own accounts.

The clinical commissioning group has joint operations with the Local Authority in respect of defined

elements of the Better Care Fund (BCF) entered into through a pooled budget in accordance with section

75 of the NHS Act 2006. Details of the pooled budget are given in Note 13.

1.4 Revenue

Revenue in respect of services provided is recognised when (or as) performance obligations are satisfied

by transferring promised services to the customer, and is measured at the amount of the transaction price

allocated to that performance obligation.

Where income is received for a specific performance obligation that is to be satisfied in the following year,

that income is deferred.

Payment terms are standard reflecting cross government principles.

1.5 Employee Benefits

1.5.1 Short-term Employee Benefits

Salaries, wages and employment-related payments, including payments arising from the apprenticeship

levy, are recognised in the period in which the service is received from employees.

The cost of leave earned but not taken by employees at the end of the period is recognised in the

financial statements to the extent that employees are permitted to carry forward leave into the following

period.

5

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Notes to the financial statements

1.5.2 Retirement Benefit Costs

Past and present employees are covered by the provisions of the NHS Pensions Schemes. These

schemes are unfunded, defined benefit schemes that cover NHS employers, General Practices and other

bodies allowed under the direction of the Secretary of State in England and Wales. The schemes are not

designed to be run in a way that would enable NHS bodies to identify their share of the underlying

scheme assets and liabilities. Therefore, the schemes are accounted for as though they were defined

contribution schemes: the cost to the clinical commissioning group of participating in a scheme is taken as

equal to the contributions payable to the scheme for the accounting period.

For early retirements other than those due to ill health the additional pension liabilities are not funded by

the scheme. The full amount of the liability for the additional costs is charged to expenditure at the time

the clinical commissioning group commits itself to the retirement, regardless of the method of payment.

The schemes are subject to a full actuarial valuation every four years and an accounting valuation every

year.

1.6 Other Expenses

Other operating expenses are recognised when, and to the extent that, the goods or services have been

received. They are measured at the fair value of the consideration payable.

1.7 Operating Lease

1.7.1 The Clinical Commissioning Group as Lessee

Plant and equipment held under finance leases are initially recognised, at the inception of the lease, at fair

value or, if lower, at the present value of the minimum lease payments, with a matching liability for the

lease obligation to the lessor. Lease payments are apportioned between finance charges and reduction of

the lease obligation so as to achieve a constant rate on interest on the remaining balance of the liability.

Finance charges are recognised in calculating the clinical commissioning group’s net expenditure.

Operating lease payments are recognised as an expense on a straight-line basis over the lease term.

1.8 Cash

Cash is cash in hand and deposits with any financial institution repayable without penalty on notice of not

more than 24 hours.

In the Statement of Cash Flows, cash is shown net of bank overdrafts that are repayable on demand and

that form an integral part of the clinical commissioning group’s cash management.

1.9 Provisions

Provisions are recognised when the clinical commissioning group has a present legal or constructive

obligation as a result of a past event, it is probable that the clinical commissioning group will be required

to settle the obligation, and a reliable estimate can be made of the amount of the obligation. The amount

recognised as a provision is the best estimate of the expenditure required to settle the obligation at the

end of the reporting period, taking into account the risks and uncertainties.

1.10 Clinical Negligence Costs

NHS Resolution operates a risk pooling scheme under which the clinical commissioning group pays an

annual contribution to NHS Resolution, which in return settles all clinical negligence claims. The

contribution is charged to expenditure. Although NHS Resolution is administratively responsible for all

clinical negligence cases, the legal liability remains with clinical commissioning group.

1.11 Non-clinical Risk Pooling

The clinical commissioning group participates in the Property Expenses Scheme and the Liabilities to

Third Parties Scheme. Both are risk pooling schemes under which the clinical commissioning group pays

an annual contribution to the NHS Resolution and, in return, receives assistance with the costs of claims

arising. The annual membership contributions, and any excesses payable in respect of particular claims

are charged to operating expenses as and when they become due.

