Date ratified September Review Date September This Policy supersedes the following document which must now be destroyed:

Document Title Reference Number Lead Officer Author(s) (name and designation) Ratified by Overseas Visitors Charges Regulations Policy NTW(O)64 Lisa Quinn Executive Director of Performance and Assurance Lesley Willoughby Head of Income and Contracted Services Business Delivery Group Date ratified September 2015 Implementation Date October 2015 Date of full implementation January 2016 Review Date September 2018 Version number V01.1 Review and Amendment Log Version Type of Change Date V01 New Sep 15 V01.1 Update Oct 17 Description of Change New Policy updated due to change in DH Guidance Update due to clinical transition This Policy supersedes the following document which must now be destroyed: Document Number V01 Title Overseas Visitors Charges Regulations Policy

Overseas Visitors Charges Regulations Policy Section Contents Page No. 1 Introduction 1 2 Purpose 1 3 Duties, Accountability and Responsibilities 1 4 Definition of Terms Used 4 5 Procedure / Process 5 6 Identification of Stakeholders 9 7 Training 9 8 Implementation 9 9 Fair Blame 9 10 Fraud, Bribery and Corruption 10 11 Monitoring Compliance 10 12 Associated Documents 10 13 References 11 Standard Appendices attached to Policy A Equality Analysis Screening Toolkit 12 B Training Checklist and Training Needs Analysis 17 C Audit Monitoring Tool 19 D Policy Notification Record Sheet - click here Appendix 1 Pre Attendance Form Appendices listed separate to Policy Appendix 2 Overseas Visitors Charging Regulations Guidance

STATEMENT OF PURPOSE The new Policy has arisen due to the need to adhere to the National Health Service (Charges to Overseas Visitors) Regulations 2015. The Charging Regulations place a legal obligation on the Trust to establish whether a person is an overseas visitor to whom charges apply or whether they are exempt from charges by virtue of the Charging Regulations for the NHS services provided. When charges apply, the Trust must charge the person liable (usually the patient) for the costs of the NHS services and recover the cost from them.

1 Introduction 1.1 In April, 2015, guidance was updated on what should happen when a person who is not ordinarily resident in the UK needs NHS treatment provided by a hospital in England. Such a person will be subject to the National Health Service (Charges to Overseas Visitors) Regulations 2015. A person who is not ordinarily resident in the UK falls within the definition of an overseas visitor and may incur a charge for treatment. 1.2 A person does not become ordinarily resident in the UK simply by: having British nationality; holding a British passport; being registered with a GP; having an NHS number; owning property in the UK, or having paid (or currently paying) National Insurance contributions and taxes in this country. Whether a person is ordinarily resident is a question of fact, for which a number of factors are taken into account. 1.3 The Charging Regulations place a legal obligation on the Trust to establish whether a person is an overseas visitor to whom charges apply or whether they are exempt from charges by virtue of the Charging Regulations for the NHS services provided. When charges apply, the Trust must charge the person liable (usually the patient) for the costs of the NHS services and recover the cost from them. 1.4 Significant changes have been made to the exemption categories by these Charging Regulations. An exemption for temporary migrants coming to the UK for six months or more from outside the EEA / Switzerland has been introduced. They are required to pay the immigration health charge (referred to as the health surcharge), are exempt, or payment is waived. Payment of, or exemption or waiver from the health surcharge entitles the person to free NHS services on the same basis as an ordinarily resident patient while their visa remains valid, which means they must not be charged. 1.5 The full guidance can be found at: Guidance on overseas visitors hospital charging regulations - Publications - GOV.UK 2 Purpose 2.1 The aim of this Policy is to ensure all clinical and administrative staff who deal with patient admissions are aware of the guidance on implementing the overseas visitors hospital charging regulations and the need to identify overseas visitors. 1

