Monitoring questions for health and care providers in the criminal justice system

Page last updated: 12 May 2022
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Organisations we regulate

During the monitoring call our inspector will focus on these specific key lines of enquiry. You can open the questions to see the type of detail they will be interested in.

Safe

S1: How do systems, processes and practices keep people safe and safeguarded from abuse?
  • How do you ensure staff recognise safeguarding issues for adults, children and other vulnerable people, and that they take appropriate action?
  • How do you ensure that the management of any safeguarding concerns does not discriminate people, and that their human rights are protected?
  • What are your arrangements to respond to medical emergencies?
  • Who is providing social care in-house? Does the local authority continue to provide essential equipment when/as required?
  • How are safeguarding concerns being identified, escalated, and managed? (in collaboration with other providers?)
  • How has the prevalence of self-harm been affected?
  • How are healthcare staff contributing to ACCT/ ACDT? Are ACCT documents audited by healthcare? Are there any current action plans?
  • What action have you taken to ensure that restrictive regimes are not detrimental to individual patients?
  • What additional measures are you taking around patients in segregation/isolation with reduced access?

Infection control

  • What changes have you made to infection control arrangements to protect staff and patients using the service?
  • How do you ensure staff have the appropriate time for donning/doffing and cleaning between seeing patients?
  • When was your last audit of IPC/PPE/ the environment and facilities? What did it tell you and what actions have you taken?
  • How is deep cleaning arranged and managed?
  • What are the processes to ensure safe communicable disease management?

Coronavirus (COVID-19) vaccination delivery

  • Are infection risks to staff and people using the service being thoroughly assessed and managed?
  • Consider:
    • Patient flow (particularly when vaccinations are being delivered on prison wings)
    • Appropriate access to PPE
    • Processes to manage clinical waste safely and securely
S2: How are risks to people assessed, and their safety monitored and managed, so they are supported to stay safe?

Safety systems and risks to people

  • What actions have you taken in the last six months as a result of learning from serious incidents to ensure people are kept safe?
  • How are patients who need urgent care and treatment identified, prioritised, and protected from discrimination?
  • How do you recognise and manage the deteriorating patient?
  • What are your arrangements to respond to medical emergencies?
  • How do you ensure appropriate staffing levels and skill mix to cope with demand? (for example, weekends, bank holidays, seasonal pressures, epidemics)
  • What agreements are in place with staff in the establishment to ensure patient safety?
  • What areas for improvement have been identified?
  • What escalation plans are in place to manage emerging risks within the establishment?

COVID-19 vaccination delivery: managing adverse reactions

  • Is there access to emergency medicines in the location where vaccinations are being delivered, and how are these checked?
  • What access is there to emergency medical support in the event of an adverse reaction?
S3: Do staff have all the information they need to deliver safe care and treatment to people?
  • How do you manage clinical records to ensure safe care and treatment?
  • How do you manage referrals to and from other providers?
  • How do you monitor and prioritise referrals and delays?
  • How do you manage access to long-term condition clinics and routine care to minimise avoidable deaths in custody?
S4: How does the provider ensure the proper and safe use of medicines, where the service is responsible?
  • Have you made any changes to your approach to medicines management? (for example, in relation to repeat prescribing, ongoing monitoring requirements for high risk medicines)
  • If so, what were they and how has this affected care?
  • How are people’s medicines reconciled, in line with current national guidance, when transferring between locations or changing levels of care?
  • How are you ensuring sufficient stock and future supply? Is out-of-hours medication stock used?
  • What medicines are being issued for released prisoners to take?
  • Are you managing any system blocks to ensuring medicines?
  • What audit cycles are in place for medicines management?
  • Are there any significant incidents relating to medicines, and action plans?

COVID-19 vaccination delivery: Receipt and storage

  • How are records kept of the vaccine received?
  • How is the cold chain maintained? (In particular consider the need for additional fridges and how vaccinations are transported to the wings.) What records are kept?
  • What is the process to monitor expiry dates and dispose of unused vaccines?
  • What contingency arrangements are in place in case of failure of cold storage?
  • How are vaccinations stored and transported securely on site?

