NHS Blackpool annual report 2021-22 – Section 2a – Corporate governance report

The Member Practices of the CCG

Practice Name Address
Abbey Dale Medical Centre 50 Common Edge Road, Blackpool. FY4 5AU
Adelaide Street Family Practice 118 Adelaide Street, Blackpool. FY1 4LN
Arnold Medical Centre 204 St Anne’s Road, Blackpool. FY4 2EF
Bloomfield Medical Centre

(and Grange Park Health Centre)

118-120 Bloomfield Road, Blackpool. FY1 6JW

(Dinmore Avenue, Grange Park, Blackpool. FY3 7RW)

Cleveleys Group Practice Kelso Avenue, Cleveleys, Blackpool. FY5 3LF
Crescent Surgery Cleveleys Cleveleys Health Centre, Kelso Avenue, Cleveleys, Blackpool.

FY5 3LF

Elizabeth Street Surgery

(Closed 31 October 2021)

61 Elizabeth Street, Blackpool. FY1 3JG
Glenroyd Medical Centre Moor Park Health and Leisure Centre, Bristol Avenue, Blackpool. FY2 0JG
Highfield Surgery South Shore Primary Care Centre, Lytham Road, Blackpool.

FY4 1TJ

Layton Medical Centre 200 Kingscote Drive, Blackpool. FY3 7EN
Marton Medical Practice Whitegate Health Centre, Whitegate Drive, Blackpool. FY3 9ES
Newton Drive Health Centre Newton Drive, Blackpool. FY3 8NX
North Shore Surgery Moor Park Health and Leisure Centre, Bristol Avenue, Blackpool. FY2 0JG
South King Street Medical Centre 25 South King Street, Blackpool. FY1 4NF
Stonyhill Medical Practice South Shore Primary Care Centre, Lytham Road, Blackpool.

FY4 1TJ

St Paul’s Medical Centre Dickson Road, North Shore, Blackpool. FY1 2HH
Waterloo Medical Centre 178 Waterloo Road, Blackpool. FY4 3AD

 

The Members’ Council (known locally as the Practice Link meetings)

 

The membership and Register of Interests for the Members’ Council can be accessed on the CCG website: https://www.fyldecoastccgs.nhs.uk/about-us/lists-and-registers/

 

The CCG Governing Body

  • Roy Fisher, CCG Chairman
  • Dr Amanda Doyle, Chief Clinical Officer / Accountable Officer (up to 31 July 2021)
  • Andrew Bennett, Interim Accountable Officer (from 1 August 2021)
  • David Edmundson, Lay Member (Governance) / Chairman, Audit Committee
  • Chris Brown, Lay Member / Member, Audit Committee
  • Helen Williams, Lay Member (Patient and Public Engagement) / Member, Audit Committee
  • Dr Marie Williams, GP Member / Vice Chairman
  • Dr Leanne Rudnick, GP Member
  • Dr Sujata Singh, GP Member
  • Dr Cruz Augustine, GP Member
  • Dr Michelle Martin, GP Member
  • Dr Susan Green, GP Member (up to 30 April 2021)
  • Dr Ian Stewart, Secondary Care Doctor / Member, Audit Committee
  • Andrew Harrison, Chief Finance Officer
  • John Gaskins, Acting Chief Finance Officer assumed Executive responsibility on behalf of Andrew Harrison as and when required
  • Jane Scattergood, Director of Nursing and Quality (Director of Nursing and Quality, Lancashire and South Cumbria Integrated Care System from 1 July 2021)
  • Nick Medway, Interim Deputy Director of Nursing and Quality assumed Executive responsibility on behalf of Jane Scattergood from 1 July 2021
  • Dr Arif Rajpura, Director of Public Health, Blackpool Council

The following are in attendance at Governing Body meetings (non-voting rights):

 

  • Yvonne Rispin, Director of Ambulance and NHS111 Commissioning
  • Dr Ben Butler-Reid, Clinical Director (up to 31 August 2021)
  • Dr Neil Hartley-Smith, Clinical Director
  • Jane Higgs, NHS Interim Management and Support (Locality Director)

The Register of Interests for the Governing Body Members can be accessed on the CCG website: https://www.fyldecoastccgs.nhs.uk/about-us/lists-and-registers/

The Register of Gifts and Hospitality can be accessed on the CCG website: https://www.fyldecoastccgs.nhs.uk/about-us/lists-and-registers/

Committees of the Governing Body

 

Six committees assist in the delivery of the statutory functions and key strategic objectives of the CCG:

 

  • Audit Committee
  • Clinical Commissioning Committee
  • Finance and Performance Committee
  • Primary Care Commissioning Committee
  • Remuneration Committee
  • Quality Improvement and Engagement Committee

 

For full details of committee functions, membership, and attendance for 2021/22, see pages 75-83 of the Governance Statement.

Members of the CCG Audit Committee

 

  • David Edmundson, Lay Member (Governance) (Chair)
  • Chris Brown, Lay Member
  • Helen Williams, Lay Member (Patient and Public Engagement)
  • Dr Ian Stewart, Secondary Care Doctor

 

External Audit

  • Fee – During 2021/22, KPMG LLP was the external auditor for NHS Blackpool CCG. The CCG has paid KPMG £76,500 for external audit services which includes £62,500 base audit fee, £10,000 for the value for money aspect of the audit and £4,000 for the audit of IFRS 16 implementation (all figures exclusive of VAT).
  • The financial statements also include an estimate of the fee associated with the audit of the 2021/21 mental health investment standard returns. It is expected that this additional service will be undertaken by KPMG in 2022/23. The fee is estimated at £10,000 (exclusive of VAT).

 

Cost Allocation and Charges for Information

‘We certify that the CCG has complied with HM Treasury guidance on cost allocation and the setting of charges for information’.

 

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 to make him or herself aware of any relevant audit information and to establish that the CCG’s auditor is aware of it.

 

Personal Data Related Incidents

The CCG recognises the importance of maintaining data in a safe and secure environment. It uses the Serious Incidents Requiring Investigation (SIRI) tool to assess any matters involving potential data loss to the organisation. The tool requires the reporting of any data incidents rated at level two or above via the information governance toolkit.

 

Modern Slavery Act

The CCG fully supports the Government’s objectives to eradicate modern slavery and human trafficking but does not meet the requirements for producing an annual Slavery and Human Trafficking Statement as set out in the Modern Slavery Act 2015.

 

 

Statement of 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 (NHSE/I). NHSE/I has appointed the Chief Clinical Officer to be the Accountable Officer of Blackpool Clinical Commissioning Group (up to 31 July 2021).  An Interim Accountable Officer was appointed in post from 1 August 2021.

 

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.
  • 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).
  • 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 Section 14R 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), NHSE/I has directed each Clinical Commissioning Group to prepare for each financial year financial 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 net expenditure, Statement of Financial Position, and cash flows for the financial year.

 

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

 

  • Observe the Accounts Direction issued by NHSE/I, 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;
  • Assess the CCG’s ability to continue as a going concern, disclosing as applicable, matters related to going concern;
  • Prepare the financial statements 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.

 

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), Managing Public Money and in my Clinical Commissioning Group Accountable Officer Appointment Letter.

 

The CCG’s deficit for 2021/22 has been reported by the external auditors under Section 30(b) of The Local Audit and Accountability Act 2014.

 

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.

 

 

 

 

 

 

 

 

 

 

 

 

Andrew Bennett

Interim Accountable Officer, NHS Blackpool Clinical Commissioning Group

13 June 2022

 

 

Governance Statement

Introduction and Context

NHS Blackpool Clinical Commissioning Group (CCG) is a body corporate established by NHS England on 1 April 2013 under the National Health Service Act 2006 (as amended).