3 Duties, Accountability and Responsibilities 3.1 The guidance suggests that a designated person should be identified to oversee the implementation of the charging regulations, describing the role as the Overseas Visitor Manager (OVM). This is currently the Head of Income and Contracted Services. 3.2 The Overseas Visitor Manager s role is to see that the Charging Regulations are applied in practice, so that those overseas visitors who are lawfully entitled to free treatment receive it without charge, and that those who are not exempt from charges are charged. 3.3 It is therefore important to identify patients who are not ordinarily resident in the UK and then determine if they are exempt from charges or not under the Charging Regulations. 3.4 Where a patient is identified as chargeable and claims s/he cannot pay, an OVM should then assess when the patient can be reasonably expected to return home and inform the clinician of this, so that the clinician can then consider if and what treatment can wait. 3.5 OVMs should ensure that: Payment is received in advance of providing urgent treatment, wherever possible, and in advance of providing non-urgent treatment in all cases; and Any debts incurred following the provision of immediately necessary treatment or urgent treatment (when advance payment was not obtained) are recovered, wherever possible. 3.5.1 OVMs and other non-clinical staff must not make decisions on urgency of treatment or deny any patient access to a clinician. 3.6 There will be some cases where treatment is required before entitlement is checked. Treatment should not be delayed if a clinician decides that the treatment is urgent or necessary but if it is suspected that the patient is an overseas visitor they should be informed that they may have to pay for treatment. However, the Trust must also ensure that treatment which is immediately necessary is provided to any patient, even if they have not paid in advance. Failure to provide immediately necessary treatment may be unlawful under the Human Rights Act 1998. Urgent treatment should also be provided to any patient, even if deposits have not been secured. Non-urgent treatment should not be provided unless the estimated full charge is received in advance of treatment. 3.7 What is immediately necessary, urgent and non-urgent treatment? 3.7.1 Only clinicians can make an assessment as to whether a patient s need for treatment is immediately necessary, urgent or non-urgent. 2

In order to do this they may first need to make initial assessments based on the patient s symptoms and other factors, and conduct further investigations to make a diagnosis. These assessments and investigations will be included in any charge. 3.7.2 Immediately necessary treatment is that which a patient needs: To save their life, or To prevent a condition from becoming immediately lifethreatening, or Promptly to prevent permanent serious damage from occurring. 3.7.3 The Trust must always provide treatment which is classed as immediately necessary by the treating clinician irrespective of whether or not the patient has been informed of, or agreed to pay, charges, and it must not be delayed or withheld to establish the patient s chargeable status or seek payment. 3.7.4 Urgent treatment is that which clinicians do not consider immediately necessary, but which nevertheless cannot wait until the person can be reasonably expected to return home. 3.7.5 Clinicians may base their decision on a range of factors, including the pain or disability a particular condition is causing, the risk that delay might mean a more involved or expensive medical intervention being required, or the likelihood of a substantial and potentially life threatening deterioration occurring in the patient s condition if treatment is delayed until they return to their own country. 3.7.6 For urgent treatment, every effort must be made, given the individual s circumstances, to secure payment in the time before treatment is scheduled. 3.7.7 However, if that proves unsuccessful, the treatment should not be delayed or withheld for the purposes of securing payment. Treatment is not made free of charge by virtue of being provided on an immediately necessary or urgent basis. Charges found to apply cannot be waived. 3.7.8 Non-urgent treatment is planned treatment that could wait until the patient can return home. The Trust does not have to provide non-urgent treatment if the patient does not pay in advance and should not do so until the estimated full cost of treatment has been received. 3.7.9 The decision on whether a patient s need for treatment is immediately necessary, urgent or non-urgent is only for clinicians to make. 3

