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Agenda Item: 6 Paper Ref: 6.1
Governing Body Assurance Framework
MEETING: NHS Enfield Clinical Commissioning Group Governing Body
DATE: 22 May 2013
TITLE: Governing Body Assurance Framework
LEAD BOARD MEMBER:
Aimee Fairbairns, Director of Quality and Integrated Governance
AUTHOR: Bridget Pratt, Head of Governance & Risk
CONTACT DETAILS:
SUMMARY:
The 2013/2014 Governing Body Assurance Framework (GBAF) will set out the key risks to achieving the CCG’s strategic objectives and priorities. They include risks associated with quality and safety, maximising productivity, efficiency and cost effectiveness.
The GBAF (also known as the Board Assurance Framework (BAF)) is an important document for providing external assurance (for example to NHS England, Audit and the public) that Enfield CCG is sighted on its risks and has a robust system of internal control.
The Governing Body is only properly able to fulfil responsibilities through an understanding of the principle risks facing the organisation.
Assurance Framework Process
The Assurance Framework is populated and updated through an escalation process described in Enfield CCG’s Risk Management Strategy.
The Assurance Framework provides the Governing Body with all key risks from 1st April 2013. It incorporates open risks from the 2012/2013 Assurance Framework which was part of Enfield CCG’s governance and risk management process as a shadow organisation.
The Assurance Framework enables a focused view on the challenges to the delivery of the CCG’s key objectives agreed in 2012/2013. Corporate Objectives from 2012/13 and their
1
review will form part of the organisational development process for 2013/14. Until the 2013/14 corporate objectives have been developed, the 12/13 objectives remain in place.
There has been a robust review of significant risks by Senior Responsible Officers and Risk Leads. Open risks from the 2012/2013 Assurance Framework have been reviewed and obsolete risks have been redefined. Risks that have been fully implemented have been closed and archived. New risks impacting on the CCGs corporate objectives have been incorporated and labelled as new risks in the document. Enfield CCG continues to work with Public Health to identify and mitigate risks relating to the Joint Strategic Needs Assessment and the Health & Wellbeing Strategy. This will feed into the CCG’s risk management and monitoring process in 2013/2014.
SUPPORTING PAPERS:
The Assurance Framework is relevant to the CCG Commissioning Strategic Plan, Operating Plan, Corporate and Directorate Risk Registers.
RECOMMENDED ACTION:
• The Governing Body is asked to note the Assurance Framework which has been developed from the 12/13 Assurance Framework. A full review of the 2013/2014 Assurance Framework will be undertaken at the June Audit Committee with further update to the July Governing Body Meeting.
• In line with the Enfield CCG Risk Management Strategy, the Assurance Framework will form part of regular reporting to the Executive Committee, Audit Committee and Governing Body.
Objective(s) / Plans supported by this paper: Constitution
The GBAF applies to all plans related to services commissioned by the CCG
Patient & Public Involvement (PPI): Enfield CCG aims to involve patients and the public in implementing its corporate objectives.
Equality Impact Analysis: This is conducted in line with commissioning intentions.
Risks: As cited on the GBAF, Corporate and Directorate Risk Registers
Resource Implications: Resources implications associated to Assurance Framework risks are considered and specified as part of the risk review process
Audit Trail: The 2012/2013 GBAF went through rigorous review at the Audit Committee, CCG Executive and Quality & Safety Committee and a similar process will apply in 2013/2014. Next steps:
• Develop and strengthen the CCGs 13/14 corporate objectives via the organisational development programme.
2
• Audit Committee sign off of the Assurance Framework for the July Governing Body Meeting
• Implement the Datix electronic risk management software for monitoring and updating the Assurance Framework and Risk Registers. A programme of training will be rolled out for Risk Leads by the end of June 2013.
Contents
1. Assurance Framework ....................................................................................... 4
2. Document creation ............................................................................................. 4
3. Corporate Objectives.......................................................................................... 5
4. Governing Body Assurance Framework ............................................................. 6
5. Risk Grading Matrix .......................................................................................... 20
6. Appendix 1: How to interpret the Enfield CCG Board Assurance Framework ...... 21
3
1. Assurance Framework
The purpose of the Governing Body Assurance Framework (GBAF) is to:
• Identify the main risks to achieving Enfield CCG’s objectives,
• List and evaluate the mitigations in place to the reduce the likelihood or impact of the risk,
• Summarise the remedial or proposed actions that further mitigate the likelihood or impact of the risk.