 

The CCG’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 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.

 

As at 31 March 2022, the CCG is not subject to any directions from NHS England issued under Section 14Z21 of the National Health Service Act 2006.

 

Scope of Responsibility

As Interim Accountable Officer, I have responsibility for maintaining a sound system of internal control that supports the achievement of the CCG’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 Interim Accountable Officer Appointment Letter.

 

I am responsible for ensuring that the CCG 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 CCG as set out in this governance statement.

 

Governance Arrangements and Effectiveness

The main function of the Governing Body is to ensure that the CCG 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 as are relevant to it.

 

The members of the CCG are responsible for determining its governing arrangements, which are set out in the CCG’s Constitution which is published on the CCG’s website:

https://www.fyldecoastccgs.nhs.uk/document/blackpool-ccg-constitution-pdf/

 

The CCG is accountable for exercising its statutory functions. It may grant authority to act on its behalf to any of its members, its Governing Body, employees or a committee or sub-committee of the CCG. Section 6 of the CCG’s Constitution details the governing structure of the CCG. The extent of the authority to act of the respective bodies and individuals depends on the powers delegated to them by the CCG as expressed through the Constitution; the CCG’s Scheme of Reservation and Delegation; and for committees, their terms of reference.

 

The CCG’s Scheme of Reservation and Delegation (Appendix D of the Constitution) sets out those decisions that are reserved for the membership as a whole, and those decisions that are the responsibilities of the Governing Body, committees and sub-committees, individual members, and employees.

 

During the reporting period, arrangements have been maintained to ensure that the CCG was able to properly discharge its statutory functions, duties, and responsibilities. In addition, robust performance management processes remained in place with clear lines of accountability through established formal arrangements.

 

The CCG’s Constitution outlines the principles of good governance which must be adhered to at all times in the way by which the CCG conducts its business. These include the need for the highest standards of propriety, impartiality, integrity, and objectivity in relation to the stewardship of public funds, the management of the organisation and the conduct of its business.

 

The CCG’s Constitution establishes those matters and arrangements that are reserved to the Members’ Council and those which are delegated to the Governing Body and the relevant CCG committees.

 

Taken together these documents enable maintenance of a robust system of internal control. The CCG remains accountable for all of its functions, including any it has delegated.

 

Assurance is provided to the Members’ Council through the following structural and organisational control:

 

 

Fylde Coast CCGs Committee Arrangements

Committees of the Governing Body have been established as either ‘Joint Committees’ or ‘Committees in Common’ as appropriate, except the Remuneration Committee.  ‘Joint Committees’ operate as a single committee containing members from both CCGs. They use a single agenda and usually reach one conclusion or recommendation on matters put before them.  A ‘Committees in Common’ meeting is effectively a forum in which separate organisations hold their equivalent committees within the same arrangements.

 

Membership of ‘Committees in Common’ is, therefore, exclusive to those proposed by the host organisation and whilst there may be different agendas, there is common debate around single topic items for those agendas. However, decisions and voting takes place consecutively with each organisation making its decision specific to its own agenda.

 

Terms of reference and membership of the Governing Body committees – In  light of the proposed structural changes to establish greater integrated commissioning across Lancashire and South Cumbria and the need to prioritise how existing CCG staffing resources were used, it was recommended and subsequently agreed by the Governing Body that the review of all committee terms of reference would not be undertaken but recognising that should there be any changes in terms of CCGs or committee business, reviews would be considered.  Terms of reference and membership of the Governing Body committees can be found at https://www.fyldecoastccgs.nhs.uk/blackpool-ccg-committees/.

Fylde Coast CCGs Leadership Arrangements

Up to and including 31 July 2021, Dr Amanda Doyle was the Accountable Officer (AO) / Chief Clinical Officer (CCO) of NHS Blackpool CCG, NHS Fylde and Wyre CCG and NHS West Lancashire CCG. This was in addition to her role of Senior Responsible Officer (SRO) for the Lancashire and South Cumbria Integrated Care System (ICS).  From 1 August 2021, Andrew Bennett was the Interim Accountable Officer of NHS Blackpool CCG, NHS Fylde and Wyre CCG and NHS West Lancashire CCG.  This was in addition to his role of Senior Responsible Officer (SRO) for the Lancashire and South Cumbria Integrated Care System (ICS) (this latter role up to 13 March 2022).

 

During 2021/22, in addition to her role of CCG Director of Nursing and Quality, Jane Scattergood was also the Lancashire and South Cumbria ICS Director of Nursing and Quality.

 

Andrew Harrison continued in his role as Chief Finance Officer of NHS Morecambe Bay CCG in addition to his existing roles as Chief Finance Officer of NHS Blackpool CCG and NHS Fylde and Wyre CCG.  In order to support this arrangement, John Gaskins continued in his role as Acting Chief Finance Officer for Blackpool CCG and Fylde and Wyre CCG.

 

During 2021/22, interim leadership and management arrangements were put in place to ensure the Fylde Coast CCGs continued to operate effectively and safely. Dr Neil Hartley-Smith and Dr Ben Butler-Reid, Clinical Directors, took on the formal Chief Operating Officer responsibilities, supported by Jane Higgs providing interim management and support.

 

COVID-19 Pandemic

During 2021/22, all NHS organisations continued to work extremely hard in their response to the COVID-19 pandemic.  As reported in the previous year’s report, the CCG modified its arrangements and CCG staff continued to work from home.  The CCG operated in accordance with guidance issued by NHSE/I and whilst there was some relaxation of ‘business as usual’ requirements, organisations continued to have a statutory responsibility to ensure effective and robust governance arrangements were in place.  This enabled organisations to realign their capacity and resources in order to operate effectively in the current climate and make safe decisions.  Governing Body and committee meetings continued to be held via videoconference throughout the year.

 

Members’ Council (known locally as the GP Practice Link meetings)

The CCG has an established Members’ Council known as the GP Practice Link.   The membership is the Member Practices’ representatives and the terms of reference of the Members’ Council are:

 

 

 

  • To provide clinical input into clinical commissioning decisions
  • To provide Member Practice input on CCG governance issues needing the approval of Member Practices
  • To provide opportunities for sharing best practice for localities and workstreams.

 

During 2021/22, due to the revised COVID-19 governance arrangements described above, the GP Practice Link met once (virtually), and this was a joint meeting with the Fylde and Wyre CCG Council of Members to receive communications on national, regional, and local issues.

 

Governing Body

The Governing Body has responsibility for:

 

  • Ensuring that the CCG has made appropriate arrangements for ensuring that it exercises its functions effectively, efficiently, and economically and complies with the CCG’s principles of good governance
  • Determining the remuneration, fees, and other allowances payable to employees or other persons providing services to the Group and the allowances payable under any pension scheme it may establish under paragraph 11 (4) of Schedule 1A of the 2006 Act, inserted in Schedule 2 of the 2012 Act
  • Approving any functions of the CCG that are specified in regulations (section 14L(5) of the 2006 Act, inserted by section 25 of the 2012 Act)
  • Planning, setting the vision, strategy, and operational plans
  • Approving commissioning plans
  • Monitoring performance against plans
  • Providing assurance of strategic risk
  • Commissioning community health services; maternity services; elective hospital services; urgent and emergency services including accident and emergency, ambulance, NHS111, patient transport services and out of hours; older people’s services; children’s services, including those with complex healthcare needs; rehabilitation services; wheelchair services; mental health services; learning disability services; continuing healthcare; and certain specified primary care functions delegated to the CCG by NHSE/I.

