AGENDA NHS Leeds Clinical Commissioning Group ... · 4/11/2018 · NHS Leeds Clinical Commissioning Group Extraordinary Governing Body Meeting Date: Wednesday 11 April 2018 Time:

AGENDA NHS Leeds Clinical Commissioning Group

Extraordinary Governing Body Meeting

Date: Wednesday 11 April 2018

Time: 09.00 – 09.45

Venue: The Old Fire Station, Gipton, Leeds, LS9 6NL

Item Description Lead Paper Time

GB 18/01

Welcome and Apologies Purpose: To record apologies for absence and confirm the meeting is quorate.

Gordon Sinclair

N

09.00

GB 18/02

Declarations of Interest Purpose: To record any Declarations of Interest relating to items on the agenda: a) Financial Interest

Where an individual may get direct financial benefit from the consequences of a decision they are involved in making;

b) Non-Financial professional interest Where an individual may obtain a non-financial professional benefit from the consequences of a decision they are involved in making;

c) Non-financial personal interest Where an individual may benefit personally in ways that are not directly linked to their professional career and do not give rise to a direct financial benefit, because of the decisions they are involved in making; and

d) Indirect Interests Where an individual has a close association with another individual who has a financial interest, a non-financial professional interest or a non-financial personal interest who would stand to benefit from a decision they are involved in making.

Gordon Sinclair

N

GB 18/03

Questions from Members of the Public Purpose: To receive questions from members of the public

Gordon Sinclair

N 09.05

GB 18/04

Operational Planning Narrative 2018/19 Purpose: To receive the planning narrative for review

Katherine Sheerin / Visseh Pejhan-Sykes

Y 09.15

GB 18/05

Financial Policy Approval Purpose: To approve key CCG financial policies

Visseh Pejhan-Sykes

Y 09.30

Item Description Lead Paper Time

Dates of Future Meetings: Wednesday 23 May 2018, 1pm Wednesday 25 July 2018, 2pm Wednesday 26 September 2018, 2pm Wednesday 28 November 2018, 2pm Wednesday 30 January 2019, 2pm Wednesday 27 March 2019, 2pm

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Agenda Item: GB 18/04 FOI Exempt: No

NHS Leeds CCG Governing Body Meeting

Date of meeting: 11 April 2018

Title: Operational Planning Narrative 2018/19

Lead Governing Body Member: Katherine Sheerin, Interim Director, Strategy, Performance and Planning Visseh Pejhan-Sykes, Chief Finance Officer

Category of Paper Tick as

appropriate

()

Report Author: Mark Fox, Head of Operational Planning and Performance Judith Williams, Head of Corporate Reporting & Strategic Financial Planning

Decision

Reviewed by EMT/SMT/Date: n/a

Discussion

Reviewed by Committee/Date: n/a

Information

Checked by Finance (Y/N/N/A - Date): Yes

Approved by Lead Governing Body member (Y/N): Yes

Joint Health & Wellbeing Strategy Outcomes – that this report relates to

1. People will live longer and have healthier lives

2. People will live full, active and independent lives

3. People’s quality of life will be improved by access to quality services

4. People will be actively involved in their health and their care

5. People will live in healthy, safe and sustainable communities

Corporate Impact Assessment: Does the Report have any of the following key implications? - Insert brief commentary or refer to body of report or N/A

Statutory/Legal/Regulatory/Contractual requirements

N/A

Financial Implications See section 2

Communication and Involvement Issues N/A

Workforce Issues N/A

Equality Issues including Equality Impact assessment

N/A

Environmental Issues N/A

Information Governance Issues including Data Protection Impact Assessment

N/A

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EXECUTIVE SUMMARY: The NHS already has two-year contracts and improvement priorities set for the period 2017/19. However, in February 2018, NHS England confirmed the requirement for CCGs to refresh existing activity and finance plans for 2018/19. A first full draft of the operational planning activity and finance plans were submitted to NHS England (NHSE) on 8 March 2018. This report provides an overview of how the CCG will deliver the priorities set by NHS England for 2018/19 for Leeds and includes a summary of the CCG’s financial plan for 2018/19. Appendix A to this paper provides an overview on how the CCG plans to deliver these priorities and Appendix B provides an overview of the CCGs financial plan for 2018/19.

NEXT STEPS:

Further feedback based on our 8 March 2018 draft submission has been provided by NHS England and we are currently progressing with making any further necessary changes. Any changes made prior to the 30 April 2018 will be communicated to both the Clinical Chair and Chief Executive in advance of final plan submission, subject to Governing Body’s approval to delegate authority to them.

RECOMMENDATION: The Governing Body is asked to:

a) CONSIDER Appendix A attached to this document: “The Leeds CCGs Partnership Operational Planning Narrative – 2018/19”.

b) CONSIDER Appendix B: “Overview of Leeds CCG Financial Plan 2018/19”. c) DELEGATE AUTHORITY to the Clinical Chair and Chief Executive to approve the

final version of the activity and financial plans prior to submission on 30 April 2018.

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1. SUMMARY 1.1 The NHS already has two-year contracts and improvement priorities set for the period

2017/19. These were based on the NHS Operational Planning and Contracting Guidance 2017-2019 published in September 2016 and reflected in the March 2017 document Next Steps on the NHS Five Year Forward View.

1.2 In February 2018, NHS England confirmed the requirement for CCGs to refresh existing activity and finance plans for 2018/19. In addition to this national requirement, the regional support team for Yorkshire and Humber requested CCGs respond to ‘ten key questions’ to give assurance on CCGs’ and providers’ developing finance and activity plans which were aligned and agreed with one another.

1.3 A first full draft of the operational planning activity and finance plans were submitted to NHS England (NHSE) on 8 March 2018. The responses to the ‘ten key questions’ were submitted to the Yorkshire and Humber regional support team on the same day.

1.4 The responses to the ‘ten key questions’ do not provide a detailed account of the action the Leeds CCG will undertake during 2018/19 to meet the priorities set by NHS England. Therefore, Appendix A to this paper provides an overview of how the CCG will deliver these priorities for Leeds.

1.5 An overview of the 2018/19 financial plan is presented below.

1.6 Following the draft submission of both the activity and financial plans to NHS England on the 8 March 2018, NHS England requested a small number of amends be made. These changes are as a result of NHS England undertaking an assessment of both provider and commissioner plans and where elements of the plans were assessed to be “misaligned”, feedback was provided by NHS England. These “misalignments” were as a result of the short timescales imposed on providers and commissioners by NHS England to submit a draft plan on 8 March 2018, which did not allow alignment prior to submission. Since 8 March, we have discussed our plan discrepancies with our main provider Leeds Teaching Hospitals NHS Trust and have made the necessary amendments.

2. OVERVIEW OF FINANCIAL PLAN

2.1 The 2018/19 financial plan for the newly merged NHS Leeds Clinical Commissioning Group has been prepared in line with national guidance and is set on the basis that the CCG will continue to make progress on the four national priorities outlined in the 'next steps' document (A&E, cancer, mental health and primary care).

2.2 Commissioning intentions assume delivery of key national targets and the local priorities. The plan forecasts that the CCG will deliver within the required business rules and advised control total as follows:

o CCG in year breakeven in relation to the advised allocation o Maintain the existing CCG cumulative underspend being £33.7m (3.1%) (note: in

addition to this surplus the CCG has a further cumulative retained surplus £16.5m (1.5%) relating to the Sustainability and Transformation Fund, the CCG is still unclear as to the arrangements in place for future drawdown of these allocations and requests clarity)

4

o 0.5% contingency reserve uncommitted at the start of the year (note: our contingency and reserves have been phased in month 12 as required by the planning guidance)

o A low underlying recurrent position 0.56% o Management costs not to exceed allocation o Nil non recurrent requirement o Achievement of the Mental Health Investment Standards o Inclusion of £3 per head practice transformational support over two years (2017/18

and 2018/19)

2.3 The in-year Quality, Innovation, Productivity and Prevention (QIPP) requirement is £35.5m (2.9%) and there is significant risk associated with achievement. The CCG has embarked on an externally facilitated overhaul of QIPP arrangements covering governance, oversight, resourcing and the development of a detailed tracking process and monitoring system. Our financial stability moving into subsequent years has a very high level of risk associated with it and we are unclear as to the recurrent or non-recurrent nature of the additional national CCG £1.4b resource announced as part of the Autumn Statement.

2.4 We have finalised our contract positions with our main providers and these are all materially aligned apart from one where we have identified a £1.5m contract gap with Leeds Community Healthcare NHS Trust (LCH). We have provided a signed copy (by both parties) to NHS England of the financial agreement between the CCG and LCH to support the CCG’s version of the financial plan figure. However, the CCG operates within a seriously challenging health and social care economy with significantly challenging control totals across the major service providers including the main acute provider, Leeds Teaching Hospitals NHS Trust.

2.5 The CCG plan is being aligned with the West Yorkshire and Harrogate sustainability and transformation plan. This system-wide plan must focus on commissioning and providing cost effective services and the delivery of QIPP programmes through transformation whilst keeping system wide organisations financially stable at the same time as managing the increasing demands of health and social care needs within the local population.

2.6 Appendix B contains an overview of the CCG’s financial plan for 2018/19. 3. NEXT STEPS

3.1 Further feedback based on our 8 March 2018 draft submission has been provided by NHS

England and we are currently progressing with making any further necessary changes. Any changes made prior to the 30 April 2018 will be communicated to both the Clinical Chair and Chief Executive in advance of final plan submission, subject to Governing Body’s approval to delegate authority to them.

4. RECOMMENDATION The Governing Body is asked to: a) CONSIDER Appendix A: “The Leeds CCGs Partnership Operational Planning Narrative

– 2018/19”. b) CONSIDER Appendix B: “Overview of Leeds CCG Financial Plan 2018/19”. c) DELEGATE AUTHORITY to the Clinical Chair and Chief Executive to approve the final

version of the activity and financial plans prior to submission on 30 April 2018.

Appendix A

DRAFT – March 2018 v5.0 Page 1 of 26

The Leeds CCG Operational Planning Narrative – 2018/19

Contents ‘Must Do’ 3: Primary Care Pages 2-5 ‘Must Do’ 4: Urgent and emergency care Pages 6-10 ‘Must Do’ 5: Referral to treatment times and elective care Pages 11-13 ‘Must Do’ 6: Cancer Pages 14-15 ‘Must Do’ 7: Mental Health Pages 16-22 ‘Must Do’ 8: People with Learning Disabilities Pages 23-24 ‘Must Do’ 9: Improving quality in organisations Pages 25-26

Appendix A


Area of Plan Description / Response

‘Must Do’ 3: Primary Care

Progress against all Next Steps on the NHS Five Year Forward View and General Practice Forward View commitments. This includes all CCGs: a) Providing extended access to GP services, including at evenings and weekends, for

100% of their population by 1 October 2018. This must include ensuring access is available during peak times of demand, including bank holidays and across the Easter, Christmas and New Year periods.

b) Delivering their contribution to the workforce commitment to have an extra 5,000

doctors and 5,000 other staff working in primary care. CCGs will work with their local NHS England teams to agree their individual contribution and wider workforce planning targets for 2018/19. At national aggregate level we are expecting the following for 2018/19:

• CCGs to recruit and retain their share of additional doctors via all available national and local initiatives;

• 600 additional doctors recruited from overseas to work in general practice; • 500 additional clinical pharmacists recruited to work in general practice (CCGs

whose bids have been successful will be expected to contribute to this increase);

• An increase in physician associates, contributing to the target of an additional 1000 to be trained by March 2020 (supported by HEE);

• Deliver increase to 1,500 mental health therapists working in primary care. c) Investing the balance of the £3/head investment for general practice transformation

support. d) Actively encourage every practice to be part of a local primary care network, so that

there is complete geographically contiguous population coverage of primary care networks as far as possible by the end of 2018/19, serving populations of at least 30,000 to 50,000.

e) Investing in upgrading primary care facilities, ensuring completion of the pipeline of

Estates and Technology Transformation schemes, and that the schemes are delivered within the timescales set out for each project.

f) Ensuring that 75% of 2018/19 sustainability and resilience funding allocated is spent by

December 2018, with 100% of the allocation spent by March 2019. g) Ensuring every practice implements at least two of the high impact ‘time to care’

actions. h) In all practices, delivering primary care provider development initiatives for which CCGs

will receive delegated budgets, including online consultations. i) Where primary care commissioning has been delegated, providing assurance that

statutory primary medical services functions are being discharged effectively. j) Lead CCGs expected to commission, with support from NHS England Regional

Independent Care Sector Programme Management Offices, medicines optimisation for care home residents with the deployment of 180 pharmacists and 60 pharmacy technician posts funded by the Pharmacy Integration Fund for two years.

Appendix A


a) We have established one Leeds Access Steering Group that can ensure a consistent approach to the commissioning intention relating to access and combine the collective resource to avoid duplication and increase capacity across the City. Recognising that there is a limited pool of workforce and financial resource and therefore working collaboratively is paramount to ensure one part of the system does not destabilise others parts of the system.

The steering group is responsible for:

Leading and enabling the establishment of an extended access model across Leeds

Overseeing and supporting delivery groups where the member sign up, design and testing of access models is being undertaken

Ensure the developing model fully integrates and supports the Leeds Urgent Care Strategy, Leeds Plan and Winter Resilience Plans

Provide regular and timely communications to all internal and external stakeholders

Oversees and co-ordinates NHSE performance returns

The Leeds CCGs Partnership through the steering group had already aspired to ensure that 100% of the population would be able to access extended services in advance of the March 2019 deadline through working with the evolving confederation to ensure equity of approach and are now working towards delivering this aspiration by October 2018.

b) The Leeds CCGs Partnership has been developing a Primary Care Workforce Strategy

which has been led by the Lead Nursing Officer for System Integration. The workforce has identified some strategic aims which ultimately support the delivery of our trajectories relating to workforce. The strategic aims are:

To enable the Primary Care Workforce to support the needs of the local population. The workforce:

o will be designed around the needs of the local population o will work flexibly across organisational boundaries o will include new roles and new and innovative ways of working

including digital technology o will be motivated and empowered by leaders who understand the role

of others and work to build relationships and work collaboratively to achieve better outcomes

o will be well trained, feel supported and have access to continuing professional development

o will be seen as a vibrant, exciting and attractive career where people want to train, work and stay to develop their career

Leeds CCGs Partnership has taken the lead on the development and implementation of a proposal to recruit an additional 30 GPs in 2018/19 with a total of 105 GPs over the next 2-3 years to the West Yorkshire region from overseas. This project has been approved and begins in April 2018 with new recruits projected to start arriving in October 2018. The project includes an additional £695,000 of local funding to ensure the recruitment and retention of GPs is successful. Support for delivery in practices will be achieved through the GP training practices working in a hub and spoke model and additional clinical supervision support for non-training practices accepting overseas recruits.

The Leeds CCG has a number of GPs on the GP Retention Scheme and is working to

Appendix A


support the network or Training Practices across the city and wider region, particularly those servicing more deprived communities.

c) During 2017/18 there was a mixed approach to the use of the £3 transformational

monies (£1.50 per head of registered population across 2 years) across the three Leeds CCGs which has been reviewed for 2018/19 so that there is consistency of approach across the City. The remaining £1.50 will be invested in creating transformational capacity within general practice through the identification of a Lead GP, nurse and practice manager for a number of geographical localities across the city. The role for these leaders has 2 elements:

1. Connecting and collaborating with other general practices to consider and address issues, challenges and opportunities in delivering the ambitions of GPFV and the CCG local improvement scheme; and

2. Representing general practice ‘at scale’ as a provider in developing and delivering integrated models of care within local networks.

d) Every general practice in Leeds is part of a ‘local care partnership’. The term ‘local care

partnership’ has been adopted in Leeds to describe a way of working that provides integrated local care for local people, recognising general practice and the registered list as the cornerstone of planned out-of-hospital (community) and urgent care provision. It has been adapted from the ‘primary care home’ model that describes a unit of care delivery at a geographical population level. Nationally the ‘primary care home’ model describes delivery being built around populations of 30-50,000. In Leeds we believe the exact size and geography will emerge over time based on natural communities, current primary care collaborations and how clinical services are best delivered. Given these factors and the population of Leeds, we would expect 18 Local Care Partnerships to form across the city.

e) The Leeds CCG has 10 Estates and Technology Transformation schemes in progress, all of which are at varying stages of the approval process. The Leeds CCG will continue to work with partners at NHS England to support practices through the final stages of the approval process and through the implementation and build phase to ensure that projects are delivered within the agreed timescales.

f) The Leeds CCG will continue to work with primary care colleagues within NHS England to award resilience funding to practices and networks of practice, identifying where possible schemes that can be delivered within the wider STP footprint to further support primary care at scale.

g) The Leeds CCGs Partnership has established a workload steering group which has a remit to oversee the progress of the 10 high impact areas and some of the specific initiatives identified within the GPFV such as online consultations, active signposting and clinical correspondence management. The Leeds CCGs Partnership has made good progress during 2017/18 in the delivery of those initiatives and will continue to monitor progress in the delivery of two ‘time to care’ initiatives in each practice in Leeds. As a city we already have 100% coverage for a social prescribing service which is one of the 10 High Impact Actions. A decision has been made to extend the current provider contract up to August 2019 and then procure a single citywide social prescribing service going forward.

Appendix A


h) Discussions have been taking place at a regional level between Informatics Leads and Primary Care Commissioning Leads in relation to online consultations. A project proposal was submitted to NHS England on 22 December which outlined an STP approach to delivering a solution. The costs submitted included a portion of the funding for a regional project team to support roll out, implementation and support for as many practices as possible that were ready to implement a new system, plus an allocation to reimburse practices already using a compliant system. Further discussions occurred at a regional level on Monday 12 Feb to agree that the preferred approach would be to run the first wave of procurement at a regional basis but for CCGs or groups of CCGs to have Lots for a local solution allowing more flexibility and local involvement in the evaluation process. Funding allocation for 2017-18 will be paid to each CCG by the end of Feb with a required to spend before the end of March. Locally in Leeds we have a large group of practices in Leeds West already in the process of developing and implementing an online consultation system with funding from the GP Access Fund. This currently covers 30 of the 37 practices in the West. Across the rest of the city there are one or two practices using an established system and one practice in North also developing their own system in house. Subject to these systems being approved through the DPS practices would be reimbursed their fair share of the funding received from NHS England for continuing to use them. A survey was sent out to practices in December 2017 which indicated an additional 27 practices across the city would be interested in having an online consultation system. Due to the timescales for procurement and implementation we have included all of these as early adopter practices to have a system in place by 30 September 2018. This will mean that at least 50% of practices across Leeds will be using an online consultation system by October 2018.

i) During 2017/18, a Primary Care Commissioning Committee in Common was established to reflect the joint working of the three Leeds CCGs. Post April 2018, the Leeds CCG will continue to operate as a fully delegated CCG with one Primary Care Commissioning Committee, supported by a primary care operational group which has representative from NHS England included to assure of our approach in relation to the delegated of primary care functions.

j) We await further guidance from the NHS England Regional Independent Care Sector

Programme Management Office to understand what role, if any, the Leeds CCG will undertake in medicines optimisation for care home residents funded by the Pharmacy Integration Fund.