6

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Notes to the financial statements

1.12 Financial Assets

Financial assets are recognised when the clinical commissioning group becomes party to the financial

instrument contract or, in the case of trade receivables, when the goods or services have been delivered.

Financial assets are derecognised when the contractual rights have expired or the asset has been

transferred.

The CCGs financial assets are classified as 'financial assets at amortised cost' (under IAS 39 in previous

years' referred to as 'loans and receivables') and are measured at amortised cost less any impairment.

1.12.1 Impairment

For all financial assets, the clinical commissioning group recognises a loss allowance representing the

expected credit losses on the financial asset.

The clinical commissioning group adopts the simplified approach to impairment in accordance with IFRS

9, and measures the loss allowance for trade receivables and contract assets at an amount equal to

lifetime expected credit losses. For other financial assets, the loss allowance is measured at an amount

equal to lifetime expected credit losses if the credit risk on the financial instrument has increased

significantly since initial recognition (stage 2) and otherwise at an amount equal to 12 month expected

credit losses (stage 1).

HM Treasury has ruled that central government bodies may not recognise stage 1 or stage 2 impairments

against other government departments, their executive agencies, the Bank of England, Exchequer Funds

and Exchequer Funds assets where repayment is ensured by primary legislation. The clinical

commissioning group therefore does not recognise loss allowances for stage 1 or stage 2 impairments

against these bodies. Additionally DHSC provides a guarantee of last resort against the debts of its arm's

lengths bodies and NHS bodies and the clinical commissioning group does not recognise allowances for

stage 1 or stage 2 impairments against these bodies.

1.13 Financial LiabilitiesFinancial liabilities are recognised on the when the clinical commissioning group becomes party to the

contractual provisions of the financial instrument or, in the case of trade payables, when the goods or

services have been received. Financial liabilities are de-recognised when the liability has been

discharged, that is, the liability has been paid or has expired.

The CCGs financial liabilities are classified as 'financial liabilities at amortised cost' and are measured at

amortised cost.

1.14 Value Added Tax

Most of the activities of the clinical commissioning group are outside the scope of VAT and, in general,

output tax does not apply and input tax on purchases is not recoverable. Irrecoverable VAT is charged to

the relevant expenditure category or included in the capitalised purchase cost of fixed assets. Where

output tax is charged or input VAT is recoverable, the amounts are stated net of VAT.

1.15 Sources of estimation uncertainty

The following are assumptions about the future and other major sources of estimation uncertainty that

have a significant risk of resulting in a material adjustment to the carrying amounts of assets and liabilities

within the next financial year.

7

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Notes to the financial statements

1.15.1 Acute Contracts Expenditure

Healthcare services from acute NHS providers are commissioned under service level agreements.

Providers use the monthly activity data to inform their monthly Service Level Agreement Monitoring

(SLAM) reports and to charge the CCG for activity provided. The latest available SLAM information

covers February (Month 11) data and this is available at the beginning of April. Providers estimate the

March activity and the CCG reviews this un-validated activity for reasonableness. Throughout the year,

the CCG may issue contract challenges against invoiced activity and, where these have yet to be

resolved, will make an estimate of the amounts that it believes will not be paid. The CCG also estimate

amounts recoverable against payments to date where activity has fallen below contracted levels or

additional amounts payable where activity exceeds contracted activity.

1.16 Accounting Standards That Have Been Issued But Have Not Yet Been Adopted

The Department of Health and Social Care Group Accounting Manual does not require the following IFRS

Standards and Interpretations to be applied in 2018/19. These Standards are still subject to HM Treasury

FReM adoption, with IFRS 16 being implemented in 2020/21.

● IFRS 16 Leases – Application required for accounting periods beginning on or after 1 January 2019, but

not yet adopted by the FReM: early adoption is not therefore permitted.

The application of IFRS 16 as revised would not have a material impact on the financial statements for

2018/19, were they applied in that year. As disclosed in note 6, the CCG does not currently have signed

leases with NHS Property Services Limited and therefore based on current leases, it is not expected that

IFRS 16 will have a material impact once it is applied since the CCG has no material operating leases.

