dr. sloan harper, director of integrated care, health and social care board northern ireland
DESCRIPTION
Regulation in Primary Care - Impact in Northern IrelandTRANSCRIPT
Regulation in Primary Care
-Impact in N Ireland
Dr Sloan Harper
Director of Integrated Care
Health & Social Care Board
Primary care providers NI
GP Practices 351
GP Out of Hours providers 5
Community Pharmacies 530
Dental practices 380
Optometry practices 281
How do we improve primary care
services?
• Targets & performance?
• Choice & competition?
• Inspection & regulation?
General Medical Services Regulation
The Health and Personal Social Services (General Medical
Services Contracts) Regulations (NI) 2004 and amendments.
• GP Contract – a clinical governance framework
• Practices failing to meet the requirements can be issued a “remedial
notice” requiring improvement within a defined period, followed by a
“breach notice” and termination of contract
General Medical Services Regulation
The Health and Personal Social Services (Primary Medical Services
Performers Lists) Regulations (NI) 2004 and Amendments.
• Individuals can be removed if they have not provided GMS services
in last 24 months, on basis of GMC decisions, convictions for certain
serious crimes.
• Inclusion on the list can be deferred during investigations.
• Regional Performance Panel with professional and lay members
advises HSCB
Benefits and Challenges• Statutory basis provides definitive requirements and
ways to address shortcomings• Clinical underperformance
• Infrastructure
• Workforce development & accreditation
• Processes can be slow, including time for GMC
investigations
• Cultural issues
• Motivation
• Trust
Procedure for handling of concerns about FPS Practitioners
Concerns Raised
Stage 1
Allocated to Case Officer
Stage 2
Regional Professional Panel
Stage 3
Reference Committee
Director of Integrated Care
Director of Integrated Care
through Assistant Directors
GMS, Pharmaceutical,
Dental, Optometry Services
Director of Integrated
Care through Chair of
Panel
HSCB Board through
Reference Committee
All cases managed, recorded,
concluded
Managed, recorded and
reported to Regional
Professional Panel or
referred to RPP
Advice on investigation and
management including
direct referral to Counter
Fraud and Probity Services;
onward referral to
Reference Committee
Adjudication on referral to
disciplinary authorities eg
national regulators, PSNI*,
HPSS Tribunal.
Adjudication on PMPL**
actions for GPs
Accountability Outcomes
* PSNI: Police Service of NI ** PMPL: Primary Medical Performers' List
Quality & Outcomes Framework (QoF) 2013/14
N Ireland England Scotland Wales
GP Practices 351 7,921 995 465
Max points
available
912 900 923 969
Average
points
achieved
896.5 831.4 900.8 928.9
%
Achievement
98.3% 92.4% 97.6% 95.9%
50%
55%
60%
65%
70%
75%
80%
85%
90%
95%
100%
105%
1 10 19 28 37 46 55 64 73 82 91 100109118127136145154163172181190199208217226235244253262271280289298307316325334343352
% O
utc
om
es
HSC Board GMS Practices
Hypertension5 (HYP002NI) - The percentage of patients with hypertension in whom the last blood pressure (measured in the previous 9 months) is 150/90 or less
(maximum threshold - 70%)
2009/2010 Practice Outcome
2013/2014 Practice Outcome
Pharmacy
Regulated through:
• Contractual – terms of service set out in
Regulation
• Professional – registration of premises,
superintendent pharmacists and responsible
pharmacists
Medicines
• Human Medicines Regulations (subsumed
Medicines Act)
• Misuse of Drugs Act
Challenges
• Medicines – regulation complexity
• Pharmacists – patient facing role
• Pharmacy support staff – regulation
• Contractual – patient registration; pharmacist
lists
Support for Good Medical Practice…
Dental Regulations
Principal
• General Dental
Services Regulations
(1993)
• HPSS Quality
Improvement
Regulations (2003)
• GDC Standards for the
Dental Team (2013)
Supporting
• Disciplinary Regulations
(2014)
• Patient Charge
Regulations (1989)
• Ionising Radiation
Regulations (2000)
Implementation/ Enforcement of Regulations
GDS Regulations
• Post-treatment record checks
• Post-treatment patient
examinations
• Practice declarations
HQI Regulations-
• 15 published dental practice
quality standards.
• Compliance checked by
annual RQIA practice
inspections
GDC Standards
• Ethical responsibility to follow
• Employers, commissioners
and patients may refer.
• Referrals have to pass
through two screening stages
before a full hearing
Dental
Benefits
• Clear rules, fairness
to all
• Clear lines of
accountability
• Public Confidence
• Assurance of Quality
Challenges
• Tension b/n running a
business and
maintaining quality
• Variation in standards
• Stress among
practitioners
• Resources to monitor
contacts
General Ophthalmic Services
HPSS GOS Regulations (NI) 2007• Schedule 1: (Regulation 2) Terms of Service outlines
requirements for premises and equipment, access hours,
and clinical records etc.
• Schedule 2: (Regulation 3) Constitution of Ophthalmic
Committee
These are backed up by HSC (Disciplinary Procedures)
Regulations (NI) 2014 giving HSCB powers to investigate
allegations that a practitioner has failed to comply with Terms of
Service
General Ophthalmic Services (GOS)Approach taken to governance of ophthalmic service provision
Governance
REGULATIONS
QUALITY ASSURANCE
PATIENT FEEDBACK
1. Current regulatory framework - General Ophthalmic Services
Regulations (Northern Ireland) 2007 - Principal Regulations and Terms of
Service applied to all contractors
2. Directorate of Integrated Care – Manual for the investigation and processes
for management of underperformance
Head of Optometry
Clinical Adviser Team
(1 clinical adviser is Governance lead)
DoIC Business Support
(Governance ABSMs)
Benefits and Challenges
• Listing of all
contractors
• Governance
arrangements in
place to ensure
compliance with
Regulations and
drive up quality.
• No powers of
suspension
• Internal audit has
recommended that
HSCB negotiate and
agree a new GOS
contract to better
monitor & action
performance.
How else could we seek to improve clinical
services?
• Collaboration and co-operation
Delivering integration
What are Integrated Care Partnerships?Networks of providers - Working together to deliver the right care, in the right place at the right time.
ICP Areas