Appendix A



‘Must Do’ 4: Urgent and emergency care

a) Ensure that aggregate performance against the four-hour A&E standard is at or above 90% in September 2018, that the majority of providers are achieving the 95% standard for the month of March 2019.

b) Implementation of the NHS 111 Online service to 100% of the population by December

2018.

c) Access to enhanced NHS 111 services to 100% of the population, with more than half of callers to NHS 111 receiving clinical input during their call. Every part of the country should be covered by an integrated urgent care Clinical Assessment Service (IUC CAS), bringing together 111 and GP out of hours service provision. This will include direct booking from NHS 111 to other urgent care services.

d) By March 2019, CCGs should ensure technology is enabled and then ensure that direct booking from IUC CAS into local GP systems is delivered wherever technology allows.

e) Designate remaining UTCs in 2018/19 to meet the new standards and operate as part of an integrated approach to urgent and primary care.

f) Work with local Ambulance Trusts to ensure that the new ambulance response time standards that were introduced in 2017/18 are met by September 2018. Handovers between ambulances and hospital A&Es should not exceed 30 minutes.

g) Deliver a safe reduction in ambulance conveyance to emergency departments.

h) Continue to make progress on reducing delayed transfers of care (DTOC), reducing DTOC delayed days to around 4,000 during 2018/19, with the reduction to be split equally between health and social care.

i) Continue to improve patient flow inside hospitals through implementing the “Improving Patient Flow” guidance (https://improvement.nhs.uk/resources/good-practice-guide-focus-on-improving-patient-flow/). Focus specifically on reducing inappropriate length of stay for admissions, including specific attention on ‘stranded’ and ‘super stranded’ patients who have been in hospital for over 7 days and over 21 days respectively.

j) Ensure that fewer than 15% of NHS continuing healthcare full assessments take place in an acute setting.

k) Continue to progress implementation of the Emergency Care Data Set in all A&Es (Type 1 and Type 2 by June 2018; and Type 3 by the end of 2018/19).

l) Increase the number of patients who have consented to share their additional information through the extended summary care record to 15% and improve the functionality of e-SCR by December 2018.

m) Implement a proprietary appointment booking system at particular GP practices, 50% of integrated urgent care services and 50% of UTCs by May 2018, supported by improved technology and clear appointment booking standards issued by December 2018.

n) Continue to rollout the seven-day services four priority clinical standards to five

https://improvement.nhs.uk/resources/good-practice-guide-focus-on-improving-patient-flow/

https://improvement.nhs.uk/resources/good-practice-guide-focus-on-improving-patient-flow/

Appendix A


specialist services (major trauma, heart attack, paediatric intensive care, vascular and stroke) and the seven-day services four priority clinical standards in hospitals to 50% of the population.

a) Challenges across the urgent and emergency care system continue across all points of delivery across Leeds. Attendances at our A&E departments continue to be static but we have seen an increase in activity within our walk-in and minor injury services across the city. Non elective admissions have decreased slightly as a result of the implementation of effective ambulatory care pathways and we have seen short stay admissions decrease. Patient acuity and continues to impact on the whole pathway especially for the frail elderly population resulting in longer length of stays and “stranded patients” contribute towards outflow issues across the system. The city continues to work in partnership to address the significant challenge to improve the

four-hour A&E standard. The 2018/19 Leeds recovery plan will focus on a number of agreed

system priorities resulting from the winter evaluation and outcomes of the series of interventions including the winter room and the Multi Agency Discharge Event (MADE). The plan will incorporate the 5 elements of the national A&E delivery plan with the aim to deliver the four-hour standard by September 2018 and 95% by March 2019. In addition, the plan supports the delivery of seven day hospital services and CORE 24 (1 hour standard for mental health crisis).

b) Leeds CCGs Partnership agreed to become an early adopted of the NHS 111 Online service in 2017/18. Consequently, the service has been available to 100% of the population since December 2017.

c) In line with the national Integrated Urgent Care Service Specification, Leeds will be developing its own local Clinical Assessment Service (CAS). This will functionally integrate 24/7 urgent care access, give clinical advice and book/signpost citizens into the relevant treatment service by bringing together all single points of access and local directories of services. The local CAS will act as the stable front door into the Leeds Health and Care system. It will be staffed (virtually and physically) by health and care professionals who are familiar with the Leeds system.

d) Leeds CCG is working towards ensuring direct booking from the Leeds care clinical assessment service into local GP systems is delivered by March 2019.

e) Urgent Treatment Centres will be implemented across the City in 2018/19. These will ensure a consistent and standardised offer to help support citizens with a perceived urgent care or rapid response need. The Urgent Treatment Centres will be both community based and co-located with the Emergency Departments. The Urgent Treatment Centres in Leeds will:

Have pathways flowing between various services, such as community and acute mental health services to ensure an integrated and streamlined service is available for citizens

Support the Emergency Departments by enabling all citizens who self-present at the hospital to be streamed into the most appropriate service; and

Provide 24/7 primary care. A dedicated Operational Delivery Group oversees the delivery of the initiatives with task and finish groups adopting a flexible approach to change leading from the front line. This approach will enable all of the learning to inform the wider strategic approach to implementing the Urgent and Emergency Care review across Leeds and the wider

Appendix A


West Yorkshire STP footprint. f) Yorkshire Ambulance Service (YAS) continue face growth at both local and regional

footprint. The Ambulance Response Programme is now fully operational and current performance against the new standards are satisfactory as tail of performance shows that where the target was not met, performance was missed by marginal time.

g) The introduction of the Ambulance Response Programme by Yorkshire Ambulance

Service (YAS) aims to have a positive impact on conveyance reduction as YAS call handlers are given more time at the initial stages of assessment to determine the complaint which in turn, provides an early warning of the probability of conveyance. In 2018/19 commissioners aim to work with YAS to reduce the number of unnecessary transfers to A&E departments by adopting the principles of the Integrated urgent care specification by:

Working closely with Urgent Treatment Centre’s and community providers to allow improved access for Ambulance conveyance where appropriate. More urgent community care centres will provide alternatives rather than usual conveyance to A&E.

Developing The Leeds clinical assessment service (CAS) which will provide YAS with dedicated, local clinical resource to assist in paramedics in making clinical decisions about patients and sharing of clinical responsibility and risk and will provide YAS with front line access to both health and social care services such as district nursing, mental health services and general practice.

In addition to the above, the 999 Design and Delivery Board which sits under the 999/111 Joint Strategic Commissioning Board (JSCB) will work on service development plans to reduce the level of inappropriate conveyance to A&E.

h) The Leeds healthcare system has an aspiration to reach a national target of no more

than 3.5% of bed days occupied due to Delayed Transfers of Care (DTOC). This would equate to around 60 DTOCs at any time for the Leeds System across all providers. In recent months there has been on average around 100 DTOCs. LTHT have generally maintained the number of DTOCs at around 60-70 and whilst this is above the target for Leeds, this is generally just over 3.5% of the Trusts beds. We do however have a more significant issue with patients occupying beds supplied by Leeds and York Partnership NHS Foundation Trust (LYPFT) where DTOCs have increased from 11 in August-17 to around 30 as at latest count (February-18). This is in part due to changes in coding.

There are a number of key issues that need to be addressed in order to improve the DTOC rates including dementia bed capacity (30-40 patients) and capacity in care homes generally and minimising the time taken for assessment for ongoing care in hospitals. To that end the system is looking to increases capacity to enable patient to be transferred to community settings (beds or intermediate tier community services) where they can be cared for whilst deciding their future needs.

i) The Leeds healthcare system is looking at a range of options to improve flow out of hospital. Patient flow is now recognised as the key limiting factor in Leeds impacting on the delivery of A&E performance along with enabling the Hospital Trusts to manage its elective workload and Mental Health services to reduce the number of out of area placements. Over the coming months the system will be reviewing pathways and out of

Appendix A


hospital capacity to ensure that wherever possible patient flow can be improved. We will monitor this through reviewing the number of DTOCs alongside the relative numbers of stranded and super stranded patients. Actions are as described in the section above on DTOCs.

j) During 2017/18 we drafted a Service Improvement Plan which sets out our intended

action to ensure no more than 15% of NHS continuing healthcare full assessments take place in an acute setting. Delivery of any change is dependent of effective collaborative working with all partners including Leeds Teaching Hospitals NHS Trust (LTHT), Leeds Community Healthcare NHS Trust (LCH) and Leeds City Council. The plan will roll forward from this year and includes:

Establishing close working relationships between Continuing Care and Hospital Discharge teams; a named member of the Continuing Care service liaises regularly with colleagues in the system to support management of hospital discharge delays and inform the DTOC reporting process.

A Continuing Health Care (CHC) Nurse working with the Leeds Integrated Discharge Service (LIDS) to understand further improvement opportunities; a nurse is working alongside hospital staff to inform and help with the discharge process at the operational frontline.

Implementing a discharge to assess identification process to include potential CHC eligible people. We are working collaboratively to put in place a process to identify people who may be eligible and then support them to move to a community care bed where they will have time to recuperate further and be assessed in a more appropriate care environment. It will also reduce any delays attributed to Continuing Care and enable assessments to be completed in a timely way.

The Leeds Health and Social Care System to agree to use the 5Q Care Test process in LTHT. This is the tool that enables early identification of patients who may be eligible for CHC. This will require collaborative working with all partners.

Effective monitoring of 15 % target is in place using the Continuing Care Information Management system and reports are provided monthly to NHSE.

We are also supporting citywide work to improve Dementia care bed capacity across Leeds to enable patients with need to be place more easily.

k) Leeds Teaching Hospitals NHS Trust are progressing with the implementation of the

Emergency Care Data Set in all A&Es. Type 1 and Type 2 are expected to be in place by June 2018 and Type 3 and the data set will be in place by the end of 2018/19.

l) The Leeds CCGs Partnership has developed a local practice quality improvement dashboard which incorporates the data relating to the number of patients who have consented to share their information through the extended summary care record – this is shared at a CCG level at the Primary Care Commissioning Committee and at practice level. The number of patients is currently collected but this will be amended to reflect the target of 15% so that we can continue to monitor progress in this regard.

m) The Leeds CCGs Partnership has developed a city wide access steering group which is

integrated with the development of urgent care services recognising that the two work streams are closely aligned. We have identified a number of practices that are keen to implement direct booking via 111 and as part of our mobilisation of extended access hubs we are prioritising systems that can fully integrated with 111 direct booking and enable patients to be booked into appointment slots as part of the urgent treatment

Appendix A


centre.

n) Leeds Teaching Hospitals NHS Trust is an early adopter of the Seven Day Services Standards and has at this point demonstrated compliance with 3 (Standards 5,6 and 8) out of the 4 priority standards. At the last Seven Day Services survey our performance for standard 2 (Time to First Consultant Review) was 75% against an expected of 90%. We have worked closely and productively with the Sustainable Improvement Team in NHS England. We are focussing on the specialty areas of Acute Medicine, Elderly Medicine and Paediatrics.

Acute Medicine are using the Leeds Improvement Methodology to look at delays to Consultant review and how they can be reduced.

Elderly Medicine are restructuring their Consultants to provide a second daily ward round.

Paediatrics are looking at how their evening shift Consultants are deployed and their balance between admission prevention and reviewing in-patients.

It is important to note that all three of these clinical areas have at times struggled to recruit to Consultant vacancies (a national problem). Additionally whilst bed occupancy is running at such high levels, it is a challenge to cohort new admissions into specified clinical areas resulting in patients being moved to outlying clinical areas prior to Consultant review.

Appendix A



‘Must Do’ 5: Referral to treatment times and elective care

a) Commissioners should plan on the basis that their RTT waiting list, measured as the number of patients on an incomplete pathway, will be no higher in March 2019 than in March 2018 and, where possible, they should aim for it to be reduced.

b) Numbers nationally of patients waiting more than 52 weeks for treatment should be halved by March 2019, and locally eliminated wherever possible.

Maternity - Overall Goals for 2017-2019 Continue to make maternity services in England safer and more personal through the implementation of the Better Births. c) Deliver improvements in safety towards the 2020 ambition to reduce stillbirths,

neonatal deaths, maternal death and brain injuries by 20% and by 50% in 2025, including full implementation of the Saving Babies Lives Care Bundle by March 2019.

d) Increase the number of women receiving continuity of the person caring for them during pregnancy so that by March 2019, 20% of women booking receive continuity.

e) Continue to increase access to specialist perinatal mental health services, ensuring that an additional 9,000 women access specialist perinatal mental health services and boost bed numbers in the 19 units that will be open by the end of 2018/19 so that overall capacity is increased by 49%.

f) By June 2018, agree trajectories to improve the safety, choice and personalisation of maternity.

a) The total inpatient waiting list size at Leeds Teaching Hospitals NHS Trust (LTHT) has slightly reduced between April and December 2017 despite the very significant pressures in the system. The total over 18 week waits on the inpatient side were down at the end of December from the March position but will be likely to be higher by the end of March 2018 because of the very significant capacity losses in January and February. We are focusing on consultant triage and making best use of community provision and ensuring all hearing loss patients are reviewed initially by paediatric audiology. Good progress is being made on spinal pathways, and this is progressing. The main remaining challenges on the inpatient side relate again to paediatric specialties, and to specialties such as colorectal surgery where surgical capacity over winter months has been extremely limited. The commissioners and providers are working jointly to offer choice wherever possible, and to maximise productivity on day case lists. The LTHT outpatient waiting list size has fallen by 7% and there has been an even bigger improvement in the over 18 week position for CCG commissioned pathways. This is due to the very significant work on referral and pathway redesign in recent months.

Overall, we are confident that given the activity plans we have in place, the total incomplete pathways requirement is achievable if operating starts again in line with plans and we continue to use Independent Sector capacity where we can.

b) We are not yet clear what our March 2018 over 52 week wait position will be, because

of the uncertainty about how many patients will be treated in February and March compared to the numbers who will tip over 52 weeks. Our key risk areas are paediatric

Appendix A


surgical specialties (many of the patients in this waiting list are NHSE commissioned), and in our general surgery, colorectal and urology pathways. We had not had any 52 week waiters prior to November 2017, and should be able to reduce considerably by March 2019 particularly for the adult specialties. There are greater risks in paediatric services where there is only very limited independent sector provision. Our focus will be on maximising productivity in these specialties, and working with other providers to take advantage of any additional capacity they can create.

c) Safety is a key priority of the Leeds Maternity Strategy (2015-20), the Leeds maternity

service specification and the West Yorkshire and Harrogate Local Maternity System. The Leeds Teaching Hospitals NHS Trust is a pilot area for the Saving Babies Lives Care Bundle and is making good progress to achieving full implementation, as evidenced in the last Yorkshire and Humber Clinical Network audit (2017). Safety and quality is reviewed through quarterly local commissioning meetings, informed by both the local and regional maternity dashboards. A significant programme of work has been undertaken to reduce the still birth rate over the last few years and this has reduced from 2012 – where we were recognised as an outlier with a stillbirth rate of 7.24 per 1000 live births to, our 2016 current rate 4.3 per 100 live births. The Leeds CCG and Leeds Teaching Hospitals NHS Trust (LTHT) are fully engaged with the programmes of work of the Yorkshire and Humber Clinical Network and the Northern Region to increase the safety of maternity services e.g., Saving Babies’ Lives Care Bundle, Each Baby Counts, Saving Babies in North England (SaBiNE) Project, and the Yorkshire and Humber Stillbirth Steering and review sub-group. LTHT has participated as a wave 1 site in a three-year programme for the national Maternal and Neonatal Health Safety Collaborative launched by the Secretary of State for Health in February 2017. The purpose of the collaborative is to improve the quality and safety in maternity units by using quality improvement methodology which becomes embedded and sustainable. The CCG and provider are closely involved in the development of the LMS plan, at both board and task group level. Within the West Yorkshire and Harrogate LMS plan there is a clear commitment to agree and set trajectories for all elements of the Saving Babies Lives Care Bundle by March 2018 and Leeds will set local trajectories by June 2018 in response to these.

d) A clear priority within the Leeds Maternity Strategy (LMS) is for local women to have a

more personalised experience of maternity care and the importance of the continuity of the person caring for them. There has been significant re- development of maternity models of care in Leeds, where we now have small community teams of 4-6 midwives aligned to our local health visiting and children’s centre teams. Each woman has a named lead midwife and buddy midwife and the opportunity to develop a personalised care plan. This model will deliver continuity of the midwife caring for the woman during the antenatal and postnatal elements of the pathway. A new homebirth service has been launched early in 2018, where there is the offer of continuity of the midwife providing the care throughout the antenatal, delivery and postnatal elements of the pathway. Developments to extend the numbers of women having continuity of the person caring for them in maternity will continue during 2018/19, in line with the national guidance and target, working closely with colleagues as part of our LMS plan.

e) The Leeds Perinatal Mental Health Pathway was approved in February 2017; this sets

out the full pathway from the universal midwife and health visiting service responses,

Appendix A


through to specialist services, including the Leeds Mother and Baby Unit. Significant work is underway to implement this, including improved data collection and reporting, the development of a shared workforce development plan and an anti-stigma campaign. A key ambition is to enhance the community specialist perinatal mental health teams that do not meet the Royal College of Psychiatrists workforce standards. The CCG will be applying to the Perinatal Mental Health Community Service Development fund Wave 2 to improve this position.

f) The Leeds CCG will work with the maternity service provider as part of the wider Leeds Maternity Strategy to establish local and system wide trajectories to improve the safety, choice and personalisation of maternity care by June 2018.

Appendix A



‘Must Do’ 6: Cancer

a) Ensure all eight waiting time standards for cancer are met, including the 62 day referral-to-treatment cancer standard. The ‘10 high impact actions’ for meeting the 62 day standard should be implemented in all trusts, with oversight and coordination by Cancer Alliances. The release of cancer transformation funding in 2018/19 will continue to be linked to delivery of the 62 day cancer standard.

b) Support the implementation of the new radiotherapy service specification, ensuring that the latest technologies, including the new and upgraded machines being funded through the £130 million Radiotherapy Modernisation Fund, are available for all patients across the country.

c) Ensure implementation of the nationally agreed rapid assessment and diagnostic pathways for lung, prostate and colorectal cancers, ensuring that patients get timely access to the latest diagnosis and treatment. Accelerating the adoption of these innovations helps meet the 62 days standard ahead of the introduction of the 28 day Faster Diagnosis Standard in April 2020.

d) Progress towards the 2020/21 ambition for 62% of cancer patients to be diagnosed at stage 1 or 2, and reduce the proportion of cancers diagnosed following an emergency admission.

e) Support the rollout of FIT in the bowel cancer screening programme during 2018/19 in line with the agreed national timescales following PHE’s procurement of new FIT kit, ensuring that at least 10% of all bowel cancers diagnosed through the screening programme are detected at an early stage, increasing to 12% in 2019/20.

f) Participate in pilot programmes offering low dose CT scanning based on an assessment of lung cancer risk in CCGs with lowest lung cancer survival rates.

g) Progress towards the 2020/21 ambition for all breast cancer patients to move to a stratified follow-up pathway after treatment. Around two-thirds of patients should be on a supported self-management pathway, freeing up clinical capacity to see new patients and those with the most complex needs. All Cancer Alliances should have in place clinically agreed protocols for stratifying breast cancer patients and a system for remote monitoring by the end of 2018/19.

h) Ensure implementation of the new cancer waiting times system in April 2018 and begin data collection in preparation for the introduction of the new 28 day Faster Diagnosis standard by 2020.

a) At citywide level, we are close to meeting the 62 day standard (average performance at 83.2% in 17/18 YTD, against target of 85%). Overall local performance is impacted upon by the significant numbers of late referrals from other providers into Leeds Teaching Hospitals (post 38 days). We continue to work closely with the Alliance, West Yorkshire Association of Acute Trusts and local providers with the support of the NHS Improvement Intensive Support Team to address the barriers to delivery and have also undertaken internal focused pathway work in the specialties of urology and lung.

b) Radiotherapy commissioning is the responsibility of NHS England. We are assured that

there is a programme for upgrading local radiotherapy services managed by the Leeds Teaching Hospitals NHS Trust Cancer Board which features within our ‘high quality modern services’ work stream.