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2. Other operating revenue

2018/19 2017/18

£000 £000

Revenue from sale of services (contracts)

Education, training and research - 2

Non-patient care services to other bodies 1,363 1,117

Other contract income 4,372 4,053

Total revenue from sale of services 5,735 5,172

Other operating revenue

Charitable and other contributions to revenue expenditure: non-NHS - 50

Non cash apprenticeship training grants revenue 1 -

Other non contract revenue - (196)

Total other operating revenue 1 (146)

Total operating revenue 5,736 5,026

Notes:

1) Cash drawdown from NHS England

3. Workforce benefits and pension costs

3.1 Workforce benefits

2018/19 2017/18

Total Total

£000 £000

Salaries and wages 4,612 3,340

Social security costs 398 318

Employer contributions to NHS pension scheme 418 343

Apprenticeship levy 8 -

Termination benefits 119 32

Total gross workforce benefits expenditure 5,555 4,033

Less: recoveries in respect of workforce benefits (see below) - -

Total workforce benefits expenditure 5,555 4,033

The main source of funding for the clinical commissioning group is received from NHS England, which is

primarily drawn down as cash directly into the bank account of the CCG and credited to the General Fund.

This is not included in revenue above.

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3.2 Pension costs

Past and present employees are covered by the provisions of the two NHS Pension Schemes. Details of

the benefits payable and rules of the schemes can be found on the NHS Pensions website at

www.nhsbsa.nhs.uk/pensions.  Both are unfunded defined benefit schemes that cover NHS employers,

GP practices and other bodies, allowed under the direction of the Secretary of State for Health and Social

Care in England and Wales. They are not designed to be run in a way that would enable NHS bodies to

identify their share of the underlying scheme assets and liabilities. Therefore, each scheme is accounted

for as if it were a defined contribution scheme: the cost to the NHS body of participating in each scheme is

taken as equal to the contributions payable to that scheme for the accounting period.  

In order that the defined benefit obligations recognised in the financial statements do not differ materially

from those that would be determined at the reporting date by a formal actuarial valuation, the FReM

requires that “the period between formal valuations shall be four years, with approximate assessments in

intervening years”. An outline of these follows:

3.2.1 Accounting valuation

A valuation of scheme liability is carried out annually by the scheme actuary (currently the Government

Actuary’s Department) as at the end of the reporting period. This utilises an actuarial assessment for the

previous accounting period in conjunction with updated membership and financial data for the current

reporting period, and is accepted as providing suitably robust figures for financial reporting purposes. The

valuation of the scheme liability as at 31 March 2019, is based on valuation data as 31 March 2018,

updated to 31 March 2019 with summary global member and accounting data. In undertaking this actuarial

assessment, the methodology prescribed in IAS 19, relevant FReM interpretations, and the discount rate

prescribed by HM Treasury have also been used.

The latest assessment of the liabilities of the scheme is contained in the report of the scheme actuary,

which forms part of the annual NHS Pension Scheme Accounts. These accounts can be viewed on the

NHS Pensions website and are published annually. Copies can also be obtained from the stationery office.

3.2.2 Full actuarial (funding) valuation

The purpose of this valuation is to assess the level of liability in respect of the benefits due under the

schemes (taking into account recent demographic experience), and to recommend contribution rates

payable by employees and employers.

The latest actuarial valuation undertaken for the NHS Pension Scheme was completed as at 31 March

2016. The results of this valuation set the employer contribution rate payable from April 2019. The

Department of Health and Social Care have recently laid Scheme Regulations confirming that the

employer contribution rate will increase to 20.6% (currently 14.4%) of pensionable pay from this date.

The 2016 funding valuation was also expected to test the cost of the scheme relative to the employer cost

cap set following the 2012 valuation. Following a judgment from the Court of Appeal in December 2018

Government announced a pause to that part of the valuation process pending conclusion of the continuing

legal process.

