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Emergency support framework: discussion questions for health and care providers in the criminal justice system

The conversation with your inspector will focus on four areas. The questions are for the inspector to answer, helped by the discussion prompts. This helps us to understand how you are managing currently and whether you need support with anything. Your inspector may not need to cover all the questions as things may already be clear, so you don’t need to spend time preparing for them.

1. Safe care and treatment

1.1 Are infection risks to people using the service being thoroughly assessed and managed?
  • Are you managing to keep up to date with current infection prevention and control (IPC) methods?
  • What challenges have you faced?

Also consider (where relevant):

  • changes to IPC practice (for all locations) in line with guidance
  • lead clinician for IPC
  • dissemination of guidance to staff/additional training
  • IPC suitable for how they are delivering services, for example face-to-face, on wing etc
  • waste management (for example disposal of PPE).
1.2 Does the service have the resources to obtain, and reliable access to, all the supplies, personal protective equipment and COVID-19 testing it needs, for both staff and people who use the service?
  • Are you managing to access supplies of PPE and equipment?
    • appropriate standard?
    • sufficient amounts?
  • If no, what could be improved?
  • Do you know where to access support?
  • What arrangements are in place for staff reporting COVID-19 symptoms and how is this managed?
  • Do staff have access to testing for COVID-19?
1.3 Does the location’s environment and layout support preventing and containing transmission of infection?
  • What issues have you identified within your environment in relation to managing the pandemic?
  • What changes have you made to the layout/environment to manage the situation?

Also consider (where relevant):

  • alternative use of premises or part of premises
  • how are waiting areas organised to promote safety?
  • additional signage
  • ensuring COVID/non-COVID patients are not coming into contact with each other where possible.
1.4 Are working arrangements and procedures clear and accessible to staff, people who use the service, their supporters, and visitors to the service?
  • Where you have made changes to how you operate to manage patients with COVID-19 symptoms and non-COVID patients:
    • were health and safety risks clear to staff, patients and visitors to the service?
    • how do you ensure staff and patients understand the arrangements?
    • how have you taken into consideration vulnerable people and those with communication requirements?
  • What agreements are in place with prison staff to ensure safety of patients?
  • What information has been provided to patients about changes to service delivery and availability?
  • What areas for improvement were identified?
1.5 Are medicines being managed safely and effectively?

(including prescribing and management of medicines)

  • Have you experienced any problems with responding to medicines alerts?
  • Have you made any changes to your systems:
    • to support patients to obtain repeat prescriptions?
    • to manage patients who require support with the administration of ongoing medicines? (For example contraception/B12)
    • to manage patients who are being prescribed medicines for which they require ongoing monitoring? (For example methotrexate, lithium)
  • If a dispensing pharmacy:
    • how have your dispensing arrangements changed?
    • have you identified any issues in relation to dispensing and how are these being addressed?
    • what are the arrangements for high-risk patients, or those who are shielding?
    • how are you ensuring stock and future supply is sufficient?
  • What changes have you made to ensure patients are receiving their medicines in a timely and safe way?
    • medicines administration arrangements
    • medicines storage/transport arrangements
    • prescribing arrangements (including arrangement for remote prescriptions and management of controlled drugs)
    • management and monitoring of ‘in possession’ medicines; review of IPRAs
    • any other risks/issues? How are these being managed?
1.6 Are risks to the health and wellbeing of people using the service being properly assessed, monitored and managed?
  • Have there been any significant events/complaints related to COVID-19? If yes, how is learning from these being identified and shared?
  • What challenges have you faced in managing emerging and existing risks? For example, assessment of risk in relation to services which have been paused due to the pandemic?
  • How are you meeting challenges/managing risk in relation to how you provide services?
    • face-to-face services (including wing visits)
    • maintaining social distancing (including in waiting area and during appointments)
    • remote services (including online, telephone, video)
    • management and shielding of patients
    • reception screening arrangements (including COVID-19 screening, mental health, suicide and self-harm risks)
    • secondary screening
    • arrangements for healthcare appointments, including escorts
    • healthcare activity taking place on wings
    • access to testing for COVID-19
    • which groups of patients are being cohorted within the prison? And how?
  • How are you assured that all high-risk patients are identified and therefore shielded?
    • criteria for shielded and high risk
    • isolation arrangements
    • shielded patients’ access to healthcare/meals
    • prisoner buddies
  • Have there been changes to the level of mental health services is being provided to patients? (For example primary mental health, group work or psychological interventions, secondary mental health)
  • How are you ensuring continuity of care on release?
    • arrangements for notification of sudden or early release
    • registration of prisoners with a GP practice
    • medicines arrangements
    • liaison with community SMS and mental health teams
    • arrangements for prisoners who test positive for COVID-19 prior to release