However, in determining whether or not a required course of treatment should proceed even if payment is not obtained in advance, or if it can safely wait until the patient can return home (i.e. whether it is urgent or non-urgent), clinicians will need to know their estimated return date. 3.8 Where it is established that a patient is not ordinarily resident in the UK: The patient should be told immediately, where possible and appropriate, that they will need to be interviewed to establish their eligibility for free NHS hospital treatment; The person who identifies the patient as potentially liable should contact the Overseas Visitors Team immediately and arrange for an interview to take place. Wherever possible, that interview should take place before treatment begins, but if, in the opinion of medical staff, the treatment is needed urgently it should always go ahead without delay; 3.9 It is not intended that staff completing administration forms should do anything other than ask the baseline questions and alert the Overseas Visitors Team if necessary. There is no need and no question of staff at this stage asking supplementary questions or carrying out detailed investigations themselves unless they have been trained to do so by the Overseas Visitors Team. 3.10 It is the clinician s role to provide appropriate care for their patients and to make decisions on their treatment based on their clinical needs. As part of their normal practice, for ordinarily resident patients and chargeable overseas visitors alike, clinicians have an obligation to consider the costs associated with different treatment options and to balance these against the potential for a successful outcome. It is right that clinicians are aware of the cost implications of providing non-urgent treatment to chargeable overseas visitors who cannot or will not pay when that treatment could wait until they return home. 3.11 Clinicians are not expected to make judgements regarding the eligibility of patients to free NHS hospital treatment, but if it is the clinician who first becomes aware that a person may not be ordinarily resident in the UK, they should notify the OVM and can, if appropriate, inform the patient that charges might apply. Clinicians and other staff should not indicate to patients that treatment will be free unless and until this is established, as a charge may have to be levied if the OVM subsequently assesses them as chargeable. 3.12 Ultimately, it is always a clinician s decision on what treatment is needed. Whether the treatment is withheld or limited will depend on information received from OVMs on when the patient can return home (so that the clinician can decide if the treatment is urgent or non-urgent) and on the patient s intentions on paying (so that non urgent treatment does not commence without prior payment). 4

3.13 Those staff having first contact with the patient should ask the baseline questions, record responses on RiO and alert the OVM if necessary. Administrative staff or ward staff may need to assist in requesting evidence / proof of eligibility from the overseas visitor. 4 Definition of Terms Used 4.1 An explanation of frequently used abbreviations within the Policy can be found on page 2 of the Guidance on implementing the overseas visitors hospital charging regulations as referred to above. 5 Procedure / Process 5.1 Identifying patients who may be liable for charges 5.1.1 When a patient is seen for the first time, verification should be sought to identify overseas visitors and the relevant field completed in RiO. 5.1.2 To avoid discrimination all patients recorded in RiO should be asked the baseline questions: Are you a British citizen, European Economic Area (EEA) national or Swiss national? If yes: Do you have an EHIC / PRC / S2? If yes, take details. The UK can recover the cost of their healthcare (including A&E Services). If no, where have you lived for the past six months? (Those who have lived in the UK for the past six months are likely to be ordinarily resident here; all others should be referred to the OVM). If no (i.e. the person is a non-eea national), do you have indefinite leave to remain in the UK? If yes, where have you lived for the past six months? (Non- EEA nationals with indefinite leave to remain who have lived in the UK for the past six months are likely to be ordinarily resident here; others should be referred to the OVM). If no, do you have a valid visa or leave to enter / remain in the UK? If yes, have you paid the health surcharge or are you exempt or waived from paying it? (If yes, then they are exempt from charges; if no, then refer them to the OVM). If no, then refer them to the OVM. 5

5.3 Responses to these questions will enable the field in RiO (see screenshot below) to be completed to record either that the patient is ordinarily resident (NHS Patient) or that there is some doubt by choosing the option of overseas visitor. In all cases where there is doubt the Overseas Visitors Team should be informed. This can be done via email on IncomeTeam@ntw.nhs.uk. The questioner should inform the patient that he or she may be further interviewed. 5.4 A new picklist option of Overseas Visitor has been added into the Administrative Category field on the Referral and Admission screen in RiO. A screenshot is below. 5.5 To minimise delays and possible problems when booking in, the use of a pre-attendance form that could be included with all outpatient and inpatient appointment letters is recommended, but not mandatory. This form should explain that patients should be prepared to provide certain pieces of evidence and should have a declaration for the patient to sign in which it is clear why the questions are being asked and what use may be made of the data. Checking will then be a relatively quick and simple matter that need not add more than a few seconds to the booking in process. An example of such a form is at Appendix 1. This is available on the Trust intranet to be used by admissions staff. 5.6 Where a person is claiming exemption from charges it is their responsibility to prove they are entitled to that treatment without charge. 5.7 In some departments, catering for very elderly or mentally confused patients, or when direct admission from critical care is needed, the baseline questioning may be inappropriate or unworkable. In these cases admissions staff should still be aware of the possibility of patients being chargeable and should notify the Overseas Visitors Team of any patient who, on any non-discriminatory information they have, may be an overseas visitor. 6