• Summarise the controls, assurances and gaps relating to each main risk.
The GBAF is an important document for providing external assurance (for example NHS England, Internal Audit and the public) that Enfield CCG is sighted on its risks and has a robust system of internal control.
The GBAF is populated and updated through an escalation process described in the Enfield CCG Integrated risk management framework.
The risk scoring matrix to establish initial risk ratings is shown at section 5.
2. Document creation
This document was populated from risks identified from the following sources:
• Risk assessment of Enfield CCG objectives
• Collaboration on risk issues with CCGs in NCL and NECL
The risks were accumulated, filtered and reviewed by the Governance team with the Risk Owners and Leads to produce this Governing Body Assurance Framework.
4
3. Corporate Objectives
In 2012 the Enfield CCG Governing Body agreed the following Corporate Objectives:
1. Enable the people of Enfield to live longer fuller lives by tackling the significant health inequalities that exist between communities
2. Provide children with the best start in life
3. Ensure the right care in the right place, first time
4. Deliver the greatest value for money for every NHS pound
5. Commission care in a way which delivers integration between health, primary, community and secondary care and social care services
Corporate Objectives from 2012/13 and their review will form part of the organisational development process for 2013/14. Until the 2013/14 corporate objectives have been developed, the 12/13 objectives remain in place.
5
4.0. Full Governing Body Assurance Framework
Corporate Objective 1: Enable the people of Enfield to live longer fuller lives by tackling the significant health inequalities that exist between communities.
Risk No Executive Lead & Clinical Lead
Risk Description Initial risk rating
(LxC=RR) Controls
Assurances Current risk rating
(LxC=RR)
Gaps Actions required
Target risk
(LxC=RR) Internal External Control Assurance
CO1-01
Risk redefined from the 2012/2013 BAF
Director of Service Quality and Integrated & Medical Director
There is a risk that the CCG will not be able to invest sufficiently in services to reduce inequalities if it does not deliver its financial savings. This could lead to a failure to improve life expectancy
4 x4
=16
- Finance Recovery & QIPP (FR&Q) Committee in place to oversee the allocation of resources.
-Public Health Engagement with GPs.
-PPE Committee overseeing equality
-Executive lead in post with lead for equality.
-Equality Strategy in place.
-TOR, agendas and minutes of FR & Q Committee
-Job description and objective of Executive lead
-Equality reports
-Committee and Governance structure.
-The Governing body approved strategies.
-Minutes of PPE Meetings
-Equality Plan.
-Health & Well Being Board (HWBB) Terms of Reference (TOR), agendas and minutes.
-NHS England
-Positive Patient & Public Engagement (PPE) feedback.
3 x
4 =
12
Links with Local Authority and voluntary / 3rd sector to be strengthened.
Evidence of relationships with key stakeholders.
- Continue to work with the Health & Well Being Board.
- Continue to work with Joint Commissioning Board.
- Increase patient engagement through Patient Participation Group’s (PPG’s) and external events.
- Appoint Patient Representative to Governing Body (GB).
- Continue rigorous control of budgets through FR&Q Committee.
1 x
4=
4
Corporate Objective 2. Provide children with the best start in life
There are currently no significant risks against this objective
6
Corporate Objective 3: Ensure the right care in the right place, first time
CO3-01
Risk redefined from the 2012/2013 BAF
Barnet, Enfield & Haringey (BEH) Programme Director & Medical Director
BEH Clinical Strategy Programme: There is a risk that the transfer of services may be affected by the commencement of a judicial review which could impact on the delivery of programme.
4 x
4= 1
6
-Strong governance arrangements in place across programme and within Trusts.
-Full engagement and communication with stakeholders.
-Issues resolved as raised through the implementation phase of the programme.
Governing Body.
- BEH Clinical Strategy Programme governance including Programme Board and SRO.
4x 4
= 16
Develop joint indicators monitoring progress on primary care strategy.
Fully meet the Independent Review Panel recommendations.
- Joint indicators monitoring progress to be developed with stakeholders.
- The IRP recommendations are progressing and will be fully met. The clinical case for change is strong.