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4. Operating expenditure

2018/19 2017/18

£000 £000

Purchase of services

Services from other CCGs and NHS England 775 1,276

Services from foundation trusts 63,047 55,793

Services from other NHS trusts 157,141 145,678

Purchase of healthcare from non-NHS bodies 46,085 39,801

Purchase of social care 253 -

Prescribing costs 20,861 21,219

GMS, PMS and APMS 2

31,152 26,625

Supplies and services – clinical 114 234

Supplies and services – general 346 1,316

Consultancy services 200 188

Establishment 558 297

Transport 5 1

Premises 1,649 1,925

External audit fees 1

46 46

Other professional fees 153 60

Legal fees 54 49

Education, training and conferences 113 145

Total purchase of services 322,552 294,653

Depreciation charges

Depreciation 202 205

Total depreciation charges 202 205

Provisions expense

Provisions (473) -

Total provisions expense (473) -

Other operating expenditure

Chair, GP members and lay members 654 628

Expected credit loss on receivables (14) 5

Other expenditure 2 (20)

Total other operating expenditure 642 613

Total operating expenditure 322,923 295,471

Notes:

1) External audit fees

2) Acronyms

The external audit fees net of VAT is £39k (2017/18: £38k). The figure above is inclusive of VAT as not

recoverable by the CCG. The terms of appointment of the auditor has limited their liability to £1m.

GMS - General Medical Services, PMS - Personal Medical Services and APMS - Alternative Provider

Medical Services.

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5. Better Payment Practice Code

2018/19

Number £000

Non-NHS Payables

Total non-NHS trade invoices paid in the year 11,413 72,833

Total non-NHS trade invoices paid within target 11,127 70,481

Percentage of Non-NHS trade invoices paid within target 97.5% 96.8%

NHS Payables

Total NHS trade invoices paid in the year 3,452 227,542

Total NHS trade invoices paid within target 3,352 226,555

Percentage of NHS trade invoices paid within target 97.1% 99.6%

2017/18

Number £000

Non-NHS Payables

Total non-NHS trade invoices paid in the year 17,237 85,456

Total non-NHS trade invoices paid within target 16,929 84,226

Percentage of Non-NHS trade invoices paid within target 98.2% 98.6%

NHS Payables

Total NHS trade invoices paid in the year 3,821 252,355

Total NHS trade invoices paid within target 3,572 248,640

Percentage of NHS trade invoices paid within target 93.5% 98.5%

The Better Payment Practice Code (BPPC) requires NHS organisations to aim to pay 95% of all valid invoices,

by value and volume, within 30 days of receipt of goods or a valid invoice (whichever is later) unless other

payment terms have been agreed.

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6. Operating leases - as lessee

6.1 Payments recognised as an expense

2018/19 2017/18

Buildings Buildings

£000 £000

Total minimum lease payments 1,309 1,935

6.2 Future minimum lease payments

7. Plant and equipment

2018/19

Plant &

machinery

Information

technology

Furniture &

fittings

Total

£000 £000 £000 £000

Cost as at 1 April 2018 and 31 March 2019 1,277 42 861 2,180

Depreciation as at 1 April 2018 426 42 627 1,095

Charged during the year 85 - 117 202

Depreciation as at 31 March 2019 511 42 744 1,297

Net Book Value as at 31 March 2019 766 - 117 883

Purchased 766 - 117 883

Total as at 31 March 2019 766 - 117 883

Asset financing:

Owned - - 117 117

Held on finance lease 766 - - 766

Total as at 31 March 2019 766 - 117 883

7.1 Economic lives

Plant & machinery 1 5

Furniture & fittings 1 3

Maximum

Life (Years)

Minimum Life

(years)

Whilst our arrangements with Community Health Partnership's Limited and NHS Property Services Limited fall

within the definition of operating leases, rental charge for future years has not yet been agreed. Consequently

this note does not include future minimum lease payments for these arrangements.

Buildings: the clinical commissioning group is charged for property owned or managed by NHS Property

Services Ltd and Community Health Partnerships Ltd and is charged for its share of headquarters at Marylebone

Road, Newman Street and The Heights.