Appendix A


c) Rapid assessment and diagnostic pathways for lung, prostate and colorectal cancers are already in place and have been for some years, enabling straight to test for lung and colorectal, and a one stop shop for prostate assessment.

d) The Leeds CCG has a detailed work programme aiming to further increase the proportions of patients diagnosed at stage 1 and 2 delivered through the Early Diagnosis work stream of the Leeds Cancer Programme. The work programme includes expansion of the ACE pilot project (Accelerate, Coordinate, Evaluate) following successful application for Cancer Transformation Funds, focused on referral of patients with non-specific but concerning symptoms. The ambition is to rollout the pathway to all Leeds GPs by end of 2018, to test out delivery of Nursing assessment within community settings and to apply ACE principles to other pathways starting with Upper gastrointestinal with a view to a reduction in invasive testing. Rollout of Tele-dermatology across all Leeds GPs is also planned to improve patient experience by speeding up the 2 week wait dermatology pathway and also reducing the number of outpatient appointments that patients are required to attend. In addition through the Prevention, Awareness and Increasing Screening Uptake work stream of the Leeds Cancer Programme there is a continued focus on supporting all practices to reach national screening targets whilst raising awareness of risk factors for signs and symptoms of cancer to encourage earlier presentation.

e) The Leeds CCG awaits the full introduction of the Faecal Immunochemical Test (FIT) via the nationally commissioned and delivered NHS England programme locally. As commissioners we attend regional update/planning meetings and shall work closely with NHS England during roll-out to ensure effective communication to Primary Care.

f) Leeds Teaching Hospitals NHS Trust are currently mobilising its Yorkshire Lung

Screening Trial (due to go live September 2018). The project is the second largest such pilot in the country and shall ensure that low dose CT scanning is offered based on an assessment of lung cancer risk.

g) All breast cancer patients are now on a risk stratified pathway, which includes patient

education programme and self-management guidance; both are supported by the transfer of information to primary care through a care plan and health needs assessment.

h) As a pilot site for 28 days to diagnosis, Leeds Teaching Hospitals NHS Trust has been collating and submitting data on this standard for three cancer specialties initially Head and Neck, Prostate and Gynaecology during 2017/18. Work is now underway to embed and rollout the standard across the whole Trust during 2018 with a focus on data collection, audit and improvement.

Appendix A



‘Must Do’ 7: Mental Health

Progress to be made against all deliverables in the Next Steps on the NHS Five Year Forward View and the Implementing the Mental Health Forward View in 2018/19 with all CCGs and STPs required to: a) Each CCG must meet the Mental Health Investment Standard (MHIS) by which their

2018/19 investment in mental health rises at a faster rate than their overall programme funding. CCGs’ auditors will be required to validate their 2018/19 year-end position on meeting the MHIS.

b) Ensure that an additional 49,000 children and young people receive treatment from NHS-commissioned community services (32% above the 2014/15 baseline) nationally, towards the 2020/21 objective of an additional 70,000 additional children and young people. Ensure evidence of local progress to transform children and young people’s mental health services is published in refreshed joint agency Local Transformation Plans aligned to STPs.

c) Make further progress towards delivering the 2020/21 waiting time standards for children and young people’s eating disorder services of 95% of patient receiving first definitive treatment within four weeks for routine cases and within one week for urgent cases.

d) Deliver against regional implementation plans to ensure that by 2020/21, inpatient stays for children and young people will only take place where clinically appropriate, will have the minimum possible length of stay, and will be as close to home as possible to avoid inappropriate out of area placements, within a context of 150-180 additional beds.

e) Continue to increase access to specialist perinatal mental health services, ensuring that an additional 9,000 women access specialist perinatal mental health services and boost bed numbers in the 19 units that will be open by the end of 2018/19 so that overall capacity is increased by 49%.

f) Continue to improve access to psychology therapies (IAPT) services with, maintaining the increase of 60,000 people accessing treatment achieved in 2017/18 and increase by a further 140,000 delivering a national access rate of 19% for people with common mental health conditions. Do so by supporting HEE’s commissioning of 1,000 replacement practitioners and a further 1,000 trainees to expand services. This will release 1,500 mental health therapists to work in primary care. Approximately two-thirds of the increase to psychological therapies should be in new integrated services focused on people with co-morbid long term physical health conditions and/or medically unexplained symptoms, delivered in primary care. Continue to ensure that access, waiting time and recovery standards are met.

g) Continue to work towards the 2020/21 ambition of all acute hospitals having mental health crisis and liaison services that can meet the specific needs of people of all ages including children and young people and older adults; and deliver Core 24 mental health liaison standards for adults in 50% of acute hospitals subject to hospitals being able to successfully recruit.

h) Ensure that 53% of patients requiring early intervention for psychosis receive NICE concordant care within two weeks.

Appendix A


i) Support delivery of STP-level plans to reduce all inappropriate adult acute out of area

placements by 2020/21, including increasing investment for Crisis Resolution Home Treatment Teams (CRHTTs) to meet the ambition of all areas providing CRHTTs resourced to operate in line with recognised best practice by 2020/21. Review all patients who are placed out of area to ensure that have appropriate packages of care.

j) Deliver annual physical health checks and interventions, in line with guidance, to at least 280,000 people with a severe mental health illness.

k) Provide a 25% increase nationally on 2017/18 baseline in access to Individual Placement and Support services.

l) Maintain the dementia diagnosis rate of two thirds (66.7%) of prevalence and improve post diagnostic care.

m) Deliver their contribution to the mental health workforce expansion as set out in the HEE workforce plan, supported by STP-level plans. At national level, this should also specifically include an increase of 1,500 mental health therapists in primary care in 2018/19 and an expansion in the capacity and capability of the children and young people’s workforce building towards 1,700 new staff and 3,400 existing staff trained to deliver evidence based interventions by 2020/21.

n) Deliver against multi-agency suicide prevention plans, working towards a national 10% reduction in suicide rate by 2020/21.

o) Deliver liaison and diversion services to 83% of the population.

p) Ensure all commissioned activity is recorded and reported through the Mental Health Services Dataset.

a) To ensure delivery of all mental health priorities, we have ensured that growth in investment in mental health meets national guideline requirement i.e. growth equal to at least the overall growth in allocations. Evidence of this can be found in our financial plan submission for 2018/19.

b) A significant number of children and young people (circa 5,000) are supported in Leeds

through the school cluster model (targeted mental health service in schools). In a reflection of the positive partnership way of working we have in Leeds these school clusters are funded via schools, the Local Authority and the CCG. Each school cluster commissions a service from the resulting pooled budget and has their own information system to collect data, which creates significant challenges for meaningful submission to the MHSDS. We have agreed a trajectory with our NHS CAMHS provider to increase the number of children and young people to be supported during 2018/19 and 2019/20. Delivering the following in 2018/19 will support this ambition:

Expanding our brief intervention offer from the single point of access (SPA) service

Commissioning access to online counselling during and ensuring this is embedded within our local pathways/ service offer to best effect

Introducing self-referrals in 2018/19 to SPA to facilitate quick access – we envision this will particularly enable more children and young people to be offered brief intervention/ online counselling and support.

Appendix A


Leeds continues to refresh the Local Transformation Plan (LTP) every year and once ratified through the Health and Wellbeing Board publish it on CCG and Local Authority websites. The CCG works closely with colleagues in the STP to ensure alignment across the system and works closely with the STP on CAMHS new models of care.

c) The Children and Young People’s Community Eating Disorder Service is now well

established and has a steadily improving performance against the routine and urgent waiting time standards, where in quarter 3 of 2017/18 95.5% of routine waiters were seen within target and 100% of urgent were seen within target. We will continue to monitor the delivery of this service in 2018/19 to ensure continued compliance with the national ambition.

d) The Leeds CCG is working closely with the wave 2 West Yorkshire and Harrogate STP

CAMHS new model of care programme. Leeds already commissions an intensive outreach service that enables children and young people to be supported in their home to reduce the need for admission to a CAMHS bed and to facilitate early discharge when an admission is necessary. The focus in 2018/19 is to work with the STP programme to improve the offer for children and young people in mental health crisis in the city, as set out in our Local Transformation Plan. Work is underway to commission a 24/7 helpline as well as working to establish an alternative safe space for young people in the city in 2018/19; this is in direct response to the overwhelming feedback from young people that this is what they are wanting.

e) The Leeds Perinatal Mental Health Pathway was approved in February 2017; this sets out the full pathway from the universal midwife and health visiting service responses, through to specialist services, including the Leeds Mother and Baby Unit. Significant work is underway to implement this, including improved data collection and reporting, the development of a shared workforce development plan and an anti-stigma campaign. A key ambition is to enhance the community specialist perinatal mental health teams that do not meet the Royal College of Psychiatrists workforce standards. The CCG will be applying to the Perinatal Mental Health Community Service Development fund Wave 2 to improve this position.

f) Leeds IAPT is delivered by a consortium of 4 providers: Leeds Community Healthcare, Community Links, Touchstone and Northpoint. The consortium has recruited to 2 fully funded expansion post HIT places on the March 2018 cohort, in additional to recruiting to 3 trainee PWP posts due to start mid-March. We are scoping a Long Term Conditions (LTC) pathway into the development of IAPT delivery for 2018/19, to build on the current provision of Silvercloud LTC modules and compliment therapeutic input into current LTC pathways. An IAPT access recovery plan was produced by mental health commissioners in conjunction with IAPT providers during 2017-18. It is updated monthly by providers. Monitoring and reporting arrangements for the items in the recovery plan include those both within the IAPT service, at varying frequencies, and to commissioners monthly. The IAPT consortium submits the IAPT access recovery plan monthly to mental health commissioners, along with the IAPT dashboard data and a monthly narrative. This submission is reviewed and queries are raised as appropriate. Following this the IAPT access recovery plan is also an agenda item within the IAPT quarterly performance monitoring meetings. Commissioners report up to the Leeds CCG commissioning and contracting oversight group to highlight progress/issues to CCG

Appendix A


leadership. The IAPT access recovery plan will continue to be reviewed in line with the above description and updated and amended as appropriate

g) From January 2018 Leeds Teaching Hospitals NHS Trust (LTHT) have had 24/7 all age

Mental Health liaison across both hospital sites in Leeds. The service provided does not currently meet all principles of the CORE 24 specification as the current service is not commissioned to achieve 1 hour assessment within the Emergency Department. Leeds and York Partnership NHS Foundation Trust (LYPFT) have accessed NHS England transformation funding to progress to “true” CORE 24 model. The funding will be used to increase capacity with the Acute Liaison Psychiatry Service (ALPS) to meet the 1 hour assessment standard and establish a team base at the Leeds General Infirmary site. An LYPFT/LTHT/CCG partnership group has been established and meets bi-monthly to oversee implementation of CORE 24 model in Leeds.

h) From September 2016 the full age range early intervention for psychosis (EIP) pathway

has been provided by our third sector provider Community Links with acute support from Leeds and York Partnership NHS Foundation Trust (LYPFT). In 2017/18 the Leeds CCGs Partnership agreed a recurrent uplift to maintain provision for the full age range 14-65. However this was not at a sustainable level to meet the population need and did not include funding of full range of NICE concordant therapies or implementing the At Risk Mental State pathway (ARMs). During 17/18, Community Links scoped an ARMs pathway to inform CCG commissioning intentions for 18/19. In September 2017 the Leeds CCGs Partnership and the provider agreed an investment plan between 2018/19 and 2020/21 to achieve sustainability of provision to the full caseload across the 3 year recommended care package, increase access to required NICE concordant therapies and to implement an ARMS pathway for Leeds. The investment plan will deliver the full access and waiting time standards.

i) Leeds and York Partnership NHS Foundation Trust (LYPFT) have plans in place for

2018/19 in terms of reviewing and redesigning its crisis, rehabilitation and CMHT that ensures mental health secondary care pathways are working to its full optimum, which will ultimately improve patient flow, reduce lengths of stay, preventing hospital admissions and reducing out of area placements. Leeds CCG and LYPFT are working with STP partners in terms of developing a regional commissioning model for a Psychiatric Intensive Care Unit and work is underway between providers in terms of sharing acute bed base across the West Yorkshire footprint. Leeds CCG continues to invest within the third sector, especially, developing alternatives model to hospital such as Dial House and Crisis café.

j) CQUIN measures associated with undertaking physical health checks and interventions

in 2017/18 are expected to be partially met by Leeds and York Partnership NHS Foundation Trust (LYPFT). The Trust recently employed a physical health lead which should deliver improvements in the rate of cardio metabolic assessments for patients with schizophrenia from 2018/19. Primary care and Mental Health lead commissioners are working together to overcome

Appendix A


issues associated with the requirement to agree a shared care protocol between secondary and primary care to deliver the requirement of collaboration with primary care clinicians. From Q1 2018/19 the Trust will commence in the use of an electronic system for sharing clinical information between LYPFT and primary care. LYPFT will be using the Message Exchange for Social Care and Health (MESH) to send communications to GPs; this will interface directly with the main GP systems (EMIS, SystmOne etc.).

k) Leeds CCG, along with Leeds City Council, commissions Leeds Mind to deliver

employment support and job retention; this service is WorkPlace Leeds (WPL). WPL is currently delivering an Individual Placement and Support (IPS) service at a ‘Good IPS Fidelity’ level and have employment workers embedded within the Community Mental Health Teams, however further development is expected during 2018-19 to achieve ‘Exemplary IPS Fidelity’. WPL has a longstanding relationship with Leeds and York Partnership Foundation Trust (LYPFT) and indeed when WPL was established they trialled the IPS approach and achieved the Centre for Excellence award. The service has evolved since then but continues to take its approach from the IPS principals. Leeds CCG Mental Health commissioners are working with STP partners and providers to formulate a bid for Wave 1 IPS expansion.

l) The Dementia diagnosis rate within Leeds has exceeded 66.7% since March 2015, the

original date for this ambition, and the numbers with a diagnosis have continued to increase since then. The ambition for Leeds is to sustain the steady improvement in diagnosis, which by 2020 should see a diagnosis rate in the top banding of the CCG IAF, and approaching 80%. The approach taken in Leeds is one of “timely” diagnosis, which works by improving public awareness, reducing stigma, and offering an effective pathway to diagnosis and post-diagnosis support. Improving the local pathway benefits people who may be developing symptoms of dementia by offering a good experience of memory assessment. This includes shorter waiting times, which remains an NHS Mandate goal for 2020. In 2018-19 we will:

Review the Leeds pathway for dementia diagnosis and support, in the light of local developments and new NICE guidance (expected June 2018).

Continue to work with Leeds and York Partnership Foundation Trust (LYPFT) to reduce waiting times for memory assessment and diagnosis.

Complete LYPFT evaluation of GP-hosted memory clinics and consider further development to fill geographical ‘gaps’.

Seek to sustain and improve the post-diagnosis support offer, including sustaining the Memory Support Worker service, carer support and BME support.

Further develop the quality and consistency of the GP annual review and ongoing support in primary care, by including dementia in the Collaborative Care and Support Planning approach.

Developing the approach of Memory Support Workers sharing care records and contributing to care plans via GP systems.

m) Developing the workforce is integral to the Local Transformation Plan for Children and

Young People’s Mental Health and Wellbeing (LTP). A workforce development strategy to underpin the LTP is due completion at the end of 2017/18. The MindMate Champions programme has 80% of all schools now enrolled. This programme develops

Appendix A


the local school workforce to support emotional resilience and early help in this setting where children and young people spend so much of their time. A key element of the programme is access to expert help, a menu of subsidised mental health training for school staff and key resources to utilise in the school setting. Leeds is a long-standing member of the CYP-IAPT programme and CYP-IAPT principles will strongly inform the workforce development strategy. New roles, skill mix and service models are being tested across the health, education and social care system and the strategy will reflect this. Leeds CCG continues to engage with HEE and STP colleagues on workforce issues via the NHS England Yorkshire and Humber Clinical Network Lead Commissioner Forum.

n) The Leeds suicide prevention work stream is overseen by the Citywide strategic multi-

agency partnership suicide prevention group that meets quarterly led by Public Health, Leeds City Council. The strategic suicide prevention group oversees the citywide suicide prevention plan for the city. This plan is informed by a detailed Suicide Audit undertaken every three years for the population of Leeds. This ensures that resources are directed towards appropriate evidence-based and needs led interventions. Key outcomes from this work have included:

Additional recurrent Investment identified

Commissioning of a bespoke peer led Suicide Bereavement Service which is nationally recognised as good practice.

Insight informed approach to commissioning community development interventions with men at risk of suicide. Third sector have taken this work forward

Production of National Media Guidelines

Gold standard Audit process cited by PHE in their national guidelines

Recognition of the local “adopt a block” partnership work with isolated men living in deprived areas of Leeds. This work is led by the West Yorkshire Fire and Rescue Service

Invested in targeted SafeTalk, Applied Suicide Intervention Skills Training (ASIST) and Mental Health First Aid training for those working with our at risk groups.

Commissioned new Mentally Healthy Leeds which is an upstream prevention service and includes suicide prevention activity in its specification.

Developed Crisis cards for front line services and wider population to use

The key actions for next two years are to:

Refresh of the suicide action plan for 2018-21

Reprocure the peer led post-intervention service

Launch Mentally Healthy Leeds

Engagement with primary care to support their key role in Suicide prevention

Develop real time data surveillance support across West Yorkshire with regional partners (Linked to STP)

Ensure greater targeting of resources at high-risk groups and continue to working with the 3rd sector to support development and delivery of plans

Begin planning of next Suicide Audit to commence in 2019

Ensure potential for new investment in suicide prevention activity with at risk groups.

o) Working with Touchstone, the Together Women Project, Leeds Police and Leeds Youth

Offending Service, we are expanding the already successful Wakefield service into Leeds. Funded by NHS England, this will be an innovative support service for people

Appendix A


who have contact with the criminal justice system; the team are based at Elland Road Police Station. The Liaison and Diversion Service is a multi-disciplinary team that works with people of all ages, including children and young people. The service supports individuals who have contact with police stations, the course, prisons and probation that are experiencing vulnerabilities such as mental health and learning disabilities, substance misuse and other complex needs. Touchstone is providing mental health nurses, support workers, peer and volunteer support as well as management support to the service. The team is working collaboratively with individuals and services to reduce risk factors associated with offending through providing short-term support and signposting service users to longer term support. We focus on the causes of individual behaviours, identifying needs, providing holistic person-centred support and supporting individuals to move into education and employment opportunities.

p) The Leeds CCG is working to ensure children and young people’s mental health services

that we commission and fund submit data to the Mental Health Services Data Set (MHSDS). Currently the data submitted by the CAMHS provider is not flowing accurately due to an information system issue (Care Notes). We are working with Leeds Community Healthcare NHS Trust to address this. In addition some CAMHS practitioners who are embedded in other services, such as the Youth Offending Service, and the MindMate Single Point of Access are not yet submitting data, though this will be addressed during 2018/19. During 2017/18 Leeds commissioned the Child Outcomes Research Consortium (CORC) to undertake a feasibility study to advise on the submission of data from commissioned services not yet submitting to MHSDS, such as the third sector city-centre counselling provision, the Children’s Liaison Psychology service and school clusters (part funded by the CCG). The Liaison psychology service and third sector provision will begin submitting data during 2018/19.