2. Staffing arrangements

2.1 Are there sufficient numbers of suitable staff to provide safe care and treatment in a dignified and respectful way?
  • Have there been significant changes to staffing arrangements?
  • If yes, what challenges has this presented?
    • changes to staffing structure (including recruitment of staff)
    • staff support where roles and responsibilities have changed, and new ways of working have been adopted (for example in relation to technology)
    • supervision/training/oversight arrangements for staff
    • arrangements for new staff (including induction and employment checks)
    • ensuring people get care and support from workers with the right knowledge and skills
  • Are you proactively assessing staff who may be at increased risk of getting COVID-19? including: Black, Asian and Minority Ethnic (BAME) colleagues, older colleagues, pregnant women, returnees, and those with underlying health conditions
2.2 Are there realistic and workable plans for managing staffing levels if the pandemic or other causes lead to shortfalls and emergencies?
  • How has the pandemic affected your ability to staff the service?
    • what has this meant for patients who use your services?
    • what have you needed to do to mitigate any impact on staffing levels?
    • where do you go to seek support?
  • Have you been able to engage with local system arrangements to share staff where required?

3. Protection from abuse and protection of human rights

3.1 Are people using the service being protected from abuse, neglect, discrimination and loss of their human rights?
  • How have you responded to issues which may affect the equality, diversity and human rights of your patients?
  • How do you ensure people continue to receive individualised assessments and are a part of the decision-making in line with relevant guidance?
  • What action have you taken to ensure that very restricted regimes are not detrimental to individual patients?
  • What are the arrangements for patients receiving social care support or palliative care?
    • provision of social care
    • management and review of DNACPRs/Advanced decisions (including GP discussion regarding these)
    • management of palliative patients at present (in the prison and at hospice/hospital) including those who are potentially COVID-19 positive
    • certification of death
3.2 Are the service’s safeguarding and other policies and practice, together with local systems, properly managing any concerns about abuse and protecting people’s human rights?
  • Have there been changes to how safeguarding concerns are being escalated and managed?
  • Have there been any safeguarding incidents and how have you responded to these? Any themes/trends?
  • Have you reviewed safeguarding registers and reviewed patients/communicated with other agencies where necessary?
  • How have you tried to identify vulnerable patients during the pandemic?
  • How has the prevalence of self-harm been affected?
  • How are healthcare staff contributing to ACCT/ACDT?

4. Assurance processes, quality monitoring and business risk management

4.1 Is the provider monitoring and protecting the health, safety and wellbeing of staff?
  • What changes have you made to ways of working to support your staff and ensure their safety? For example remote working solutions/caring responsibilities
  • Do staff have appropriate equipment, technology and systems that ensure confidentiality (where they are homeworking)?
  • Do staff have access to psychological support services where required?
4.2 Does the provider have effective systems and methods for monitoring the overall quality of the service and for responding to business risks and issues as they arise?
  • How has the pandemic affected your ability to monitor the overall quality of care?
  • How are you keeping up to date with relevant standards and guidance relating to the delivery of care and treatment? How are these being shared with staff?
  • How are ‘business as usual’ processes and systems being managed? (for example, medication reviews, long-term condition reviews, cervical screening, management of care plans, childhood immunisations and two-week wait referrals, other referrals)
  • Are GPs/nurses seeing patients for review, or are these completed without the patient present?
  • Are external specialist staff still coming in and providing full range of care?
  • What changes have you made to systems to ensure access to your services, in response to COVID-19?
    • remote access - telephone assessments, video or online consultations
    • people who have communication needs e.g. deaf people/people who do not speak English.
  • How are you identifying and supporting ‘high risk’ patients/groups with their ongoing care needs?
  • How are complaints being managed? How do prisoners access complaint forms?
  • How are you monitoring feedback and trends?
4.3 Is the provider supporting staff and people who use the service to raise any concerns and give feedback?
  • How are you continuing to support staff to speak up and raise concerns?
  • How have you managed to promote team working, for example, team meetings?
  • Are leaders accessible to staff when needed?
  • Have any areas of improvement been identified?
4.4 Is care and treatment provided to people being properly recorded?
  • Has the impact of the pandemic led to changes or issues with regard to how records are kept and shared?
  • Are you experiencing any barriers to sharing or accessing patient information with other providers?
4.5 Is the provider able to work effectively with system partners when care and treatment is being commissioned, shared or transferred?
  • How are you coordinating care with partners and/or stakeholders, and sharing information?
    • other providers, sub-contractors, local commissioners, national bodies

Indicators we will use to prioritise assessments

Your inspector will use their knowledge of your service and will look at some specific indicators for the data that we hold to help decide what risk you may be facing.

The information we use will evolve as the situation changes, moving from this initial focus on what we know about services from existing data, to a focus on COVID-related priorities and recovery plans.

  • Population size against the establishment's operational capacity
  • Change in the population size in recent years
  • Establishment has been re-rolled recently
  • Proportion of establishment’s population aged 50 or over
  • Time since last multi-agency inspection
  • Self-harm incidents against target
  • No active locations registered for the establishment
  • One or more safeguarding enquiries in last 12 months
  • One of more whistleblowing enquiries in last 12 months
  • Three of more complaints in last 12 months
  • Current breaches of regulations
  • Registered manager not in place
  • A location has registered since the last multi-agency inspection.
Last updated:
03 July 2020