 

During 2021/22, in response to the COVID-19 pandemic, there continued to be an emphasis on system working across Lancashire and South Cumbria and the NHS continued to enact a Command-and-Control system wherein national direction was implemented through a distinct chain of command directly linking strategic intent with operational delivery.  NHS England/Improvement (NHSE/I) guidance was issued to support providers and commissioners to free up capacity and resource to focus on the challenges of the pandemic.

 

The Governing Body met quarterly under this strategic framework and its agendas were more focussed and its papers streamlined.  Agendas incorporated a range of reports to support delivery of its key functions including quality performance and finance. A regular update was also provided on the development and implementation of key aspects of service delivery across the Lancashire and South Cumbria Integrated Care System (ICS), the Fylde Coast Place Based Partnership (PCB) and Primary Care Networks (PCNs).  The Governing Body received regular update reports on the COVID-19 pandemic.

 

Throughout 2021/22, due to the COVID-19 pandemic and Government social isolation requirements constituting special reasons to avoid face to face gatherings, meetings of the Governing Body continued to be held via videoconference.  Members of the public were invited to submit questions to the Governing Body in advance of the meetings and since January 2021 have been able to join the meetings virtually to observe.

 

Agendas, papers including minutes which show attendance at meetings are published on the CCG’s website at: www.fyldecoastccgs.nhs.uk/about-us/governing-bodies/

 

The quorum for the Governing Body is no less than half of the core membership, including at least one Lay Member and a minimum of two clinicians.  During 2021/22, the Governing Body met ‘in common’ with the NHS Fylde and Wyre CCG Governing Body, on eight occasions.

 

The Governing Body has delegated responsibility for a range of functions to its committees, which are set out in the approved terms of reference of each committee/group and the CCG’s standing orders and scheme of reservation and delegation.  The CCG’s operational scheme of delegation has been regularly overseen by the Audit Committee to ensure it facilitates informed and prompt decision-making, is ‘fit for purpose’ and that the robust and appropriate organisational and financial controls across the CCG are maintained.

 

It is my view that the Governing Body has operated effectively in meeting its responsibilities throughout the period 1 April 2021 to 31 March 2022.

 

The committees with delegated responsibilities of the Governing Body are as follows and the terms and reference and membership for each can be accessed on the CCG website: https://www.fyldecoastccgs.nhs.uk/blackpool-ccg-committees/.

 

Audit Committee (Committees in Common held with Fylde and Wyre CCG)

The Audit Committee provides the Governing Body with an independent and objective view of the CCG’s financial systems, financial information and compliance with laws, regulations and directions governing the CCG. The key duties of the Audit Committee are governance, risk management and internal control. The committee shall review the establishment and maintenance of an effective system of integrated governance, risk management and internal control, across the whole of the CCG’s activities that support the achievement of the CCG’s objectives. In particular, the committee will review the adequacy and effectiveness of:

 

  • All risk and control related disclosure statements (in particular the Governance Statement), together with any accompanying Head of Internal Audit opinion, External Audit opinion or other appropriate independent assurances, prior to submission to the Governing Body.
  • The underlying assurance processes that indicate the degree of achievement of the organisation’s objectives, the effectiveness of the management of principal risks and the appropriateness of the above disclosure statements.
  • The underlying assurance process that indicates the degree of Financial Systems robustness and responsiveness to delivering financial control.
  • The underlying assurance process for complying with the Value for Money responsibilities of the CCG.
  • The policies for ensuring compliance with relevant regulatory, legal and code of conduct requirements and any related reporting and self-certifications.
  • The policies and procedures for all work related to counter fraud, bribery and corruption as required by NHSCFA.

 

The members of the Audit Committee are the Lay Members on the CCG’s Governing Body (with the exception of the CCG Chairman) and the CCG’s Secondary Care Doctor.  The Lay Member for Governance chairs the committee and holds the office of the Conflicts of Interest Guardian.  The committee met six times during the year.  Minutes and attendance at Audit Committee meetings are published on the CCG’s website via the Governing Body meeting papers.

 

Remuneration Committee

The Remuneration Committee determines the pay and remuneration, fees, and other allowances for employees. The committee also determines the remuneration and conditions of service and reviews the performance of the Accountable Officer and other very senior team members and determines annual salary awards if appropriate.

 

The members of the Remuneration Committee are the CCG Chairman and the three Lay Members of the CCG’s Governing Body. The Remuneration Committee met once during the year.

 

Finance and Performance Committee (Joint meetings held with Fylde and Wyre CCG)

The Finance and Performance Committee has responsibility to:

 

  • Oversee the performance of the CCG in delivering the national targets and objectives included in the local commissioning plan, ensuring the effective and efficient use of resources whilst delivering financial balance
  • Assure that the commissioning portfolio delivers against contracted performance metrics and outcomes, (recognising the leadership of the Primary Care Commissioning Committee for primary care contracts)
  • Give assurance to the CCG Governing Body on finance, performance, service reviews, procurement and planning of all commissioned services and contracts, including those dependent upon Partnership Agreements and joint working arrangements, (recognising the leadership of the Quality Improvement and Engagement Committee for quality matters).
  • Receive routine monitoring reports that evaluate CCG performance against mandated national and regional metrics as well as locally agreed indicators that ensure the CCG is meeting its defined objectives.
  • Undertake monitoring of commissioned services via Provider performance reporting and provide assurance to the CCG Governing Body that services delivered for patients are done so effectively, consistently and in line with specified requirements and regulation.
  • Scrutinise the performance of commissioned contracts, assure the CCG Governing Body of compliance and oversee action plans where performance is deemed to need corrective actions.
  • Consider and review high level financial issues and risks, and ensure corrective plans are in place where variation from plan requires action.
  • Ensure the CCG meets its financial duties and objectives
  • Ensure the CCG complies with all information governance requirements.

 

During 2020/21, a command-and-control structure was put in place associated with the NHS response to the COVID-19 pandemic. This along with the changed nature of NHS commissioner to provider contractual relationships and the CCG’s most material Independent Sector contracts operating under a national contract as part of the pandemic response resulted in many of the previously usual finance and performance oversight arrangements becoming less complex. In response to this situation, an internal review of governance arrangements when operating under the command and control structures was undertaken following which a further review was carried out and the CCGs stood down the Finance and Performance Committee meetings ensuring that the oversight that the committee would previously have provided was undertaken by the Governing Body from a finance perspective with the Quality Improvement and Engagement Committee having oversight on performance matters.  This arrangement continued during 2021/22.

 

Membership comprises representatives from across the Fylde Coast CCGs and includes two Lay Members (of which one is the committee Chair and one the Vice Chair), the Chief Clinical Officer or a Clinical Director, four GP Elected Clinical Members, the Chief Finance Officer and one other Executive.  Other officers would attend on an ad hoc basis.

 

Quality Improvement and Engagement Committee (Joint meetings held with Fylde and Wyre CCG)

The Quality Improvement and Engagement Committee provides strategic oversight and assurance to the Governing Body relating to the quality, public and service user engagement and the continual improvement of all CCG directly and jointly commissioned services. It ensures that effective, relevant, and appropriate decisions are made in protecting the health and wellbeing of the population we serve. The key responsibilities of the committee are that:

 

  • Service quality, patient engagement and involvement are integral to the work of the CCG.
  • All the services that the CCG commissions, including its joint and partnership arrangements (ICP/ICS etc), are safe and effective and have been influenced by tangible public and patient involvement and engagement.
  • There is continuous scrutiny in the quality of commissioned services, including primary care and patient outcomes.
  • The principles of quality assurance and clinical governance are integral to performance monitoring arrangements for all CCG commissioned services and are embedded within consultation, service development and redesign, evaluation of services and the decommissioning of services
  • Assurance is provided to the Governing Body about public involvement and the difference it has made, and that the CCG is meeting its statutory duties.
  • There is oversight of the development, implementation and monitoring of:
  • The CCG’s strategic approach to Quality Improvement Strategy and Quality Assurance
  • Communications and Engagement Strategy
  • Equality and Inclusion Strategy
  • Risk Management Strategy
  • Safeguarding
  • Other relevant strategies
  • Patients have effective and safe care, with a positive experience of services.
  • The quality and outcomes of treatment and care commissioned by the CCG, or provided by its member practices, is improving against national or locally agreed measures.
  • Early warning systems are in place to identify concerns relating to the quality and safety of services and that appropriate action is taken in response to those concerns.
  • The views of all our communities underpin the work of the CCG and meet its Constitutional duties and requirements.
  • The CCG is fulfilling its statutory duties for Equality and Diversity, particularly the Equality Act 2010, through the implementation of the Equality Delivery System.
  • CCG corporate governance arrangements are robust (e.g. regarding service quality risk identification and risk management; FOIs; statutory Health and Safety responsibilities).