3x4
= 12
CO3-02
Risk redefined from the 2012/2013 BAF
Director of Service Quality and Integrated Governance & Medical Director
Changes in the provider landscape which also includes the BEH Clinical Strategy could affect the Quality and Safety of patient care during transition.
4 x
4 =
16
-BEH Clinical Cabinet.
-Clinical Quality Review Groups for each contract.
-Quality and Safety Committee reporting.
-Performance reporting through governance framework to the Governing Body.
-Quality and Safety Committee.
-Governing Body.
-Clinical Cabinet.
-BEH Programme Board.
-Internal Audit.
-Joint BEH CCG Gateway review.
-NHS England external clinical assurance process
3 x
4 =
12
Enfield CCG Integrated Quality and Performance report in development
Full reporting against BEH quality metrics not yet fully established
-Clinical Cabinet to receive quality report June 2013.
-Work with CSU to ensure report delivers to agreed timescales (June 2013).
2 x
4 =
8
New risk
CO3-03
BEH MH Programme Director & Mental Health Clinical Lead
There is a risk that the Trust Development Agency (TDA) will not authorise BEH MHT to proceed to FT Status which could impact on service, business continuity and prolonged period of uncertainty.
4x4-
16
-Contribute to the TDA Gateway Review to ensure an accurate reflection of clinical practice is captured.
-Work collaboratively with BEH on the implementation of an action plan arising from TDA recommendations.
Governing Body TDA review
3 X
4=12
Implementation of action plan following TDA review
Awaiting TDA review
-Joint response with BEH once TDA review is completed.
-Scrutiny of Governing Body.
3 X4
=12
7
Corporate objective 4: Deliver the greatest value for money for every NHS pound
Risk No. Executive Lead & Clinical Lead
Risk Description
Initial risk rating
(LxC=RR)
Controls
Assurances Current risk rating
(LxC=RR)
Gaps
Actions required Target risk
(LxC=RR) Internal External
Control Assurance
CO4 -01
Risk redefined from the 2012/2013 BAF
Interim Director of Strategy & Performance & CCG Chair
The CCG is at risk of not complying with statutory responsibilities due to the lack of clarity on the arrangements in place for the following areas:
-Health & Safety
-Security
-Infection Control
-Mandatory training
-Emergency Planning/business continuity plans
-Complaints and IFRs
This could result in legal challenge and adverse publicity or a serious incident.
3 x
5 =
15
- Commissioning Support Unit (CSU) has confirmed mandatory training is included in Service Level Agreement (SLA).
Working with the CSU to clarify what is covered within SLA for:
-Emergency Planning/business continuity plans
-Complaints and IFRs
-Where necessary, contingency management arrangements by senior managers, overseen by lead Director/s
-Regular contracts and CSU meetings.
-CCG management review of transferred functions and options to adapt structure to accommodate non-CSU provided functions presented to Executive Group 08/05/13.
-NHS England.
-Internal & External Audit.
2 x
5 =1
0
-Confirmation received from the CCG that that the following areas are not included in the SLA:
-Health & Safety
-Security
-Infection Control
-Lack of clarity regarding specification of some CSU services and CCG decision lead roles due to early stage of development
Services listed below are not part of the CSU core offer:
• Health & Safety
• Security
• Infection Control
CSU service provides point of co-ordination and advice, not the full direct service:
• Occupational health
• Equality and Diversity Policies
• Legal Affairs/legal claims
-Arrangements to be put in place following discussions with the CSU.
-Chief Officer to decide on adaptations to structure within budget based on CCG management review of transferred functions with Chair and other Executive Group members.
-Presentation of key changes to Governing Body.
-Remuneration and Nomination Committee to consider any new very senior roles within its remit.
2 x
5 =1
0
8
Risk No. Executive Lead & Clinical Lead
Risk Description
Initial risk rating
(LxC=RR)
Controls
Assurances Current risk rating
(LxC=RR)
Gaps
Actions required Target risk
(LxC=RR) Internal External
Control Assurance
New risk
CO4 -02
Interim Director of Strategy & Performance & CCG Chair
Risk of differing service scope expectations between CCG and CSU in first agreement year, due to the changing face of commissioning landscape. This may include business elements that are not yet in place / still to be set up affecting operational capability to deliver commissioning support services.
4 x
4 =
16
- CCG strategy and business plan.
