The Strategic Health Authority Adult Safeguarding Leads Network recently devised a protocol for the placement out of area of those in receipt of individual packages of care (including continuing healthcare).
It serves as a reminder of the importance of robust safeguarding arrangements when commissioning health care; building on existing DH guidance and emphasising the importance of strong communications between commissioners when complex needs and the need for specialist provision, requires a placement outside their local area.
Commissioners must ensure that the quality of care is monitored, notwithstanding the locality of the provider and focus on returning the person to their local community where possible.
The guidance reinforces the point that commissioners remain responsible not just for reviewing eligibility for funding, but also ensuring compliance with regulatory requirements by frequent monitoring, in order to assure themselves that the services they commission are meeting expected requirements.
Given the lack of wider intelligence about the quality of providers gained through the local monitoring process, commissioners must therefore ensure they notify the local primary care trust (PCT)/clinical commissioning group (CCG) where a placement is made out of area so that if a local PCT/CCG or partner agency has concerns about the standard of care provided by a care home or independent health care provider within their area; they can and must, notify the commissioning PCT/CCG to enable a review of the individual’s care needs to take place. Any concerns identified through such a review should then be communicated, as appropriate, to the local commissioner. Template letters of notification have helpfully been provided.
The protocol does leave open the possibility of reciprocal arrangements by which local PCT/CCGs review all patients in their area, but it reinforces the point that responsibility for the quality of care nonetheless remains with the commissioning PCT/CCG.
While this is a welcome reminder of the importance of collaborative working and monitoring, the guidance fails to address placements at the request of the individual or their family. It also does not alter or replace the duties to act under local multi-agency safeguarding adult procedures.
This protocol has been adopted by all strategic health authorities in March 2012 and is intended for adoption and application across England by all PCTs; CCGs and supporting bodies in order to promote collaborative working to ensure the safety and well being of patients and service users.