Board Assurance Framework

Board Assurance Framework Document information Version Version 3.0 Reported to To be reported to Newham CCG Board meeting 09.09.2013 Next review October 2013 Author Luke Moore Governance and Manager Chair: Dr Zuhair Zarifa Accountable Officer: Steve Gilvin 1

Contents 2. Purpose and Scope... 3 2.1 Board Assurance Framework... 3 2.2 Management Governance... 3 2.3... 4 2.4 Identifiers... 4 3. Board Assurance Framework... 5 3.1 profile... 5 3.2 Area 1- To reduce health inequalities, improve access and reduce variation... 6 3.3 Area 2 - To develop Integrated Care, in particular to support improved management of long term conditions... 12 3.4 Area 3 - To ensure robust patient and public engagement is embedded in the operations of Newham CCG and at all stages of the commissioning cycle... 13 3.5 Area 4 -To ensure that Newham CCG achieves robust financial stability and balance to supporting effective working and implementation of our plans... 14 3.6 Area 5 - To support quality improvements in primary care services to ensure they are fit for purpose and able to support the shift in care out of hospital... 18 3.7 Area 6 - To ensure that Newham CCG has transparent and effective corporate and clinical governance arrangements in place to comply with relevant legislation and mitigate the risk of non-delivery of strategic objectives... 23 4. How to interpret the Newham CCG BAF... 26 4.1 profile... 26 4.2 Full BAF risk entries... 27 5. Newham CCG Grading Matrix... 28 2

2. Purpose and Scope 2.1 Board Assurance Framework The primary purpose of the Newham CCG Board Assurance Framework (BAF) is to: 1) Act as a mechanism for alerting and appraising the Board of the main risks to achieving to the CCG in terms of achieving strategic objectives as set out in the Operating Plan 2) List, evaluate and provide assurance to the Board regarding the mitigations in place to the reduce the likelihood or impact of the risk 3) Summarise to the Board the remedial or proposed actions that further mitigate the likelihood or impact of the risk The BAF is also an important document for providing external assurance (to NHS England, Internal Audit and patients and public) that the CCG is sighted on its risks and has a robust system of internal control. A guide to interpreting individual BAF entries is shown at 4. How to interpret the Newham CCG BAF The risk scoring matrix to establish initial risk ratings is shown at 5. Newham CCG Grading Matrix 2.2 Management Governance Management is embedded in Newham CCG s Governance Structure:- The Audit Committee is responsible for scrutinising the group s Management policies and procedures. Accountable to the group s Board, the Committee provides the Board with an independent and objective view of the group s financial systems, financial information and compliance with laws, regulations and directions governing the group in so far as they relate to finance. The Executive Committee is responsible for approving internal control arrangements, risk sharing and pooling agreements. The Chief Officer is responsible for approving the group s arrangements for business continuity and emergency planning. The Chief Finance Officer is responsible for approving the group s Counter Fraud, Security Management and Management arrangements. The Governing Board is responsible for approving and monitoring the Board Assurance Framework. 3

2.3 BAF risks have been categorised into six main risk areas. Five of these risks areas link to the core strategic objectives of Newham CCG, as outlined in the Newham CCG Operating Plan. These are: 1. To reduce health inequalities, improve access and reduce quality variation 2. To develop Integrated Care, in particular to support improved management of long term conditions 3. To ensure robust patient and public engagement is embedded in the operations of Newham CCG and at all stages of the commissioning cycle 4. To ensure that Newham CCG achieves robust financial stability and balance to supporting effective working and implementation of our plans 5. To support quality improvements in primary care services to ensure they are fit for purpose and able to support the shift in care out of hospital The Board has taken the view to include a sixth risk area to highlight the importance of establishing and maintaining good governance practices to enable the CCG to effectively deliver against its core strategic objectives: 6. To ensure that Newham CCG has transparent and effective corporate and clinical governance arrangements in place to comply with relevant legislation and mitigate the risk of non-delivery of strategic objectives It is recognised that a number of BAF risks will be linked to one or more of the above risk areas. This will be noted where applicable on the risk profile template (section 3.1). 2.4 Identifiers Each BAF risk will be assigned a unique risk identifier (number). This will be based upon the primary area of risk identified from the five designed risk areas and subsequently the order in which the risk is added to the BAF. For example, the first risk added to the BAF with a primary risk area of category 1 (to reduce health inequalities etc.) would be assigned a risk identifier of 1.1. 4