-Agreed SLA between CCG and CSU for core and additional services.
-GB Agreed updated SLA with KPIs between CCG and CSU for core and additional services 22 January 2013.
-Quarterly SLA review meetings scheduled.
- Annual SLA review and acceptance of in year variations to agreement scheduled.
-CCG and CSU Collaborative working through issues identified in new commissioning requirements.
-Commissioning Support Director (CSD) management of inclusion of new service or amendment to service.
-CCG Executive Committee.
-Joint commissioning support delivery issues log reviewed 2 to 4 times per month by Interim DS&P and CSD.
-System wide DoH and NHS England approval of NEL CSU Business Plans.
-Internal Audit.
4 x
4 =
16
Confirmation of operating framework: service specifications, standard operating procedures and service line costings
Service specifications, standard operating procedures and service line costing are in production
- Confirmation by CSU of new operating framework.
-Joint resolution of service offer delivery issues, including briefings on standard operating procedures and connectivity with CCG functions and decision leads.
-Request new service requirements or amendments to services under current SLA with clear specification.
2 x
4 =
8
9
Risk No. Executive Lead & Clinical Lead
Risk Description Initial risk rating
(LxC=RR) Controls
Assurances Current risk rating
(LxC=RR)
Gaps
Actions required Target risk
(LxC=RR) Internal External
Control Assurance
CO4 -03
Risk redefined from the 2012/2013 BAF
Director of Finance & Commissioning (DF&C) & Chair of the Finance & Recovery Committee
Risk that the CCG will not achieve financial balance for the year 2013/2014. This could lead to:
-Reduced ability to achieve all Corporate Objectives,
-Negative media coverage and reduced public support for the CCG.
4 x
5 =
20
-Robust processes in place to ensure delivery of the financial outturn including the 2013/14 QIPP Plan.
-Transformation Programme Group (TPG) in place and meeting every two weeks to ensure QIPP achievement and provider run rate reductions
-Documented reporting process for the reporting of financial data to the Financial, Recovery & QIPP Committee.
-Minutes of Transformation Programme Group.
-Minutes of ECCG Governing Body demonstrate Board oversight.
-Monitoring by NHS England.
-Internal & External Audit Reports.
3 x
5 =
15
-Identify new opportunities for savings utilising external reviews e.g. PwC.
-Improve data quality, which will better inform procurement proposals.
-Continued reporting of Financial status to FR&Q Committee.
-Audit Committee Scrutiny.
2 x
5=
10
Risk No Executive Lead & Clinical Lead
Risk Description Initial risk rating
(LxC=RR) Controls
Assurances Current risk rating
(LxC=RR)
Gaps
Actions required Target risk
(LxC=RR) Internal External
Control Assurance
10
Risk No Executive Lead & Clinical Lead
Risk Description Initial risk rating
(LxC=RR) Controls
Assurances Current risk rating
(LxC=RR)
Gaps
Actions required Target risk
(LxC=RR) Internal External
Control Assurance
CO4 - 04
Risk redefined from the 2012/2013 BAF
Interim Director of Strategy & Performance & CCG Chair
- There is a risk that Enfield CCG may not discharge the 7 conditions on Authorisation set by NHS England if:
• The rectification plan not approved by NHS England.
• Milestone/s not met for planned discharge of conditions at June Authorisation Assurance Review with NHS England.
• Governance of collaboration agreements between CCGs is not sufficiently effective as assessed by NHS England.
• risk share agreements between CCGs is not sufficiently effective as assessed against the Operating Plan and Financial Recovery Plan by NHS England .
This may result in negative media coverage and reduced public opinion.
-Organisational Development Plan to secure current and future leadership and management capabilities.
4 x
5 =2
0 -Establishment of NHS Enfield CCG as a CCG on 6 March 2013 by NHS England with 7 Authorisation Conditions, including one legal direction (out of 119 criteria).
-Rectification Plan submitted by deadline of 12/04/13m
-Inclusion of Rectification Plan deliverables and milestones in Integrated Performance Reporting process.
.
-ECCG operating plan
-Authorisation rectification plan deliverables and action on any variances included in Integrated Performance Reporting.
-Executive Group Review.
-Governing Body Reports.
-Organisational Development Plan.
NHS England
2 x
5 =
10
-NHS England commentary of rectification plan not yet received. Due w/c 13/05/13.