Appendix A



‘Must Do’ 8: People with Learning Disabilities

All Transforming Care Partnerships (TCPs), CCGs and STPs are expected to: a) Continue to reduce inappropriate hospitalisation of people with a learning disability,

autism or both, so that the number in hospital reduces at a national aggregate level by 35% to 50% from March 2015 by March 2019. As part of achieving that reduction we expect CCGs and TCPs to place a particular emphasis on making a substantial reduction in the number of long-stay (5 year+ inpatients).

b) Continue to improve access to healthcare for people with a learning disability, so that the number of people receiving an annual health check from their GP is 64% higher than in 2016/17. CCGs should achieve this by both increasing the number of people with a learning disability recorded on the GP Learning Disability Register, and by improving the proportion of people on that register receiving a health check.

c) Make further investment in community teams to avoid hospitalisation, including through use of the £10 million transformation fund.

d) Ensure more children with a learning disability, autism or both get a community Care, Education and Treatment Review (CETR) to consider other options before they are admitted to hospital, such that 75% of under-18s admitted to hospital have either had a pre-admission CETR or a CETR immediately post admission.

e) Continue the work on tackling premature mortality by supporting the review of deaths of patients with learning disabilities, as outlined in the National Quality Board 2017 guidance.

a) Transforming Care Partnership (TCP) Leeds has established a Transforming Care Partnership and developed an integrated strategic commissioning and delivery plan designed to deliver the TCP in Leeds over the next three years. The outcomes to be achieved by the plan over the next three years include:

By March 2018, reduce the number of inpatient beds used by people with complex learning disabilities and/or autism by 50%.

Prevent specialist hospital admissions where possible for people with complex learning disabilities, autism or both. A Positive Behavioural Support service to support this ambition is currently being developed. The Community Learning Disability Team has been reconfigured to provide enhanced community support.

Develop effective pathways through transition for young people with complex learning disabilities and/or autism. Pathways have been developed in partnership with Children’s services.

Ensure people with complex needs relating to their learning disability and/or autism can be supported in the community and benefit from a coordinated approach to the delivery of housing and accommodation. This includes the development of new build accommodation and new providers into the city. We are also exploring how to support local small providers to support some individuals with particular complex needs.

In order to support this process, a number of different work streams have been established to oversee the development and implementation of the local Transforming Care Plan. The Leeds CCG and Leeds City Council are participating in NHS England led strategies to identify and minimise barriers to discharge.

b) A project over two years, completed in 2016 focussed on improving access to health

checks, providing training and education to GP practice staff across the three Leeds

Appendix A


CCGs, and guidance to ensure that reasonable adjustments are made to support accessing health checks. The work undertaken has provided General Practices with tools and resources which going forward will support practice staff to:

Implement improved patient identification, increasing the numbers of people eligible for the learning disability annual health check

Easy read formats for patient letters to support attendance at health checks

Information and advice on how to improve consultations with learning disability patient

Accessible information to patients on diagnosed health conditions.

Work has been undertaken to improve the general practice audit to establish the current rate of take up of Annual Health Checks. Data gathered will be used to set improvement plans as part of the prevention element of the Leads Health and Care Plan (local delivery plan for West Yorkshire STP). Learning from previous General Practice audits will influence the design and delivery of a revised audit introduced in 2017/18 which going forward will be undertaken on a quarterly basis. Through the review of the community learning disability team a health facilitation team has been developed to work with primary care.

c) Our transforming care plan includes a range of measures to improve access to health services, education and training of staff, and making necessary reasonable adjustments for people with a learning disability or autism. Experts by experience “get me better champions” volunteer in acute local hospitals to promote the development of reasonable adjustments. Investment has been made into the promotion of cancer screening for people with learning disabilities and or autism.

d) We continue to work closely with Child and Adolescent Mental Health Services

(CAMHS) to ensure staff awareness of when to alert us to the need to undertake a community Care, Education and Treatment Review (CETR) and we are intending to revisit previous awareness raising. We are planning to develop a risk stratification policy, in partnership with CAMHs, social care, education and families which will support the assessment of need for a CETR, inclusion on the Community Support Register and referral to the planned Intensive Positive Behaviour Service.

e) The Leeds CCGs Partnership have established processes to ensure providers are aware

of their responsibility to review death of individuals with a Learning Disability and the requirement to ensure adequate availability of trained reviewers within each provider. Our processes are based upon NHS England’s Learning Disabilities Mortality Review (LeDeR) Programme.

Appendix A



‘Must Do’ 9: Improving quality in organisations

Describe how you will: a) Ensure all organisations have plans to improve quality of care, particularly for

organisations in special measures. b) Drawing on the National Quality Board’s resources, measure and improve efficient use

of staffing resources to ensure safe, sustainable and productive services.

c) Participate in the annual publication of findings from reviews of deaths, to include the annual publication of avoidable death rates, and actions they have taken to reduce deaths related to problems in healthcare.

The Leeds CCG recognises the three core components of quality i.e. patient safety, patient experience and clinical effectiveness, as well as the more recent additions of responsiveness and well-led. Our commissioning intentions will ensure that providers are supported to manage additional demand for services associated with public health and primary care initiatives as well as demographic changes. We have developed and agreed a Quality Framework, which sets out the approach and intentions of the Leeds CCG in the commissioning and monitoring of quality and services. It forms the blueprint for the quality team in how we commission and monitor for quality in services and is mapped against the requirements of the NHS national contract for health services and other national requirements, as well as planning for the development of new requirements.

The Framework is owned by our Director of Quality and Safety and Medical Director and is overseen by the Leeds CCG Quality and Performance Committee. It is published on our website to inform the public of our intentions and ambitions in support of our statutory duties.

The Framework sets out how we set, monitor and improve standards of quality in the services that we commission through the following mechanisms and processes:

We meet regularly with senior teams from our major providers at the Clinical Quality Review Group meetings to assure us that they are meeting the required standards of quality and safety. This includes assurance on staffing levels, skill mix and bank/agency usage. We cross-check this information with other measures of quality to ensure that quality care is not compromised.

We monitor mortality rates, and seek assurance that providers have robust governance mechanisms in place to review deaths, including deaths of people with Learning Disabilities (LeDeR process) and identify issues for improvement. We seek assurance providers respond appropriately to national reports.

We make sure that all contracts we hold with providers contain clear standards which reflect good quality care, i.e. that are:

o Safe o Effective o Positive patient experience o Responsive; and o Well led (culture and leadership).

We meet regularly with commissioners from around the region and CQC, to share information and to understand quality in health and social care services across West Yorkshire.

We utilise feedback from our patients, service users and their families to inform our commissioning intentions and service improvements. This is analysed through compliments, concerns and complaints, and from websites such as NHS Choices

Appendix A


and Care Opinion and also information through our Patient Advice and Liaison service (PALs)

We work with CQC and other partners so that we can share concerns about our local providers and understand any risks to patients and decide what action needs to be taken.

We have implemented an Enhanced Quality Surveillance process, which provides a co-ordinated, consistent approach to concerns raised and to agree the necessary actions. This also incorporates a process to support GP practices, Care Homes and other providers who receive poor CQC ratings.

We are working with Leeds City Council to develop and implement aligned processes for Quality Assurance and Quality Improvement in Care Homes.

We are working with our GP members to develop and implement new ways of providing services, led by GPs and other healthcare professionals, with the aim of providing services that are better focused to the health needs of local communities and providing more services away from hospitals.

We work with our providers to understand the types and numbers of incidents that happen. We look for patterns and trends and also review any investigations to make sure they are of high quality.

The Leeds CCG is working with primary care to develop incident investigation skills to ensure that lessons are identified and support patient safety improvements across primary care within Leeds.

We undertake quality visits to different hospitals and departments and we speak to patients to understand their experiences. We also speak to staff about how it feels to work in the service. We also check that the environment is clean and tidy and that patients have the information they need in different formats.

We are developing a pathway approach to conducting quality visits across all providers.

In order to ensure that people receive the most effective care possible and that is in line with nationally agreed standards (NICE), we ask our providers to demonstrate how they assess their services for compliance with these standards, and as commissioners we also use them as the benchmark when designing or changing pathways of care.

Appendix B

NHS Leeds CCG 15F

Financial Position

Revenue Resource Limit

£ 000 2017/18 blank12018/19

Recurrent 1,175,500 1,217,915

Non-Recurrent 19,120 240

Total In-Year allocation 1,194,620 1,218,155

Income and Expenditure

Acute 559,799 573,370

Mental Health 130,969 136,898

Community 132,397 133,990

Continuing Care 50,456 51,738

Primary Care 151,320 154,557

Other Programme 44,762 31,594

Primary Care Co-Commissioning 108,658 112,484

Total Programme Costs 1,178,361 1,194,632

Running Costs 16,259 17,432

Contingency - 6,091

Total Costs 1,194,620 1,218,155

£ 000 2017/18 2018/19

Underspend/(Deficit) In-Year Movement - 0

In-Year (RAG) GREEN GREEN

Net Risk/Headroom (1)

Risk Adjusted Underspend/(Deficit) (0)

Risk Adjusted Underspend/(Deficit) (RAG) RED

Underlying position - Underspend/ (Deficit) 6,430 6,820

Underlying position - Underspend/ (Deficit) % 0.5% 0.6%

Contingency - 6,091

Contingency % 0.0% 0.5%

Contingency (RAG) GREEN

Notified Running Cost Allocation 17,459 17,432

Running Cost 16,259 17,432

Under / (Overspend) 1,200 -

Running Costs (RAG) GREEN GREEN

Population Size (000) 876.0 881.7

Spend per head (£) 18.56 19.77

Key Planning Assumptions

2017/18 2018/19

Notified Allocation Change (£'000) 30,542

Notified Allocation Change (%) 3 sep ccg 2.9%

Tariff Change - Acute (%) 3 sep ccg 0.0%

Tariff Change - Non Acute (%) 3 sep ccg 0.0%

Demographic Growth (%) 3 sep ccg 1.7%

Non Demographic Growth - Acute (%) 3 sep ccg 2.1%

Non Demographic Growth - Cont.Care(%) 3 sep ccg 1.2%

Non Demographic Growth - Prescribing (%) 3 sep ccg 4.4%

Non Demographic Growth - Other Non Acute (%) 3 sep ccg 0.1%

Mental Health Investment Standard Y

Net Efficiency Savings

£ 000 2017/18 2018/19

Recurrent (inclusive of full year effect) 23,800 33,464

Non-Recurrent - -

Total 23,800 33,464

% of Notified Resource 2.0% 2.7%

Unidentified - 0

% Unidentified 0.0% 0.0%

BCF Minimum Pooled Fund 51,229 52,202

RAG GREEN GREEN

BALANCE SHEET memorandum -

Movement on historic underspend/(deficit) 2017/18 2018/19

Brought forward underspend/(deficit) 33,662 33,662

Adjusted for in-year (drawdown)/draw-up - -

In-year change from plan/In-year deficit - 0

Balance carried forward 33,662 33,662

Underspend/(Deficit) % 3.1% 3.0%

Underspend (RAG) GREEN GREEN

Allowable drawdown within business rules 23,000 22,608

Validation

Risk Adjusted Underspend/(Deficit) Cumlative 33,662

Risk Adjusted Underspend/(Deficit) % 3.0%

Risk Adjusted Underspend/(Deficit) (RAG) GREEN

1

Agenda Item: GB 18/05 FOI Exempt: No

NHS Leeds CCG – Governing Body Meeting

Date of meeting: 11 April 2018

Title: Financial Policies

Lead Governing Body Member: Visseh Pejhan-Sykes, Chief Finance Officer

Category of Paper Tick as

appropriate

()

Report Author: Rosemary Reynolds , Deputy Chief Finance Officer – Corporate Finance, Michelle Van Toop, Associate Director of Procurement & Contracting

Decision

Reviewed by EMT/SMT: N/A

Discussion

Reviewed by Committee: Audit Committees in Common – 26 February 2018

Information

Checked by Finance (Y/N/N/A): Y

Approved by Lead Governing Body member (Y/N): Y

Joint Health & Wellbeing Strategy Outcomes – that this report relates to:

1. People will live longer and have healthier lives X

2. People will live full, active and independent lives X

3. People’s quality of life will be improved by access to quality services X

4. People will be actively involved in their health and their care X

5. People will live in healthy, safe and sustainable communities X

Corporate Impact Assessment: Does the Report have any of the following key implications? - Insert brief commentary or refer to body of report or N/A

Statutory/Legal/Regulatory/Contractual requirements

The Procurement Policy describes how the CCG partnership will comply with procurement and competition legislation.

Financial Implications Implementing the correct procurement policies and procedures has a significant impact on Commissioning for Value

Communication and Involvement Issues N/A

Workforce Issues N/A

Equality Issues including Equality Impact assessment

N/A

Environmental Issues N/A

Information Governance Issues including Privacy Impact Assessment

In accordance with GDPR all new procurements must comply with the DPIA policy

2

EXECUTIVE SUMMARY:

As part of the requirements for CCG merger a combined Budgetary Control Framework, Detailed Financial Policies, Operational Scheme of Delegation and Procurement Policy were developed, and submitted to the Leeds CCGs Partnership Audit Committees in Common on 26 February 2018.

The Audit Committees endorsed the policies and the External Auditors (KPMG) confirmed that they were assured by the process to review the policies, that they complied with relevant guidance and were appropriate for the merged CCG. The Governing Body is therefore asked to approve the policies, as attached at Appendices 1-4.

NEXT STEPS: Once agreed the policies will be uploaded to the CCG website and CCG staff made aware of the policies and of their responsibilities regarding compliance.

RECOMMENDATION: The Governing Body is asked to:

(a) Approve the Budgetary Control Framework, Detailed Financial Policies, Operational

Scheme of Delegation and Procurement Policy.

NHS LEEDS CLINICAL COMMISSIONG GROUP

DRAFT BUDGETARY CONTROL FRAMEWORK

April 2018

Version: 01

Appendix 1

NHS Leeds Clinical Commissioning Group Draft Budgetary Control Framework

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BUDGETARY CONTROL FRAMEWORK

Table of Contents 1 INTRODUCTION & BACKGROUND .................................................................. 2 2 ROLES & RESPONSIBLITIES ........................................................................... 3

2.1 CCG Financial Duties ................................................................................. 3 2.2 Delegation of Budget Responsibility ........................................................... 4 2.3 Budget – Definition ..................................................................................... 4

2.4 Budget Holders ........................................................................................... 4 2.5 Budget Holder Role & Responsibility .......................................................... 4 2.6 Finance Officer Responsibility .................................................................... 6

3 BUDGET SETTING ............................................................................................ 6

3.1 Budget Setting Process ............................................................................. 6 3.2 Recurrent and Non-recurrent Funding/Expenditure ................................... 7 3.3 Cost Improvement Plans ........................................................................... 7 3.4 Business Cases ......................................................................................... 8 3.5 Reserves ................................................................................................... 8 3.6 Carry forwards from previous year ............................................................. 9 3.7 External funding, allocations and pilots ...................................................... 9

4 BUDGETARY MANAGEMENT ........................................................................ 10

4.1 Reporting Procedures .............................................................................. 10 4.2 Investigation of Variances ........................................................................ 11 4.3 Underspends ........................................................................................... 11 4.4 Overspends ............................................................................................. 12 4.5 Virement between budgets ...................................................................... 13 4.6 Virement limits ......................................................................................... 13 4.7 Establishment Control .............................................................................. 14 4.8 Compliance with HMRC legislation .......................................................... 14 4.9 Agency Staff Budgets .............................................................................. 14 4.10 Consultancy Spending ............................................................................. 14 4.11 Better Payment Practice Code................................................................. 15 4.12 Cash Management .................................................................................. 15 4.13 Training .................................................................................................... 15

5 CAPITAL .......................................................................................................... 15 6 BUSINESS CASES .......................................................................................... 16 7 COUNTER FRAUD .......................................................................................... 16 APPENDIX 1 - Consultancy spending controls ......................................................... 18


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BUDGETARY CONTROL FRAMEWORK 1 INTRODUCTION & BACKGROUND

In the current economic climate it is even more important than ever to ensure that there are robust budgetary control procedures in place to make best use of the available resources. The Prime Financial Policies (previously called Standing Financial Instructions) detail the financial responsibilities, policies and procedures to be adopted by the CCG. Together with the Standing Orders, Scheme of Reservation & Delegation, financial procedure notes and other locally generated policies, they cover all aspects of financial management and control. Budget holders are required to review procedures for financial management to ensure that they meet the standards laid down and must comply with the directions & guidance in this document. Financial performance is a key objective for senior managers within the CCG and, as such, failure to comply with budgetary control procedures may be treated as a breach of conduct. The budgetary control framework is a key element of the CCG’s internal control environment. It is designed to assist budget holders and managers in the discharge of their responsibilities. It describes the ground-rules within which budgets are to be operated in the financial year, it clarifies roles and responsibilities in respect of budgetary control and it ensures that the budgetary processes of the CCG form part of the overall assurance framework.

The aims of the framework are:

To develop management understanding and capacity in relation to financial matters. This should be to enable managers to get the best possible value from the budgets at their disposal.

To provide the CCG with the necessary controls to ensure that expenditure is incurred in accordance with the CCG’s approved budget.

A number of underlying key themes will be maintained in the framework:

Budgets will be set within the CCG’s expected resource.

Budgets will be set so that they are achievable and realistic with all budget setting methodologies and assumptions being made clear.

Expenditure will not be permitted to exceed budgets without the approval of the CCG Chief Finance Officer.


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There will be no automatic right to receive a budget at the same level as previous years. Budget holders will need to demonstrate how resources within their control are being spent and identify the resultant value for money benefits derived therefrom. Budgets will also reflect the CCG’s policy on management and operational cost reduction schemes and targets.

Actual staff posts will not be permitted to exceed funded establishments.

Budget reports will be issued on a regular basis for appropriate review and action.

Where practicable, expenditure and income budgets will be linked but identified separately in order that trends and performance can be monitored.

Clear ownership / accountability of budgets by budget holder / managers will be required and evidenced through formal sign-off of budgets.

Any proposal requiring additional funds must have appropriate finance input and sign-off, including identification of the source of funding, prior to submission to the Governing body or delegated committee for approval.

2 ROLES & RESPONSIBLITIES 2.1 CCG Financial Duties

The CCG is required to meet a number of key statutory and administrative financial duties:-

Resource limits – a statutory duty to keep expenditure with specified resource limits. The CCG has resource limits for both revenue (RRL) and capital (CRL), which must be met individually;

Cash limits (CL) – a statutory duty not to exceed its cash limit, i.e. do not spend more than the specified cash limit. The CCG has a combined cash limit for both revenue and capital;

Financial balance – CCGs are expected to achieve NHS England set financial control totals each year,.

Better Payments Practice Code – CCGs are required to aim to pay all valid invoices within 30 days of receipt unless other payment terms have been agreed. To meet compliance at least 95% of invoices must be paid within the target.


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2.2 Delegation of Budget Responsibility

The Accountable Officer will delegate responsibility for the management of budgets to individuals in line with the scheme of delegation to permit such managers to perform their duties. Any delegation of budgets by the Accountable Officer will be specified in a financial scheme of delegation, which will provide a clear definition of responsibility for the control of expenditure, the exercise of virements and the limits on the authorisation of expenditure.

2.3 Budget – Definition

A budget is a specific sum of money allocated to carry out a specific plan for a specific period. It expresses plans and intentions in resource and financial terms having regard for the quantity and quality of services to be given.

2.4 Budget Holders

Budgets will be held by the individuals who are responsible for running services or delivering specific objectives. Such responsibility will be mirrored by accountability, through a budget, for the use of resources in discharging those responsibilities. It is recognised that an awareness of financial control should be embedded within the culture of the organisation. As such budget holders are responsible for ensuring that they, and staff within their team, are conversant with current finance issues and understand the financial implications of their decisions and actions. Whilst recognising these working relationships, budgetary responsibility is vested in one individual for accountability purposes.

2.5 Budget Holder Role & Responsibility

A nominated Finance Officer will be allocated to each budget to help the budget holder manage their financial resources. All budget holders have a number of responsibilities. These include:-

Set realistic budgets in conjunction with the Finance Officer within the sum allocated.

Deliver the service/objective within the financial and manpower limits set within the budget.