3. Board Assurance Framework 3.1 profile Identifier s last reviewed: September to October 2013 (for October 2013 update to Newham CCG Board) to Summary Owner rating (April 2013) October 2013 forecast 1.1 1,2,4,5 Failure to deliver QIPP Plans within target Scott Hamilton 15 12 8 4 1.2 1,2,4,5 Failure to develop future QIPP plans appropriate to the evolving needs of the CCG in a timely and robust manner Trend End of Year Difference between target and forecast Scott Hamilton 12 12 8 4 1.3 1,2 CSU ability to deliver on contracted services due to capability / capacity. Scott Hamilton 20 10 5 5 1.4 1 Quality of Commissioned Services at Barts Health Chetan Vyas 15 15 5 10 1.5 1,2 Failure to establish and/or maintain effective enagement and collaborative working arrangements with the Local Authority Satbinder Sanghera 9 9 3 6 1.6 1,2,4,5,6 Failure to recruit develop and retain key staff Steve Gilvin 20 9 6 3 2.1 1,2 3.1 1,2,3 4.1 4 Failing to develop models of integrated care and robust cost and savings assumptions to support the shift to care out of hospital Scott Hamilton 15 15 10 5 Failing to embed meaningful patient and public engagement at all levels of the CCG Satbinder Sanghera 10 10 10 0 Monitoring and planning for the possible impact to CCG from Barts Health financial Chad Whitton performance 20 15 10 5 4.2 4 Failure to monitor performance and activity at Barts Health Chad Whitton 15 15 10 5 4.3 4 Financial management of the CCG Chad Whitton 16 8 4 4 4.4 4 Transfer of a proportion of the specialised commissioning budget from NCCG to NHS England Scott Hamilton 20 15 10 5 5.1 5 Failing to build appropriate capacity and support for Primary Care Jane Lindo 12 12 4 8 5.2 5,6 Staff skills and competencies within the CCG Chetan Vyas 16 12 4 8 5.3 5,6 Board skills and competencies within NCCG Chetan Vyas 12 12 8 4 5.4 4,5 5.5 5 Failure to develop practices as the "power house" of commissioning through development of Clusters as Commissioners Failing to develop new and functional Extended Primary Care Providers/Shared Services Providers Margaret Chirgwin 12 12 8 4 Margaret Chirgwin 12 12 8 4 6.1 6 CCG has outstanding conditions for authorisation Satbinder Sanghera 12 1 1 0 6.2 6 NCCG is underpreared for its role in emergency planning procedures Satbinder Sanghera 12 8 2 6 6.3 6 Information Governance arrangements for NCCG are in an undeveloped state. Satbinder Sanghera 15 9 3 6 5

Severe (5) x Possible (3) = High (15) Major (4) x Possible (3) = Medium (12) Major (4) x Unlikely (2) = Medium (8) 3.2 Area 1- To reduce health inequalities, improve access and reduce variation 1.1. Failure to deliver QIPP Plans within target to 1.1 1,2,4,5 Lead Director of Delivery (Scott Hamilton) Description Failure to deliver QIPP plans could result in: - A reduced ability to deliver local service improvements for patients (this year and beyond) - An increase in the likelihood of performance management measures from NHS England - Adverse media coverage - Failure to meet national QIPP financial targets and a deterioration in the CCG financial position which impact the CCG's ability to implement service redesign and invest to save initiatives to support improvements in commissioned care and the shift in care out of hospital Programme Boards (*Commissioning Committees from Aug 2013) have responsibility for managing/monitoring QIPP schemes with oversight from Quality and Delivery PG and Executive Committee - QIPP trackers developed for each initiative to monitor progress against objective - led by Carl Edmonds for CSU and Scott Hamilton for CCG - QIPP trackers are reported to NCCG Quality Committee and fed back to CCG Board as part of Activity and Finance report - QIPP trackers also scrutinised at NCCG Executive with input from QIPP leads to report on mitigations to keep trackers on target - Senior management meeting between CCG and CSU relating to finance activity and performance - Terms of reference, agendas, minutes of Commissioning Committee meetings, Q&D PB and CCG Executive Committee (for oversight) demonstrate CCG focus on delivery - Service level agreement between NCCG and NEL CSU demonstrates CSU support in development and monitoring of QIPP initiatives - management leads are in post working with CSU teams (e.g. Borough Team and Health Intelligence) to ensure delivery within financial envelope. - McKinsey Consulting were commissioned by NHS England to undertake a review and report on the robustness of NCCG QIPP Plans and identify scope for further initiatives and savings. No formal process (i.e. threshold) in place for exception reporting to Board as trackers are reviewed in the context of individuals schemes (it is expected that this would be picked up through Quality / Executive Committees and reported to Board via special discussion paper as and when required) - NHS England sign-off of CCG QIPP initiatives by March 2013 - QIPP tracker regularly reviewed by SMT - Prepare and submit detailed QIPP plans with a focus on low level implementation for 2013/14/15/16. - Revise QIPP plans to ensure they contain high level strategic intentions and delivery plans until 2014-15 - Focus on stakeholder and PPE strategy to ensure patients and public are effectively engaged in the detail of QIPP initiatives - Revise QIPP plans to ensure they contain high level strategic intentions and delivery plans until 2014/15 - CCG Governance revised to enable broader oversight of QIPP initiatives - * Review completed and revised CCG Governance structure in place from August 2013 6