-NCL CCGs’ Collaboration Risk Sharing Agreement yet to be agreed by all CCGs.
-Risk share agreement document approved by all NCL CCGs.
-External review of Financial Recovery Plan (see Risk Register for Financial Recovery & QIPP.
Delivery of actions against milestones set out in the Rectification Plan and also assurance review with NHS England in June 2013
1 x
5 =
5
11
Risk No.
Executive Lead & Clinical Lead Risk Description
Initial risk rating
(LxC=RR) Controls
Assurances Current risk rating
(LxC=RR)
Gaps
Actions required
Target risk
(LxC=RR)
Internal External Control Assurance
CO4-05
Risk redefined from the 2012/2013 BAF
Director of Finance & Commissioning & Chair of Finance Recovery & QIPP Committee
Insufficient QIPP Schemes may result to the CCG not meeting its 3 year QIPP plan (this risk is also linked with acute care contracts over performing).
This could lead to:
-Reduced ability to achieve all Corporate Objectives.
-Negative media coverage and reduced public opinion.
5 x
5 =2
5
-QIPP plans are a key enabler for achieving future financial planning and balance.
-Fortnightly QIPP Plan Steering / Transformation Programme Group (TPG) has been established to oversee development of 3 year financial plan and QIPP Schemes.
-Financial Recovery Plan to identify weakness and risk to delivery.
-Commissioning Strategic Plan to NCB.
-Finance, Risk & QIPP Committee and GB overview and controls in place.
-QIPP reporting to CCG.
-Transformation Programme Office (TPO) performance monitoring reviews reporting to TPG.
-Financial Recovery & QIPP Committee (FR&QP).
-Review all QIPP plans for approval by CCG Governing Board.
-Monitoring by NHS England.
-Internal Audit Review Report.
2 x
5 =
10
-Review all QIPP plans for approval by CCG Governing Board
Continued Review & performance monitoring connected with TPG and FR& Q Committee
-CCG/GP Leadership & Engagement in programme to deliver QIPP.
-Identification of further saving opportunities.
-Cooperation and collaborative work with providers and CCGS in the development of health system –wide plans.
-Project Management Control.
1 x
5= 5
12
Risk No.
Executive Lead & Clinical Lead Risk Description
Initial risk rating
(LxC=RR) Controls
Assurances Current risk rating
(LxC=RR)
Gaps
Actions required
Target risk
(LxC=RR)
Internal External Control Assurance
New risks
C04 - 06
Director of Finance & Commissioning & Chair of Finance Recovery & QIPP Committee
Transfer of Specialist commissioning to NHS England. There is a risk that the CCG’s will be adversely affected by the impact of the transfer of Specialist Commissioning Services to NHS England which could impact on the CCG’s financial position. Risk increased by additional reduction of £9m from CCG allocation
4x5
= 20
-CSU reconciliation of Specialist Commissioning baseline and impact by provider.
-NHS England expectation is the impact on the CCG will be neutral following monthly reconciliation.
-Finance Recovery and QIPP Committee.
-CSU Contracts and Analytics Team review and control of Specialist Commissioning values.
-External Audit
-NHS England
3x5
= 20
Revised reconciliation being carried out by the CSU following £9m reduction in CCG allocation.
Clarity of monthly reconciliation process and impact of month 6 review based on actual costs.
Obtain confirmation of neutrality
Complete reconciliation and assess Financial implications – 30th June 2013. (Completion of this action should result in a reduced target risk consequence score).
Inform NHS England of implications and obtain confirmation of neutrality – 30th June 2013.
3x4
= 12
New risk
C04 -07
Director of Finance & Commissioning & Chair of Finance Recovery & QIPP Committee
Finalisation of 2013/14 SLA’s with major providers. There is a risk to the CCG if SLA’s with major Acute, Mental Health and community Providers are not finalised and signed which could impact on the CCG’s financial position and performance delivery.
4x5
= 20
-Affordability analysis
-CSU updates on progress on contractual negotiations
-Report to GB
-Weekly Contract Steering Group Meetings Simon to confirm if this exists.
-Direct discussions between senior CCG executives and provider executives.
Internal & External Audit
2x5
= 10
SLA to be finalised
Report to GB Report to May GB on Current Status – 30th June 2013.