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8. Current trade and other receivables

31 March 2019 31 March 2018

£000 £000

NHS receivables: revenue 2,818 2,619

NHS prepayments 961 867

NHS accrued income 326 657

Non-NHS and other WGA receivables: revenue 618 1,090

Non-NHS and other WGA prepayments 1 536

Non-NHS and other WGA accrued income 535 461

Expected credit loss allowance-receivables (2) (17)

VAT 8 9

Other receivables and accruals 118 242

Total current trade and other receivables 5,383 6,464

8.1 Receivables past their due date but not impaired

DHSC

Group Bodies

Non DHSC

Group Bodies

£000 £000

By up to three months 2,223 548

By three to six months 267 25

By more than six months 327 45

Total 2,817 618

DHSC

Group Bodies

Non DHSC

Group Bodies£000 £000

By up to three months 1,718 1,075

By three to six months 446 -

By more than six months 420 15

Total 2,584 1,090

9. Current trade and other payables

31 March 2019 31 March 2018

£000 £000

NHS payables: revenue 12,887 17,964

NHS accruals 4,919 2,959

Non-NHS and other WGA payables: revenue 5,121 3,639

Non-NHS and other WGA accruals 11,423 4,221

Social security costs 51 50

Tax 56 67

Other payables and accruals 1,518 7,797

Total current trade and other payables 35,975 36,697

The great majority of trade is with NHS England and other CCGs. As NHS England and CCGs are funded by

the Government, no credit scoring of them is considered necessary.

31 March 2019

31 March 2018

Other payables include £233k outstanding pension contributions as at 31 March 2019 (31 March 2018: £249k)

and include GP Pension contributions in respect of primary care co-commissioning.

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10. Borrowings and finance lease obligations

Current Non-current Current Non-current

£000 £000 £000 £000

Finance lease liabilities 121 828 121 917

Total Borrowings 121 828 121 917

Total current and non-current 949 1,038

10.1 Present value of minimum lease payments

31 March 2019 31 March 2018

Total Total

£000 £000

Within one year 121 121

Between one and five years 443 443

After five years 385 474

Present value of minimum lease payments 949 1,038

Included in:

Current borrowings 121 121

Non-current borrowings 828 917

Total 949 1,038

10.2 Minimum lease payments

31 March 2019 31 March 2018

Total Total

£000 £000

Within one year 125 125

Between one and five years 499 499

After five years 499 624

Less: future finance charges (174) (210)

Present value of minimum lease payments 949 1,038

31 March 2019 31 March 2018

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11. Provisions

Current Non-current Current Non-current

£000 £000 £000 £000

Other 594 630 983 1,125

Total 594 630 983 1,125

Total current and non-current 1,224 2,108

Total

Other

£000

Balance at 1 April 2018 2,108

Utilised during the year (412)

Reversed unused (472)

Balance at 31 March 2019 1,224

Expected timing of cash flows:

Within one year 594

Between one and five years 630

Balance at 31 March 2019 1,224

Other provisions comprise of:

31 March 201831 March 2019

Dilapidations: A provision of £918k was bough forward in respect of dilapidation and other costs

associated with the lease expiration of offices at Marylebone Road utilised by the North West London

Collaboration of CCGs. During the year costs incurred were £97k and £227k was reversed unused.

The provision carried forward is £594k.

HMRC: A provision was bought forward of £245k in respect of a HMRC investigation into payment of

tax and national insurance by contractors engaged by NHS Central London CCG and recharged to the

other CCGs. The investigation has now been closed with no costs incurred during the year, and the

provision has been reversed during the year.

Milson Road: A provision of £945k was bought forward for void costs and £315k was utilised during the

year. The provision carried forward is £630k.

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12. Financial instruments

12.1 Financial risk management

12.1.1 Currency risk

12.1.2 Credit risk

12.1.3 Liquidity risk

12.2 Financial assets

31 March 2019 31 March 2018

Financial Assets measured at amortised cost £000 £000

Trade and other receivables with NHSE bodies 2,738 2,835

Trade and other receivables with other DHSC group bodies 750 881

Trade and other receivables with external bodies 809 1,111

Other financial assets 118 241.63

Cash and cash equivalents 43 118

Total 4,458 5,186

12.3 Financial liabilities

31 March 2019 31 March 2018

Financial Liabilities measured at amortised cost £000 £000

Trade and other payables with NHSE bodies 2,819 1,602

Trade and other payables with other DHSC group bodies 21,075 23,228

Trade and other payables with external bodies 10,455 3,953

Other financial liabilities 1,518 7,797

Private Finance Initiative and finance lease obligations 949 1,037

Total 36,817 37,618

Due to the short-term nature of trade and other payables and other financial liabilities the carrying value

approximates their fair value.