Severe (5) x Possible (3) = High (15) Major (4) x Possible (3) = Medium (12) Major (4) x Unlikely (2) = Medium (8) 1.2 Failure to develop future QIPP plans appropriate to the evolving needs of the CCG in a timely and robust manner to Lead Description 1.2 1,2,4,5 Director of Delivery (Scott Hamilton) Failing to develop future QIPP plans in a timely and/or robust manner could result in: - Failure to reach savings targets due to inaccuracies in underlying savings assumptions - Reputational damage to CCG - The possibility of performance measures - 13/14 QIPP process fully mapped with QIPP identified, Lead Senior Officers appointed, risk assessed plans and KPIs, and summarised in trackers. - Trackers updated and reviewed monthly at H6Executive Committee. - Outcomes and QIPP progress reported monthly to Board. - Quarterly QIPP review meetings with input form CCG QIPP leads, finance and CSU to look in-depth at in-year delivery of QIPP to date, forward assessment for 2014/15 with assessment of need to carry over QIPP plans + gap identification for additional savings requirements (Outputs form QIPP review meetings to be cascaded through CCG Practice Member Council and clusters in parallel with 14/15 commissioning round Monthly update and review of trackers inc financial and KPI delivery. Monthly review by Executive Committee. Monthly update in A&F report to Board. Remedial process available to ensure targets are met. Ongoing review to identify further QIPP. 14/15 target and early development programme core to CSP. QIPP identified at scheme level and risk rated in Operation Plan financial template. Monthly report to NHSE. McKinsey assessment provided to CCG and NHSE and NHSE assurance provided through a deep dive assessment in July 2013. Detailed remedial process to be identified. N/A Internal audit review of QIPP - results to be reviewed and process adjusted to reflect recommendations. Development of remedial process to be agreed by Quality Committee and Executive Committee. Development of source and apps financial model to determine 2014/15 and 2015/16 QIPP requirements. Development of detailed plan for QIPP identification, scheme development and risk rating as integral part of CSP planning. 7

Severe (5) x Likely (4) = High (20) Severe (5) x Unlikely (2) = Medium (10) Severe (5) x Rare (1) = Low (5) 1.3 NEL CSU ability to deliver on contracted services due to capability or capacity to Lead 1.3 1,2 Director of Delivery (Scott Hamilton) Description NEL CSU failing in capability/capacity to deliver on contracted services could result in: - the increased likelihood of failure to deliver CCG strategic objectives, including: - Delivering QIPP plans on time and on target - Monitoring and resolution of quality issues with service providers - Monthly SLA review meetings between Senior CCG and CSU teams - Quarterly review meeting with CSU Chief Executive - Annual review to test services provided under SLA are fit for purpose with marketing testing - SLA between NCCG and NEL CSU sets out agreed service areas and performance requirements covered under the contract - CSU KPI's and meeting schedules WELC POD meeting every two weeks to review performance - Monthly CSU Executive Meeting for escalation - Finalise KPIs for CSU including local Newham KPIs - Establish a CCG network for performance management of CSU - Develop contingency plans for alternative commissionin g support arrangements - Embed CSU into the CCG governance structure - Documented process for escalation and contract levers to manage performance - Market test exercise to be undertaken - Service line price list from CSU - Quarterly SLA review conducted with CSU - Restructure agreed of the CSU team internal process - CCG Governance restructure - Developed KPIs and performance management process for CSU - Established an escalation process for the resolution of issues 8

Severe (5) x Possible (3) = High (15) Severe (5) x Possible (3) = High (15) Severe (5) x Rare (1) = Low (5) 1.4 Quality of Commissioned Services at Barts Health to Lead Description 1.4 1,2 Deputy Director of Quality (Chetan Vyas) Failure to manage and effectively monitor the quality of commissioned care providers could result in: - Failure to meet contractual targets which will negatively impact upon the healthcare of the local population, CCG finances and reputation. - Poor value for money for the CCG and the taxpayer - Potential risk in falling to adequately identify, monitor and manage quality performance issues which could result in unacceptable standards of care and the possibility of serious incidents occurring Barts Health CQRM and SPR meetings which include trend analysis and assurance reports across key quality indicators WELC POD Quality Leads meetings to commence in July 13 Quality Leads of WELC CCGs routinely share information and intelligence regarding Barts Health CSU Quality and Contracting Team working with DD of Quality reshed Amber Alerts mechanism rolled out across Member Practices July 2013 CCG Quality and Delivery Programme Board (*Quality Committee from August 2013) where quality of services at Barts Health is discussed - ToRs in place for routine meetings - Agenda and papers for 1st Quality Leads meeting - Amber Alerts received and responded to by Barts Health - Quality reports that indicate the quality of services at Barts Health - Minutes from Quality and Delivery Programme Board (*Quality Committee from August 2013) - SLA with CSU to support contract and performance monitoring arrangements - Agendas and minutes of Barts health CQRM and SPR meetings - Embedded - None quality identified at monitoring of present Barts Health - Robust recovery action plans from provider to remedy quality concerns - CCG capacity to fully understand the quality of services across Barts Health upon commenceme nt of Lead Commissioner Role Review quality - NCCG Governance management processes review completed and with CSU revised governance Agree ways of working structure (inc. remit of with WELC CCG Quality Quality Committee) Leads agreed and in place Review Amber Alerts from August 2013 process after one quarter and provide a report to the Quality and Delivery Programme Board and CCG Board - NCCG Board Development session on 25/07 with specific focus on Barts quality, performance and finance - Barts Health Summit meeting scheduled for 02/08 to involve key stakeholders: TDA, WELC CCGs, NHSE and NELCSU Explore the possibility of securing extra resources to support the quality management of Barts Health upon commencement of Lead Commissioner role 9