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Spend funds only as required and to manage funds / manpower such that the best possible value for money is obtained at all times from the public purse.

Work within the establishment control process to ensure that all posts are properly funded and approved.

Timely approval and accurate coding of financial documents, eg invoices.

Monitor budgets on a regular basis, at least monthly.

Work closely with Finance Officers, keeping them informed of any forthcoming financial issues, identifying risks that will affect the financial position and agreeing the likely year end forecast outturn position.

Inform the Finance Officer of the underlying reasons for any budget variances, taking into account any virement options.

When areas of overspend have been highlighted, develop an action plan to demonstrate how the circumstances are to be corrected, keeping the Finance Officer informed of reasons for the variance and the action being taken to correct the position.

Comply with the Financial Directions for NHS CCGs in England and the CCG’s Standing Orders, Prime Financial Policies, Detailed Financial Policies and Tendering & Contracting procedures at all times.

Budgets must be maintained in accordance with the CCG’s overall plans and policies and must be used only for the purpose for which they are provided except where otherwise approved by the Governing body.

Budget holders are responsible for the production of business cases to the level and standard outlined in section 6 of this document in response to any requests from the Executive Team. These could be required in support of bids for additional funding or in order to justify expenditure which is already budgeted for within existing budgets.

The management of a budget may be delegated to a named budget manager by the budget holder. Whilst the budget manager must comply with all the above requirements, the budget holder remains accountable for the performance of the budget(s) under their control. A comprehensive list of budget holders and budget managers will be maintained by the Finance Team. Executive Officers are responsible for ensuring that any change within the budget authorisation hierarchy is


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properly notified in writing to their nominated Finance Officer at the earliest opportunity.

2.6 Finance Officer Responsibility

Each budget holder will be allocated a Finance Officer whose responsibility it will be to:-

Provide accurate, timely and relevant information to help budget holders manage their budgets;

Make contact with budget holders on a regular basis to discuss any budgetary issues and forecasts;

Work closely with budget holders to understand the nature and patterns of expenditure and agree the likely forecast outturn position at the year end (i.e. the extent to which expenditure is likely to deviate from budget).

Provide advice and assistance to budget holders in the management of their budgets. Notwithstanding this, budget holders are ultimately responsible for the consequences of their decisions.

Provide advice and assist the budget holder complete business case documentation for new developments or reviews of existing services.

Maintain a financial risk register, ensuring this is owned and updated by the budget holder.

Maintain records to ensure that budgets accurately reflect the approved establishment levels.

3 BUDGET SETTING

3.1 Budget Setting Process

The financial plans and resultant annual budgets are based on the CCG’s anticipated resources, risks, efficiency targets and developments known at the time of setting the budget. Budgets will originate from discussions between budget holders and finance managers, informed by ongoing discussion throughout the year. Finance Officers will ensure that they have access to the latest strategic planning assumptions applied by the CCG’s Senior Management Team. For planning purposes recurrent budgets will be ‘rolled over’ to form the baseline for the following year. However there will be no automatic right to receive this rolled forward budget in full. Budget holders will need to


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demonstrate how resources within their control are being spent and identify the resultant value for money benefits. They may be called upon to justify specific spending schemes via the business case process before elements of their full budget is released to them. The business planning cycle will ensure that all identified developments and cost pressures are assessed, prioritised and approved by the CCG with reference to local and national targets. Throughout the year, it will also serve as a tool for evaluating and potentially disinvesting in services which are already in place. Inflation adjustments will be applied in line with agreed financial planning assumptions. Budgets are subject to Cost Improvement or Efficiency targets set both nationally and locally by the CCG. Budget holders are required to develop realistic and achievable schemes in order to meet these targets. All budgets must be agreed and “signed-off” by the appropriate budget holder.

Budgets must be approved by Governing body prior to the start of the financial year and in advance of any new financial commitments being made.

3.2 Recurrent and Non-recurrent Funding/Expenditure

Recurrent (on-going) and non-recurrent (current year only/time limited) budgets will be separately identified and agreed with budget holders and managers. Under no circumstances should recurrent expenditure be committed against non-recurrent funding unless by prior written agreement of the CCG Chief Finance Officer. Non-recurrent funding may only be used to meet non-recurrent expenditure and will be withdrawn at the commencement of the next financial year unless by prior written agreement of the CCG Chief Finance Officer. Where external funding streams are identified as being non-recurrent, a written agreement which confirms funding arrangements must be signed by the external stakeholder/agency prior to any financial commitment being made by the CCG (eg. advertising posts).

3.3 Cost Improvement Plans

Cost efficiency measures will be agreed with budget holders prior to the start of each financial year and deducted from base budgets. Each


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measure will be monitored and reviewed on a monthly basis against the planned savings. Where actual performance is below that planned, a revised action plan must be agreed to deliver the agreed savings. The ownership of any savings plan (i.e. who may claim to such savings) must be identified at the outset when plans are made.

3.4 Business Cases

Business Cases must be produced in line with guidance in section 6. Business Cases will be required for all proposed developments. They may also be requested by the Executive Team in connection with any existing schemes within a budget holder’s area of responsibility. All Business Cases must have appropriate input and support from the finance department. In particular the source of funding must be identified and confirmed by the Finance Officer prior to submission to the Governing body or delegated committee for approval. This will ensure that the associated costs are accurate and provide an additional check to ensure that all financial considerations have been taken into account. It will also ensure that, for both new and existing schemes, there is absolute clarity around the reasons for and the benefits and outcomes of the schemes under review. Any changes to commissioned activity/spend and cost pressures impacting on budgetary spend must be approved in the same way as new developments. Baseline budgets will not be automatically reset to accommodate cost pressures. Budget holders must formally apply for additional budgetary resources under the same rules as for investments & developments using through the agreed business planning process. Approved development funding will be retained within Reserves until confirmation is received that the development has commenced. At such a time the budget will be released to a designated budget holder through the formal budget virement process. The amount released to the budget holder will reflect any slippage between the planned start date and the actual start date. Further advice regarding the format & content of a business case can be obtained from the Finance Officer.

3.5 Reserves

The CCG Chief Finance Officer, on behalf of the Accountable Officer, will endeavour to create such reserves as are deemed necessary to secure the ability of the CCG to meet its financial duties. Reserves may include sums to cover future pay awards, price inflation, unforeseen contingencies, non-recurrent spending or other specific items as not yet allocated to individual budgets.


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The CCG Chief Finance Officer may exercise discretion to partly or wholly allocate reserves directly to departments for subsequent allocation to specific budgets.

Reserves will be reviewed on a monthly basis to determine both their adequacy and necessity. All changes to revenue resource allocations notified by the Department of Health will be reflected initially in reserves. Budget holders do not have an automatic right to receive an allocation direct into their budgets. Funds will only be released from reserves when the CCG Chief Finance Officer is satisfied that:

The appropriate approval process and procedures have been complied with;

There is a sound financial strategy in place for spending the resource;

The purpose is in line with the CCGs strategic objectives and demonstrates value for money;

The proposed use of resource is not or cannot be funded from within existing budgets; and

The commitment will not jeopardise the CCGs ability to meet its statutory duties and financial targets.

3.6 Carry forwards from previous year

Automatic carry-forwards of unused budget funds for individual budgets from the prior financial year will not be available. Where a CCG has received ‘ring fenced’ income (not allocations), which would otherwise be lost to the organisation, non-recurrent budget carry forwards may be considered subject to written approval by the Chief Finance Officer. Under no circumstances can unused allocations received from the Department of Health or NHS England be carried forward.

3.7 External funding, allocations and pilots

No applications should be made for any additional external funding towards pilots or service developments without formal financial sign-off. This is to ensure that any projected costs submitted are validated and that the finance department is aware of the application in order to track receipt of the external funding.


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No funds should be committed until allocations have been confirmed.

4 BUDGETARY MANAGEMENT 4.1 Reporting Procedures

Each budget holder will be provided with a monthly budget report within 10 working days of the month end to which the report relates. In order to provide an accurate financial position, prior to the reports being finalised:-

Accruals (sums entered to reflect resources consumed but not yet actually paid for) will be entered by the Finance Team on a monthly basis. This includes for Goods / Services Received and not paid for (“GRNI”).

Prepayment adjustments (sums entered to reflect payments made in advance of resources consumed) will also be entered by the Finance Team on a monthly basis.

No accruals or prepayment adjustments will be entered which are merely ‘balances to budget’.

Error suspense reconciliations will be cleared promptly each month by the Finance Team before the deadline for monthly closedown of the general ledger.

A schedule of dates on which budget holders and managers will receive budget statements in respect of each accounting period will be issued. Executive Officer level budget holders will receive summarised versions of financial statements identifying performance against each budget area within their remit. All budget holders will continue to receive detailed budget statements by Cost Centre and will also be provided with additional information in relation to payroll expenditure. Budget holders will be instrumental in underwriting the accuracy of forecasts provided in conjunction with the Finance Officer as they should have a more in-depth understanding of their budget area and be aware of any commitments (e.g. Purchase orders raised / SLAs agreed and performance to date). A regular review will take place, involving both the Finance Officer and budget holder to ensure that the budget reports reflect a true record of


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the expenditure position to date and to agree the forecast position for the year end. The CCG Chief Finance Officer will produce a monthly position statement for the Governing body which will:-

highlight performance against the CCG’s key financial targets;

provide explanations for major variances against budgets and action being taken to rectify the position;

identify major financial risks that could affect the CCG’s financial position and details of any action being taken to mitigate them.

4.2 Investigation of Variances

A budget holder must manage their overall budget position within the resources available. Variances, where income or expenditure differs from the budget, during the year need to be fully understood by the budget holder in order that the underlying financial position can be determined and appropriate management action taken to bring expenditure back in line with the budget. All significant variances should be investigated rapidly by the budget holder in liaison with the Finance Officer. When variances become apparent during the monthly reporting cycle, every effort should be made to investigate the cause of the variance within one week. In respect of significant adverse variances, action to remedy (or cover) the problem should be taken as quickly as possible, but only after seeking appropriate advice. Failure to take prompt action could lead to more drastic measures becoming necessary at a later stage. As part of the year end closedown process, budget holders will be asked to highlight and explain any significant variance in advance of the audit. The investigation threshold will be linked to the external auditors materiality or testing level.

4.3 Underspends

Budget holders are encouraged to generate savings and underspends, without reducing quality of service or administrative performance. Budget holders should note that underspends in any year are not normally carried forward for use in a subsequent year. If a budget is forecast to be underspent, the savings will be classified into two distinct categories:


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1) Fortuitous – these are savings which accrue without the budget holder taking any specific action, eg staff turnover.

2) Planned – these are savings which are the direct result of specific

action taken by the budget holder. Fortuitous savings will normally be vired to Central Reserves for the CCG to use, for example, to alleviate financial pressures elsewhere within the CCG or to fund new investments/developments. For planned savings, discussion with the CCG Chief Finance Officer will determine whether some/all of the savings should be retained by the budget holder in the current year. Wherever possible budget holders should be allowed to retain planned underspends for alternative use provided that sound proposals can be put forward which will not jeopardize the CCG’s overall financial position. Confirmation will be required that any commitment is of a non-recurrent nature and that the budget holder has clearly identified how and when savings will be released.

Notwithstanding these arrangements, the CCG Chief Finance Officer has the right to request the use of any planned savings to alleviate financial pressures elsewhere within the CCG or to fund new developments.

4.4 Overspends

A budget holder does not have the authority to overspend their budget(s). The Governing body must safeguard its overall spending position with regard to the CCG’s statutory financial duties and will expect appropriate prompt action to be taken in order to minimize the serious consequences of potential overspending. Where budget holders become aware that possible significant overspends could arise, immediate action must be taken to rectify the situation. The budget holder must inform the CCG Chief Finance Officer or a senior member of the Finance Team as quickly as possible. Delay that leads to a loss in opportunity to regulate overspending will be viewed as a serious breach of conduct. Expenditure for which no budgetary provision has been made and which cannot be covered by delegated powers of transfer must not be incurred without the express permission of the Governing Body. The Governing Body have delegated this power to the Accountable Officer or CCG Chief Finance Officer. When this power is exercised, it must be reported to the Governing Body at the earliest opportunity.


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Where power to transfer between budgets or budget headings has not been delegated, setting an underspend against a corresponding overspend is not permitted. Overspends will not normally be carried forward from one year to another. Executive Officers and budget holders are expected to provide a financial strategy to ensure that a balanced budget is achieved.

4.5 Virement between budgets

As a general principle, budget holders must not incur expenditure which is normally chargeable to the budgets of other budget holders without prior written authority. Virement (transfer) of funds between budgets/reserves may be necessary during the year for a number of reasons. One of these would relate to the peaks and troughs of service demand that may of necessity require some flexing of budgets. Budget holders may wish to vire funds from within their own budgets (budget lines) or with budgets held by others. In all cases, a virement form must be completed (in conjunction with the Finance Officer) and signed by both the budget manager and the designated Finance Officer.

In those cases where transfers between budget holders are requested, the signature of both budget holders will be required before any budget is amended. The recipient should not assume that the virement will occur and must not take any action which commits expenditure until all signatures have been obtained. A record of all budget changes from initial base budgets will be maintained by the Finance Team. Virements cannot be actioned for:

Non-recurrent funds to meet recurrent commitments;

Transfers between capital and revenue (either way) without written approval of the CCG Chief Finance Officer;

Where it would increase running costs, unless approved by the CCG Chief Finance Officer.

4.6 Virement limits

The Accountable Officer and CCG Chief Finance Officer have unlimited powers of virement. Executive Officers and budget holders are required to consult with their Finance Officer when considering the financial viability of virement


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proposals. The CCG Chief Finance Officer will be informed of all authorised virements.

4.7 Establishment Control

Prior to placing a job advertisement the proper establishment control procedure must be followed. In completing the establishment control documentation the originating manager must:-

Identify how the full cost of the post will be funded. This will include, where applicable, costs relating to salary, travel, training, furniture, equipment, computer, mobile phone, etc.

Explain why the post should be filled, the impact on service delivery of not filling the vacancy and the financial impact of filling/not filling the vacancy.

Establishment control forms completed in respect of all posts must be counter-signed by the Finance Officer as additional confirmation of availability of funding for the post.

Copies of all changes to establishments will be sent to the Finance Team to ensure that they are matched with budgets.

The above will facilitate the better management of budgets by ensuring that financial information is kept up to-date and will ensure that posts are only placed against funded positions.

4.8 Compliance with HMRC legislation

The establishment control process must demonstrate compliance with HMRC requirements in relation to IR35/Off payroll regulations.

4.9 Agency Staff Budgets

The establishment control process must be followed for all agency staff requirements. Where agency staff are used, the appropriate establishment budget will be charged the actual agency/bank staff time (whole time equivalent) as well as cost. The cost of agency staff is normally more expensive than NHS staff and therefore a budget manager must ensure that sufficient funds are available within the overall budget to accommodate this additional cost.

4.10 Consultancy Spending

Monitor, the NHS Development Authority and NHS England implemented consultancy spend controls effective from 2nd June 2015. The controls process requires NHS providers and NHS commissioners to demonstrate value for money of proposed consultancy support


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against a number of assessment criteria, plus a post implementation report on benefits of work and value added. The local CCG procedure for managing this requirement is appended at appendix 1

4.11 Better Payment Practice Code

Each CCG is required to pay at least 95% (by volume and value) of NHS and non-NHS creditors within 30 days unless other payment terms have been agreed. It is important, therefore, that those who are required to authorise invoices / or provide proof of delivery of goods or services against purchase orders should do so immediately or as soon as practicable upon receipt. The Finance Team will actively manage performance against this target and will contact all budget holders to ensure that appropriate actions are taken in a timely manner.

4.12 Cash Management

CCGs are required to keep minimal month end cash balance. It is not allowed to carry surplus cash above this limit nor is it allowed to run with an overdraft. To support the achievement of this very tight control, budget holders are required to confirm the payment profile for significant expenditure budgets with their Finance Officer. The Finance Team will maintain a rigorous cash forecasting regime to oversee compliance and will be required to manage any variation from the forecast on a monthly basis.

4.13 Training

Budget holders will receive appropriate training in budget management from Finance staff. It is essential that any training requirements are raised with your Finance Officer at the regular review meetings to ensure that there are no gaps in control.

5 CAPITAL

Capital expenditure is expenditure on a tangible productive asset, costing £5,000 or more, with an expected life in excess of one year. The figure of £5,000 includes VAT where this is non-recoverable.

A group of assets which individually may cost less than £5,000, but collectively cost more than £5,000 may be capitalised where the items fulfil all of the following criteria:-

Individually the items cost more than £250;


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They are functionally interdependent;

They are acquired at about the same date and are planned for disposal at about the same date; and

They are under single managerial control.

A business case must be prepared for all capital schemes. Each proposal must have appropriate input and support from the Finance Officer prior to submission to the Governing body or delegated sub committee/individual for approval. This will ensure that the associated costs, including revenue, are accurate and provide an additional check to ensure that all financial considerations have been taken into account. Ultimate approval of all capital schemes rests with the NHS England. Where schemes are proposed, no assumptions may otherwise be made regarding the splitting of capital costs between revenue and capital budgets. However, notwithstanding the above, any capital scheme must clearly include and have approval for any revenue commitments arising from the scheme. No virement will be permissible between revenue funding and capital funding without the written agreement of the CCG Chief Finance Officer. Once approved each capital scheme will have a designated budget holder who will be responsible for ensuring that expenditure does not exceed approved values. The general rules stipulated within this budgetary control framework will also apply to capital expenditure.

6 BUSINESS CASES

This guidance should be read in conjunction with section 3.4. Detailed guidance on business case format along with a template is saved on the CCG extranet.

Further advice regarding the format & content of a business case can be obtained from the designated Finance Officer.

7 COUNTER FRAUD NHS Protect, part of the NHS Business Services Authority, is responsible for tackling all fraud and corruption in the NHS. It is there to protect NHS resources so that they can be used to provide the best possible patient care. The CCG’s Fraud & Corruption Policy defines the policy for dealing with suspected fraud and other fraudulent acts, dishonesty involving employees, contractors and their employees.


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The CCG has a designated Local Counter Fraud Specialist (LCFS) who is the main point of contact for anyone in the CCG who is concerned or suspicious. Staff who have any concerns or suspicions of any activity that may be fraudulent should contact one of the following immediately:-

Local Counter Fraud Specialist on 01904 725145 Chief Finance Officer on 0113 843 5497 National Fraud & Corruption Reporting Line on 0800 028 40 60Or

alternatively report their concerns via the: NHS Online Fraud Reporting Form www.reportnhsfraud.nhs.uk

Staff are protected by the Hearing Staff Concerns ‘Whistle-blowing’ Policy. This, together with the Fraud & Corruption Policy, can be found on the CCG intranet site.


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APPENDIX 1 - Consultancy spending controls Introduction Monitor, the NHS Trust Development Authority (TDA) and NHS England (NHSE) implemented consultancy spend controls effective from 2nd June 2015. The controls process requires NHS providers and NHS commissioners to demonstrate value for money of proposed consultancy support against a number of assessment criteria, plus a post implementation report on benefits of work and value added. The controls and definitions Any future consultancy contracts awarded over and above £50k (inclusive of VAT) require prior approval through a business case process by NHS England (see Consultancy spending controls: a note to CCGs available on the extranet) Any future contracts over £250k will be subject to more senior approval requirements within NHS England as detailed in the above guidance. The controls also apply to extensions of existing contracts where the total value of the contract (including the proposed extension) exceeds £50K. Consultancy (for the purposes of these controls is defined in NHS manual for accounts as) – The provision to management of objective advice and assistance relating to strategy, structure, management or operations of an organisation in pursuit of its purposes and objectives. Such assistance will be provided outside the “business as usual” (BAU) environment when in-house skills are not available and will be of no essential consequence and time-limited. Services may include the identification of options with recommendations and/or assistance with (but not delivery of) the implementation of solutions. The consultancy category will include areas such as: o strategy; o finance; o organisational and change management;


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o IT; o property and construction; o procurement; o legal services; o marketing and communication; o HR; o training and education; o programme and project management, and o technical.