 

The Quality Improvement and Engagement Committee provides assurance in the delivery of the above responsibilities and duties to the Governing Body by regularly reviewing and approving performance reports. The committee holds to account the relevant Governing Body leads and the senior management team of the CCG for their relevant responsibility and accountable areas.

 

The committee usually meets monthly. The Membership comprises representatives from across the Fylde Coast CCGs and includes the Secondary Care Doctor, two Lay Members, up to seven GP Elected Clinical Members, a CCG Clinical Director, the Chief Operating Officer, Director of Nursing and Quality (nominated deputy) and Head of Quality. Other officers attended on an ad hoc basis.

 

During 2021/22, the committee met on 11 occasions and meetings were held via videoconference with reduced agendas and focussed/exception reports where appropriate.  Minutes and attendance at Quality Improvement and Engagement Committee meetings are published on the CCG’s website via the Governing Body meeting papers.

 

Patient and Public Engagement and Involvement Forum (PPEI)

The Fylde Coast Patient and Public Engagement and Involvement Forum (PPEI) is accountable to the Quality Improvement and Engagement Committee.  The Forum meets monthly and has responsibility for ensuring that the voice of patients and carers, and public and stakeholders views inform the commissioning decisions of the CCG. The key aims of the forum are to:

 

  • Ensure the CCG fulfils its statutory responsibilities to make arrangements to involve and consult patients and the public in service planning and operation, and in the development of proposals for change and involve and engage people in line with the Equality Act 2010
  • Work in partnership with relevant bodies such as the Health and Wellbeing Board and Healthwatch, and engage with different groups and communities, and
  • Ensure effective mechanisms are in place to capture the voice of practice populations.

 

The Forum is chaired by a Fylde Coast CCG Lay Member for patient and public involvement. Membership includes representation from Healthwatch, patient representatives and people from the community, voluntary and faith sector, including those representing older people, carers, children and young people and the LGBT community.  During 2021/22 the meeting has been held virtually but has also been paused at times due to the pandemic.

 

Primary Care Commissioning Committee (Committees in Common held with Fylde and Wyre CCG)

NHS England and NHS Improvement (NHSE/I) has delegated to the CCG the authority to exercise certain specified primary care commissioning functions. The Primary Care Commissioning Committee has responsibility for the management of these delegated functions and the exercise of the delegated powers in accordance with the agreement entered into between NHSE/I and the CCG.  The committee makes decisions on the review, planning and procurement of primary care services, under delegated authority to the CCG from NHSE/I and NHS Improvement. Meetings are usually held bi-monthly and are held in public.  Papers for the meetings can be accessed via the CCG’s website.

 

The membership comprises all the CCG’s Lay Members, one of whom Chairs the committee and one acting as Vice Chair of the committee (excluding the Audit Committee Chair), the Secondary Care Doctor (and proxy Lay Member), the Chief Operating Officer, the Chief Finance Officer, the Director of Nursing and Quality (nominated Deputy) and a CCG Clinical Director.  Representatives from the local authority, Healthwatch, Lancashire Coastal Local Medical Committee and NHSE/I are also invited to attend committee meetings. Other officers may be required to attend on an ad hoc basis.  Minutes and attendance at the Primary Care Commissioning Committee meetings are published on the CCG’s website.

 

During 2021/22, the committee met on five occasions and meetings were held via videoconference.  The committee welcomed representation from two Patient Participation Group chairs who were able to bring their valuable experience of working with local GP Practices to the discussions.

 

Clinical Commissioning Committee (Joint meetings held with Fylde and Wyre CCG)

The Clinical Commissioning Committee provides clinical advice and insight and assurance to the Governing Body that the CCG is commissioning and actioning the operational implementation of service priorities in line with the needs of the local population and the strategic objectives of the CCG. It has operated throughout the reporting period.

 

The membership comprises all the GP Elected Clinical Members, from whom the Chair and Vice Chair are nominated, the Chief Operating Officer, the Director of Nursing and Quality, the Secondary Care Doctor, and the Directors of Public Health (Blackpool Council and Lancashire County Council).  Other CCG officers are invited to participate in support of the committee’s work.  The committee usually meets six times a year and the minutes of the meetings are available on the CCG’s website via the Governing Body meeting papers.

 

UK Corporate Governance Code

NHS Bodies are not required to comply with the UK Code of Corporate Governance. However, whilst the detailed provisions of the UK Corporate Governance Code are not mandatory for public sector bodies, compliance with relevant principles of the code is considered to be appropriate and good practice. This Governance Statement is intended to demonstrate how the CCG has due regard to the principles set out in the Code and which are considered appropriate for CCGs.

 

Discharge of Statutory Functions

In light of recommendations of the 1983 Harris Review, the CCG 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 CCG 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. Directors have confirmed that their structures provide the necessary capability and capacity to undertake all of the CCG’s statutory duties.

Risk Management Arrangements and Effectiveness

The CCG accepts that all activities have elements of inherent risk, identifying and mitigating the risks are fundamental CCG activities.  This facilitates flexible and dynamic planning/provision and oversight and promotes clear standards of internal control.  The Corporate Risk Register and Governing Body Assurance Framework are the tools that continuously promote, embed and support risk management principles throughout the organisation.

 

The Governing Body is responsible for risk management within the CCG, ensuring that a framework of systems and processes for effective risk management are in place and for monitoring compliance in line with risk appetite.  The Governing Body Assurance Framework (GBAF) is the vehicle for strategic review and reporting significant CCG risks.

 

Both Fylde Coast CCGs have continued to consolidate their work, staffing structures, and risk management processes, so whilst remaining two separate statutory bodies, the two Governing Bodies remain clearly sighted on both existing and new risks across the whole Fylde Coast footprint.

 

The Accountable Officer is responsible for assuring the Governing Body that an effective system of governance and internal control exists within the CCG.

 

Risk leadership is driven from executive level, built into the strategic planning process, and then managed operationally through a robust process of governance around decision-making as set out in the CCG’s Scheme of Delegation within the CCG’s Constitution.

 

The Accountable Officer has responsibility for the overall management of arrangements for corporate governance and takes an executive level responsibility for physical risks, in particular health and safety, fire, safeguarding and compliance with claims and complaints, with the Director of Nursing and Quality (nominated Deputy) taking a day-to-day responsibility for these risks.  The Head of Quality is the Caldicott Guardian.

 

The Chief Finance Officer, as well as being the Senior Information Risk Owner (SIRO) is responsible for ensuring that all financial risk, security, information governance, business support and procurement risks are managed.

 

Senior managers are responsible for ensuring the implementation of risk management systems and processes within their area of control.

