Contracting, governance and risk in social prescribing
A range of contracting approaches can be used when developing social prescribing. They should be proportionate to the value and complexity of the services being provided. They may be:
- Grants with local voluntary services to initiate a local scheme. NHS England has developed a ‘Bitesize guide’ which includes practical advice on deciding if this is a good way forward (NHS England 2015).
- Short form of the NHS Standard Contract. Guidance and technical support are available and include advice on the workforce, liability and reporting issues commissioners and providers need to consider (NHS England 2016).
- “Lead”, “Prime” or “Alliance” contracting (using the NHS Standard Contract. LH Alliances Ltd 2014). Commissioners enter into a contract with a single lead provider or prime contractor who then sub-contracts specific roles and responsibilities to other providers and remains responsible to the commissioners for the delivery of the entire service.
National standards and requirements for all providers
- Duty of care applies to all staff and volunteers
- “You must aim to provide high-quality care to the best of your ability and say if there are many reasons why you may be unable to do so” (Unison 2013).
- Employers must provide all staff with clear roles and responsibilities, with appropriate training.
- Information governance
- NHS Digital provides a comprehensive range of advice and resources on confidentiality standards, legal requirements, and toolkits for NHS and partner organisations.
- The Information Commissioner’s Office also provides guidance on data protection, including self-assessment and advice for organisations holding personal data .
- Patient Safety
- The NHS Improvement “Sign Up to Safety” campaign is intended to support ‘locally led, self-directed safety improvement’ and their website provides resources and advice to assist organisations to achieve continuous improvement.
- The National Quality Board provides advice and resources, including their 2015 report on Improving Experiences of Care (NHS England 2015ii). This includes a shared understanding of what a good experience of care means, and why it matters, developed with a wide range of partners including NHS, patient and professional groups.
Governance and risk
- Governance arrangements will need to be relevant to the local model used for social prescribing. One area of concern may be the management of risk. There are risks associated with referring people on to resources beyond the NHS, where there may be less regulation and formal monitoring.
- There may be different levels of risk. For example, supported navigation based on a GP practice would place more risk on the practice than simply providing information and signposting.
- There is also a risk to the individual if they do not use a local resource which could help them manage their health better.
- Common sense should help commissioners, clinicians and others to understand and manage the balance of risks.
- An accountable body can be identified for clinical and information governance, which monitors and takes decisions to manage risk.
- Existing accountable partnership structures could be extended to include social prescribing.
- A new implementation group could be established with a range of relevant stakeholders to be the accountable body.
- Social prescribing is about people using a range of resources to help them manage their health. Many of those resources will be small and not have the knowledge or capacity to use NHS level clinical governance procedures. The local partnership agreement is therefore needed for how safety or other concerns will be managed. Some governance and risk issues will need the explicit reference in contracts/grant agreements, e.g. safeguarding and mental capacity. Others will be more variable and draw on a variety of experience of good practice.
- Commissioning options include
- the devolution of responsibility for governance to a Commissioned Lead Provider.
- the use of agreements between referrers and the places to which people are referred that all those who work there undergo e.g. safeguarding and other relevant training
- careful collection of feedback and evaluation from those who have used resources (sometimes referred to as a “Trip Advisor” model)
The Gloucestershire Voluntary & Community Sector Alliance has created with the CCG a “Kite Mark” for services to “indicate their credentials for taking part in this initiative” and requires completion of a questionnaire.