COVID-19 vaccination delivery: Administration and delivery of the vaccine

  • How is the cold chain monitored and maintained during transport on site?
  • How are decisions made on the level of stock that needs to be held to meet the needs of patients coming to the service?
  • Are there suitable facilities to prepare doses of the vaccine and how are these monitored and maintained?
  • Does the environment in which the vaccine is administered maintain patient’s privacy and dignity and are they suitable for people with access or other needs?
  • Is the provider ensuring staff are working to relevant Patient Specific Directions (PSDs), Patient Group Directions (PGDs) or National Vaccination protocols when preparing and/or administering a vaccine?
  • What information about the vaccine is provided to patients?
  • What is the process around secure sharps disposal, and support from prison officers to assure clinical staff safety during vaccination administration?

COVID-19 vaccination delivery: Standard operating procedures and governance

  • Are there standard operating procedures (SOPs) or policies in place to cover all aspects of vaccine administration and storage at the location?
  • Are there clear records of temperature monitoring from receipt through to administration?
  • Are there clear stock control records from receipt through to administration?

Effective

E1: Are people's needs assessed and care and treatment delivered in line with current legislation, standards and evidence-based guidance to achieve effective outcomes?
  • How are you identifying, cascading and keeping up to date with changes in clinical guidance?
  • What are your oversight arrangements for clinical care provided by clinical and non-clinical staff?
  • How are you maintaining reception screening arrangements? (in particular, mental health/suicide and self-harm risks)
  • How is secondary screening taking place?
  • How are patients being offered healthcare appointments?
  • What healthcare activity is taking place within accommodation units?
  • How are you managing arrangements to bring patients to healthcare?
  • What level of mental health service is being provided to patients, including:
    • primary mental health
    • group work or psychological interventions
    • secondary mental health
  • How are you, or will you be, notified of sudden or early releases and what are the processes to ensure the smooth transition of patients’ healthcare needs into the community?
  • How are you registering prisoners with a GP practice before release?
  • What liaison with community Substance Misuse Services and mental health teams is taking place?
  • Where you have introduced any additional reporting and monitoring arrangements due to COVID-19, which do you plan to continue?
  • Who is available to certify death?
E3: How does the service make sure that staff have the skills, knowledge and experience to deliver effective care, support and treatment?
  • How do you ensure that all staff (clinical and non-clinical), including those being flexibly re-deployed, have the skills and knowledge to carry out their roles and responsibilities effectively?
  • How do you ensure that the staff who deal with patients are operating within the appropriate scope of practice at the point of recruitment, and ongoing? For example, audit of consultations? (including within primary care networks where relevant).
  • What additional staff training has been provided to improve/increase staff skills, for example triage and minor illness/long-term condition management?
  • How are regular training needs analyses conducted? What arrangements are there for mandatory face-to-face training that is overdue?

COVID-19 vaccination delivery: Training and supervision

  • How have staff been trained for their roles? Are there records of training available?
  • Is COVID vaccination discussed in supervision sessions?
E5: How are people supported to live healthier lives and, where the service is responsible, how does it improve the health of its population?
  • How do you ensure that people who are affected by health inequalities are receiving the care they need?
  • How are you promoting good health/targeted approaches in response to coronavirus (COVID-19) and people at risk?
  • What arrangements are there to ensure patients maintain their physical and mental wellbeing during instances of prolonged isolation or lockdown?
  • How are you promoting and facilitating healthy lifestyles for patients or people who use services?

Caring

C1: How does the service ensure that people are treated with kindness, respect and compassion, and that they are given emotional support when needed?
  • How have you adapted how you support and engage with patients and their families/loved ones (for example, in the context of more remote working)?
  • How do you gain an understanding of the impact of the COVID-19 pandemic on patients’ physical and mental health?
  • How has the service adapted to consider patients who might be nervous about leaving their cell or being in close proximity to other patients or staff?
C2: How does the service support people to express their views and be actively involved in making decisions about their care, support and treatment as far as possible?
  • How do you support people to express their views and actively involve them to make decisions as far as possible?
  • Where COVID-19 has changed the way a service is provided, how has this been explained to patients to inform decision-making?
  • How do you encourage your patients to speak up and have a voice?