2x5
= 10
New risk
C04-08
Director of Finance & Commissioning & Chair of Finance Recovery & QIPP Committee
Retrospective Continuing Care Claims. There is risk to the CCG if the cost of retrospective claims are not accurately assessed which could impact on the CCGs financial position.
4x5
= 20
CCG involvement in 2012/13 annual accounts process for NHS Enfield including 30% reserve proposed in 2012/13 results
Finance, Recovery & QIPP Committee
NHS England
2x5
= 10
None at present
None at present
Keep under review
2x5
= 10
13
Risk No.
Executive Lead & Clinical Lead Risk Description
Initial risk rating
(LxC=RR) Controls
Assurances Current risk rating
(LxC=RR)
Gaps
Actions required
Target risk
(LxC=RR)
Internal External Control Assurance
New risk
C04- 09
Interim Director of Performance & Strategy & Medical Director
Access to SUS National data system is only available to ECCG for PCT closedown purposes for 12/13. Enfield CCG is not able to access patient data from the SUS system until national agreement is determined. This may cause delays to schemes incurring financial risk to performance and contract monitoring and accessing information for Enfield Transformation
4x5
= 20
-CSU Director of Analytics working to resolve the issue
-Consistent and continual communication between CCG and CSU.
-Application of Information Governance advice and good practice resulting in suspension of CCG use of patient identifiable data.
CCG Executive -NHS England
-NHS Information Centre.
-Information Commissioner
-Internal Audit.
4x5
= 20
Lack of sufficient controls issue is National and requires DOH/Information Centre action
No clear timescale for resolution
-Continued dialogue with CSU Director of Analytics.
-Resolution requires national determination.
3x5
= 15
New risk
C04-010
Director of Finance & Commissioning & Medical Director
Performance risks: Acute Provider is unable to meet Constitution target for waiting times on referral to treatment, A&E and diagnostic waits resulting in individuals waiting beyond the national standard.
4x5
= 20
- Formal contracts in place with providers
-Contract and Quality Review Group meeting structures in place.
-Performance improvement plans in place from provider.
Regular exception reports and monthly monitoring performance reports
-NHS England.
-Internal Audit.
4x5
= 20
Detailed information requested from provider on a validation and demand and capacity modelling process to validate the current position
Questions requesting more detailed information and explanation of how the Trust is providing assurance to its Trust Board
-The Trust is undertaking a validation process and has been required to provide a recovery action plan.
-Full impact is being assessed with the Trust supported by CSU and appropriate plans will be determined to minimise impact.
3x5
= 15
14
Risk No.
Executive Lead & Clinical Lead Risk Description
Initial risk rating
(LxC=RR) Controls
Assurances Current risk rating
(LxC=RR)
Gaps
Actions required
Target risk
(LxC=RR)
Internal External Control Assurance
New risk
C04-011
Director of Finance & Commissioning & Medical Director
Barnet, Enfield & Haringey Mental Health Trust is unable to meet national target for increasing access to psychological therapies resulting in potential for an imbalance in demand/supply with increased waiting times and potential increased referrals to secondary services.
4x5
= 20
Formal contracts in place with providers
Performance Reports
External review of service to determine an appropriate way forward.
4x5
= 20
Level of investment to be finalised
Contract not agreed with provider for 13/14 and level of investment is yet to be confirmed
-Level of investment to be confirmed.
-Contract to be finalised.
-External review to be completed to determine appropriate way forward – expected timescale for review July.
3x5
= 15
Corporate Objective 5: Commission care in a way which delivers integration between health, primary, community and secondary care and social care services
Risk No.
Executive Lead & Clinical Lead
Risk Description Initial risk rating
(LxC=RR) Controls
Assurances Current risk rating
(LxC=RR)
Gaps
Actions required Target risk
(LxC=RR) Internal External Control Assurance
CO5-01
Redefined risk from the 2012/2013 BAF
Chief Officer & Medical Director
Primary Care Strategy: As the CCG no longer commissions Primary Care, there is a risk that some initiatives will be more complex to commission and the CCG will need additional support from NHS England & other bodies which may result in a potential delay in the implementation of the Primary Care Strategy
4x4=
16
-Medical Director and Primary Care Lead Networks Champions in place.
-Project Delivery team now fully in place.
-Oversight and direction by Primary Care Strategy Implementation. Board
-Primary Care Strategy Board.
