The failures of governance around the provision of healthcare have been much in the news after scandals such as Ian Paterson. Not surprising then that the Independent Healthcare Providers Network (IHPN) has published its refreshed version of the Medical Practitioners Assurance Framework (MPAF) designed to improve the safety and quality of care that independent providers deliver to patients.
Launched in 2019, the framework was developed by former NHS national medical director Sir Bruce Keogh in the wake of the Ian Paterson investigations and identified as a dynamic document which would reflect best practice around medical governance in the health system.
The framework is now ‘firmly’ part of the patient safety and regulatory landscape, with the CQC adopting its principles to assess the well-led component of its inspections. It is also a requirement of the NHS Standard Contract 2022/23 that all independent sector providers delivering NHS funded care, adhere to it.
Since its launch, much has changed – not surprising after numerous inquiries focused on the patient safety and governance landscape - from the Bishop of Norwich’s independent inquiry report into Ian Paterson to Baroness Cumberlege’s Independent Medicines and Medical Devices Safety Review. There have been other initiatives such as the Learn from Patient Safety Events service (previously known as the National Reporting and Learning System) due to go live from mid-2023, and the wider regulatory changes set out in the Health and Care Act 2022. We have yet to see what emerges from the consultation on appropriate indemnity for clinicians and the recommendations in the Paterson inquiry report. We can expect further references to governance and regulation to emerge from those deliberations.
Ensuring MPAF remains relevant and useful to both independent healthcare providers and healthcare professionals, changes have been made across a several key areas.
The refresh retains the principles-based approach of the framework and continues to emphasise the importance of organisational culture and leadership behaviours in driving clinical governance and the quality of patient care across the independent sector.
Responding to recent safety and regulatory changes, the framework gives greater prominence to patient consent and the need for greater transparency on conflict-of-interest declarations which were key themes in both the Paterson and Cumberlege reviews. It also incorporates the IHPN Development Plan as an appendix detailing how the Network will support IHPN member organisations and stakeholders with continuing to implement the MPAF.
There are also changes to the practising privileges section to ‘better allow for a risk-based approach’ requiring that practising privileges are reviewed biennially for all medical practitioners and more regularly in circumstances where additional scrutiny is required.
The refresh incorporates an expanded section on raising and responding to concerns, with more support tools for independent providers. Providers will also be required to have structured support for practitioners returning to practice after an investigation and has more detail on best practice for the management of patient complaints. In addition, in the ‘Medical Practitioners Responsibilities’ section, healthcare professionals are now asked to seek appropriate help if experiencing pressures that may lead to an impairment of their practice.
The framework’s development has been supported by a reference group consisting of representatives from the Department of Health and Social Care, CQC, the GMC, NHS Resolution, Royal Colleges, Federation of Independent Practitioner Organisations, and the Patients Association. The IHPN will be developing a suite of resources, including training events to ensure providers are in good shape to demonstrate their well-led credentials to CQC.
It is worth noting the findings of the CQC’s 2021/22 State of Care report which shows that the overall ratings for independent health acute services in 2022 are now rated good (82%) and outstanding (8%), described by Dawn Hodgkins, Director of Regulation at the IHPN as “ demonstrating the sector’s clear commitment to providing the best possible patient care.”
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