Specific Exclusions: o expenditure with Commissioning support Units (CSU’s), and o internal and external audit (including counter fraud services).

The controls do not currently apply to interim agency staff although this has not been ruled out as a further control in the future for CCGs. For completeness agency staff can be defined as – Staff brought in to cover for a professional, functional or management role, usually on a short term basis. For example, the resource brought in may provide cover for a vacancy, maternity leave or period of sickness, or provide additional resources for a seasonal peak in workload. This category may include professional interim staff who are likely to have a degree of organisational involvement e.g. by managing staff or by representing the team at meetings. Internal process Budget holders should - o Identify resource needed including cost and for how long.


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o Ensure funding available within budget - obtain sign off from finance that funding is available. o If the initial Cost >£50k - full Business case required and submitted to SMT. o If the initial cost plus extension >£50k - full Business case required and submitted to SMT. o If the total cost < £50k - request to SMT in the form of a brief report Following SMT approval Business Cases will be forwarded to NHSE for approval in accordance with the guidance. SMT will receive ongoing monitoring reports on consultancy expenditure throughout the year. Business case template and guidance can be found on the extranet under finance. Post implementation Post implementation reports will be required to be submitted to NHSE on ALL (including under £50k) consultancy expenditure. Please contact CCG Finance department with any queries on the controls or process.

THIS PAGE IS INTENTIONALLY BLANK

DRAFT

DETAILED

FINANCIAL

POLICIES

Version: 01

Date: April 2018

Appendix 2

Version: 01 Effective Date:

Page 2 of 31

Contents 1. Introduction .............................................................................................................................................. 4

1.1 General ............................................................................................................................................. 4

1.2 Responsibilities and Delegation ................................................................................................... 5

2. Audit .......................................................................................................................................................... 8

2.1 Audit Committee .............................................................................................................................. 8

2.2 Chief Financial Officer .................................................................................................................... 9

2.3 Role of Internal Audit .................................................................................................................... 10

2.4 External Audit ................................................................................................................................ 11

2.5 Fraud and Corruption ................................................................................................................... 11

2.6 Security Management .................................................................................................................. 11

3. Resource Limit Control......................................................................................................................... 12

3.1 Cash and Resource Limits .......................................................................................................... 12

3.2 Allocations ...................................................................................................................................... 12

3.3 Budgetary Delegation ................................................................................................................... 12

3.4 Budgetary Control and Reporting ............................................................................................... 13

3.5 Capital expenditure ....................................................................................................................... 14

3.6 Monitoring Returns ....................................................................................................................... 14

4. Banking Arrangements ........................................................................................................................ 14

4.1 General ........................................................................................................................................... 14

4.2 Commercial (Bank) and Government Banking Service (GBS) Accounts ............................. 14

4.3 Banking procedures ...................................................................................................................... 14

4.4 Tendering and review ................................................................................................................... 15

5. Income, Fees and Charges and Security of Cash, Cheques and Other Negotiable Instruments ……………………………………………………………………………………………………………………………………………………………15

5.1 Income Systems ............................................................................................................................ 15

5.2 Fees and Charges ........................................................................................................................ 15

5.3 Debt Recovery ............................................................................................................................... 15


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5.4 Security of Cash, Cheques and Other Negotiable Instruments ............................................. 16

6. Capital investment, asset register and security of assets .............................................................. 16

6.1 Capital Investment ........................................................................................................................ 16

6.2 Asset Registers ............................................................................................................................. 18

6.3 Security of Assets ......................................................................................................................... 19

7. Payment of staff .................................................................................................................................... 19

7.1 Funded Establishment ................................................................................................................. 19

7.2 Processing Payroll ........................................................................................................................ 20

7.3 Contracts of Employment ............................................................................................................ 21

8. Payment of Accounts ........................................................................................................................... 21

9. Tendering and Quotations ................................................................................................................... 22

10. Contracting and Purchasing ................................................................................................................ 23

11. Terms of Service, Allowances and Payment of Members of the NHS Governing Board and Employees ..................................................................................................................................................... 24

11.1 Remuneration and terms of service ........................................................................................... 24

11.2 Funded Establishment ................................................................................................................. 25

11.3 Staff Appointments ....................................................................................................................... 25

11.4 Contracts of Employment ............................................................................................................ 25

12. Non - Pay Expenditure ......................................................................................................................... 25

13. Stores and Receipt of Goods .............................................................................................................. 26

13.1 General Position ............................................................................................................................ 26

13.2 Control of Stores, Stocktaking, Condemnations and Disposal .............................................. 26

14. Disposals and Condemnations, Losses and Special Payments ................................................... 26

14.1 Disposals and Condemnations ................................................................................................... 26

14.2 Losses and Special Payments .................................................................................................... 27

15. Information Technology ....................................................................................................................... 28

15.1 General ........................................................................................................................................... 28

15.2 Finance ........................................................................................................................................... 28


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16. Information Governance ...................................................................................................................... 28

17. Retention of Documents ...................................................................................................................... 29

18. Risk Management and Insurance ....................................................................................................... 29

19. Custody of Seal, Sealing of Documents and Signature of Documents………………………….31

1. Introduction

1.1 General

1.1.1 These Detailed Financial Policies (DFPs) are issued in accordance with the Directions

issued by the Secretary of State for Health under the provisions of the NHS Act 2006 as

amended by the Health and Social Care Act 2012, with responsibilities set out under that

and subsequent secondary legislation for the regulation of the conduct of NHS Leeds

clinical commissioning group (NHSLCCG) in relation to all financial matters. They shall

have effect as if incorporated in the Standing Orders (SOs) of the NHSLCCG.

1.1.2 These DFPs detail the financial responsibilities, policies and procedures adopted by the

NHSLCCG. They are designed to ensure that the NHS LCCG’s financial transactions are

carried out in accordance with the law and Government policy in order to achieve probity,

accuracy, economy, efficiency and effectiveness. They should be used in conjunction

with the matters reserved to the Governing Body and the scheme of delegation.

1.1.3 These DFPs identify the financial responsibilities that apply to everyone working for the

NHSLCCG and its constitutional organisations. The user of these DFPs must also take

into account relevant prevailing Department of Health and/or Treasury instructions. The

Chief Financial Officer must approve all financial procedures.

1.1.4 Should any difficulties arise regarding the interpretation or application of any of the DFPs,

the advice of the Chief Financial Officer must be sought before acting. The user of these

DFPs should also be familiar with and comply with the NHSLCCG Standing Orders (SOs).

1.1.5 The failure to comply with DFPs and standing orders can in certain circumstances be

regarded as a disciplinary matter that could result in dismissal.

1.1.6 If for any reason these DFPs are not complied with, full details of the non-compliance and

any justification for non-compliance shall be reported to the next formal meeting of the

Audit Committee for determining or ratifying action. All members of the Governing Body,

and all staff, have a duty to disclose any non-compliance with these DFPs to the Chief

Financial Officer as soon as possible.

1.1.7 Wherever the title Chief Officer, Chief Financial Officer, or other nominated officer is used

in these instructions, it shall be deemed to include such other directors or employees as

have been duly authorised to represent them, except in respect of Banking Arrangements

(see section 4).

1.1.8 Any expression to which a meaning is given in the National Health Service Act 2006 (as


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amended) or in the Financial Directions made under the Act shall have the same meaning

in these instructions; and

(a) “Budget" means an amount of resources expressed in financial terms proposed by

the NHSLCCG for the purpose of carrying out over a specific period all or part of the

functions of the NHSLCCG.

(b) “Budget Holder" means the individual with delegated NHSLCCG authority to

manage finances (income and expenditure) for a specific area of the organisation.

(c) “Budget Manager" refers to those officers who are required to manage budgets on

behalf of the respective Budget Holder.

(d) “Chief Officer" means the officer of the NHSLCCG (who is directly accountable to

the Governing Body).

(e) “Accounting Officer” means the officer responsible and accountable for funds

entrusted to the NHSLCCG. He/she shall be responsible for ensuring the proper

stewardship of public funds and assets. The Accounting Officer for the NHSLCCG is

the Chief Officer.

(f) “Governing Body” means the Chair, non-executive directors and voting executive

directors of the NHSLCCG collectively as a body.

(g) “Leadership Team” is the senior management team of the NHSLCCG as designated

by the Chief Officer.

(h) “Officer" means employee of the NHSLCCG or any other person holding a paid appointment or office with the NHSLCCG.

1.2 Responsibilities and Delegation

1.2.1 The Governing Body

1.2.1.1 The Governing Body exercises financial supervision and control by:

(a) formulating the financial strategy;

(b) requiring the submission and approval of budgets within approved allocations/overall

income;

(c) defining and approving essential features of financial arrangements in respect of

important procedures and financial systems, including the need to obtain value for

money; and

(d) defining specific responsibilities placed on members of the Governing Body and

officers as indicated in the Scheme of Delegation document.

(e) approval of the Financial Statements and Annual Report

1.2.1.2 The Governing Body has resolved that certain powers and decisions may only be


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exercised by the Governing Body in formal session. These are set in the CCG’s

Constitution Document.

1.2.1.3 The Governing Body will delegate responsibility for the performance of its functions in

accordance with the SOs and the scheme of delegation document adopted by the

NHSLCCG.

1.2.2 The Chief Officer and Chief Financial Officer

1.2.2.1 The Chief Officer and Chief Financial Officer will, as far as possible, delegate their

detailed responsibilities, but they remain accountable for financial control.

1.2.2.2 Within the Instructions it is acknowledged that the Chief Officer will have ultimate

responsibility for ensuring that the NHSLCCG meets its obligation to perform its functions

within the financial resources made available to it. The Chief Officer has overall executive

responsibility for the NHSLCCG activities and is responsible to the Governing Body for

ensuring that it stays within its resource and cash limits.

1.2.2.3 The Chief Officer will delegate detailed responsibility for financial activities and controls to

the Chief Financial Officer but retain overall accountability. The extent of such delegation

will be determined in the NHSLCCG scheme of delegation and should be kept under

review by the Governing Body.

1.2.2.4 The Chief Officer, through the Chief Financial Officer, shall be responsible for the

implementation of the NHSLCCG financial policies and for co-ordinating any corrective

action necessary to further these policies.

1.2.2.5 It shall be the responsibility of the Chief Officer to ensure that existing staff and all new

employees are notified of their responsibilities within these instructions, and in particular

policy in relation to potential corruption and the acceptance of gifts and hospitality. The

general principle is that all staff and members of the Governing Body must be, and must

be seen to be, fair, impartial and unbiased at all times. The offer or receipt of any gift and

hospitality can create actual or perceived conflicts of interest, but at the same time refusal

could cause embarrassment or unintentional offence. The offer of a gift, favour, or

exceptionally generous hospitality should be treated with caution. For further information

see NHSLCCG’s Standards of Business Conduct Policy.

1.2.2.6 The Chief Officer shall ensure that the NHSLCCG has a programme of risk management,

in accordance with current Department of Health assurance framework requirements,

which shall be approved by the Governing Body and monitored by the Audit Committee.

1.2.2.7 The programme of risk management shall include:

a) a process for identifying and quantifying risks and potential liabilities;

b) engendering among all levels of staff a positive attitude towards the control of risk;

c) management processes to ensure that all significant risks and potential liabilities are

addressed including effective systems of internal control and decisions on the

acceptable level of retained risk;


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d) contingency plans to offset the impact of adverse events;

e) audit arrangements including internal audit and health and safety reviews; and

f) arrangements to review the risk management programme.

1.2.2.8 The existence, integration and evaluation of the above elements will assist in providing a

basis to make a statement on the effectiveness of internal control within the annual report

and accounts as required by the Department of Health.

1.2.3 The Chief Financial Officer

1.2.3.1 The Chief Financial Officer is responsible for:

a) implementing the NHSLCCG financial policies and for co-ordinating any corrective

action necessary to further these policies;

b) maintaining an effective system of financial control including ensuring that detailed

financial procedures and systems incorporating the principles of separation of duties

and internal checks are prepared, documented and maintained to supplement these

instructions; and

c) ensuring that sufficient records are maintained to show and explain the NHSLCCG

transactions, in order to disclose, with reasonable accuracy, the financial position of

the NHSLCCG at any time.

1.2.3.2 Without prejudice to any other functions of the NHSLCCG, and employees of the

NHSLCCG, the duties of Chief Financial Officer shall include:

a) The provision of financial advice to the NHSLCCG and its employees;

b) The design, implementation and supervision of systems of internal financial control;

and

c) The preparation and maintenance of such accounts, certificates, estimates, records

and reports as the NHSLCCG may require for the purpose of carrying out its

statutory duties, including preparing the Financial Statements and Annual Accounts.

1.2.3.3 The Chief Financial Officer shall ensure that insurance arrangements exist in accordance

with the risk management programme and shall demonstrate value for money for any

insurance obtained.

1.2.4 Governing Body Members and Employees

1.2.4.1 All members of the Governing Body and employees, severally and collectively, are

responsible for:

a) the security of the property of the NHSLCCG;

b) avoiding loss;

c) exercising economy and efficiency in the use of resources; and


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d) conforming with the requirements of SOs, DFPs, scheme of delegation and financial

procedures.

1.2.4.2 It shall be the duty of any officer having evidence of, or reason to suspect, financial or

other irregularities or impropriety in relation to these regulations to report these suspicions

to the Chief Financial Officer. The Chief Financial Officer will consider the suspicions to

determine if the case should be referred to the Counter Fraud Specialist. A detailed

investigation should not be conducted as this may compromise any investigation by the

Counter Fraud Specialist.

1.2.4.3 For all members of the Governing Body and any employees who carry out a financial

function, the form in which the financial records are kept and the manner in which

members of the Governing Body and employees discharge their duties must be to the

satisfaction of the Chief Financial Officer.

1.2.5 Contracts, Contractors and their Employees

1.2.5.1 Directors responsible for arranging contracts for the provision of items and/or services

shall ensure that those contracts are correctly monitored and governed within the

contract's terms and conditions.

1.2.5.2 Any contractor or employee of a contractor who is empowered by the NHSLCCG to

commit the NHSLCCG to expenditure or who is authorised to obtain income shall be

covered by these instructions. It is the responsibility of the Chief Officer to ensure that

such persons are made aware of this.

1.2.5.3 All contractors must agree to, and sign copies of, the NHSLCCG Information Governance

policies and in particular the requirements of the Data Protection Act before accessing

NHSLCCG records.

1.2.5.4 All contractors must agree to, and sign copies of, the NHS LCCG IT Security Policy before accessing any of the NHSLCCG IT systems.

2. Audit

2.1 Audit Committee 2.1.1 In accordance with SOs (and as set out in guidance issued by the Department of Health

under EL(94) 40), the NHSLCCG shall establish an Audit Committee. The terms of reference of the Audit Committee shall be drawn up and approved by the Governing Body, and are incorporated in the SOs. The Audit Committee will provide an independent and objective view of internal control by: a) overseeing internal and external audit services;

b) reviewing financial and information systems, monitoring the integrity of the financial

statements (including Annual Accounts and Annual Reports) and reviewing

significant financial reporting judgements;

c) reviewing the establishment and maintenance of an effective system of risk

management and internal control, across the whole of the organisations activities,


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that supports achievement of the organisations objectives.

d) monitoring compliance with SOs and DFPs;

e) ensuring that the organisation has adequate arrangements in place for countering

fraud and reviewing the outcomes of counter fraud work;

f) reviewing schedules of losses and compensations and making recommendations to

the Governing Body;

g) reviewing the work of other committees, and other significant assurance providers or

functions, which can provide relevant assurances; and

h) requesting and reviewing reports and positive assurances from directors and

managers on overall arrangements for governance, risk management and internal

control.

2.1.2 Where the Audit Committee considers there is evidence of ultra vires transactions,

evidence of improper acts, or if there are other important matters that the Committee wish

to raise, the Chairman of the Audit Committee should raise the matter in the first instance

with the Chief Financial Officer and the Chief Officer. If the matter has still not been

resolved to the Audit Committee's satisfaction, then the matter will be raised at a full

meeting of the Governing Body. Exceptionally the matter may need to be referred to the

Department of Health (DoH).

2.2 Chief Financial Officer

2.2.1 The Chief Financial Officer is responsible for:

a) ensuring there are arrangements to review, evaluate and report on the effectiveness

of internal financial control, including the establishment of an effective internal audit

function;

b) ensuring that the internal audit is adequate and meets the government mandatory

audit standards;

c) deciding at what stage to involve the police in cases of misappropriation and other

irregularities not involving fraud or corruption; and

d) ensuring that an annual internal audit report is prepared for the consideration of the

Audit Committee (and the Governing Body). The report must cover:

a clear opinion on the effectiveness of internal control in accordance with

current assurance framework guidance issued by the Department of Health

including, for example, compliance with control criteria and standards;

major internal financial control weaknesses discovered;

progress on the implementation of internal audit recommendations;

progress against plan over the previous year; and

strategic audit plan covering the coming three years; and a detailed plan for


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the coming year.

2.2.2 The Chief Financial Officer or designated auditors are entitled without necessarily giving

prior notice to require and receive:

a) access to all records, documents and correspondence relating to any financial or

other relevant transactions, including documents of a confidential nature;

b) access at all reasonable times to any land, premises or members of the Board or

employee of the NHSLCCG; and

c) explanations concerning any matter under consideration.

2.3 Role of Internal Audit 2.3.1 Internal audit will provide an independent and objective opinion on risk management,

control and governance arrangements by measuring and evaluating their effectiveness.

The Head of Internal Audit will provide an annual opinion on the effectiveness of the whole

system of internal control.

2.3.2 The opinion will be based on a systematic review and evaluation of risk management,

control and governance which comprises the policies, procedures and operations in place

to:

a) establish and monitor the achievement of the organisations strategic and operational

objectives;

b) identify, assess and manage strategic and operational risks to achieving the

organisations objectives;

c) identify the extent of compliance with, and the financial effect of, the relevant

established policies, plans and procedures;

d) identify the adequacy and application of financial and other related management

controls;

e) ensure the integrity and reliability of information, accounts and data, including

internal and external reporting and accountability processes; and

f) identify the extent to which the NHSLCCG assets and interests are accounted for

and safeguarded from loss of any kind, arising from:

fraud and other offences;

waste, extravagance, inefficient administration;

poor value for money; or

other causes.

2.3.3 Internal Audit shall also independently verify the board assurance framework statements

in accordance with NHS guidance.


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2.3.4 The Head of Internal Audit will make suitable provision to form an opinion on key systems

operated on behalf of other organisations, and key systems being operated by other

organisations, either by deriving the opinions themselves or by relying on the opinions

provided by other auditors/review bodies.

2.3.5 Whenever any matter arises which involves, or is thought to involve, irregularities

concerning cash, stores, or other property or any suspected irregularity of a pecuniary

nature, the Chief Financial Officer must be notified immediately.

2.3.6 The Head of Internal Audit will normally attend Audit Committee meetings and has a right

of access to all Audit Committee members, the Chair and Chief Officer of the NHSLCCG.

2.3.7 The Head of Internal Audit shall be accountable to the Chief Financial Officer. The

reporting system for internal audit shall be agreed between the Chief Financial Officer, the

Audit Committee and the Head of Internal Audit. The agreement shall be in writing and

shall comply with guidance on reporting contained in the Government Internal Audit

Standards. The reporting system shall be reviewed at least every three years.