5.8 Due to the potential complexity within MH Services and the impact of MHA, Appendix 2 contains some example scenarios relating to potential overseas visitors and which regulation from the Guidance may be relevant. This is not an exhaustive list. 5.9 Any queries on identifying overseas visitors should be sent to the Income team Incometeam@ntw.nhs.uk 5.10 The Income Team will receive a monthly report from RiO identifying overseas visitors. 5.11 Following the Guidance (Chapter 13 - Financial Matters) and the Trust s Debt Recovery Procedures all appropriate charges will be made. 6 Identification of Stakeholders 6.1 The consultation of this Policy has been carried out in line with Section 7 within the Trust s Policy, NTW(O)01 Development and Management of Procedural Documents. 6.2 This Policy follows the criteria set out in NTW(O)01 Development and Management of Procedural Documents, this Policy was circulated Trustwide for a four week consultation to the standard distribution listed below: North Locality Care Group Central Locality Care Group South Locality Care Group Corporate Decision Team Business Delivery Group Safer Care Group Communications, Finance, IM&T Commissioning and Quality Assurance Workforce and Organisational Development NTW Solutions Local Negotiating Committee Medical Directorate Staff Side Internal Audit 7

7 Training 7.1 All staff should be made aware of the Policy. Those staff involved in the assessment and admission of patients into NTW should be given appropriate training to enable completion of the RiO fields. Further details on training requirements can be found in Appendix B. 8 Implementation 8.1 The Policy will be implemented through raising staff awareness via the Trust Policy Bulletin and RiO Training. Once notified of potential overseas visitors the Income Team will follow the guidance to ensure all relevant debt is charged for and recovered. 9 Fair Blame 9.1 The Trust is committed to developing an open learning culture. It has endorsed the view that, wherever possible, disciplinary action will not be taken against members of staff who report near misses and adverse incidents, although there may be clearly defined occasions where disciplinary action will be taken. 10 Fraud, Bribery and Corruption 10.1 NHS Protect has national responsibility to lead work on protecting NHS staff and resources from crime. It has responsibility for tackling fraud, bribery, corruption, criminal damage, theft and other unlawful action such as market-fixing. 10.2 When there is a suspicion that an overseas visitor is attempting to access, or has accessed, free NHS treatment by fraud or deception, this should be reported to the relevant NHS body's Local Counter Fraud Specialist (LCFS), the NHS Fraud and Corruption Reporting Line on 0800 028 40 60 or online at www.reportnhsfraud.nhs.uk. The LCFS and / or NHS Protect will undertake a professional investigation and seek to apply criminal and civil sanctions, where appropriate. 8

11 Monitoring Compliance 11.1 The Policy will be monitored for compliance by: Reporting overseas visitors to the Income and Contracted Services Team on an exception basis; Establishing of those identified as overseas visitors how many are charged for treatment; Establishing of those identified as overseas visitors how many are exempt from treatment; Establishing the value of income from overseas visitors within the financial year; Establishing the value of outstanding debt for overseas visitors within the financial year; Establishing the value of outstanding debt for overseas visitors that is written off within the financial year. 11.2 See Appendix C for further details. 12 Associated Documents NTW(O)01 Development and Management of Procedural Documents 13 References Department of Health Guidance Implementing the overseas visitors hospital charging regulations. Published 1st October, 2012, updated 31st October, 2013 9

