A Care Quality Commission (CQC) review of governance and leadership at the British Pregnancy Advisory Service (BPAS) has found that action is needed to strengthen oversight of risk and better support staff in their delivery of care.
CQC inspectors carried out a provider well led assessment at BPAS UK after inspections of some individual BPAS service locations indicated potential concerns at an organisational level.
The well led review found that operational leaders promoted an open and transparent culture where most staff felt safe to raise concerns and report incidents. Safeguarding processes were in place and front-line staff were supported with appropriate training and guidance by an experienced central safeguarding team.
In addition, a clear set of core organisational values had been developed and shared across all BPAS services and a programme of site visits by the leadership team was being undertaken to improve staff engagement.
However, inspectors also identified some areas where governance processes lacked rigour and found that clinical and corporate risks were not always recognised and escalated to ensure effective organisation wide learning and improvement.
BPAS provides reproductive healthcare and termination of pregnancy services to women and birthing people of childbearing age and operates across the UK. It has 49 clinics in England which fall into scope of CQC regulation.
Inspectors visited the BPAS’s administrative headquarters in Warwickshire over two days in February 2023. They looked at a range of performance data, quality audits, board papers, internal reports, and complaints records. They also spoke directly to several members of the senior leadership team.
The review found there was a strong organisational focus on delivering services to meet people’s individual needs and feedback submitted through the provider’s online client satisfaction survey showed that 98% of respondents would recommend BPAS to someone who needed similar care.
Previous inspections of most BPAS locations had found that clinical, environmental, and operational risks were being identified and managed appropriately, but the well led review found there was no system to track risks across the organisation and no clear standard route by which local risks could be escalated to the executive team.
The organisation’s notification policy was confusing and did not reflect all the types of event or incident that CQC must be informed about. This information was contained in a separate document. As a result, it was not clear if all local BPAS managers were fully aware of their legal responsibility to submit statutory notifications to the regulator.
While processes were in place to monitor and manage the quality of care, they were not always effective. This had prompted some individual BPAS services to develop their own standard operating procedures, which led to local variation and made it harder for leaders to track organisation wide performance.
Incident reporting systems were complex and did not have sufficient clinical input to identify themes and trends or pinpoint learning to support improvements. There were also delays in investigating incidents and no formal central process for sharing learning and information across all BPAS services.
Leaders were aware of the importance of honesty and transparency following incidents and for staff to know they could speak up without fear of retribution. However, BPAS freedom to speak up guardians (FTSU) – members of staff appointed to provide independent and impartial support to colleagues in speaking up and raising concerns – were all senior members of the executive team. Inspectors also found that there was no FTSU provision in each individual service.
There was limited clinical oversight at a provider level and some leaders lacked awareness of how services were being delivered locally. There was minimal evidence that Board members were actively engaged in operational issues and able to provide independent challenge to organisational decisions.
Carolyn Jenkinson, Deputy Director of Secondary and Specialist Healthcare, said:
“We inspected a number of BPAS services last year as part of our planned and risk-based inspection programme. Those inspections found a number of examples of good practice, but in some cases, they also identified concerns. We’ve seen positive action in response by local services with steps being taken to act on CQC’s findings and address safety risks that were identified - and we continue to monitor this progress.
“However, that local action must now be supported by action at a corporate level to ensure that senior management and members of the Board have true oversight and that robust governance arrangements are in place.
“We shared our immediate feedback from the inspection with senior leaders and they are clear on the governance issues that need to be addressed. We remain in regular contact with BPAS and will monitor the quality and safety of services as they progress their improvement plans.”