Responsive

R1: How do people receive personalised care that is responsive to their needs?
  • How do you take into account patient choice about how, when, where they want to be seen?
  • How do you ensure that people with information and communication needs are able to access appointments and services in ways that meet their needs?
  • How does care provision take account of the needs of individual people? (for example, Trans people, people who have a disability, people with long term conditions or mental health needs)
  • Have you identified any barriers to care provision, particularly for patients with protected characteristics? For example, disabled people, older people, people in Black, Asian and minority ethnic groups. If yes, what actions have been taken to combat them?
  • How are DNACPRs/advanced decisions being managed and reviewed? Are GPs available to discuss this with patients?
  • How many vulnerable patients are there within the secure facility who have additional needs and vulnerabilities, or specific health care pathways i.e. palliative patients present in the prison/hospice/hospital?
  • How do you carry out reviews of asthma/diabetes/atrial fibrillation/chronic heart disease/chronic obstructive pulmonary disease or epilepsy, and other reviews?
  • Are GPs or nurses seeing patients for review, or are these completed without the patient present?
  • Are external specialist staff coming in and providing a full range of care?
  • Where services are now provided in the living accommodation, are appropriate rooms used?
  • What communication aids are available where you are speaking to patients through the cell door?

COVID-19 vaccination delivery: Encouraging uptake of vaccination

  • How are you communicating the benefits of vaccination to patients, and managing concerns or misinformation?
R3: Can people access care and treatment in a timely way?
  • How are you managing access to services?
    • Do you have backlogs of activity and long waiting times as a result of coronavirus? How are you managing this? What are your recovery plans?
    • How are you ensuring that high-risk/vulnerable patients and pathways are being identified and prioritised appropriately?
    • What are your arrangements to follow-up and support patients whose care and treatment was delayed due to coronavirus? For example, patients with non-COVID related issues.
    • How are you ensuring equitable access to appointments when they are needed, especially for people with protected characteristics and vulnerable groups? For example, people who are at the end of their life.
  • What information has been provided to patients about changes to service delivery and availability?
  • How are patients accessing remote consultations and what technology is in place to support this?
  • How do you access support for any out-of-hours concerns?
  • Do patients have access to social care?

COVID-19 vaccination delivery: Access to treatment

  • How are patients being prioritised to receive the vaccination?
  • What arrangements are put in place for the individual to receive a second dose whether that be in custody or the community?

Well-led

W3: Is there a culture of high-quality, sustainable care?
  • What actions are you taking to protect and support the health, safety, and wellbeing of staff, particularly those who are high-risk or in Black, Asian and minority ethnic groups? For example, COVID-19 testing.
  • How do you promote equality and diversity, and check that staff feel supported, respected, and valued?
  • What training and support is available for staff using new technology to deliver care?
  • What consultation is there with staff around ongoing safety of staff and patients?
  • What arrangements are there for senior staff to visit or support staff in custodial environments?
W5: Are there clear and effective processes for managing risks, issues and performance?
  • Has your business model/operating model changed since the pandemic? If so, how and what has been the impact on staff and people who use your services?
  • How do you assure yourself that you are providing a safe service? For example, regular audits and increased supervision etc
  • How are you monitoring business risks and issues, and what actions are you taking to respond to them?
    • What are the arrangements for business continuity? For example, arrangements for diverting calls, contingency planning for staff shortages/outbreak onsite, changes made in light of COVID-19
    • How are you flexing the service/models of care to adapt to changing circumstances, including second wave of COVID-19?
  • How are you working with partners to review and update local pathways?
  • What escalation plans are there to manage emerging risks within the establishment?
  • What areas of improvement have been identified, and are being implemented? For example, safety or patient care and treatment.

COVID-19 vaccination delivery

  • What systems and processes are in place to manage risks/issues in relation to COVID vaccination delivery? Consider:
    • Ensuring a designated person has clinical oversight of the staff delivering the vaccination
    • Maintaining oversight of the vaccine’s storage and use
    • Managing drug alerts and recalls and cascading relevant information to staff
    • Systems are in place to respond to relevant medical devices and medicines alerts
    • Systems and processes to ensure consent is obtained in line with guidance
    • Liaison with prison/IRC management around receipt of vaccinations on site and arrangements to administer the vaccination to patients.
W8: Are there robust systems and processes for learning, continuous improvement and innovation?
  • What systems are in place to support people (staff/people who use your services and their families/carers) to speak up and raise concerns?
  • How do you support people to provide feedback?
  • How do you demonstrate that you have a learning culture and routinely embed learning from significant events and complaints?