 

Staff members at all levels complete mandatory training including those aspects of risk management that are relevant to their role.  This ensures that staff have the capabilities and knowledge of basic risk management principles, including foreseeing potential risks.  Information and learning from good practice are shared through staff briefings.  All staff are aware that they must comply with the CCG’s risk management policies.

 

The CCG’s Risk Register is a prioritised list of risks identified to the CCG through the risk assessment process.  All CCG managers are responsible for ensuring that risk assessments are undertaken and reviewed within their area of control which forms the Risk Register.

 

The Executives, the Senior Management Team, the Quality Improvement and Engagement Committee, the Finance and Performance Committee and the Primary Care Commissioning Committee regularly review and agree the scoring of all risks.  Risks scoring 12 and above on the Risk Register are submitted to the Governing Body and Audit Committee via the Governance Body Assurance Framework.

 

The challenge of COVID-19 across the period presented new risk considerations for the CCG incorporating risks to staff from the isolation of home working to an emerging focus on restoration of services.  Although necessitated by COVID-19 as a legacy and in transition to an ICB CCGs are now adopting a stance of agile working as a permanent operating model.

 

It is the policy of the Fylde Coast CCGs to:

 

  • provide clear leadership and direction on risk management, promoting openness and transparency
  • embed a culture where risk management principles are implemented, and risk management is an essential function of the organisation’s activity
  • ensure structures, processes and sufficient resources are in place to support the identification, assessment, management and monitoring of risks
  • assure the public, patients, staff, partner organisations and other stakeholders that Fylde Coast CCGs implement their commitment to manage risk effectively.

 

 

Key Risks Summary

 

The COVID-19 pandemic continued to challenge routine CCG activity during 2021/22 including rolling over of existing commissioning arrangements and centralisation of commissioning and finance arrangements. This together with disparate homebased and arm’s length working arrangements and the imperatives of CCG staff supporting incident management and specific pandemic responses (e.g. testing; vaccination; novel service development) has presented significant challenge to normal working practices, including risk management.

 

Looking to forthcoming organisational change, risk owners and functional leads are being challenged to critically review their existing risks in line with identified risk appetite and distil a focussed suite of risks that will safely communicate Governing Body concerns into the new Integrated Care Board from 1 July 2022 (subject to legislation).

 

Within this context key current risks relate to staffing capacity, financial resources available versus the demand on this and service delivery of several commissioned services against quality and performance targets.

Internal Control Framework

The system of internal control is the set of processes and procedures in place in the CCG 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 and 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 CCG’s Governing Body Assurance Framework is the internal control process that enables the CCG to focus on risks in delivering its principle annual objectives, be assured that adequate controls were operating to reduce those risks to acceptable levels and highlight any gaps in control and assurance that may hinder the achievement of those objectives.

 

Within year, the Governing Body has revisited and affirmed its risk appetite and whilst there can be no tolerance for safeguarding, fraud and regulatory breaches considering each risk against its stated appetite, the Governing Body can agree tolerances or direct required actions appropriately.  This has been augmented by the presentation of risks in a more user-friendly version of the Governing Body Assurance Framework.

 

The Governing Body’s own assessment of the effectiveness of the organisation’s system of internal control is aided through delivery of the risk-based internal audit plan, as approved by the Audit Committee, including reviews of the assurance framework, and a range of control systems. In accordance with Public Sector Internal Audit Standards, the Head of Internal Audit provides an annual opinion, based upon, and limited to the work performed, on the overall adequacy and effectiveness of the organisation’s risk management, control, and governance processes (i.e. the organisation’s system of internal control). This is achieved through a risk-based plan of work, agreed with management, and approved by the Audit Committee, which provides a reasonable level of assurance.

 

Annual Audit of Conflicts of Interest Management

The Managing Conflicts of Interest Policy (including Gifts and Hospitality), aligned across both Blackpool CCG and Fylde and Wyre CCG, was reviewed at an Audit Committees in Common meeting in December 2021.  The policy was subsequently approved at a Governing Bodies in Common meeting (Blackpool CCG and Fylde and Wyre CCG) in February 2021.  The policy follows NHSE/I statutory guidance (latest published June 2017) and can be accessed at:

https://www.fyldecoastccgs.nhs.uk/document/fylde-coast-ccgs-managing-conflicts-of-interest-policy-v1-2-final-february-2022-pdf/

 

CCGs are required to undertake an annual internal audit of conflicts of interest management. To support CCGs to undertake this task, NHSE/I published a template audit framework.

 

MIAA carried out the annual audit of conflicts of interest with the CCG during December 2021 to February 2022.  Overall, the CCG has demonstrated that arrangements are in place to satisfy NHSE/I requirements with regard to conflicts of interest.  The following compliance levels, as per NHSE/I requirements, have been assigned to each area:

 

Scope Area RAG Rating Level

 

Governance arrangements

 

l Fully Compliant
Declarations of interests and gifts and hospitality

 

l Fully Compliant
Register of interests, gifts and hospitality and procurement decisions

 

l Fully Compliant
Decision making processes and contract monitoring

 

l Fully Compliant
Reporting concerns and identifying and managing breaches/non-compliance

 

l Fully Compliant

 

Key:

l Fully Compliant             l Partially Compliant               l Non-Complaint

 

Overall, there has been a consistent level of compliance with NHSE/I guidance compared to the previous years.

 

Data Quality

The CCG contracts several services from the Midlands and Lancashire Commissioning Support Unit (MLCSU), from which the data provided is utilised in presentations to the Governing Body and relevant committees. The 2021/22 Service Auditor’s Report on MLCSU provides assurance on financial data including accounts payable, accounts receivable, treasury and cash management, the financial ledger and financial reporting.

 

The Governing Body receives data relating to the performance of the CCG. This includes activity and financial data. The quality of data received from providers we commission services from is routinely validated to ensure accuracy. If any anomalies or unexpected trends occur, they are investigated with Providers. The Quality and Performance report is a regular item on the Governing Body agenda and can be found on the website.

 

Information Governance

The NHS Information Governance Framework sets the processes and procedures by which the NHS handles information about patients and employees, personal identifiable information.  The NHS Information Governance Framework is supported by an Information Governance Toolkit and the annual submission process provides assurance to the CCG, other organisations and to individuals that personal information is dealt with legally, securely, efficiently, and effectively.

 

The CCG’s information governance feeds into Finance and Performance Committee then into the Governing Body as part of the CCG’s integrated governance structure.  The CCG’s Chief Finance Officer has Executive responsibility for information governance and is the Senior Information Risk Officer (SIRO), with responsibility for ensuring that information risk is assessed and managed within the organisation.

 

The Head of Quality is the Caldicott Guardian for the CCG.  The Caldicott Guardian acts as the ‘information conscience’ for the organisation and is responsible for protecting the confidentiality of patient/service-user information and enabling appropriate information sharing.

 

The CCG is continually reviewing its information governance provision.  Control measures are in place to ensure risks to data security are managed and controlled.  The CCG has put an information risk management process in place led by the SIRO.  Information asset owners and administrators have been identified to cover the CCG’s main systems and records stores, along with information held at team level.

 

There is high importance on ensuring that there are robust information governance systems and processes in place to help protect patient and staff personal information.  An information governance management framework and structure chart has been created to highlight lines of responsibility for information governance within the organisation.  All staff are required to undertake annual information governance training electronically, via ESR.  The CCG has a Data Security and Protection Policy, a Staff Information Governance Handbook, and an Information Governance Code of Conduct to ensure staff are aware of their information governance roles and responsibilities.

 

There are processes and systems in place for incident reporting and investigation of serious incidents.  We are developing information risk assessment and management procedures and a programme will be established to fully embed an information risk culture throughout the organisation against identified risks.