Moderate (5) x Possible (3) = Medium (9) Moderate (3) x Possible (3) = Medium (9) Moderate (3) x Rare (1) = Low (3) 1.5 Failure to establish and/or maintain effective engagement and collaborative working arrangements with the local authority to Lead 1.5 1,2 Head of Governance and Engagement (Satbinder Sanghera) Description Failure to establish effective engagement and collaborative working with the Local Authority could result in: - Reputational damage and/or increased complaints/ adverse media coverage - Duplication of effort e.g. around jointly commissioned care areas - Services which fail to meet population needs - Poor value for money through missed opportunities - Joint Commissioning Programme Board (*Partnership Commissioning Committee from August 2013) meets monthly with LA input with a focus on jointly commissioned areas of care. - Monthly joint ops meeting with LA to discuss areas of commonality to ensure VFM and to identify further joint working opportunities -Section 75/256 contracts agreed with LBN - Health and Well Being Board - Integrated Care Transformation Programme - Work plan and membership of Partnership Commissioning Committee established with LBN Senior Team and CCG GP Chair. - S75/256 agreements and MOUs in place for joint working and joint services to continue. - H&W strategy and implementation plan that both organisations have agreed and are jointly implementing - Clarity on governance arrangements for the Integrated Care Transformation Board - Joint agenda and work programme agreed for Partnerships Committee, Health and Wellbeing and Integrated Care - Awaiting NHS England monitoring / performance management process for novated services such as Health Visiting, School Nursing etc. - None identified at present - Development of a communications and engagement strategy to highlight the range of communication mediums used to engage and collaborate with stakeholders. - Further clarification on the role of LBN representation on CCG Board and the working partnership on the Health and Wellbeing Board. - Identify CCG representation on other LBN Partnership Boards such as Children's Trust - NCCG Governance review completed and revised governance structure (inc. remit of Partnerships Commissioning Committee) agreed and in place from August 2013 10

Severe (5) x Likely (4) = High (20) Moderate (3) x Possible (3) = Medium (9) Minor (2) x Possible (3) = Medium (6) 1.6 Failure to recruit develop and retain key staff to Lead Description 1.6 1,2,4,5,6 Chief Failure to recruit and Executive or retain key staff Officer across the (Steve Gilvin) organisation could result in: - loss of organisation memory - Increased difficulty in monitoring and meeting QIPP targets and strategic objectives - Negative financial implications as a result of increased recruitment costs - Nearly all permanent posts now recruited to - External recruitment being undertaken if no suitable candidates in internal redeployment pool - Temporary staff recruited if business need is agreed - Training and - NEL CSU skills support for development temporary/short programme in term place for all staff recruitment and to support substantive succession recruitment planning and the processes development of future organisational leaders. - One substantive post in CCG structure currently vacant (Performance Manager) - All staff to undertake - CCG Head of an appraisal process Informatics post with PDPs to support appointed as at 21/07/13 career and skills development - appraisals and agreed 2013/14 PDPs for all staff to be finalised and signed-off by end September 2013 11

Severe (5) x Likely (4) = High (20) Severe (5) x Possible (3) = High (15) Severe (5) x Unlikely (2) = Medium (10) 3.3 Area 2 - To develop Integrated Care, in particular to support improved management of long term conditions 2.1. Failing to develop models of integrated care and robust cost and savings assumptions to support the shift of care out of hospital to Lead 2.1 1,2 Bob Arora, Integrated Care Project Lead Description - Increased activity levels in acute and increased cost under PBR arrangements - Fragmentation of care pathways and a lack of joined up services - Lack of clarity around national IG guidelines for risk stratification and integrated care could impede linking of patient data across providers - Failure to work collaboratively with providers to ensure flows of money effectively follow the patient journey could lead to cost duplication, i.e. an increase in costs for community provision without subsequent reduction in acute capacity 3 dedicated integrated care work streams established: - 1. Rapid Response 2. Discharge support - including Mental Health liaison and discharge support (RAID model) 3. Coordination - CCG and local authority leads for IC appointed to lead development of IC in Newham - IC Programme Board (* IC Transformation Board from August 2013) and delivery work streams (ToR, Minutes) - WELC Integrated Care Board to look at elements of IC that can be effectively developed and delivered across WELC - NCCG IC Programme Board receives regular reports and integrates with WELC IC Board. _ Monthly reports from NCCG IC Transformation Board to NCCG Board to track and monitor progress of the development of Integrated Care UC streamer model supports appropriate A&E admissions avoidance - IC Management lead post to be readvertised - One Integrated Care project management support post remains vacant awaiting recruitment LBN advertising for a Band 7 IC Transformatio n Manager to support the delivery of Integrated Care Work closely with providers to develop appropriate reimbursements models aimed at ensuring the money follows the patients and where appropriate releasing capacity savings in acute (recognition that savings may not be only financial but also possibility in freeing up Consultant time to provide step down support to Community and Primary Care). 2x Project management support roles appointed to support the overall delivery of the Integrated Care programme 12

