Take action now to be ready for the Patient Safety Incident Response Framework

Organisations delivering care under the NHS Standard Contract have until autumn 2023 to implement the Patient Safety Incident Response Framework – a new approach to responding to patient safety incidents.

PSIRF is flexible, relying on local data and systems analysis to support providers in establishing their own improvement priorities. PSIRF does not prescribe which incidents to investigate: providers must develop their own policy and plan for responding to PSIs, enabling them to focus time and resource into investigating and implementing improvements relevant to their own context and population.

To achieve PSIRF’s objectives, providers must understand their patient safety risk profile properly to inform their approach to investigations and to develop their Patient Safety Incident Response Policy and Plan.

Who does PSRF apply to?

PSIRF will apply to all who work under the NHS Standard Contract including maternity and specialist services and in amended fashion to private providers performing NHS functions.

How does PSIRF help achieve effective learning and improvement?

Compassionate engagement is at PSIRF’s core, recognising that effective learning and improvement means working with all affected by PSIs, including patients, families and staff.

Acknowledging that resources for investigating PSIs and implementing improvements are finite, the focus is on proportionate responses, maximising improvements by identifying key priorities and the incidents to be investigated. This targeted and focused approach, informed by the risk profile and Patient Safety Incident Response Plan, makes providers responsible for driving their own improvement.

Provided that ICBs and regulators are satisfied that risk and improvement work is being appropriately managed to address known contributory factors through Patient Safety Incident Response Plans and governance structures, providers will not need to investigate every PSI fully. However, providers will need processes to address those incidents not requiring full investigation, such as through MDT discussion or targeted feedback and must still engage with those affected. The duty of candour still applies.

What is required?

To implement PSIRF, providers must develop two key documents:

1. Patient Safety Incident Response Policy

2. Patient Safety Incident Response Plan

Providers must therefore understand their PSI profile. For many, this will need procedural and cultural changes to ensure all available data is captured, overcoming silos across claims, complaints, inquests, patient safety and governance teams.

There is a template Policy and Plan on NHS England’s website. To work with these, particularly the Plan template, providers must first analyse all of their data to inform their improvement objectives.

Involving patient safety and addressing inequalities

Addressing health inequalities should be easier with PSRIF’s flexibility, local plans, and the involvement of patient safety partners including patients, families and carers as an effective means of oversight. Certainly, inequalities should be the uppermost consideration when developing Patient Safety Incident Response Policies and Plans.

The challenge

For most providers, PSIRF will require significant cultural change. Rather than measuring the quality of investigations and reports, the focus will be on measurable improvements. Key challenges include:

• Capturing all data to inform risk profiles and improvement plans
• Working collaboratively with patient safety partners to set improvement objectives
• Allocating resource between investigations and improvement oversight
• Ensuring appropriate and compassionate responses to PSIs not for full investigation

Hempsons’ healthcare law team are advising providers across the country on PSIRF implementation. Contact Liz Hackett for more information.