Emergency Preparedness, Resilience and Response (EPRR)

Emergency Preparedness, Resilience and Response (EPRR)

Introduction

The NHS needs to plan for and respond to a wide range of emergencies and business continuity incidents that could affect the health/patient safety of individuals or populations. Typically these are related to severe weather, outbreaks of diseases (e.g., flu) and major transport incidents. A significant amount of planning and testing takes place across the public sector under the Civil Contingencies Act (2004). In the health service this work is referred to as EPRR.

Background

The Health and Social Care Act (2012) significantly affected EPRR arrangements with many functions being distributed to new bodies e.g., Public Health England, NHS England and CCGs. The overarching document that described this change which was enacted on 1st April 2013 was called NHS Commissioning Board Emergency Preparedness Framework 2013.

This significant change particularly in the commissioning and public health systems has been under review and refinement, with further guidance documents being developed including a set of core standards which have been consulted upon (albeit with short deadlines). The outcome of the consultation of this set of core standards for the NHS attached at Appendix 1. The document also gives a more simplified description and summary of the EPRR requirements which was in the NHS Commissioning Board Emergency Preparedness Framework.

NHS England has required that all relevant organisations complete a self-assessment matrix with a RAG (red, amber, green) rating against these core standards. This completed assessment for CCGs in Nottinghamshire and Nottingham City is attached at Appendix 2. CCGs are category 2 responders, the description of this can be found in page 6 and 7 of the Core standards attachment (Appendix 1)

There is an annual assurance process for EPRR category 1 and 2 responders to be held on 13th October. This is a confirm and challenge meeting where the CCGs will be represented by Vicky Bailey (Chief Officer, NHS Rushcliffe CCG) and Hazel Buchanan (NHS Nottingham North and East CCG). Part of that assurance is that Boards and Governing Bodies will have received the assessment and provide a statement of compliance and any action cards for amber and red statements. This has to be signed off by the 29th September 2014. The statement of compliance is in Appendix 4.

This came from NHS England on the 31st July and are national timescales

Local situation

1. Collaboration

CCGs in the geographical county of Nottinghamshire have agreed to collaborate on EPRR while still retaining their statutory accountability. This is allowed in the guidance with a role for a lead CCG. This role is taken by Rushcliffe CCG. This is a pragmatic solution as much of the partnership work on emergency planning has the local authorities and the Police as the lead organisations. They come together in the Local Resilience Forum (LRF) where the NHS is represented by NHS England Area Team. The meeting where the NHS providers and commissioners come together is called the Local Health Resilience Partnership (LHRP). Vicky Bailey attends this as Chief Officer of Rushcliffe CCG and representative of CCGs. There is a memorandum of understanding for the LHRP signed by all CCG Accountable Officers (Appendix 3)

Governing Body members will recall the work across CCGs on financial risk sharing and the development work done by PWC. This agreement specifically mentions EPRR as one of the areas where risk is formally shared. This is to ensure that in the event of an emergency where resources need to be committed at scale the on call managers are able to enact this on behalf of each other.

2. Contractual levers

The main duties of CCGs are to support NHS England, and also assure via contracts that providers have suitable business continuity plans. The NHS Standard Contract supports CCGs and Providers under schedule 2E whereby there is a requirement for providers to detail their ‘essential services continuity plan’. Therefore all providers with whom CCGs have an NHS standard contract will have these plans. To enact, providers confirmed their business continuity plans in relation to a heat wave and these were followed up by CCGs during 2013 and 2014 when an alert was released from the met office.

3. Leadership and assurance

Each CCG has a Business Continuity Plan. This was approved at the Rushcliffe Governing Body on 20th March 2013. All CCG business continuity plans were submitted to NHS England Area Team and then onto NHS Midlands and East in February 2013 as part of and EPRR assurance framework

It is a requirement of the Core Standards that each CCG has a Director level accountable officer. For Rushcliffe CCG this is Vicky Bailey.

The CCGs exercise their duties as category 2 responders by being part of an on call rota 24/7. The managers on the rota are all band 8c and above. There are two rotas, one for Mansfield and Ashfield and Newark and Sherwood, and one for Nottingham City, Nottingham North and East, Nottingham West and Rushcliffe CCGs. This rationale for 2 rotas is that CCGs also have to provide a 24/7 on call response to system resilience (reporting of ED breaches for example), the majority of which relate to acute providers.