While the finance lease obligation is payable by instalments through to 2028, the fair value of the liability is

not materially different to the carrying value.

Because the majority of the clinical commissioning group's revenue comes from parliamentary funding, it

has low exposure to credit risk. The maximum exposures as at the end of the financial year are in

receivables from customers, as disclosed in the trade and other receivables, note 8.

The clinical commissioning group is required to operate within revenue and capital resource limits, which

are financed from resources voted annually by Parliament. The clinical commissioning group draws down

cash to cover expenditure, as the need arises. The clinical commissioning group is not, therefore, exposed

to significant liquidity risks.

Financial reporting standard IFRS 7 requires disclosure of the role that financial instruments have had

during the period in creating or changing the risks a body faces in undertaking its activities.

Because the clinical commissioning group is financed through parliamentary funding, it is not exposed to

the degree of financial risk faced by business entities. Also, financial instruments play a much more limited

role in creating or changing risk than would be typical of listed companies, to which the financial reporting

standards mainly apply. The clinical commissioning group has limited powers to borrow or invest surplus

funds and financial assets and liabilities are generated by day-to-day operational activities rather than being

held to change the risks facing the clinical commissioning group in undertaking its activities.

Treasury management operations are carried out by the finance department, within parameters defined

formally within the clinical commissioning group standing financial instructions and policies agreed by the

Governing Body. Treasury activity is subject to review by the NHS clinical commissioning group and internal

auditors.

The clinical commissioning group is principally a domestic organisation with the great majority of

transactions, assets and liabilities being in the UK and sterling based.

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13. Joint arrangements - interests in joint operations

2018/19 2017/18

£000 £000

18,293 17,024 Better Care Fund

The clinical commissioning group's share of expenditure handled by the pooled budgets was:

The clinical commissioning group has two pooled budgets with The London Borough of Hammersmith and

Fulham (LBHF) under Section 75 of the NHS Act 2006. LBHF is the host for each of the pooled budgets.

The first pooled budget is in respect of Community Equipment Services.

The second pooled budget is in respect of the Better Care Fund (BCF) and incorporates the pooled budget

for Community Equipment Services.

The BCF was announced by the Government in the June 2013 spending round to drive the transformation

of local services to ensure that people receive better and more integrated care and support. The fund is to

be deployed locally on health and social care through pooled budget arrangements between local

authorities and clinical commissioning groups.

Name of arrangement

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14. Related party transactions

GP Practices

GP Practice Governing Body member 2018/19

Expenditure

2017/18

Expenditure

Amounts

payable

£000 £000 £000

Brook Green Medical Centre Dr J Cavanagh 2,094 1,856 30

Brook Green Surgery Dr P Skinner 539 524 27

Hammersmith Surgery Dr P Ruprai 1,398 1,346 29

North End Medical Centre Dr J Cavanagh 2,894 - -

The Bush Doctors Practice Dr J Cavanagh 1,536 - -

The Lillie Road Surgery Dr A Wilson 2,993 993 27

The Bush Doctors Practice Mrs V Andreae - 1,543 41

GP Federation

GP Federation Nature of Interest Note 2018/19

Expenditure

2017/18

Expenditure

£000 £000

Hammersmith and Fulham GP Federation Practices are members 1 1,195 733

Notes:

Other

Organisation Governing Body Member Nature of Interest

2017/18

Expenditure

31 March 18

Amounts

payable£000 £000

St Davids Nursing Home Mr P Young Trustee 58 9

1. All GP practices in the borough including those in which CCG Governing Body members are partners or shareholders are

members of the federation.