-Monthly reporting to CCG Executive.
-Health & Well Being Board.
-Internal Audit Review.
3x4=
12
-Potential conflicts of interest may lead to lack of Clinical approval of improvement scheme.
-Lack of capacity of health watch to provide a patient perspective.
-Currently no peer review group established for Locally Enhanced Service (LES) approval.
-Wider audit of adherence to the Conflict of Interest policy.
-Wider audit of the Conflict of Interest Policy via internal audit.
-Monthly reporting to CCG Board and Executive in implementation plan.
2x4=
8
15
Risk No.
Executive Lead & Clinical Lead
Risk Description Initial risk rating
(LxC=RR) Controls
Assurances Current risk rating
(LxC=RR)
Gaps
Actions required Target risk
(LxC=RR) Internal External Control Assurance
New risk
CO5-02
Chief Officer & Medical Director
Primary Care Strategy: Poor GP engagement, co-ordination of relevant teams and lack of defined outcome measures may result in not achieving goals of the Primary Care Strategy through networking arrangements
4x4=
16
Workshops by GP Champions at Network Level have taken place
-Primary Care Strategy Board
-Monthly reporting to CCG Executive
-Internal Audit Review
3x4=
12
Lack of awareness of GPs impacting on GP engagement and uptake of improvement schemes
Lack of defined outcomes
-Further workshops and planning sessions on GP involvement to be held.
-Further clinical led focus groups on taking up new activities.
2x4=
8
New risk
CO5-03
Chief Officer & Medical Director
Risk that the budget allocated to Enfield for 2013/2014 will not be spent in full which could result in reduced capacity and expertise in delivering local health care with a consequential political impact
4x4=
16
Regular budget reporting
-Primary Care Strategy Board.
-Monthly reporting to CCG Executive.
-Internal Audit Review.
-Local Budget Reporting at CCG level.
-Internal Audit Review
3x4=
12
Lack of early clarity in total budget allocation
The approval process for new schemes (see risk MDR 006)
-Need to establish correct budget allocation for this year.
-Establish local cost code centres with the finance team.
-On-going review of project business cases to ensure they are realistic and delivering on time.
2x4=
8
New risk
CO5-04
Chief Officer & Medical Director
Delivery of web enabled GP clinical IT systems is delayed due to lack of programme management which could impact the implementation of the PCS
4x4=
16
Regular meetings between Primary Care Strategy Manager & GP IT Manager
Reporting to Primary Care Implementation Board
-Internal Audit Review
3x4=
12
Lack of clear planning timetable and resource allocation
Gap of Local presence from CSU IT Team and regular exception reporting
Programme team to deliver a robust timetable and resource plan.
IT Senior Programme Manager to attend the Primary Care Implementation Board.
2x4=
8
16
4.1. Governing Body Assurance Framework- Risk Profile
Risk Risk description
Initial Risk
Rating APR
MAY JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR
CO1- 01
There is a risk that the CCG will not be able to invest sufficiently in services to reduce inequalities if it does not deliver its financial savings. This could lead to a failure to improve life expectancy
16 12 4 4 0
CO1- 02Increased prevalence in long term conditions, high mortality rates relating to cancer and Cardiovascular Disease (CVD) In East Localities in comparison to the West Localities.
16 12 12 12 0
CO1- 03Childhood obesity rates in the Borough are amongst one of the highest in the country and represent the seventh and twelfth highest rates in London respectively.
16 16 12 12 0
CO3-01
There is a risk that the transfer of services under the BEH Clinical Strategy Programme may be affected by the commencement of a Judicial Review which could impact on the delivery of programme.
16 16 12 12 0
CO3- 02Changes in the provider landscape which also includes the BEH Clinical Strategy could affect the Quality and Safety of patient care during transition.
16 12 12 12 0
CO3-03
There is a risk that the Trust Development Agency (TDA) will not authorise BEH MHT to proceed to FT Status which could impact on service, business continuity and prolonged period of uncertainty.