EPRR was part of the Q2 and Q3 CCG assurance meetings with NHS England. There are subgroups of the LHRP attended by other CCG staff ie the LHRP working group, HAZMAT task and finish group, Nottinghamshire flood group where operational matters are discussed

In addition, a cross CCG meeting takes place three times a year (to which NHS England is invited) where the on call handbook is reviewed, and all on call incidents reviewed (these have all previously been reported to NHS England)

4. Training

The majority of training is at LRF level and is linked to strategic and tactical responses. NHS England has a training strategy to enable it to take its lead role in the LRF. There is no specific CCG category 2 level training, so it has been identified that CCGs will undertake the tactical LRF training as it will provide an overview of how CCGs would support NHS England as a category 2 responder in a major incident. This has been highlighted as amber in the assessment as the training is not available until 13th February 2015. A mitigation is that many of the CCG on call managers have had had previous training when they were with the PCT. There have been no significant issues of risk in relation to on call. There have been times where there has been a lack of understanding about the new roles of organisations post the health and social care Act but these have not posed patient risk. These have lessened as the system changes have bedded in

Statement of Compliance

The statement of compliance has been included in appendix 4. The statement of compliance confirms the CCGs responsibility in emergency planning and provides additional assurance to the Annual Report. The statement provides evidence and support in relation to the following:

· Self-contained policy statement

· Annual Report 2014/15

· Included in induction material

· Utilised on intranets and web-sites

Appendix 1 – Core Standards

The attached document sets out the minimum core standards for NHS organisations and providers.

The core standards relate to the following:

General

NHS organisations and providers of NHS funded care must:

i. Nominate an director level accountable emergency officer who will be responsible for EPRR; and

ii. Contribute to area planning for EPRR through local health resilience partnerships (LHRPs) and other relevant groups.

Emergency Preparedness Resilience and Response

NHS Organisations and providers of NHS funded care must:

I. have suitable, proportionate and up to date plans which set out how they plan for, respond to and recover from emergency and business continuity incidents as identified in national and community risk registers;

II. Exercise these plans through:

• A communications exercise every six months;

• A desktop exercise once a year; and

• A major live exercise every three years;

III. Have appropriately trained, competent staff and suitable facilities available round the clock to effectively manage an emergency and business continuity incident; and

IV. Share their resources as required to respond to an emergency or business continuity incident.

Business Continuity planning

NHS organisations and providers of NHS funded care must have suitable, proportionate and up to date plans which set out how they will maintain prioritised activities when faced with disruption from identified local risks; for example, severe weather, IT failure, an infectious disease, a fuel shortage or industrial action.

Appendix 2 - Assurance Framework Against Core Standards

The attached spread sheet details the areas of compliance for the CCGs. Specific information is presented with blue text.

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Appendix 3 – Memorandum of Understanding

This memorandum of understanding (MOU) sets out the agreed contribution to emergency preparedness, resilience and response (EPRR) within Nottinghamshire between the NHS England Derbyshire and Nottinghamshire Area Team (AT) who leads on EPRR acting, in its EPRR functions, on behalf of the NHS at the Nottinghamshire local resilience forum (LRF); and organisations (including CCGs) and providers.

The key principles are as follows:

a. The NHS England AT is empowered to use / call upon such relevant resources as may be necessary from any one or all of the NHS funded commissioners and providers within the Nottinghamshire LRF area in response to a major incident.

b. Each commissioner and provider is required to maintain appropriate plans detailing how the organisations plan for, respond to and recover from a major incident. Organisational Incident response plans should contain provision for training key staff and provision for exercising the plan to ensure it is effective.

c. No organisation should be expected to suffer financially from being asked to respond to an emergency (unless under Standard Contract Sections 30.10 - 30.19); equally, no organisation should wait until full financial consequences are clear before initiating a response.

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Appendix 4 – Statement of Compliance

The Governing Body of Rushcliffe CCG recognises the importance and the role of the CCG as a Category 2 responder, in relation to emergency preparedness, resilience and response.

The Governing Body is aware that the NHS needs to be able to plan for and respond to a wide range of emergencies and business continuity incidents that could affect health or patient safety. The Governing Body acknowledges that under the Civil Contingencies Act (2004), NHS organisations and providers of NHS funded care must show that they can effectively respond to emergencies and business continuity incidents while maintaining services to patients

The Governing Body have assigned an Emergency Accountable Officer and recognise the role of the Chief Officer for NHS Rushcliffe CCG as the co-ordinating CCG of and for the Local Health Resilience Partnership.

The Governing Body can provide assurance that the CCG have the necessary processes and infrastructure in place, for the core standards relevant to a Category 2 responder in relation to the following:

General

NHS organisations and providers of NHS funded care must:

i. nominate an director level accountable emergency officer who will be responsible for EPRR; and

ii. Contribute to area planning for EPRR through local health resilience partnerships (LHRPs) and other relevant groups.

Emergency Preparedness Resilience and Response

NHS Organisations and providers of NHS funded care must:

II. Exercise these plans through:

• A communications exercise every six months;

• A desktop exercise once a year; and

• A major live exercise every three years;

III. Have appropriately trained, competent staff and suitable facilities available round the clock to effectively manage an emergency and business continuity incident; and

IV. Share their resources as required to respond to an emergency or business continuity incident.

Business Continuity Planning

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