Severe (5) x Possible (3) = High (15) Severe (5) x Unlikely (2) = Medium (10) Severe (5) x Unlikely (2) = Medium (10) 3.4 Area 3 - To ensure robust patient and public engagement is embedded in the operations of Newham CCG and at all stages of the commissioning cycle 3.1 Failing to embed meaningful and measurable patient engagement at all levels of the CCG structure and throughout the commissioning cycle to Lead 3.1 1,2,3 Head of Governance and Engagement (Satbinder Sanghera) Description Failure to implement meaningful PPE strategies could result in: 1. CCG unable to deliver on Section 242 of the NHS Act 2006, which mandates NHS organisations to involve patients in the planning, development of proposals and commissioning of healthcare services. 2. Reputational damage and / or increased complaints / adverse media coverage 3. Services which fail to meet population needs (and consequently offer poor value) Established PPE platforms: - Newham Patient Forum, Community erence Group, Health and Social Care Network and PPGs - Appointment of Board Lay- Member responsible for PPE - Head of Governance and Engagement and PPE Manager posts in place - PPE Strategy and action plan- Complaints monitoring process adds additional level of assurance around capturing patient feedback - PPE Manager to build capacity of CCG staff to deliver effective PPE and embed across all levels of the CCG - CCG website - PPE support commissioned through Forum for Health and Wellbeing - Patient forums and PPGs act as mediums to capture feedback - Development of a CCG Comms. and Engagement Strategy - More detail required around processes in place to monitor the effectiveness of patient engagement activities - PPE Manager leading on engagement strategy with support from CSU on comms. element Development of a communications and engagement strategy and action plan to build on existing engagement platforms and develop new platforms to increase borough wide participation and strengthen inclusion of hard to reach groups - Conduct a scoping exercise to potentially further develop the role of PPGs at cluster level - Develop a forward plan to track and coordinate PPE needs across the CCG and ensure the CCG is delivering on its duty to involve - Increase promotion of how to get people involved through community outreach and CCG communication channels 13

Severe (5) x :Likely (4) = High (20) Severe (5) x Possible (3) = High (15) Severe (5) x Unlikely (2) = Medium (10) 3.5 Area 4 -To ensure that Newham CCG achieves robust financial stability and balance to supporting effective working and implementation of our plans 4.1 Monitoring and planning for the possible impact to NCCG arising from the financial performance of Barts Health to Lead 4.1 4 Chief Finance Officer (Chad Whitton) Description Failure to monitor and plan for the impact on the CCG arising from the financial performance at Barts Health could result in: - Reduced ability to plan for/shift care out of hospital - reduction in local acute services Requirements for allocation of contingency funding to support Barts Health which could reduce CCGs bargaining power in other provider contract negotiations - WELC Mgt and CCG Acute Collaborative Commissioning Commissioning Committee Governance Structure overseeing implementation of contract including indepth analytics, claim management. - CCG Acute Commissioning Committee overseeing CCG specific analysis. - Dedicated CCG/CSU capacity to ensure effective monitoring and contract control - Updates on Barts financial performance picked up through discussions with collaborative leads through the WELC Clinical Strategy Groups - Barts Health provide an update on the CIP programme to the WELC Clinical Strategy group attended by COs, Chair's, and CFOs of all WELC CCGs - pertinent updates will be fed back via reporting to NCCG Board WELC Mgt and Collaborative review, Monthly contract meetings, monitoring against projected activity including agreed BH Productivity Improvement Plan - CCG review of Barts CIP plan to sign-off that CCG are happy there are no material quality implications as a result of proposed savings - In depth analysis of Barts Health Cost Improvement Programme (CIP) - Formal access and input to Barts Health Turnaround and other associated plans - Timely access to Barts Health financial reporting - Co-ordination of monitoring and control - triangulation with Specialised commissioning activity - Clarification of commitment to WELC CCGs through risk share on impact of turnaround - Input and agreement required with Commissioning Lead to Barts Health Turnaround Plan - Board development session to focus on mitigation strategies for Barts financial risk. Development of BH Productivity Improvement Plan - CSU dedicated team to monitor contract 14

Severe (5) x Likely (4) = High (20) Severe (5) x Possible (3) = High (15) Severe (5) x Unlikely (2) = Medium (10) 4.2 Failure to monitor performance and activity levels at Barts Health to Lead 4.2 4 Chief Finance Officer (Chad Whitton) Description Failure to monitor performance and activity at Barts Health could result in: - Increased risk of over performance due to loss of 5% cap and collar arrangement and move to PBR contract for 2013/14 with associate risk of uplift in contract value. - Reduced bargaining position in contract negotiations with other providers - Reduction in the CCG's budget to support the shift in care out of hospital and integrated care work streams - Disaggregation of specialised commissioned services could lead to duplication of charge - Focus on demand management initiatives at cluster level - Contractual levers including KPIs and CQUINS - Monthly CQRM and SPR meetings to review quality and performance issues at the Trust - Urgent Care reprocurement and service re-design to support the management of patients in non acute setting and appropriate streaming of patients to non-urgent community care settings - Development of virtual ward to reduce admissions and LOS - Clinical engagement in Barts Health productivity agreement - Regular update via weekly CFO/WELC Collaborative Telcons with Lead Commisioner CFO - Minutes of cluster meetings to demonstrate work around demand management - Clinical engagement into CQRM and SPR processes - Monthly high level service review meetings between NCCG and Barts Health SLA with CSU for contract and finance activity monitoring arrangements - NHS England performance management processes would ensure that a development plan is initiated upon major slippages - Tripartite formal agreement between NHS London, DH and Barts Health (on Merger FBC and Barts CIP) - NCCG Informatics / information analyst post remains vacant - Emerging national IG regulations may prohibit CCGs from accessing PID data around financial activity which could prevent clinical challenge - Strong well established collaborative working arrangements with other significant commissioners (WELC) - Robust alignment with specialised commissioning - Development of demand management targets at cluster level - Triangulation with specialised commissioning contract and monitoring teams - Continuation of regular update via weekly CFO/WELC Collaborative Telcons with Lead Commisioner CFO - Triangulation with TDA/NHSE on turnaround to ensure limited liability - Recruitment of informatics/analytics capacity to work with CSU to enhance effectiveness of monitoring - CCG Head of Informatics post appointed as at 21/07/13 15