2.4 External Audit

2.4.1 From 17/18 onwards, clinical commission groups must have an ‘auditor panel’ to advise

on the appointment of their external auditors. Prior to this, under the Health and Social

Care Act 2012, NHS England were responsible for arranging for the Audit Commission to

appoint External Auditors for the CCG.

2.5 Fraud and Corruption

2.5.1 In line with their responsibilities, the NHSLCCG Chief Officer and Chief Financial Officer

shall monitor and ensure compliance with NHS Counter Fraud Authority’s Counter Fraud

Standards for.

2.5.2 The NHSLCCG shall appoint an accredited counter fraud specialist to carry out the duties

of the Counter Fraud Specialist as specified by the NHS Fraud and Corruption Manual

and guidance.

2.5.3 The Counter Fraud Specialist shall report to the Chief Financial Officer and shall work with

staff in NHS Protect in accordance with the NHS Fraud and Corruption Manual.

2.5.4 The Counter Fraud Specialist will provide a written report, at least annually, on counter

fraud work within the NHSLCCG.

2.6 Security Management 2.6.1 In line with their responsibilities, the Chief Officer will monitor and ensure compliance with

directions issued by NHS Protect’s Security Management Standards for Commissioners.

2.6.2 The NHSLCCG shall nominate a suitable person to carry out the duties of the Security

Management Specialist as specified by NHS Protect’s Security Management Standards

for Commissioners.2.6.3 The Chief Officer has overall responsibility for controlling and

coordinating security. However, key tasks are delegated to the relevant director and the


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appointed Security Management Specialist.

3. Resource Limit Control

3.1 Cash and Resource Limits

3.1.1 The NHSLCCG is required by statutory provisions not to exceed Cash and Resource

Limits. The Chief Officer has overall executive responsibility for the NHSLCCG activities

and is responsible to the NHSLCCG governing body for ensuring that it stays within these

limits.

3.1.2 The definition of use of resources is set out in RAB directions on use of resources which

are available on the www.gov.uk website

The Chief Financial Officer will:

a) provide monthly reports in the form required by the Secretary of State;

b) provide regular financial reports in the form agreed by the Governing Body;

c) ensure money drawn from the NHS England against cash limit is required for

approved expenditure only, and is drawn only at the time of need, follows best

practice as set out in ‘Cash Management in the NHS’; and

d) be responsible for ensuring that an adequate system for monitoring financial

performance is in place to enable the NHSLCCG to fulfil its statutory responsibility

not to exceed its annual revenue and capital resource limits and cash limit.

3.2 Allocations

3.2.1 The Chief Financial Officer will:

a) periodically review the basis and assumptions used by the NHS England for

distributing allocations to the NHSLCCG and ensure that these are reasonable and

realistic and secure the NHSLCCG entitlement to funds;

b) prior to the start of each financial year submit to the Governing Body for approval a

report showing the total allocations received and their proposed distribution

including any sums to be held in reserve;

c) regularly update the Governing Body on significant changes to the initial allocation

and the uses of such funds; and

d) establish a system for management of the Capital Resource Limit and the approval

of investment proposals.

3.3 Budgetary Delegation

3.3.1 The Chief Officer may delegate the management of a budget to permit the performance of a

defined range of activities. This delegation must be in writing and be accompanied by a

clear definition of:


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a) the amount of the budget;

b) the purpose(s) of each budget heading;

c) individual and group responsibilities;

d) limits on exercising virements;

e) achievement of planned levels of service; and

f) the provision of regular reports.

3.3.2 The Chief Officer and delegated budget holders must not exceed the budgetary total or

virement limits set by the Governing Body.

3.3.3 Any budgeted funds not required for their designated purpose(s) revert to the immediate

control of the Chief Officer, subject to any authorised use of virement.

3.3.4 Non-recurring budgets should not be used to finance recurring expenditure without the

authorisation in writing of the Chief Officer, as advised by the Chief Financial Officer.

3.4 Budgetary Control and Reporting

3.4.1 The Chief Financial Officer will devise and maintain systems of budgetary control. These

will include:

a) regular financial reports to the Governing Body in a form approved by the Governing

Body containing:

income and expenditure to date showing trends and forecast year-end

position;

performance against the CCGs statutory and other financial duties

capital project spend and projected outturn against plan;

explanations of any material variances from plan; and

details of any corrective action where necessary and the Chief Officer’s and/or

Chief Financial Officer's view of whether such actions are sufficient to correct

the situation;

b) the issue of timely, accurate and comprehensible advice and financial reports to

each budget holder, covering the areas for which they are responsible;

c) investigation and reporting of variances from financial and workforce budgets;

d) monitoring of management action to correct variances;

e) arrangements for the authorisation of budget transfers.

3.4.2 Each budget holder is responsible for ensuring that:

a) any likely overspending or reduction of income which cannot be met by virement is

not incurred without the prior approval of the Finance Department.;


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b) the amount provided in the approved budget is not used in whole or in part for any

purpose other than that specifically authorised subject to the rules of virement; and

c) no permanent employees are appointed without the approval of the Chief Officer

other than those provided for within the available resources and manpower

establishment as approved by the Governing Body.

3.5 Capital expenditure

3.5.1 The general rules applying to delegation and reporting shall also apply to capital

expenditure. (The particular applications relating to capital are contained in section 6).

3.6 Monitoring Returns

3.6.1 The Chief Financial Officer is responsible for ensuring that the appropriate monitoring

forms are submitted to the requisite monitoring organisation.

4. Banking Arrangements 4.1 General 4.1.1 The Chief Financial Officer is responsible for managing the NHSLCCG banking

arrangements and for advising on the provision of banking services and operation of

accounts. This advice will take into account guidance/ Directions issued from time to time

by the Department of Health. In line with Cash Management in the NHS the NHSLCCG

should minimise the use of commercial bank accounts and consider using the Government

Banking Service (GBS) as its supplier for all banking services.

4.1.2 The Chief Financial Officer shall approve the banking arrangements.

4.2 Commercial (Bank) and Government Banking Service (GBS) Accounts


a) commercial bank accounts and accounts operated through the Government Banking

Service;

b) establishing separate bank accounts for the NHSLCCG non-exchequer funds;

c) ensuring payments made from commercial banks or Government Banking Service

accounts do not exceed the amount credited to the account except where

arrangements have been made;

d) reporting to the Governing Body all arrangements made with the NHSLCCG

bankers for accounts to be overdrawn; and

e) monitoring compliance with DH guidance on the level of cleared funds.

4.3 Banking procedures

4.3.1 The Chief Financial Officer will prepare detailed instructions on the operation of


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commercial and GBS bank accounts, which must include:

a) the conditions under which each commercial and GBS bank account is to be

operated; and

b) those authorised to sign cheques or other orders drawn on the NHSLCCG accounts.

4.3.2 The Chief Financial Officer must advise the NHSLCCG bankers in writing of the conditions

under which each account will be operated.

4.4 Tendering and review

4.4.1 For those non-exchequer funds, if any, held outside the GBS, the Chief Financial Officer

will review the commercial banking arrangements of the NHSLCCG at regular intervals to

ensure they reflect best practice and represent best value for money by periodically

seeking competitive tenders for the NHSLCCG commercial banking business. These

competitive tenders should be sought at least every 5 years. The results of the tendering

exercise should be reported to the Governing Body. This review is not necessary for GBS

accounts.

5. Income, Fees and Charges and Security of Cash, Cheques and Other Negotiable Instruments

5.1 Income Systems

5.1.1 The Chief Financial Officer is responsible for designing, maintaining and ensuring

compliance with systems for the proper recording, invoicing, collection and coding of all

monies due.

5.1.2 The Chief Financial Officer is also responsible for the prompt banking of all monies

received.

5.2 Fees and Charges

5.2.1 The Chief Financial Officer is responsible for approving and regularly reviewing the level

of all fees and charges other than those determined by the Department of Health or by

Statute. Independent professional advice on matters of valuation shall be taken as

necessary. Where sponsorship income (including items in kind such as subsidised goods

or loans of equipment) is considered the guidance in the Department of Health

Commercial Sponsorship – Ethical standards in the NHS shall be followed.

5.2.2 All employees must inform the Chief Financial Officer promptly of money due arising from

transactions which they initiate/deal with, including all contracts, leases, tenancy

agreements, private patient undertakings and other transactions.

5.3 Debt Recovery

5.3.1 The Chief Financial Officer is responsible for the appropriate recovery action on all

outstanding debts.


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5.3.2 Income not received should be dealt with in accordance with losses procedures.

5.3.3 Overpayments should be detected (or preferably prevented) and recovery initiated.

5.4 Security of Cash, Cheques and Other Negotiable Instruments


a) approving the form of all receipt books, agreement forms, or other means of officially

acknowledging or recording monies received or receivable;

b) ordering and securely controlling any such stationery;

c) the provision of adequate facilities and systems for employees whose duties include

collecting and holding cash, including the provision of safes or lockable cash boxes,

the procedures for keys, and for coin operated machines; and

d) prescribing systems and procedures for handling cash and negotiable securities on

behalf of the NHSLCCG.

5.4.2 Official money shall not under any circumstances be used for the encashment of private

cheques or IOUs.

5.4.3 All cheques, postal orders, cash etc., shall be banked intact. Disbursements shall not be

made from cash received, except under arrangements approved by the Chief Financial

Officer.

5.4.4 The holders of safe keys shall not accept unofficial funds for depositing in their safes

unless such deposits are in special sealed envelopes or locked containers. It shall be

made clear to the depositors that the NHSLCCG is not to be held liable for any loss, and

written indemnities must be obtained from the organisation or individuals absolving the

NHS LCCG from responsibility for any loss.

5.4.5 During the absence (e.g. on holiday) of the holder of a safe or cash box key, the acting

officer shall be subject to the same controls as the normal holder of the key. There shall

be written discharge for the safe and/or cash box contents on the transfer of

responsibilities and the discharge document must be retained for inspection.

5.4.6 Any loss or shortfall of cash or other negotiable instruments, however occasioned, shall

be reported immediately in accordance with the agreed procedure for reporting losses.

(See Section 14 - Losses and special payments).

6. Capital investment, asset register and security of assets

6.1 Capital Investment

6.1.1 The Chief Officer:

a) shall ensure that there is an adequate appraisal and approval process in place for

determining capital expenditure priorities and the effect of each proposal upon

plans;


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b) is responsible for the management of all stages of capital schemes and for ensuring

that schemes are delivered on time and to cost; and

c) shall ensure that the capital investment is not undertaken without securing the

availability of resources to finance all revenue consequences, including capital

charges.

6.1.2 For every capital expenditure proposal the Chief Officer shall ensure:

a) that a business case (in line with the guidance contained within the Capital

Investment Manual) is produced setting out:

an option appraisal of potential benefits compared with known costs to

determine the option with the highest ratio of benefits to costs;

the involvement of appropriate NHSLCCG personnel and external agencies;

appropriate project management and control arrangements; and

that the Chief Financial Officer has certified professionally the costs and

revenue consequences detailed in the business case.

6.1.3 For capital schemes where the contracts stipulate stage payments, the Chief Officer will

issue procedures for their management, incorporating the recommendations of

“Estatecode”.

6.1.4 The Chief Financial Officer shall assess on an annual basis the requirement for the

operation of the construction industry tax deduction scheme in accordance with HMRC

guidance.

6.1.5 The Chief Financial Officer shall issue procedures for the regular reporting of expenditure

and commitment against authorised expenditure.

6.1.6 The approval of a capital programme shall not constitute approval for expenditure on any

scheme.

6.1.7 The Chief Financial Officer shall issue to the manager responsible for any scheme:

a) specific authority to commit expenditure;

b) authority to proceed to tender; and

c) approval to accept a successful tender.

6.1.8 The Chief Officer will issue a scheme of delegation for capital investment management in

accordance with “Estatecode” guidance and the Governing Body’s Standing Orders.

6.1.9 The Chief Financial Officer shall issue procedures governing the financial management,

including variations to contract, of capital investment projects and valuation for accounting

purposes. These procedures shall fully take into account the delegated limits for capital

schemes included in Annex C of HSC (1999) 246.

6.1.10 The Chief Officer and Chief Financial Officer shall ensure that the arrangements for

financial control and financial audit of building and engineering contracts and property


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transactions comply with the guidance contained within CONCODE and ESTATECODE.

The technical audit of these contracts shall be the responsibility of the relevant Director.

6.2 Asset Registers

6.2.1 The Chief Officer is responsible for the maintenance of both the register of assets and the

register of inventory items, taking account of the advice of the Chief Financial Officer

concerning the form and the method of updating the registers.

6.2.2 Each employee has a responsibility to exercise a duty of care over the assets of the

NHSLCCG and it shall be the responsibility of senior staff in all disciplines to apply

appropriate routine security practices in relation to NHSLCCG assets. A substantial or

persistent breach of agreed security practices shall be reported to the Chief Financial

Officer, who will determine the necessary action, including reference to the Security

Management Specialist for investigation

6.2.3 The Chief Officer shall define the items of equipment which shall be recorded on either the

capital asset register or the inventory register. The Capital Accounting Manual, as issued

by the Department of Health, will be considered when determining the minimum data set

for the capital asset register.

6.2.4 Additions to the fixed asset register must be clearly identified to an appropriate budget

holder and be validated by reference to:

a) properly authorised and approved agreements, architect's certificates, supplier's

invoices and other documentary evidence in respect of purchases from third parties;

b) stores, requisitions and wages records for own materials and labour including

appropriate overheads; and

c) lease agreements in respect of assets held under a finance lease and capitalised.

6.2.5 Where capital assets are sold, scrapped, lost or otherwise disposed of, their value must

be removed from the accounting records and each disposal must be validated by

reference to authorisation documents and invoices.

6.2.6 The Chief Financial Officer shall approve procedures for reconciling balances on fixed

asset accounts in ledgers against balances on fixed asset registers.

6.2.7 Land and buildings shall be held at values in accordance with the NHSLCCG accounting

policies which comply with the Financial Reporting Manual (FReM) issued by HM

Treasury.

6.2.8 The value of each asset shall be depreciated using methods and rates as specified in the

NHSLCCG accounting policies which comply with the FReM. Estimated useful lives and

depreciation rates of assets will be reviewed on an annual basis.

6.2.9 The Chief Financial Officer shall calculate and account for capital charges as specified in

the FReM.

6.2.10 Budget holders will ensure that the respective asset register for their areas will be


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physically checked annually.

6.2.11 The asset register and the inventory register shall also record items which are transferred

from one part of the NHSLCCG to another. It is the responsibility of the budget managers

to inform the Chief Financial Officer of these changes.

6.2.12 The Chief Financial Officer shall maintain an up to date register of properties owned or

leased by the NHSLCCG. This should include details of location, tenancy (where

appropriate), and custody of the deeds and lease documents.

6.3 Security of Assets

6.3.1 Asset control procedures (including fixed assets, cash, cheques and negotiable

instruments, and also including donated assets) must be approved by the Chief Financial

Officer. This procedure shall make provision for:

a) recording managerial responsibility for each asset;

b) identification of additions and disposals;

c) identification of all repairs and maintenance expenses;

d) physical security of assets;

e) periodic verification of the existence of, condition of, and title to, assets recorded;

f) identification and reporting of all costs associated with the retention of an asset; and

g) reporting, recording and safekeeping of cash, cheques, and negotiable instruments.

6.4 All discrepancies revealed by verification of physical assets to fixed asset register shall be

notified to the Chief Financial Officer.

6.5 Whilst each employee and officer has a responsibility for the security of property of the

NHSLCCG, it is the responsibility of Governing Body members and senior employees in

all disciplines to apply such appropriate routine security practices in relation to NHS

property as may be determined by the Governing Body. Any breach of agreed security

practices must be reported in accordance with agreed procedures.

6.6 Any damage to the NHSLCCG premises, vehicles and equipment or any loss of

equipment or supplies shall be reported by staff in accordance with the agreed procedure

for reporting losses.

6.7 Where practical, assets should be marked NHSLCCG property.

7. Payment of staff

7.1 Funded Establishment

7.1.1 The workforce plans incorporated within the annual budget will form the funded

establishment. The funded establishment of any budget holder may not be varied without

the approval of the Chief Officer.


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7.2 Processing Payroll


a) specifying timetables for submission of properly authorised time records and other

notifications;

b) final determination of pay;

c) making payment on agreed dates; and

d) agreeing methods of payment.

7.2.2 The Chief Financial Officer will issue instructions regarding:

a) verification and documentation of data;

b) timetable for receipt and preparation of payroll data and the payment of employees;

c) maintenance of subsidiary records for superannuation, income tax, social security

and other authorised deductions from pay;

d) security and confidentiality of payroll information;

e) checks to be applied to completed payroll before and after payment;

f) arrangements for ensuring compliance with the provisions of the Data Protection

Act;

g) methods of payments available to various categories of employees and officers;

h) procedures for payment by cheque or bank credit;

i) procedures for the recall of cheques and bank credits;

j) pay advances and their recovery;

k) maintenance of regular and independent reconciliation of pay control accounts;

l) separation of duties of preparing records and inputs and verifying outputs and

payments; and

m) system to ensure the recovery from leavers of sums of money and property due by

them to the NHSLCCG.

7.2.3 Appropriately nominated managers have delegated responsibility for:

a) submitting time records, and other notifications in accordance with agreed

timetables;

b) completing time records and other notifications in accordance with the Chief

Financial Officer’s instructions and in the form prescribed by the Chief Financial

Officer; and


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c) submitting termination forms in the prescribed form immediately upon knowing the

effective date of an employee’s resignation, termination or retirement. Where an

employee fails to report for duty in circumstances that suggest they have left without

notice, the Chief Financial Officer must be informed immediately.

7.2.4 Regardless of the arrangements for providing the payroll service, the Chief Financial

Officer shall ensure that the chosen method is supported by appropriate (contracted)

terms and conditions, adequate internal controls and audit and review procedures, and

that suitable arrangements are made for the collection of payroll deductions and payment

of these to appropriate bodies.

7.2.5 All employees shall be paid by bank credit transfer, unless otherwise agreed by the Chief

Financial Officer.

7.3 Contracts of Employment

7.3.1 The Governing Body shall delegate responsibility to the Chief Officer or their nominee for

ensuring that all employees are issued with a Contract of employment in a form approved

by the Governing Body and which complies with employment legislation and deals with

variations to or termination of contracts of employment.

8. Payment of Accounts

8.1 The Chief Financial Officer shall be responsible for the prompt payment of accounts and

claims. The term "payment" includes any arrangements established to settle payments

upon a non-cash basis. Payment of contract invoices shall be in accordance with contract

terms. All payments shall comply with the Government's policy on prompt payment.

8.2 All authorised officers shall inform the Chief Financial Officer promptly of all money

payable by the NHSLCCG arising from transactions which they initiate, including

contracts, leases, tenancy agreements and other transactions.

8.3 The Chief Financial Officer shall be responsible for maintaining a system for the

verification, recording and payment of all accounts payable by the NHSLCCG. This

system will incorporate an approved officer’s signatory list of the budget holders, budget

managers and their deputies who are authorised to certify the following:

a) goods have been duly received, examined, are in accordance with specification and

order, are satisfactory and that the prices are correct;

b) work done or services rendered have been satisfactorily carried out in accordance

with the order; that, where applicable, the materials used were of the requisite

standard and that the charges are correct;

c) in the case of contracts based on the measurement of time, materials or expenses,

the time charged is in accordance with the time sheets, that the rates of labour are

in accordance with appropriate rates, that the materials have been checked with

regard to quantity, quality and price and that the charges for the use of vehicles,

plant and machinery have been examined;


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d) where appropriate, the expenditure is in accordance with regulations and that all

necessary authorisations have been obtained; and

e) the account is arithmetically correct; and the account is in order for payment.