16 12 12 12 0
CO4-01
The CCG is at risk of not complying with its statutory responsibilities due to the lack of clarity on the arrangements in place for the following areas: Health & Safety, Fire , Security, Infection Control, Emergency Preparedness, Business Continuity, Compalints and Individual Funding Requests
15 10 10 10 0
Target risk
Difference between forecast
and target
End of 2013/14 forecast
ProgressQTR4QTR3QTR2
2014
QTR1
17
CO4-02
Risk of differing service scope expectations between CCG and CSU in first agreement year, due to the changing face of commissioning landscape. This may include business elements that are not yet in place / still to be set up affecting operational capability to deliver commissioning support services.
16 16 8 8 0
CO4-03
Risk that the CCG will not achieve financial balance for the year 2013/14. this could lead to: reduced ability to achieve all corporate objectives, negative media coverage and reduced public support for the CCG
15 15 10 10 0
CO4-04
There is a risk that Enfield CCG may not discharge the 7 conditions on Authorisation set by NHS England. This may result in negative media coverage and reduced public confidence.
20 10 5 5 0
CO4-05Insufficient QIPP Schemes may result to the CCG not meeting its 3 year QIPP Plan (this risk is also linked with acute contracts over perforrning)
25 10 5 5 0
CO4- 06
There is a risk that the CCG will be adversely affected by the impact of the transfer of Specialist Commissioning Services to NHS England which could impact on the CCG's financial position. Risk increased by additional reduction in £9 M from CCG allocation.
20 20 12 12 0
CO4-07
There is a risk to the CCG if SLA’s with major Acute, Mental Health and community Providers are not finalised and signed which could impact on the CCG’s financial position and performance delivery.
20 10 10 10 0
CO 4-08There is risk to the CCG if the cost of retrospective claims are not accurately assessed which could impact on the CCGs financial position.
20 10 10 10 0
CO4-09
Access to SUS National data system is only available to ECCG for PCT closedown purposes for 12/13. Enfield CCG is not able to access patient data from the SUS system until national agreement is determined. This may cause delays to schemes incurring financial risk to performance and contract monitoring and accessing information for Enfield Transformation
20 20 15 15 0
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CO 4-10Acute Provider is unable to meet constitution target for waiting times- Referral to Treatment resulting in individuals waiting beyond the national standard.
20 20 15 15 0
CO4-11Barnet, Enfield & Haringey Mental Health Trust is unable to meet national target for increasing access to psychological therapies resulting in demands/supply with increased referrals t d i
20 20 15 15 0
CO5- 01
As the CCG no longer commissions Primary Care, there is a risk that some initiatives will be more complex to commission and the CCG will need additional support from NHS England & other bodies which may result in a potential delay in the implementation of the primary care Strategy.
16 12 8 8 0
CO5- 02Poor GP engagement, co-ordination of relevant teams and lack of defined outcome measures may result in not achieving goals of the Primary Care Strategy through networking arrangements.
16 12 8 8 0
CO5- 03
Risk that the budget allocated to Enfield for 2013/2014 will not be spent in full which could result in reduced capacity and expertise in delivering local health care with a consequential political impact
16 12 8 8 0
CO5- 04
Delivery of web enabled GP clinical IT systems is delayed due to lack of programme management which could impact the implementation of the PCS 16 12 8 8 0
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5. Risk Grading Matrix
Key
L (Likelihood) x C (Consequence) = RR (Risk Rating)
This is the grading matrix used to grade all Enfield CCG risks.
Red (15-25) Extreme risk
Amber (8–12) High risk
Yellow (4–6) Moderate risk
Green (1-3) low risk
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6. Appendix 1: How to interpret the Enfield CCG Board Assurance Framework
This is the full Board Assurance Framework entry and has one line per risk
Which Strategic objective is at risk?
What is the risk’s unique identifier?
Job title and initials of the risk lead(s).
What could prevent the organisation from achieving this strategic objective?Consider: Patient harm, financial impact, reputation, etc as listed in the Integrated Risk Management Strategy.
This is the risk rating in terms of:Likelihood x SeverityWith no mitigating controls in place.
What documents provide evidence relating to the effectiveness of the control measures? E.g.Internal: Board reportsExternal: NCB review
What additional controls and assurances are needed or could be added?
This is the risk rating in terms of:Likelihood x SeverityWith mitigating factors in place.
Summary of the plans to address the gaps in control /
assurance and (Indicate target dates and action
owners).
This is the risk rating that the CCG would accept. What risk is within the CCG’s risk appetite.
What can be done to reduce either:The likelihood of the risk occurring OR reducing the impact if it does occur?
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End
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