Major (4) x Likely (4) = High (16) Major (4) x Unlikely (2) = Medium (8) Major (4) x Rare (1) = Low (4) 4.3 Financial management of Newham CCG to Lead 4.3 4 Chief Finance Officer (Chad Whitton) Description Failure to plan for a sustainable financial future could result in: - Major impact on the CCG's ability to deliver its strategic objectives and QIPP targets - Severe impact on CCG finances and the likelihood of a deterioration in the budget position with the possibility of a deficit budget at year end - Severe damage to CCG reputation - The possibility of performance management measures being imposed by NHS England - Finance plan for 2013/14 has a 1% surplus target and will provide 2% nonrecurrent headroom and 1% contingency, 50% of which is to cover acute contracting risk. There will be a risk reserve of 2.3 million and plans to commit the balance of 3.8m brought forward 12/13 surplus on nonrecurrent pump-priming initiatives. - Detailed monthly reporting to NCCG Board and Q&D Programme Board - Monthly FIMS return to NHS England - Substantive CFO in post - Documented NCCG Board approval of Financial Plan - Audit Committee TOR, agenda and minutes - CCG Board and Q&D PG minutes - Financial reports process to Board provides indicative position at ledger close - NHS England approval of financial plan as part of the authorisation process - Review of - Final standing financial plan financial - Scheme of instructions delegation and scheme of delegation - Review of core governance policies including prime financial policies in Sept/Oct 2013 agreed with NCCG Audit Committee - Internal audit review agreed for the following areas: Continuing Care; Clinical Governance & Quality; Governance Framework - Phase One & Two; Budgetary Control, Financial Reporting & QIPP; Commissioning & Contract Management ; Contract Monitoring Commissioning Support Unit ; Payroll & Financial Feeders; Management / Board Assurance Part Two; Remuneration of Members. 16

Severe (5) x Likely (4) = High (20) Severe (5) x Moderate (3) = High (15) Severe (5) x Unlikely (2) = Medium (10) 4.4 Transfer of a proportion of the specialised commissioning budget from NCCG to NHS England to Lead 4.4 4 Director of Delivery (Scott Hamilton) Description There is a risk that the CCG will not be able to fully recover funding transferred pro-rata to NHS England to enable the Londonwide costs of specialised commissioning to be met. As a result: - This could impact the CCG's ability to reach acceptable Heads of Terms with providers (* though outline HoT have been agreed with major Acute and Community providers for 2013/14) - The NCCG Board holds overall responsibility for commissioning services within budget - Programme Boards (*Commissioning Committees from August 2013) hold devolved budgets for their defined areas of commissioning - CCG providers are engaged through Programme Boards and contract negotiation meetings. Director of Delivery holds overall responsibility for acute commissioning - A technical group led by the London area DoF and including CCG representatives is working with the SCG to ensure CCGs contributions are matched to commitments throughout the year with appropriate repatriation of excess funding Deep dive into the detail of the main areas of specialist commissionin g to be undertaken jointly between CCG Informatics Lead and NELCSU team. - Detailed work to be undertaken by NCL/NELC CCG in conjunction with the CSU contracting team to monitor and challenge the contract value of specialist commissioning services transferred to NHS England - Capturing and coding of CCG specialist commissioning activity to be established with activity flows linked to established pathways and protocols - CCG to define and referral activity and guidelines for specialised commissioning - CGG Head of Informatics post appointed as at 21/07/13 17

