Primary Care Commissioning Committee 24 May 2017 Details Part 1 X Part 2 Agenda Item No. 6 Title of Paper: Board Member: Author: Presenter: Practice List Closure Procedure Dr Jeff Schryer, Clinical Lead (Primary Care) Rachele Schofield, Primary Care Manager Amy Lepiorz, Deputy Director of Primary Care Please indicate: For Decision X For Information For Discussion Executive Summary Summary Please note that it is the intention that this paper accompanies that submitted to the PCCC in October 2016 authored by Amy Lepiorz, Deputy Director of Primary Care & QIPP. Within that paper, the application process for list closure was explained and this second paper has been written to provide the Committee with the decision making tools to support that process. Risk High Medium X Low Recommendations Strategic themes Any increase in requests for or approvals of temporary suspension of patient registration is a symptom of rising pressure in primary care, which creates a risk to patients, neighbouring practices and the commissioner; however the risk to patients being registered with an oversubscribed practice should also be taken into account therefore, any requests for formal, informal or temporary list closures will be escalated to the PCCC for discussion and recommendation. The Primary Care Commissioning Committee are asked to support the process laid out in this paper, noting that any applications for practice list closures will be presented to the Primary Care Work Stream for discussion and a recommendation presented to the PCCC for approval. To deliver improved outcomes and reduce health inequalities for patients through better preventative strategies To deliver service re-design in priority areas through innovation To develop primary care to become excellent and high performing commissioners x To develop the CCG leadership to work with the Local Authority to be excellent integrated commissioners To develop robust and effective working relationships will all stakeholders and partners to drive integrated commissioning To deliver long term financial sustainability through effective commissioning and innovative investment across the wider system To develop and influence the provider landscape through development of a Locality Care Organisation (LCO) Equality Analysis Assessed? Supports NHS Bury CCG Governance arrangements x 24 May 2017 Practice List Closures Page 1 of 5
Practice List Closure Procedure 1 Background Please note that it is the intention that this paper accompanies that submitted to the PCCC in October 2016 authored by Amy Lepiorz, Deputy Director of Primary Care & QIPP. Within that paper, the NHS England application process for list closure was explained and this second paper has been written to provide a decision making tool to support that process. NHS England has produced Commissioner Guidelines for Responding to Requests from Practices to Temporarily Suspend Patient Registration (Formal and Temporary/Informal) and the CCG has produced the following local guidance based on the content of that document: https://www.england.nhs.uk/wp-content/uploads/2016/12/suspend-pat-reg-respns-guid.pdf 2 Introduction GMS and PMS contracts allow for Practices to request permission from the CCG to close their lists to new patients via a Formal List Closure. Practices may also approach the CCG to discuss an Informal / Temporary List Closure where the practice is experiencing short term issues which could impact on patient safety. It should be noted that an informal closure is not recognised under the GMS/PMS/APMS regulations/contract. The following paper will outline the procedure that member practices and Bury CCG are to follow should an application be made. 3 Formal List Closures GMS & PMS contracts stipulate the processes which must be followed in the event that a practice believes they need to close their register. Practices must request permission from the CCG to close their list to new patients, which may be done to allow practices a degree of workload control over the management of their services where there is: unusual and sustained demand from patients workforce or recruitment difficulties that affect a practices ability to provide services to an acceptable and safe standard During this time, Bury CCG will need to consider the: continued availability of primary care services for the resident population length of the closure and the conditions that would need to exist to trigger a re-opening of the list availability of alternative provision for new patients impact on neighbouring practices Bury CCG does not have the power to halt practices delivery of additional and/or enhanced services as a means to reduce practice workload thereby keeping the patient list open. When a practice does formally close its list, the requirement is to close between three and twelve months; not less than three months. An approved closure notice must specify what the time period is. 4 Informal / Temporary List Closure Practices can suffer unforeseen pressures which can reasonably be predicted to be short term problems. In these circumstances there may be a real or perceived risk to safe patient care by accepting more new patients onto the list and action to address this should be taken by the practice and received by the Primary Care Manager as a trigger for support and help. It should be noted that an informal/temporary list closure is not recognised contractually or by the CCG, and will only be considered where issues within the Practice are raising concerns around patient safety. The CCG cannot prescribe what length of time an approval of a temporary list suspension is appropriate as this will vary depending on the circumstances. The key words are unpredictable and/or short term and no longer than 3 months. Date: 24 May 2017 Practice List Closures Page 2 of 5