Appendix A Equality Analysis Screening Toolkit Names of Individuals involved in Review Date of Initial Screening Review Date Christopher Rowlands September 2013 September 2016 Service Area /Locality Policy to be analysed Is this policy new or existing? NTW(O)64 Overseas Visitors Charges New Regulations What are the intended outcomes of this work? Include outline of objectives and function aims The Charging Regulations provide for the making and recovery of charges for services provided to persons not ordinarily resident in the UK, using powers set out in section 175 of the NHS Act 2006. They place the legal obligation on relevant NHS bodies (those providing NHS hospital treatment) to make and recover charges for NHS treatment that they provide, and in doing so to: Ensure that patients not ordinarily resident in the UK are identified; Assess liability for charges in accordance with the Charging Regulations; Charge those liable to pay; and Recover the charge from those liable to pay. The regulations specify that charges may only be made for services provided at a hospital or by staff employed to work at or under the direction of a hospital. The Charging Regulations define an overseas visitor as anyone not ordinarily resident in the UK. Ordinarily resident is not defined in either the Charging Regulations or the NHS Act. It takes its meaning from case law and applies to a person who is: living lawfully in the United Kingdom voluntarily and for settled purposes as part of the regular order of their life for the time being with an identifiable purpose for their residence here that has a sufficient degree of continuity to be properly described as settled. Other than resident status within other identified groups, none of the equality groups are excluded from potentially being considered ordinarily resident here. Migrants will be ordinarily resident in the UK if they are here on a lawful, voluntary and settled basis for the time being. A person is not excluded from becoming ordinarily resident here because of their nationality as long as they have, or have been given, a legal right to be in the UK. The Charging Regulations do not deny anyone access to NHS services, only to apply charges to nonresidents for those services, unless an exemption from charge category applies to them. Some services are exempt from charge to all overseas visitors, including treatment provided inside an Accident and Emergency Department, treatment for certain infectious and / or sexually transmitted diseases, family planning services and compulsory psychiatric treatment. Further, the Guidance advises that, unless the treatment a person needs is clinically considered non- 10

urgent, it should be provided to them without delay, even if they have not paid in advance. Chapter 4 of the Guidance has been significantly redrafted to make this point clear after consultation with interested parties followed by a full public consultation. Who will be affected? e.g. staff, service users, carers, wider public etc Service Users Protected Characteristics under the Equality Act 2010. The following characteristics have protection under the Act and therefore require further analysis of the potential impact that the policy may have upon them Disability Sex Men and women are treated equally within the Charging Regulations. Both sexes are capable of benefiting from any of the exemption categories. However, the DH advises that for maternity care, which obviously only women receive, it should be treated without exception as immediately necessary, meaning that it must always be provided regardless of if charges have been paid or are likely to be recovered. The Guidance does not advise that any other services, that men could benefit from, should similarly be considered automatically as immediately necessary. This is justified by the significant risks to both mother and baby if health goes unchecked, and the fact that, at least for delivery, it inevitably cannot be delayed. Race Age A person of any race is able to benefit from the exemption from charge categories within the Charging Regulations. However, there is anecdotal evidence that non-white people or people for whom English is not their first language are, on some occasions, targeted in the application of the Charging Regulations due to speculation or assumption that they are not resident here. This is clearly unacceptable and longstanding guidance to the NHS has advised that each patient must be treated the same in assessing for charges. In order to tackle this discrimination, the updated Guidance has been reiterated and strengthened in a section titled Avoiding discrimination in establishing if charges apply. It now points out NHS bodies legal equality duties and advises that staff involved in assessing for charges are trained in how to exercise those duties. Those in receipt of UK state retirement pensions can benefit from certain exemptions that younger people cannot. This is no different from other welfare benefits eg pension payments itself, tax rules etc. Some of the exemption from charge categories are dependant on a person s age. The children of exempt overseas visitors are also exempt in certain circumstances, since it would be unreasonable to expect them be apart from their parent, whilst children in the care of the Local Authority are also exempt since they are clearly vulnerable. When a child is not entitled to free NHS hospital treatment, the person liable is their parent or guardian. Some of the exemption from charge categories are dependant on a person s age. The children of exempt overseas visitors are also exempt in certain circumstances, since it would be unreasonable to expect them be apart from their parent, whilst children in the care of the Local 11