Major (4) x Likely (4) = High (16) Major (4) x Possible (3) = Medium (12) Major (4) x Rare (2) = Low (4) 3.6 Area 5 - To support quality improvements in primary care services to ensure they are fit for purpose and able to support the shift in care out of hospital 5.1 Failing to build appropriate capacity and support for the development of Primary Care to Lead 5.1 5 Deputy Director of Delivery (Jane Lindo) Description Failure to build appropriate skills, capacity and support for primary care providers could result in: - Adverse media/reputational risk - An under-resourced workforce - Primary Care Facilities not fit for purpose - Lack of capacity to manage expected increase in demand for Primary Care services as a result in the planned shift in care out of hospital -Unnecessary unscheduled admissions - Failure to meet outcome framework indicators - Development of Primary Care Strategy to include development of Performance Management Support to clusters and practices and development of future models of primary care providers e.g. federated models/networks. Development of Cluster plans to support primary care targets and demand management initiatives. - Prescribing team supporting practices - Monthly cluster meeting to review activity and quality data and other reports, discuss ideas, share concerns and share best practice between practices and other clusters - Monthly cluster leads meeting to coordinate ideas, share concerns and share best practice between clusters to feed up through the CCG structure - educational curriculum with monthly GP educational meetings reflecting key priorities - Introduction of EMIS web and training to support use -Monthly MDTs in place for Diabetes. - Each NCCG cluster has dedicated Practice Facilitator support - Project Director for Primary Care Strategy appointed to lead the development of a primary care strategy for Newham - Agendas and papers from cluster and cluster leads meetings - Cluster Plans - Extended hours schemes help to support improved access - Working collaboratively with NHS England to identify and mitigate against risks in primary care skills and capacity gaps - Working collaboratively NBC to ensure the primary care role in prevention is not reduced or lost - Statistically valid analytics to support clusters and practices to understand where there is true quality variation with national and other useful benchmarks Development of the CHN services focussed on supporting practices and patients to avoid emergency admissions (Virtual Ward, Rapid Response, Extended Primary Care Team) - Monthly Development of a cluster reports primary care strategy that incorporates a workforce skills and education mapping exercise to be undertaken to identify gaps and plan contingencies Development of a Performance framework to monitor cluster plans Strongly performance manage CSU data reporting function. At present NELIE and other reports not meeting basic requirements. Development of integrated care programme including extended Primary Care Team to support practices to keep patients out of hospital - extended district nurse pilot covering 6 practices will become fully operational end of September 18

Major (4) x Likely (4) = High (16) Major (4) x Possible (3) = Medium (12) to Lead 5.2 5,6 Deputy Director of Quality (Chetan Vyas) Description Failure to bridge skills and competency gaps throughout the organisation could lead to: - Errors or significant incidents resulting in financial and/or reputational loss - Difficulty with succession planning -Failure to deliver objectives on time and on-target - Staff Development SMT Devt Day Sessions have agenda commenced - Staff meetings are being re-shaped to encourage collective development in meetings - SMT development day held to develop the SMT None identified at present Analysis of - Training Needs to be Assessment (TNA) of undertaken CCG staff to understand subsequent to their requirements the - Continue Staff completion of Development sessions the Training - Roll-out of Personal Needs Development Review Analysis process to ensure all staff have objectives and PDPs - appraisals and 2013/14 PDPs for all staff to be finalised and signed-off by end Sept 2013 - Roll-out of Learning and Development policy to access CCG funds - Understand what learning and development opportunities CCG staff can access via the CSU 19

Major (4) x Possible (3) = Medium (12) Major (4) x Possible (3) = Medium (12) Major (4) x Unlikely (2) = Medium (8) 5.3 Board skills and competencies within NCCG to Lead Description 5.3 5,6 Deputy Director of Quality (Chetan Vyas) Failure to bridge skills and competency gaps in the Board of NCCG could lead to: - Errors or significant incidents resulting in financial and/or reputational loss - Significant reputational damage and/or adverse media interest - Difficulty with succession planning -Failure to deliver objectives on time and on-target - Potential for enforced performance management conditions from NHSE - Board Development Plan in place signed off via the authorisation process - Board Development schedule in place - Board Development Plan - Board Development Meetings - Agendas of Board Development Meetings Review of the Board Code of Conduct effectiveness to be drafted of the Board Board Conflicts of Development Policy to be reviewed Plan to and amended understand Review of how the progress made Board has collectively by the Board performed development 20

Major (4) x Possible (3) = Medium (12) Major (4) x Possible (3) = Medium (12) Major (4) x Unlikely (2) = Medium (8) 5.4 Failure to develop practices as the "power house" of GP commissioning through development of Clusters as Commissioners to Lead Description 5.4 4,5 Project Director for Primary Care Strategy (Margaret Chirgwin) Failure to build appropriate skills, capacity and support for clusters as commissioners could result in: - CCG failure to live within budget - Lack of provision for expected increase in demand for PC services as a result in the planned shift in care out of hospital - Increased activity and therefore cost under Barts PBR - Failure to meet outcome framework indicators - Development of - Each NCCG Primary Care Strategy to locality include development of (covering 2 Commissioning role of clusters)has clusters dedicated - Monthly cluster Practice meeting to discuss ideas, Facilitator share concerns and share support best practice between - Programme practices and other Director for clusters Primary Care - Monthly cluster leads Strategy meeting to coordinate appointed to ideas, share concerns and lead the share best practice development of between clusters to feed a primary care up through the CCG strategy for structure Newham - CCG engagement LES requiring attendance at cluster and CCG wide events - Monthly Practice Member Council Meetings - CCG constitution clearly defines the Clusters as Committees of the Board and their commissioning roles and responsibilities - Agreement on budget allocation methodology to practices and clusters - Agreement on risk sharing between practices and clusters - Agreement on management of cluster under and overspends at the end of year - Financial reporting at cluster and practice level - Financial and commissioning support to clusters -Board papers - Changes to constitution - Review relevant sections of the constitution -Take paper to the Board on budget allocation formula to practices and clusters for 2013/14 for shadow budget and process for 14/15 budget allocations -Take paper to the Board on risk sharing proposals within and between clusters - Take paper to the Board on how propose to manage cluster under and over spends at end of 2013/14 - Agree CCG Management and finance support required to develop clusters as commissioners (recommend an 8D supporting 2 clusters + finance to attend cluster meetings) 21