When the practice anticipates closure for longer than 3 months, they must submit an application for a formal list closure which will be processed in 21 days, unless the practice can articulate an immediate patient safety issue which needs to be resolved prior to this. 5 Risks Any increase in requests for or approvals of temporary suspension of patient registration is a symptom of rising pressure in primary care, which creates a risk to patients, neighbouring practices and the CCG; however the risk to patients being registered with an oversubscribed practice should also be taken into account therefore, any requests for formal, informal or temporary list closures will be escalated to the Deputy Director for Primary Care who will report at the next PCCC for discussion and recommendation, recognising that circumstances can rapidly change within practice. 6 Process to be adopted In all but exceptional circumstances, Practices should approach the Primary Care Manager in advance so that an action plan to minimise the impact on patients can implemented. Any request to temporarily suspend patient registration will be taken by the Primary Care Manager as a trigger for support. In some circumstances the action required to remedy a problem may take several months and in others just a few weeks e.g. a planned short term suspension of registration as part of a recovery plan through the vulnerable practice programme. Alternatively, practice capacity may be temporarily compromised by premises development or IT upgrades. Under these circumstances it would be usual to expect planning and communication with patients in advance with a specific start and end date and disruption measured in weeks not months. The process to follow upon receipt of a request to close a list, the Primary Care Manager will: seek to understand the reasons behind the action engage the LMC when an application is received facilitate what action needs to take place by the practice and/or by the Primary Care Manager for the list to be re-opened. The Primary Care Manger and the Practice will work through this process (seen as a flowchart in Table 1) to progress all requests to undertake either a Formal or Informal/Temporary List Closure. 7 Principles to be applied Applications to close a practice should not be approached lightly by either the Practice or the CCG. The final commissioning decision on whether lists are permitted to close lies with the CCG and, in order to ensure the CCG is robust in its decision making process regarding application process, the CCG will adhere to the Commissioning Principles laid out in the Primary Care Health & Wellbeing Strategy alongside the following subset of principles for list closures. The Primary Care Team s main priority is to ensure equitable access of services to all patients therefore, the CCG: Will only acknowledge, with appropriate evidence, informal list closures where a clear, immediate patient safety need has been identified and the CCG have been engaged as soon as possible Will work with Practices and the GP Federation to provide appropriate support to maintain an open list Will not routinely support applications for list closure but will treat each application individually Will only support list closures where there is a clear plan in place to reopen Will expect the practice to review all additional work and to have prioritised core contract The CCG will work with practices to communicate list closures to patients Date: 24 May 2017 Practice List Closures Page 3 of 5
The List Closure process will be reviewed as a minimum annually by the Primary Care Work Stream Group before being returned to PCCC for ratification 8 Recommendations The Primary Care Committee are asked to acknowledge that, where possible, any application to close a list will be presented to the Primary Care Work Stream for discussion and a recommendation presented to the PCCC for approval. However, where timescales do not allow for this as the Primary Care Manager must acknowledge receipt of an application to close a list within 7 days of receipt, notifying the Practice of the decision regarding closure within 21 days of receipt of the completed application template, then the Primary Care Manager and the Deputy Director of Primary Care will review the application and submit recommendations virtually to the voting members of PCCC. Rachele Schofield Primary Care Manager racheleschofield@nhs.net Date: 24 May 2017 Practice List Closures Page 4 of 5
Appendix 1 Practice Informs CCG of Intent to Close List / Application Submitted to Close List or to extend an Approved Closure Period Formal List Closure (>3 months) Informal / Temporary List Closure (<3 months) Primary Care Manager with appropriate managerial / clinical support to meet with Lead GP / PM to discuss reasons for application / temporary closure and offers support reopen / avoid closure Practice Continues / Submits Application for Formal List Closure Application Process by NHS England in line with National Policy Practice withdraws / do not pursue Application for Formal List Closure Primary Care Manager to provide any agreed support and matter closed. Practice closes list via the Informal / Temporary Route PCCC notified of the informal closure and to consider action in line with breach process and practice advised. If recognised, Primary Care Manager to work with Practice to produce a detailed Action Plan which will ensure the Practice list reopens at the end of its permitted closure period Progress to PCWG for recommendation Progress to PCCC for Ratification List Closure Approved List Closure Refused Practice advised of decision and Primary Care Manager to provide any support required NHS England to advise relevant bodies in line with Policy Primary Care Manager to work with Practice to produce a detailed Action Plan which will ensure the Practice list reopens at the end of its permitted closure period Date: 24 May 2017 Practice List Closures Page 5 of 5