 

The CCG’s Information Governance Handbook provides information and best practice for staff to follow whilst working from home during the COVID-19 pandemic.  Bi-monthly newsletters are circulated to staff which highlight different themes for information governance.  An example being hints and tips for staff to ensure there are physical controls and information are protected whilst working from home.

Information Risk and U Assure

The CCG has in place an information risk work programme that has been agreed by the SIRO to identify what information the CCG holds, stores, shares and receives from other organisations.

 

The CCG utilises the U Assure system to log information assets, internal and external data flows and systems used within the organisation.  Each team has nominated Information Asset Assistants (IAA) who identify, log, and review key information assets within their teams   A nominated Information Asset Owner (IAO) reviews the information and advises on the consequences should the assets be unavailable, damaged, destroyed or lost and its impact on the organisation.

 

The U Assure system risk scores the asset dependent on the information recorded by both the IAA and IAO.  Assets scoring higher than 12 are classed as high-risk asset and an action plan is put in place to mitigate the risk.  Additionally, if an asset is unable to be accessed after 3 days and this has a noticeable impact on the organisation, patients, or legal obligation the asset would be classed as business critical.

 

Data flow maps are created for information that is distributed between internal teams and is sent from or to external organisations.  The method of transfer is also risk assessed.  The information risk programme is an ongoing task throughout the year.

 

Data Security

The CCG provides formal assurance of its compliance with information governance requirements annually through the Data Security and Protection Toolkit (DSPT).  The DSPT is a national annual self-assessment and reporting tool that the CCG must use to assess local performance in line with the requirements set out by NHS Digital.

Subject to the passage of legislation, it is expected that Integrated Care Boards (ICBs) will be established on 1 July 2022 and Clinical Commissioning Groups (CCGs) will be abolished.  This change in timescale from April 2022, announced at the end of December 2021, means that the CCG will be required to submit a DSPT for 2021/22, which is due by 30 June 2022.  The CCG will continue to be supported by the CSU IG Team to deliver a compliant DSPT by this date and currently sees no underlying issues with achieving this.

For 2021/22, NHS Digital proposed no requirement for the CCG to submit a baseline submission or for the CCG to complete a DSPT Audit for 2021/22, although the CCGs opted to go ahead with the internal audit.  The audit has been conducted by MIAA and is currently in progress.

 

During the period 1 April 2021 to 31 March 2022, there were no incidents categorised as reportable within the CCG.

 

Business Critical Models

Business critical systems are mainly provided by Midlands and Lancashire Commissioning Support Unit. They are subject to regular external review, the outputs of which are reported to the CCG’s Audit Committee through service auditor reports. The CCG’s business critical systems have been identified and form part of the CCG’s Information Asset Register each with a suitably qualified Information Asset Owner.

 

Control Issues

In continued response to COVID-19 pressures (including movements between level 3 and 4 incidents) and the operating environment that is system first in respect of planning and delivery, previous ‘business as usual’ committees and reporting has, as in 2020/21, been stood down or operated virtually.  In order to mitigate any potential resulting control issue, the virtual approach to governance has been reviewed by each committee in the CCG to ensure respective workplan items/statutory duties are covered and that committee decision making can continue to operate.  The Governing Body and Audit Committee have received papers and agreed recommendations in respect of how governance oversight and control is maintained when operating through virtual committees and in the COVID-19 operating environment.

 

Under system operating principles some clearly documented decision making has been delegated to system committees with appropriate governance in place.  In responding to the national incident, the cell structure has remained in operation and held responsibility on some previous CCG decision making.

 

In December 2021, in light of the declaration of a Level 4 national incident in the NHS, the cell arrangements were reviewed and with effect from 20 December 2021, the hospital and out-of-hospital cell meetings were merged to provide a single joint cell.  This enabled colleagues in the NHS and local authorities to continue working closely together at system, place, and neighbourhood levels to maintain operational service delivery, take actions to mitigate risks to the system, specific sectors or communities using mutual aid when necessary.

 

In March 2020, the operational scheme of delegation in respect of Individual Patient Activity (IPA) services was temporarily amended in order to expedite continuing healthcare claims and facilitate discharge of patients during the COVID-19 incident management period.  Further six-month extensions to the revised arrangements were approved in October 2020 and March 2021 (up to 30 September 2021) in order to sustain resilience during the recovery period.  These amendments were all appropriately approved via the Audit Committee meeting or Chair’s approval and subsequent ratification by the full committee in line with the CCG’s scheme of delegation.

 

A further extension of the revised arrangements was not sought in advance of the approval lapsing on 30 September 2021.  As such there was a period of time whereby IPA staff were operating outside of the CCG’s approved scheme of delegation and were continuing to apply the delegation rules that had been in place over the previous 18 months.  There is no evidence to indicate that any untoward incidents occurred as a result of the lapse and, therefore, retrospective support of the extension to 31 March 2022 was agreed by the CCG.  This matter was formally brought to the attention of the Governing Body in March 2022.

 

Review of Economy, Efficiency and Effectiveness of the Use of Resources

NHS England is legally required to review CCGs’ performance on an annual basis.  Historically, this has been carried out under the auspices of the CCG Improvement and Assessment Framework and, more recently, the NHS Oversight Framework, with the overall assessment ratings based on a CQC-style four label categorisation.

 

As a result of the continued impact of COVID-19 and the need for the NHS to set new and updated priorities across the different phases of the response, it was not possible to apply the established methodology to determine CCGs’ ratings for 2020/21.  Therefore, a simplified approach to the 2020/21 CCG annual performance review was undertaken, taking account of the different circumstances and challenges CCGs have faced in managing recovery across the phases of the NHS response to COVID-19.

 

NHS England commented that both NHS Blackpool CCG and NHS Fylde and Wyre CCG were fully engaged with supporting both the Integrated Care System and Integrated Care Partnership developments throughout the year.

 

Over the course of the year, like all areas of England, the CCG has continued to be impacted by COVID-19, but its focus remains on improved performance across all indicators.  Some challenges remain on specific indicators, but progress is being made and robust plans are in place to improve and sustain performance.

 

The CCG has experienced and capable Executives, Clinicians, Lay Members, and senior management team delivering plans across all functions.  The CCG’s leadership has a strong track record of delivery across the various functions, as well as providing leadership within the Integrated Care Partnership/Integrated Care System (ICP/ICS).

 

The Executives are supported by strong challenge from experienced Lay representatives on the Governing Body and other committees.

 

The Fylde Coast CCG’s shared leadership team works closely with colleagues at Blackpool Teaching Hospitals NHS Foundation Trust to ensure delivery of health and care services across the Fylde Coast.  We also work closely with colleagues at Blackpool Council and Lancashire County Council as we develop integrated health and social care.  This work has continued during the pandemic and greater partnership working can be evidenced despite some of the operational challenges brought about by the pandemic.

 

The CCG has operated during 2020/21 under command-and-control structures and processes due to the COVID-19 pandemic, these have focused on system delivery and financial position underpinned and delivered by organisational planning and performance. Strong financial planning and budgetary controls are in place to ensure the CCG understands its financial position and delivers its agreed plan within the context of the overall ICS plan.  Risks to delivery being discussed at the Governing Body within the context of the wider ICS approach and system resource.

 

I have received advice from the internal and external auditors on the efficacy of the organisation’s arrangements to ensure the effective use of resources and accept their independent view that the CCG has sound processes in place.

 

Anti-fraud Arrangements

All commissioners and providers of NHS services are required to put in place arrangements to tackle fraud, bribery, and corruption, and this is undertaken by the CCG’s nominated Anti-fraud Specialist, together with the wider Anti-fraud Team at MIAA.  The CCG’s Chief Finance Officer oversees the anti-fraud arrangements for the CCG.