Gender reassignment (including transgender) Sexual orientation. Religion or belief Marriage and Civil Partnership Pregnancy and maternity Authority are also exempt since they are clearly vulnerable. When a child is not entitled to free NHS hospital treatment, the person liable is their parent or guardian. Transgender and transsexual people are able to benefit from any of the exemption from charge categories Heterosexual, bisexual, lesbian and gay people are able to benefit from any of the exemption from charge categories With the exception of the exemption for Missionaries, which would not apply to those of no belief, a person of any religion or belief is able to benefit from the other exemption categories. However, as for race, there is anecdotal evidence that people whose religion can be assumed by their appearance are, on some occasions, targeted in the application of the Charging Regulations due to speculation or assumption that they are not resident here. Again, this is unacceptable. See associated objectives of the Policy or Service. Men and women are treated equally within the Charging Regulations. Both sexes are capable of benefiting from any of the exemption categories. However, the DH advises that for maternity care, which obviously only women receive, it should be treated without exception as immediately necessary, meaning that it must always be provided regardless of if charges have been paid or are likely to be recovered. The Guidance does not advise that any other services, that men could benefit from, should similarly be considered automatically as immediately necessary. This is justified by the significant risks to both mother and baby if health goes unchecked, and the fact that, at least for delivery, it inevitably cannot be delayed. Carers Other identified groups Carers are able to benefit from the exemption from charge categories. Resident Status: Resident status is relevant when establishing if a person is entitled to free treatment by being ordinarily resident here, or by being exempt from charge under some of the exemption categories within the Charging Regulations, e.g., twelve months lawful residence. Migrants will be ordinarily resident in the UK if they are here on a lawful, voluntary and settled basis for the time being. However, those who are not lawfully here or those who do not live on a settled basis here will be chargeable for their treatment. The NHS is only automatically free to the people of England. Income: Only one exemption differentiates between those with and without resources Regulation 23(c) exempts those people from certain countries that are without resources, based on a historical international treaty. 12

Those who are chargeable, but are on a low income, might find it more difficult than those on a higher income to pay their bill. The Guidance advises the NHS to consider accepting payment by instalments where possible, and in cases when the patient is without resources, the NHS body reserves the right to write off the debt. No one will be refused urgent or immediately necessary treatment because they cannot pay. How have you engaged stakeholders in gathering evidence or testing the evidence available? Through Policy making process How have you engaged stakeholders in testing the policy or programme proposals? Through Policy making and review process For each engagement activity, please state who was involved, how and when they were engaged, and the key outputs: Stakeholders in the Policy review process Summary of Analysis Considering the evidence and engagement activity you listed above, please summarise the impact of your work. Consider whether the evidence shows potential for differential impact, if so state whether adverse or positive and for which groups. How you will mitigate any negative impacts. How you will include certain protected groups in services or expand their participation in public life. There are some differences within the Charging Regulations for some of the protected groups within the overseas visitor population. For the most part these are minor and are justifiable based on international obligations or safeguarding welfare. The greatest differential is probably based on residence status, but this is inherent in a residency based healthcare system of entitlement. In the application of the Charging Regulations, the greatest risk of inadvertently effecting people adversely within the ordinarily resident population lies with the protected characteristic groups of race and religion / belief. The Guidance issued to the NHS aims to prevent this from occurring by stressing their equality duties in the operation of their functions. The Guidance has been significantly strengthened in this manner. Need to ensure that all staff involved with the identification and interviewing of potentially liable patients should be properly advised of their role and provided with adequate training on how to exercise the general equality duty. We should monitor how the charging regulations are implemented in practice to ensure adherence to DH Guidelines. Now consider and detail below how the proposals impact on elimination of discrimination, harassment and victimisation, advance the equality of opportunity and promote good relations between groups. Where there is evidence, address each protected characteristic Eliminate discrimination, harassment and victimisation Advance equality of opportunity Promote good relations between groups N / A N / A See commentary 13

What is the overall impact? Addressing the impact on equalities See commentary See commentary From the outcome of this Screening, have negative impacts been identified for any protected characteristics as defined by the Equality Act 2010? NO If yes, has a Full Impact Assessment been recommended? If not, why not? Manager s signature: Chris Rowlands Date: September 2013 14