Major (4) x Possible (3) = Medium (12) Major (4) x Possible (3) = Medium (12) Major (4) x Unlikely (2) = Medium (8) 5.5 Failing to develop new and functional Extended Primary Care Providers/Shared Services Providers to Lead 5.5 5 Project Director for Primary Care Strategy (Margaret Chirgwin) Description Failing to develop new Extended Primary Care Providers/Shared Services Providers could result in: - Adverse media/reputational risk - An under-resourced workforce - Lack of provision for expected increase in demand for PC services as a result in the planned shift in care out of hospital - Increased activity under Barts PBR - Unnecessary unscheduled admissions - Failure to meet outcome framework indicators - Widening gap in life expectancy between best and worst off decile of the Newham population and between Newham and England average - Development of Primary Care Strategy to include development of Extended Primary Care Providers including how this market should be developed and how the CCG will commission these kinds of services and service developments - Engagement with Member Practices in the development of the strategy - Primary Care Strategy Draft Outline document - Agendas for practice Council, Cluster meetings etc. include discussion of what kind of providers the CCG should develop - The present Newham CCG procurement strategy is out of date and not reflective of the current NHS position with respect to procurement New CCG procurement strategy - NELCSU in discussion with NCCG to develop a new draft procurement strategy for discussion and approval by NCCG Board 22

Major (4) x Possible (3) = Medium (12) Insignificant (1) x Rare (1) = Low (1) Insignificant (1) x Rare (1) = Low (1) 3.7 Area 6 - To ensure that Newham CCG has transparent and effective corporate and clinical governance arrangements in place to comply with relevant legislation and mitigate the risk of non-delivery of strategic objectives 6.1 NCCG has outstanding authorisation conditions to Lead 6.1 6 Head of Governance and Engagement (Satbinder Sanghera) Description NCCG has been authorised by NHS England (With 8 remaining conditions as at the June 2013 evidence window). In order to fully discharge its commissioning duties the CCG must remove the remaining conditions as soon as possible. - Evidence to support the removal of the remaining conditions was submitted to NHS England in the June evidence window - Working with NHS England to clarify expecttaions on the WELC conditions, particularly risk share Mitigation plan developed and regularly submitted to NHS England for review Authorisation feedback and feedback on evidence submissions from NHS England to identify areas where further detail is required - Awaiting guidance on how end of year 1 assessment will be undertaken None identified at present Confirmation received from NHSE on 23/07 that all 8 outstanding conditions have been removed. 23

Major (4) x Possible (3) = Medium (12) Major (4) x Unlikely (2) = Medium (8) to Lead Description 6.2 6 Head of Governance and Engagement (Satbinder Sanghera) Uncertainty over emergency planning and NCCG's role NCCG is working with colleagues at NHS England, CSU, other CCGs and LBN to ensure that robust emergency planning remains in place throughout the transition period and into the future. - Desktop emergency planning exercise facilitated by NHS England planned for CCG and key Health Organisation EPRR leaders in July 2013 - Attending EPPR/BCP London quarterly meetings hosted by NHS England (London office) to share common concerns and best practice NCCG Business Continuity Plan developed outlining local business continuity arrangements to feed into wider emergency planning arrangements - On call rota established for EPRR between senior NCCG Directors as part of WELC Pod oncall arrangements CSU specialist support for EPRR and surge management None identified at present None identified at present Business Continuity and Emergency planning arrangements require sign-off from Executive Committee 24

Moderate (3) x Certain (5) = High (15) Moderate (3) x Likely (4) = Medium (12) Moderate (3) x Rare (1) = Low (3) 6.3 Information Governance arrangements for Newham CCG are in an underdeveloped state to Lead 6.3 6 Head of Governance and Engagement (Satbinder Sanghera) Description Information Governance arrangements for Newham CCG are under developed - IG Toolkit to be completed to ensure compliance with relevant IG legislation - IG development plan established to monitor progress against IG Toolkit completion and development of associated IG policies and procedures - Procedures are in place to ensure all NCCG staff complete mandatory IG training on an annual basis - Corporate incident reporting procedures developed to identify monitor and follow up risks or incidents which impact on IG NCCG has appointed a Caldicott Guardian, Senior Information Owner (SIRO) and Information Governance Lead to ensure the CCG remains compliant with relevant IG legislation and to promote best practice IG arrangements throughout the CCG NCCG has commissioned expert information governance support from the CSU which includes support around completion of the IG Toolkit Development of NCCG specific IG policies Shared folder resource between CCG and CSU IG support team developed with template policies for Information Governance Work in progress on completion of IG Toolkit in conjunction with specialist support from CSU IG team. - Appointments of CG, SIRO and IG leads for NCCG recognised by Audit Committee - All NCCG staff registered on IG online training tool for 2013/14 25

4. How to interpret the Newham CCG BAF 4.1 profile 26

4.2 Full BAF risk entries 27

5. Newham CCG Grading Matrix 28

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