The much anticipated NHS England’s Patient Safety Incident Response Framework (PSIRF) documentation has been published, with a flexible 12-month implementation schedule outlined. The PSIRF is a contractual requirement for all providers, including independent healthcare providers who deliver NHS-contracted services including secondary, mental health, and community services.

Since PSIRF represents a complete overhaul of the current system, some organisations may be apprehensive about how they can meet and resource the new requirements for serious incidents investigation and reporting. The key challenges especially for independent providers are likely to be around:

– How to deal with current incidents that occur during the transition period.

– Ensuring staff are up to speed and the new processes are embedded across their organisations at a time when resources are already stretched.

– Getting access to the right resources such as training and tools

The PSIRF provides the new methodology for handling patient safety incidences over the next 5 to 10 years. This article looks at some of the fundamental changes being introduced and what healthcare providers need to do to be equipped in this important area.

More flexibility for improved patient/healthcare worker outcomes

Organisations should be using this new framework to ensure that future investigations are “strategic, preventative, collaborative, fair and people-focused”. Essentially the reporting system is being transformed to be more flexible, less prescriptive and more system-focused. This means looking at the causes of any incident within the system, rather than seeking someone to blame. A serious incident is defined as an unintended or unexpected incident which could have or did lead to harm for one or more patients receiving healthcare.

In implementing PSIRF, healthcare providers have to decide which patient safety incidents require more rigorous investigations and which do not, always with an eye on positive learning outcomes when things go wrong, ensuring similar mistakes are not repeated.

While greater flexibility is a good thing, it does require clinical governance teams to decide how to get the new framework working best for them. The leaders responsible for patient safety will need to show in their planning that their organisations are prepared for these changes and that their systems and processes are developed to support safe care to patients in accordance with the new guidance.

In particular, providers need to demonstrate that they have:

– A system to determine which incidents need investigating and those that are more suited to an alternative approach

– Adequate resources available to ensure staff have enough time to conduct a meaningful investigation.

Each organisation must detail this in a patient safety incident response plan (PSIRP) which must be reviewed every two years. NHSE have published a PSIRP template to assist organisations with this.

Key Aspects of the PSIRF

While patient safety incidents are thankfully rare, this new framework prioritises compassionate engagement with patients, family and staff affected by incidents. This provides vital insight into how to improve care, ultimately making services safer for patients. The new focus is on understanding how incidents happen – including the factors which contribute to them. PSIRF was piloted by 24 Early Adopter NHS Trusts and NHS England has taken on board their feedback, which shaped the nationally rolled out framework to keep it relevant and usable. Plans will need to be updated to incorporate any new learning, the changing risk profile of an organisation, as well as any ongoing improvement initiatives.

Key PSIRF aims include:

– Having a broader range of responses to incidents, not just formal investigations.

– Develop a proactive strategy for learning from patient safety incidents (LFPSE).

– Acknowledging system failings rather than casting blame on individuals

– Making better use of data, especially looking at what works well

– Supporting appropriate and adequate patient safety training where it is needed

– Applying focused work into areas in which the most impact may be achieved

Some incidents will qualify for a Patient Safety Incident Investigation (PSII) but there will be others, where alternative proportionate responses such as case note reviews, open conversations or after-action reviews will be seen as more apt. In some other cases ‘do not investigate’ or ‘no response required’ will also be appropriate. The important thing is to have a PSIRP that sets out the criteria and for trained investigators with experience in Patient Safety Incident Investigation (PSII). They must also be afforded dedicated time and resource to identify contributory, human and causal factors as well as system factors.

The investigation timescales are also becoming more flexible with the previous 60 days timeline being replaced with individual PSII timescales being agreed in consultation with the patient and/or family.  That said, the guidance suggests that investigations should average three months and never exceed six months.

In the event of serious incidents, potential investigations will be assessed against four criteria:

– Outcome impact – is this an important issue?

– Systemic risk – is the incident systemic rather than local, based on a specific team or setting?

– Learning potential – can HSIB make new recommendations to improve the system issues present?

– Feasibility – can an effective investigation be executed?

Investigation reports are designed to make recommendations and be published in order to feed into national learning. Separately, a new central learning service, for recording and analysis of safety incidents, will replace the national reporting and learning system.

Final Thoughts

The PSIRF is a clear departure from the previous patient safety regime and implementation will require the need to design a whole new set of systems and processes. Some organisations may be concerned about having access to timely training, tools and people resources to put the framework into effect within 12 months.

Although the implementation will be challenging, once in place, the framework should be welcomed as an opportunity to provide patient safety needs in a more flexible and autonomous way in determining which incidences are investigated and how effective learning is achieved that best fits in with prevailing needs.

Sonja Woodman, Practicus 

Earlier this year Practicus facilitated a roundtable discussion on behalf of IHPN that helped shape our understanding on PSIRF. More information on Practicus and the solutions they provide to the independent healthcare sector can be found here