Communication and Training Check list for policies Appendix B Key Questions for the accountable committees designing, reviewing or agreeing a new Trust policy Is this a new policy with new training requirements or a change to an existing policy? New Policy If it is a change to an existing policy are there changes to the existing model of training delivery? If yes specify below. Are the awareness/training needs required to deliver the changes by law, national or local standards or best practice? Please give specific evidence that identifies the training need, e.g. National Guidance, CQC, NHS Resolutions etc. Please identify the risks if training does not occur. National Guidance There is a risk that income from overseas visitors who are not exempt from charges for NHS treatment is not recovered. It is a legal obligation for NHS bodies to establish whether overseas visitors are liable for charges and recover debts due. Please specify which staff groups need to undertake this awareness/training. Please be specific. It may well be the case that certain groups will require different levels e.g. staff group A requires awareness and staff group B requires training. Is there a staff group that should be prioritised for this training / awareness? Please outline how the training will be delivered. Include who will deliver it and by what method. The following may be useful to consider: Team brief/e bulletin of summary Management cascade Newsletter/leaflets/payslip attachment Focus groups for those concerned Local Induction Training Awareness sessions for those affected by the new policy Local demonstrations of techniques/equipment with reference documentation Staff Handbook Summary for easy reference Taught Session E Learning Please identify a link person who will liaise with the training department to arrange details for the Trust Training Prospectus, Administration needs All staff to be aware of guidance Clinical and administrative staff dealing with admissions to be aware of guidance and undertake RiO training for completion of field in RiO Adhoc training to be given as and when required on detail of guidance. Clinicians and admin staff dealing with admissions Staff Awareness Team Brief / CE Bulletin / Trust Policy bulletin Clinical / Admissions admin staff additional RiO training for existing staff / include in initial RiO training for all new staff on how to complete RiO field. Team/individual / case basis advice/training given on the details of the Guidance by Head of Commissioning (OVM) as and when required Lesley Willoughby Head of Income and Contracted Services 15

Appendix B continued Training Needs Analysis Staff/Professional Group Type of Training Duration of Training Frequency of Training Clinical / Admissions Admin RiO input One off Clinical / Admissions Admin Guidance awareness As required on an individual / team / case basis Copy of completed form to be sent to: Training and Development Department, St. Nicholas Hospital Should any advice be required, please contact: 0191 245 6777 (internal 56777- Option 1) 16

Monitoring Tool Appendix C Statement The Trust is working towards effective clinical governance and governance systems. To demonstrate effective care delivery and compliance, Policy authors are required to include how monitoring of this Policy is linked to auditable standards / key performance indicators will be undertaken using this framework. Overseas Visitors Charges Regulations Policy - Monitoring Framework Auditable Standard / Key Performance Indicators Frequency / Method / Person Responsible Where Results and Any Associate Action Plan Will Be Reported To Implemented and Monitored; (this will usually be via the relevant Governance Group). 1. Reporting overseas visitors to the Income and Contracted Services Team on an exception basis Monthly Report produced by the Informatics Team Finance, Infrastructure and Business Development Committee (FIBD) 2. Establishing of those identified as overseas visitors how many are charged for treatment Quarterly Report produced by the Head of Income and Contracted Services Finance, Infrastructure and Business Development Committee (FIBD) 3. Establishing of those identified as overseas visitors how many are exempt from treatment. Quarterly Report produced by the Head of Income and Contracted Services Finance, Infrastructure and Business Development Committee (FIBD) 4. Establishing the value of income from overseas visitors within the financial year Quarterly Report produced by the Head of Income and Contracted Services Finance, Infrastructure and Business Development Committee (FIBD) 17

5. Establishing the value of outstanding debt for overseas visitors within the financial year. Quarterly Report Head of Income and Contracted Services Finance, Infrastructure and Business Development Committee (FIBD) 6. Establishing the value of outstanding debt for overseas visitors that is written off within the financial year. Quarterly Report Head of Income and Contracted Services Finance, Infrastructure and Business Development Committee (FIBD) The Author(s) of each Policy is required to complete this monitoring template and ensure that these results are taken to the appropriate Quality and Performance Governance Group in line with the frequency set out. 18