Members of the governing body are required to declare any interests that they hold, either directly or through close family

members, in organisations other than the clinical commissioning group. Where the CCG incurs expenditure with or receives

income from those organisations, the organisations are known as related parties and the transactions must be reported. Those

transactions, together with the nature of the interest and the nature of the transaction, are shown below.

During the year none of the Governing Body members including executive directors, GPs and lay members, or parties related to

them, have undertaken any material transactions with the clinical commissioning group except those listed below.

Details of related party transactions with GP practices are as follows. These transactions are in respect of services provided to

the clinical commissioning group by the practice in which the Governing Body member is a partner or shareholder rather than

payments to Governing Body members themselves.

Hammersmith and Fulham GP Federation is made up of 29 GP practices in Hammersmith and Fulham and was created to

enhance the delivery of health services to the local population. Details of related party transactions with the GP Federation are

shown below:

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14. Related party transactions (cont.)

North West London Collaboration of CCGs

Clinical Commissioning Group (CCG) 2018/19

Expenditure

2018/19

Income

Amounts

payable

Amounts

receivable

£000 £000 £000 £000

NHS Brent CCG 3 300 540 91

NHS Central London CCG 255 165 1,665 354

NHS Ealing CCG 124 1,478 125 471

NHS Harrow CCG 7 37 2 3

NHS Hillingdon CCG 44 69 32 18

NHS Hounslow CCG 52 408 57 68

NHS West London CCG - 494 23 975

Department of Health and Social Care Group Bodies (DHSC)

NHS England

NHS Foundation Trusts NHS Trusts

Chelsea And Westminster Hospital NHSFT Barts Healthcare NHST

Central & North West London NHSFT Imperial College Healthcare NHST

University College London NHSFT West London Mental Health NHST

Guys & St Thomas NHSFT Central London Community Healthcare NHST

St Georges University Hospital NHSFT London Ambulance Service NHST

Royal Brompton NHSFT London North West Healthcare NHST

Royal Marsden NHSFT

Moorfields Eye Hospital NHSFT

Other government organisations

2018/19

Expenditure

2018/19

Income

Amounts

payable

Amounts

receivable

£000 £000 £000 £000

HMRC 1

1,452 293 106 20

London Borough of Hammersmith and Fulham Council 19,341 913 1,593 413

NHS Pensions Agency 1

2,955 - 233 -

NHS Property Services Ltd 302 - 532 -

In addition, the clinical commissioning group has had a number of material transactions with other government organisations

as per below:

1 Transactions with HMRC and NHS Pensions Agency are in respect of receipts and payments relating to 2018/19.

NHS Brent, Central London, Ealing, Hammersmith & Fulham, Harrow, Hillingdon, Hounslow and West London CCGs are

related parties of each other as part of the North West London (NWL) Collaboration of CCGs following a restructure and the

appointment of a single NWL Accountable Officer and Chief Financial Officer. Related party transactions with the seven

NWL clinical commsssioning groups is shown below:

The Department of Health is regarded as a related party. During the year the clinical commissioning group has had a

significant number of material transactions with entities for which the Department is regarded as their parent. Details of such

entities is as follows:

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15. Financial performance targets

NHS Clinical Commissioning Group have a number of financial duties under the NHS Act 2006 (as amended).

Performance against those duties was as follows:

Target Performance Target Performance

£000 £000 £000 £000

Expenditure not to exceed income 311,611 328,515 300,794 299,543

Revenue resource use does not exceed the amount

specified in Directions 305,875 322,779 295,769 294,517

Capital resource use on specified matter(s) does

not exceed the amount specified in Directions - - - -

Revenue resource use on specified matter(s) does

not exceed the amount specified in Directions - - - -

Revenue administration resource use does not

exceed the amount specified in Directions 3,901 3,901 3,877 3,857

2017/18: A surplus on programme costs of £1.3m and a small surplus on running costs together equal the CCG's in-

year surplus of £1.3m.

2018/19 2017/18

2018/19: A deficit on programme costs of (£16.9m) and a break even on running costs together equal the CCG's in-

year deficit of (£16.9m).

21