 

The Anti-fraud Specialist provides an Anti-fraud Annual Report which offers the CCG’s Audit Committee the opportunity to review in totality the anti-fraud work completed during the year.  The ultimate aim of all anti-fraud work is to support improved NHS services and ensure that fraud within the NHS is clearly seen as being unacceptable.

 

During 2021/22, the Anti-fraud Specialist has completed a wide range of work across the main key areas of activity as outlined by the NHS Counter Fraud Authority and agreed within the workplan approved by the Audit Committee.  The following has been achieved during the year:

  • Attendance at Audit Committees (Committees in Common with Fylde and Wyre CCG)
  • Regular meetings with key personnel including the Chief Finance Officer, and Internal Audit
  • Completion and submission of the NHS Counter Fraud Authority’s Standards for Commissioner’s Self Review Tool
  • Newsletters/briefings/circulars covering various fraud and bribery related topics
  • MIAA fraud awareness video x 3 provided to the CCG for distribution to staff
  • Undertaking the latest National Fraud Initiative Exercise
  • Updating the Anti-fraud, Bribery and Corruption Policy Counter Fraud Policy
  • COVID-19 related alerts issued to the CCG
  • Completed on behalf of the CCG, the NHSCFA Impact Assessment Return
  • Completion of various requests from the NHS Counter Fraud Authority in respect of fraud activities at the CFA
  • Completed a Personal Health Budgets proactive review
  • Commenced an Overtime review
  • Alerts, guidance papers and warnings issued and actioned
  • Responded and provided advice to management on potential fraud concerns

 

The CCG is required to comply with all the Standards for Commissioners issued by the NHS Counter Fraud Authority.  The CCG’s overall self-assessment against these standards for 2021/22 is confirmed to be GREEN, based on the collation of evidence undertaken by the Anti-Fraud Specialist.

 

Internal Audit and Internal Control

Introduction

The purpose of this Head of Internal Audit Opinion is to contribute to the assurances available to the Accountable Officer and the Governing Body which underpin the Governing Body’s own assessment of the effectiveness of the organisation’s system of internal control.  This Opinion will assist the Governing Body in the completion of its Annual Governance Statement (AGS), along with considerations of organisational performance, regulatory compliance, the wider operating environment and health and social care transformation.

This opinion is provided in the context that the CCG is in the process of transition to an ICB and like other organisations across the NHS has continued to faced unprecedented challenges due to COVID-19.

2021/22 Internal Audit Service Delivery
2.1 CCG Closedown
  • Throughout 21/22 MIAA has looked at ways we can continue to provide an internal audit service that both supports the delivery of statutory objectives and manage the transition whilst also providing a degree of flexibility to support in meeting these challenges. On this basis, each of the Lancashire CCGs agreed to ring fence approximately 10% of their 2021/22 internal audit plan days for pan system transition suppor Outcomes from this work support the Head of Internal Audit Opinion (HoIAO) and is summarised in section 4.3.3.5.
  • To support CCGs in their transition to Integrated Care Boards (ICBs), NHSE/I has and continues to issue a range of guidance. Documentation published includes a CCG Closedown & ICB Establishment Due Diligence Checklist, which outlines a number of activities and tasks that need to be completed by CCGs and ICBs as part of the transition process. The checklist includes 10 specific elements relating to Internal Audit and Anti-Fraud. MIAA has been undertaking a number of activities in response to the guidance and this is summarised in section 4.3.3.6.
2.2 COVID-19 Challenges
  • COVID-19 has continued to impact all public services, however, MIAA’s response during 2020/21 and the need to work differently has provided a strong basis for the delivery of planned work in 2021/22. We have continued to act as a critical friend throughout the pandemic providing key assurances across a range of areas including governance, risk management, finance, and quality, sharing best practice and learning from other organisations. There has remained a strong focus on engagement with organisations and the Audit Committee, with regular briefings and updates to support assurance requirements.
  • The re-introduction of restrictions and increased levels of staff sickness (both internal audit and at organisations) due to the Omicron variant and the subsequent ‘stand down’ letter issued by NHSE/I has provided additional challenges to the delivery of planned work, during the final quarter of the year. However, there has been a clear focus by both internal auditors and organisations on requirements to deliver a HoIAO and to support year end reporting.

We would like to take this opportunity to thank the Audit Committee and all the staff at the CCG for their ongoing support during the year.

 

Executive Summary

This annual report provides the 2021/2022 Head of Internal Audit Opinion for NHS Blackpool CCG, together with the planned internal audit coverage and outputs during 2021/2022 and MIAA Quality of Service Indicators.

Key Area Summary
Head of Internal Audit Opinion The overall opinion for the period 1st April 2021 to 31st March 2022 provides Substantial Assurance, that that there is a good system of internal control designed to meet the organisation’s objectives, and that controls are generally being applied consistently.
Planned Audit Coverage and Outputs The 2021/22 Internal Audit Plan has been delivered with the focus on the provision of your Head of Internal Audit Opinion.  This position has been reported within the progress reports across the financial year. Review coverage has been focused on:

  • The organisation’s Assurance Framework
  • Core and mandated reviews, including follow up;
  • A range of individual risk-based assurance reviews; and
  • CCG Closedown/ICB Transition support

Please include the summary text in the table above when referring to the Head of Internal Audit Opinion in your Annual Governance Statement.

MIAA Quality of Service Indicators MIAA operate systems to ISO Quality Standards. The External Quality Assessment, undertaken by CIPFA (2020), provides assurance of MIAA’s full compliance with the Public Sector Internal Audit Standards.

 

Head of Internal Audit Opinion
4.1 Roles and responsibilities

The whole Governing Body is collectively accountable for maintaining a sound system of internal control and is responsible for putting in place arrangements for gaining assurance about the effectiveness of that overall system.

The Annual Governance Statement (AGS) is an annual statement by the Accountable Officer, on behalf of the Governing Body, setting out:

·         how the individual responsibilities of the Accountable Officer are discharged with regard to maintaining a sound system of internal control that supports the achievements of policies, aims and objectives;

·         the purpose of the system of internal control as evidenced by a description of the risk management and review processes, including the Assurance Framework process; and

·         the conduct and results of the review of the effectiveness of the system of internal control, including any disclosures of significant control failures together with assurances that actions are or will be taken where appropriate to address issues arising.

The organisation’s Assurance Framework should bring together all of the evidence required to support the AGS requirements.

In accordance with Public Sector Internal Audit Standards, the Head of Internal Audit (HoIA) is required to provide an annual opinion, based upon and limited to the work performed, on the overall adequacy and effectiveness of the organisation’s risk management, control and governance processes (i.e. the organisation’s system of internal control).  This is achieved through a risk-based plan of work, agreed with management and approved by the Audit Committee, which can provide assurance, subject to the inherent limitations described below. The outcomes and delivery of the internal audit plan are provided in Section 4.

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, it is one component that the Governing Body considers in making its AGS.

 

4.2 Opinion

Our opinion is set out as follows:

4.2.1 Basis for the opinion

The basis for forming our opinion is as follows:

1        An assessment of the design and operation of the underpinning Assurance Framework and supporting processes.
2        An assessment of the range of individual assurances arising from our risk-based internal audit assignments that have been reported throughout the period. This assessment has taken account the relative materiality of systems reviewed and management’s progress in respect of addressing control weaknesses identified.
3        An assessment of the organisation’s response to Internal Audit recommendations, and the extent to which they have been implemented.

