GB 15/135 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 1 st 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. For 2015 CCGs are also required to complete an assessment against pandemic flu standards. 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) The self-assessment was submitted to NHS England and this was further moderated through a joint meeting on the 10 th September 2015. 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 01 November 2015. The statement of compliance is in Appendix 4. This came from NHS England 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). The financial risk share 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. 3. Leadership and assurance Each CCG has a Business Continuity Plan. This was approved at NHS Nottingham North & East CCG Governing Body meeting 15 September 2015. It is a requirement of the Core Standards that each CCG has a Director level accountable officer. For NHS Nottingham North & East CCG it is, Hazel Buchanan Director of Operations. 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 is part of the NHS England CCG assurance framework. There are subgroups of the LRF and task and finish groups for the LHRP attended by other CCG staff. 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 v1 2
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 CCG on call managers have undertaken the tactical LRF training as provides an overview of how CCGs would support NHS England as a category 2 responder in a major incident. This was highlighted as amber in the 2014 assessment and green for 2015 as it is now part of ongoing training for existing and new staff to the on call rota. 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 2015/16 Included in induction material Utilised on intranets and web-sites v1 3
Appendix 1 Core Standards The attached document sets out the minimum core standards for NHS organisations and providers. EPRR Core Standards NHS England 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. v1 4
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. CCG core standards v.2 v1 5
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 North Midlands 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. NHSE North Midlands 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. EPRR Memorandum of Understanding Nottinghamshire v1.docx v1 6
Appendix 4 Statement of Compliance The Governing Body of NHS Nottingham North & East Clinical Commissioning Group 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: 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 v1 7
disruption from identified local risks; for example, severe weather, IT failure, an infectious disease, a fuel shortage or industrial action. v1 8