 

4.2.2 Overall Opinion

Our overall opinion for the period 1st April 2021 to 31st March 2022 is:

High Assurance, can be given that there is a strong system of internal control which has been effectively designed to meet the organisation’s objectives, and that controls are consistently applied in all areas reviewed.
Substantial Assurance, can be given that that there is a good system of internal control designed to meet the organisation’s objectives, and that controls are generally being applied consistently. P
Moderate Assurance, can be given that there is an adequate system of internal control, however, in some areas weaknesses in design and/or inconsistent application of controls puts the achievement of some of the organisation’s objectives at risk.  
Limited Assurance, can be given that there is a compromised system of internal control as weaknesses in the design and/or inconsistent application of controls impacts on the overall system of internal control and puts the achievement of the organisation’s objectives at risk.
No Assurance, can be given that there is an inadequate system of internal control as weaknesses in control, and/or consistent non-compliance with controls could/has resulted in failure to achieve the organisation’s objectives.
4.3.3 Commentary

The commentary overleaf provides the context for our opinion and together with the opinion should be read in its entirety.

Our opinion covers the period 1st April 2021 to 31st March 2022 inclusive, and is underpinned by the work conducted through the risk based internal audit plan.

 

 

 

4.3.3.1 Assurance Framework
Phase 1 Opinion
Structure The organisation’s AF is structured to meet the NHS requirements.
Engagement The AF is visibly used by the organisation on an ongoing basis.
Opinion
Structure The organisation’s AF is structured to meet the NHS requirements.
Engagement The AF is visibly used by the organisation.
Quality & Alignment The AF clearly reflects the risks discussed by the Board.

 

4.3.3.2 Core & Risk Based Reviews Issued

We issued:

1 high assurance opinions: Primary Care Framework – Commissioning & Procurement
2 substantial assurance opinions: Data Security & Protection Toolkit (2020/21) (Self-assessment)

Data Security & Protection Toolkit (2021/22)

1 moderate assurance opinions: Data Security & Protection Toolkit (2020/21) (Assessment against the National Data Guardian Standards)
0 limited assurance opinions: No reviews received a limited assurance opinion.
0 no assurance opinions: No reviews received a no assurance opinion.
2 reviews without an assurance rating Conflicts of Interest

CCG Transition Group briefing note

 

4.3.3.3 Conflicts of Interest

As required by NHS England’s Managing Conflicts of Interest: Revised Statutory Guidance for CCGs (June 2017), an audit of conflicts of interest was completed following the prescribed framework issued by NHS England. The following compliance levels were assigned to each scope area:

Scope Area Compliance Level RAG rating
1 Governance Arrangements Fully Compliant l
2 Declarations of interests and gifts and hospitality Fully Compliant l
3 Register of interests, gifts and hospitality and procurement decisions Fully Compliant l
4 Decision making processes and contract monitoring Fully Compliant l
5 Reporting concerns and identifying and managing breaches / noncompliance Fully Compliant l

 

4.3.3.4 Primary Medical Care Commissioning and Contracting

The Primary Medical Care Commissioning and Contracting Internal Audit Framework for Delegated CCGs was issued in August 2018. NHSE require an internal audit of delegated CCGs primary medical care commissioning arrangements.  The purpose of this is to provide information to CCG’s that they are discharging NHSE’s statutory primary medical care functions effectively, and in turn to provide aggregate assurance to NHSE and facilitate NHSE’s engagement with CCGs to support improvement.

The 2021/22 Primary Medical Care Commissioning and Contracting review focused upon Commissioning and Procurement and provided Full Assurance (assurance rating provided as per the NHSE guidance).

 

4.3.3.5 CCG Transition – System Support

The following system support, covering a number of transition elements and workstreams, has been undertaken in year. This work complements and supports local transition work.

Lancs and South Cumbria

  • Audit Committee Engagement Events: Briefing session facilitated for Audit Committee members on CCG Transformation and ICB Establishment.
  • Financial Closedown Assurance: MIAA are providing specific assurance to support in the delivery of the workstream that meet NHSEI financial closedown requirements. This support incorporates:
    • regular contact with the Chief Finance Officer financial closedown lead to provide real time insight and guidance on proposals
    • providing assurance to the Finance Transition Group of the current delivery position for the financial closedown workstream. This is focusing upon the processes in place and includes sample testing of actions.
  • Assurance ‘Spot Checks’: MIAA will provide assurance against reported progress in relation to the Transition Programme Plan on a risk-based sample basis. This work is ongoing.
  • SBS Project Board: MIAA are undertaking a project assurance role supporting the SBS Project Board in the implementation of the ICS ledger.
  • System Group Representation and Reporting: Attendance and contribution at:
    • Finance Transition Group
    • Governance Leads Group
    • Executive Closedown Group

 

4.3.3.6 CCG Transition – Local Support

To enable us to comment on the processes in place regarding the adequacy of transition plans, we have undertaken a number of activities including:

  • Transition working group attendance; and
  • Assessing the governance processes for the completion, monitoring and sign off the CCG’s Due Diligence Checklist/Programme plan.
We can provide assurance that effective processes have been established for the completion and monitoring of the Programme Plan.

Note: the assurance provided above does not provide confirmation of the accuracy and completeness of the Due Diligence Checklist/Transition Plan.

 

 

 

4.3.3.7 Follow Up
During the course of the year we have undertaken follow up reviews and can conclude that the organisation has made good progress with regards to the implementation of recommendations. We will continue to track and follow up outstanding actions.
We have raised 1 recommendation as part of the reviews undertaken during 2021/22.  All recommendations raised by MIAA have been accepted by management.

Of these recommendations: 0 were critical and 0 were high risk recommendations.

 

4.3.3.8 Wider organisation context

This opinion is provided in the context that the Governing Body like other organisations across the NHS is facing a number of challenging issues and wider organisational factors particularly with regards to the ongoing pandemic response and ICB transition processes. The challenges for organisations have included continuing to ensure an effective pandemic response, delivering business as usual requirements and implementing and managing a transition process for the establishment of ICBs.

During the COVID response, there has been an increased collaboration between organisations as they have come together to develop new ways of delivering services safely and to coordinate their responses to the pandemic. This focus on collaboration will continue as the NHS progresses on its journey towards integrated care systems.

In providing this opinion I can confirm continued compliance with the definition of internal audit (as set out in your Internal Audit Charter), code of ethics and professional standards. I also confirm organisational independence of the audit activity and that this has been free from interference in respect of scoping, delivery and reporting.

 

Steve Connor

Managing Director, MIAA

March 2022

Louise Cobain

Assurance Director, MIAA

March 2022

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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 CCG 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 CCG achieving its principle objectives have been reviewed.

 

I have been advised on the implications of the result of my review of the effectiveness of the system of internal control by the Governing Body, the Audit Committee, the Finance and Performance Committee, the Quality Improvement and Engagement Committee, Internal Audit, and a commitment to ensure continuous improvement of the internal control system in place using the Governing Body Assurance Framework, the CCG’s Risk Register, and the NHS Oversight Framework process.

 

Conclusion

As Interim Accountable Officer, I have responsibility for reviewing the effectiveness of the system of internal control that supports the achievement of the CCG’s policies, aims and objectives, whilst safeguarding the public funds and assets for which I am personally responsible. My review has been informed in the ways outlined above. The Managing Director of Internal Audit has also provided substantial assurance that there is a generally sound system of internal control, designed to meet the organisation’s objectives, and that controls are generally being applied consistently.

 

My review recognises the control issue arising in respect of the lapse in approval of the extension of the scheme of delegation arrangements for Individual Patient Activity.  However, I am satisfied that appropriate steps have been undertaken to address this matter, including bringing it to the attention of the Governing Body.

 

I therefore conclude that NHS Blackpool Clinical Commissioning Group has a generally sound system of internal control that supports the achievement of its policies, aims and objectives.

 

 

Last updated on 23 June 2022 at 14:55 by Senior communications and engagement officer N