8.4 Appropriate prepayments will be permitted for instances relating to payments for rent,

maintenance contracts and in those instances, where, as standard business practice

demands, nominal prepayments are required (e.g. training, publications). Prepayments

which fall outside the above categories are only permitted where exceptional

circumstances apply. In such instances:

a) the appropriate Director must provide, in the form of a written report, a case setting

out all relevant circumstances of the purchase. The report must set out the effects

on the NHSLCCG if the supplier is at some time during the course of the

prepayment agreement unable to meet their commitments;

b) the Chief Financial Officer will need to be satisfied with the proposed arrangements

before contractual arrangements proceed; and

c) the budget holder is responsible for ensuring that all items due under a prepayment

contract are received and must immediately inform the appropriate Director or Chief

Finance Officer if problems are encountered.

8.5 Where an officer certifying accounts relies upon other officers to do preliminary checking,

wherever possible, the officer certifying accounts will ensure that those who check

delivery or execution of work, act independently of those who have placed orders and

negotiated prices and terms.

8.6 In the case of contracts which require payment to be made on account, during progress of

the works, the Chief Financial Officer shall make payment on receipt of a certificate from

the appropriate qualified officer or outside consultant. Without prejudice to the

responsibility of any consultant, a contractor's account shall be subjected to such financial

examination by the Chief Financial Officer and such general examination by appropriately

qualified officers as may be considered necessary, before the person responsible to the

NHSLCCG for the contract, issues the final certificate.

8.7 The Chief Financial Officer may authorise advances on the Imprest system for petty cash

and other purposes as required. Individual payments must be restricted to the amounts

authorised by the Chief Financial Officer.

8.8 The Chief Financial Officer shall ensure that payment for goods and services is made only

when the goods and services have been properly received.

9. Tendering and Quotations

9.1 The tendering policies and rules shall be applied where the NHSLCCG wishes to obtain

goods, services or works from a third party external to the NHS LCCG. These policies

and rules will be regularly updated by the Chief Financial Officer and approved by the

Governing Body.


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9.2 The purpose of the tendering rules is to ensure that best value arrangements are secured

for the NHSLCCG, that all statutory and central government requirements are met, and

that the NHSLCCG is protected from allegations of unfair practice or fraud.

9.3 EU and UK public procurement policy requires that the NHSLCCG promotes fair

competition amongst potential suppliers and is open and transparent in dealings with

suppliers and potential suppliers.

9.4 Directives by the Council of the European Union prescribing procedures and UK rules on

public procurement for the awarding of contracts for building and engineering works and

for the supply of goods, materials and manufactured articles and services shall have effect

as if incorporated in these Standing Financial Instructions.

9.5 All procurement activities carried out by the NHSLCCG must also comply with any more

specific control arrangements required by the Department of Health or HM Treasury.

9.6 The Chief Financial Officer will regularly update and agree with the Governing Body a

schedule of delegated authorities for tendering, contracting and purchasing goods and

services.

10. Contracting and Purchasing

10.1 Any goods and services procured via an order shall be ordered on an official order

document. Any purchases from petty cash are to be limited in value and type of purchase

in accordance with instructions issued by the Chief Financial Officer and documented in

the form prescribed in these instructions

10.2 Official orders shall be consecutively numbered, in a form approved by the Chief Financial

Officer and shall include such information concerning prices or costs as required. The

order shall incorporate an obligation on the supplier/contractor to comply with the NHS

LCCG or other relevant Terms and Conditions of Purchase (such as Buying Solutions).

10.3 Requisitions shall be approved only by officers authorised by the Chief Officer. The list of

authorised officers shall be maintained for management control purposes by the Chief

Financial Officer.

10.4 Details of all orders placed should be available to the Chief Financial Officer either in

paper form or accessible through a computerised accounts payable system.

10.5 The Chief Financial Officer should ensure that appropriate delegation arrangements are in

existence to ensure that no order is issued for any item for which there is no budget

provision. In exceptional circumstances, senior officers, acting only with the express

approval of the Chief Officer, may issue an order where there is no budget provision.

10.6 Orders shall not be placed in a manner devised to avoid the financial limits specified by

the NHSLCCG.

10.7 No order shall be issued for any item or items for which an offer of gifts, reward or benefit

has been made to staff. The offer and receipt of gifts and hospitality shall be recorded in

a register of gifts and hospitality, in accordance with NHSLCCG’s Standards of Business


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Conduct Policy.

10.8 Goods are not to be taken on trial or loan in circumstances that could commit the

NHSLCCG to a future uncompetitive price.

11. Terms of Service, Allowances and Payment of Members of the NHS Governing Board and Employees

11.1 Remuneration and terms of service

11.1.1 In accordance with SOs the Governing Body shall establish a Remuneration and

Nomination Committee, with clearly defined terms of reference, specifying which posts fall

within its area of responsibility, its composition, and the arrangements for reporting.

11.1.2 The Committee will:

a) Determine the terms and conditions, remuneration and travelling or other

allowances to Governing Body members, Executive Directors and Clinical Leads,

including pensions and gratuities. The Committee will also make recommendations

to the CCG Governing Body on determinations about the terms and conditions,

remuneration, and travelling or other allowances for employees and for people who

provide services to the CCG, and determinations about allowances under any

pension scheme it might establish as an alternative to the NHS pension scheme. In

addition the CCG Governing Body has delegated the following functions to its

Remuneration Committee:

b) Make recommendations to the Governing Body on specific policies relating to staff

remuneration and benefits

c) Approval of individual redundancy applications

d) Determining the remuneration and conditions of service of the senior team

e) Reviewing the performance of the Chief Officer and other senior team members and

determining annual salary awards, if appropriate

f) Considering the severance payments of the Chief Officer and usually other senior

staff, seeking HM Treasury approval as appropriate in accordance with the guidance

‘Managing Public Money’ (available on the www.hm-treasury.gov.uk website)

11.1.3 The Committee shall report in writing to the Governing Body the basis for its

recommendations. The Governing Body shall use the report as the basis for their

decisions, but remain accountable for taking decisions on the remuneration and terms of

service of officer members. Minutes of the Governing Body's meetings should record such

decisions.

11.1.4 The Governing Body will consider and need to approve proposals presented by the Chief

http://www.hm-treasury.gov.uk/


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Officer for the setting of remuneration and conditions of service for those employees and

officers not covered by the Committee.

11.1.5 The NHSLCCG will pay allowances to the Chairman and non-officer members of the

Governing Body in accordance with terms agreed by the LCCG Remuneration and

Nomination Committee

11.2 Funded Establishment

11.2.1 The manpower plans incorporated within the annual budget will form the funded

establishment.

11.2.2 The funded establishment of any department may not be varied without the approval of

the Chief Officer.

11.3 Staff Appointments

11.3.1 Members of the Governing Body and other employees may only engage, re-engage, or

re-grade employees, either on a permanent or temporary nature, or hire agency staff, or

agree to changes in any aspect of remuneration in accordance with the approved scheme

of delegation and within the limit of their approved budget and funded establishment. Any

exceptions must be approved in advance and in writing by the Accountant Officer.

11.3.2 The Governing Body will approve procedures presented by the Chief Officer for the

determination of commencing pay rates, conditions of service, etc, for employees.

11.4 Contracts of Employment

11.4.1 The Governing Body shall delegate responsibility to an officer for:

a) ensuring that all employees are issued with a Contract of Employment in a form

approved by the Governing Body and which complies with employment legislation;

and

b) dealing with variations to, or termination of, contracts of employment.

12. Non - Pay Expenditure

12.1 The Governing Body will approve the level of non-pay expenditure on an annual basis and

the Chief Officer will determine the level of delegation to budget managers.

12.2 The Chief Financial Officer will set out:

a) the list of managers who are authorised to place requisitions for the supply of goods

and services; and

b) the maximum level of each requisition and the system for authorisation above that

level.

12.3 The Chief Financial Officer shall set out procedures on the seeking of professional advice


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regarding the supply of goods and services.

13. Stores and Receipt of Goods

13.1 General Position

13.1.1 Stores, defined in terms of controlled stores and departmental stores (for immediate use)

should be:

a) kept to a minimum;

b) subjected to annual stock take;

c) valued at the lower of cost and net realisable value.

13.2 Control of Stores, Stocktaking, Condemnations and Disposal

13.2.1 Subject to the responsibility of the Chief Financial Officer for the systems of control,

overall responsibility for the control of stores shall be delegated to an employee by the

Chief Officer. The day-to-day responsibility may be delegated by him to departmental

employees and stores managers/keepers, subject to such delegation being entered in a

record available to the Chief Financial Officer.

13.2.2 The responsibility for security arrangements and the custody of keys for any stores and

locations shall be clearly defined in writing by the designated manager/officer. Wherever

practicable, stocks should be marked as health service property.

13.2.3 The Chief Financial Officer shall set out procedures and systems to regulate the stores

including records for receipt of goods, issues, and returns to stores, and losses.

13.2.4 Stocktaking arrangements shall be agreed with the Chief Financial Officer and there shall

be a physical check covering all items in store at least once a year.

13.2.5 Where a complete system of stores control is not justified, alternative arrangements shall

require the approval of the Chief Financial Officer.

13.2.6 The designated manager/officer shall be responsible for a system approved by the Chief

Financial Officer for a review of slow moving and obsolete items and for condemnation,

disposal, and replacement of all unserviceable articles. The designated officer shall report

to the Chief Financial Officer any evidence of significant overstocking and of any

negligence or malpractice (see also overlap with SFI No. 14 – Disposals and

condemnations, losses and special payments). Procedures for the disposal of obsolete

stock shall follow the procedures set out for disposal of all surplus and obsolete goods.

14. Disposals and Condemnations, Losses and Special Payments

14.1 Disposals and Condemnations

14.1.1 The Chief Financial Officer must prepare detailed procedures for the disposal of assets

including condemnations, and ensure that these are notified to managers.


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14.1.2 When it is decided to dispose of an NHSLCCG asset, the Head of Department or

authorised deputy will determine and advise the Chief Financial Officer of the estimated

market value of the item, taking account of professional advice where appropriate.

14.1.3 All unserviceable articles shall be:

a) condemned or otherwise disposed of by an employee authorised for that purpose by

the Chief Financial Officer; and

b) recorded by the condemning officer in a form approved by the Chief Financial

Officer which will indicate whether the articles are to be converted, destroyed or

otherwise disposed of. All entries shall be confirmed by the countersignature of a

second employee authorised for the purpose by the Chief Financial Officer.

14.1.4 The Condemning Officer shall satisfy himself as to whether or not there is evidence of

negligence in use and shall report any such evidence to the Chief Financial Officer who

will take the appropriate action.

14.2 Losses and Special Payments

14.2.1 The Chief Financial Officer must prepare procedural instructions on the recording of and

accounting for condemnations, losses, and special payments.

14.2.2 Any employee or officer discovering or suspecting a loss of any kind must either

immediately inform their Head of Department, who must immediately inform the Chief

Officer and the Chief Financial Officer or inform an officer charged with responsibility for

responding to concerns involving loss. This officer will then appropriately inform the Chief

Financial Officer and/or Chief Officer. Where a criminal offence is suspected, the Chief

Financial Officer must immediately inform the police, if theft or arson is involved. In cases

of fraud and corruption, or of anomalies which may indicate fraud or corruption, the Chief

Financial Officer must inform the External Auditor, the NHSLCCGs Counter Fraud

Specialist and the relevant Counter Fraud and Security Management Services regional

team in accordance with Secretary of State for Health’s Directions.

14.2.3 For losses apparently caused by theft, arson, neglect of duty or gross carelessness,

except if trivial, the Chief Financial Officer must immediately notify:

a) the Governing Body; and

b) the External Auditor.

14.2.4 Within limits delegated to it by the Department of Health, the Governing Body shall

approve the writing-off of losses.

14.2.5 The Chief Financial Officer shall be authorised to take any necessary steps to safeguard

the Governing Body interests in bankruptcies and company liquidations.

14.2.6 For any loss, the Chief Financial Officer should consider whether any insurance claim can

be made.

14.2.7 The Chief financial officer shall maintain a losses and special payments register in which


Page 28 of 31

write-off action is recorded.

14.2.8 No special payments exceeding delegated limits shall be made without the prior approval

of the Department of Health.

14.2.9 All losses and special payments must be reported to the Audit Committee at every

meeting.

15. Information Technology

15.1 General

15.1.1 In order to ensure compatibility and compliance with the NHSLCCGs IT strategy, no

computer hardware, software or facility will be procured without the authorisation of an

officer specifically appointed by the Chief Officer.

15.2 Finance

15.2.1 The Chief Financial Officer shall ensure that adequate controls exist such that the finance

computer operation is separated from development, maintenance and amendment.

15.2.2 The Chief Financial Officer and an officer specifically appointed by the Chief Officer shall

ensure that an adequate management (audit) trail exists through the computerised finance

system.

15.2.3 The Chief Financial Officer shall satisfy himself that new financial systems and

amendments to current financial systems are developed in a controlled manner and

thoroughly tested prior to implementation.

16. Information Governance

16.1 The Chief Officer shall be responsible for ensuring that the CCG has registered with the

Information Commissioner’s Office for compliance with the Data Protection Act 1998 and

shall ensure that information is published and maintained in accordance with the

requirements of the Freedom of Information Act 2000 (FOI).

16.2 The Chief Officer shall be ultimately responsible for the publishing and maintenance of a

Freedom of Information Scheme.

16.3 The Chief Officer shall be ultimately responsible for the appointment of a Caldicott

Guardian for patient information.

16.4 The Chief Financial Officer shall be primarily responsible for the accuracy and security of

the computerised financial data of the NHSLCCG in accordance with security retention

and Data Protection policies as defined by the officer designated for this purpose by the

Chief Officer.

16.5 An officer specifically appointed by the Accountable Body shall devise and implement any

necessary procedures to ensure adequate protection of the NHSLCCGs manual and

computer data, programs and hardware for which the Chief Officer is responsible, from


Page 29 of 31

accidental or intentional disclosure to unauthorised persons, deletion or modification, theft

or damage, having due regard for the Data Protection Acts and any defined NHS-wide

security requirements.

16.6 An officer specifically appointed by the Chief Officer shall ensure that adequate controls

exist over data entry, processing, storage, transmission and output to ensure security,

privacy, accuracy, completeness, and timeliness of all NHSLCCG financial systems and

data as well as the efficient and effective operation of the system.

16.7 The Chief Financial Officer shall ensure that contracts for computing services for financial

applications with another agency shall clearly define the responsibility of all parties for the

security, privacy, accuracy, completeness, and timeliness of data during processing

transmission and storage. The contract should also ensure rights of access for audit

purposes.

16.8 Where another agency provides a computer service for financial applications, the Chief

Financial Officer shall periodically seek assurances that adequate controls as outlined

above are in operation.

16.9 The Chief Financial Officer and an officer specifically appointed by the Chief Officer shall

ensure that adequate controls exist to maintain the security, privacy, accuracy and

completeness of financial data sent over transmission networks.

17. Retention of Documents

17.1 The Chief Officer shall be responsible for maintaining archives for all documents required to

be retained in accordance with Department of Health guidelines.

17.2 The documents held in archive shall be capable of retrieval by persons authorised by the

Chief Financial Officer.

17.3 Documents held in accordance with Department of Health guidance shall only be

destroyed at the express instigation of the Chief Officer. Records shall be maintained of

all documents so destroyed.

18. Risk Management and Insurance

18.1 The Chief Officer shall ensure that the CCG has a risk management strategy and

assurance framework, in accordance with current Department of Health requirements,

which must be approved and monitored by the Governing Body.

18.2 The Audit Committee will oversee the management of the assurance framework ensuring

that it meets the needs of the CCG in being able to identify and reduce risk.

18.3 The programme of risk management shall include:

a) a process for identifying and quantifying risks and potential liabilities;

b) engendering among all levels of staff a positive attitude towards the control of

risk;


Page 30 of 31

c) management processes to ensure all significant risks and potential abilities are

addressed including effective systems on internal control, cost effective

insurance cover, and decisions on the acceptable level of retained risk;

d) contingency plans to offset the impact of adverse events;

e) audit arrangements including; internal audit, health and safety review;

f) a clear indication of which risks shall be insured;

g) arrangements to review the risk management programme.

18.4 The risk register will be reviewed and updated regularly at the CCG Committees, and then

reported to the Audit Committee on a quarterly basis

18.5 The existence, integration and evaluation of the above elements will assist in providing a

basis to make a statement on the effectiveness of internal control within the Annual

Report and Accounts as required by current Department of Health guidance.

18.6 The Governing Body shall decide if the CCG will insure through the risk pooling schemes

administered by NHS Resolution or self insure for some or all of the risks covered by the

risk pooling schemes. If the Governing Body decides not to use the risk pooling schemes

for any of the risk areas (clinical, property and employers/third party liability) covered by

the scheme this decision shall be reviewed annually.

18.7 There is a general prohibition on entering into insurance arrangements with commercial

insurers. There are however, three exceptions when the CCG may enter into insurance

arrangements with commercial insurers. The exceptions are:

a) for insuring motor vehicles owned by the CCG including insuring third party

liability arising from there their use;

b) where the CCG is involved with a consortium in a Private Finance Initiative

contract and the other consortium members require that commercial insurance

arrangements are entered into;

c) where income generation activities take place. Income generation activities

should normally be insured against all risks using commercial insurance. If the

income generation activity is also an activity normally carried out by the CCG for

a NHS purpose the activity may be covered in the risk pool. Confirmation of

coverage in the risk pool must be obtained from NHS Resolution. In any case of

doubt concerning a CCG’s powers to enter into the commercial insurance

arrangements the Chief Financial Officer should consult the Department of

Health.

18.8 Where the Governing Body decides to use the risk pooling schemes administered by NHS

Resolution the Chief Financial Officer shall ensure that the arrangements entered into are

appropriate and complementary to the risk management programme. The Chief Financial

Officer shall ensure that documented procedures cover these arrangements

18.9 Where the Governing Body decides to use the risk pooling schemes administered by NHS


Page 31 of 31

Resolution for one or other of the risks covered by the schemes, the Chief Financial

Officer shall ensure that the Governing Body is informed of the nature and extent of the

risks that are self-insured as a result of this decision

18.9 The Chief Financial Officer will draw up formal documented procedures for the

management of any claims arising from third parties and payments in respect of losses

which will not be reimbursed. The procedure for this will be outlined in the Losses and

Special Payments Policy

18.10 All the risk pooling schemes require scheme members to make some contribution to the

settlement of claims (the ‘deductible’). The Chief Financial Officer should ensure

documented procedures also cover the management of claims and payments below the

deductible in each case.

19. Custody of Seal, Sealing of Documents and Signature of Document 19.1 The common seal of the CCG shall be kept by the CCG’s Lead for Governance in a

secure place.

19.2 Where it is necessary that a document shall be sealed, the seal shall be affixed in the presence of the Accountable Officer, the Chair of the Governing Body or the Chief Finance Officer and shall be attested by them.

19.3 The Accountable Officer shall keep a register in which he/she, or another manager of the CCG authorised by him/her, shall enter a record of the sealing of every document.

19.4 A seal would normally need to be applied on the following types of document:

the transfer deed for a purchase or sale of freehold land or lease a lease a licence or deed which is supplemental to a lease, for example licences to carry

out works, licences to assign, licences to underlet, a surrender of a lease other miscellaneous deeds including planning agreements such as Section 106

Agreements, Deeds of Guarantee and Deeds of Easements (rights) where the Department of Health or another statutory body insists on a document

being sealed and following advice from the CCG‟s legal advisors this is appropriate a construction contract and/or collateral warranty.

19.5 Where any document will be a necessary step in legal proceedings on behalf of the

CCG, it shall, unless any enactment otherwise requires or authorises, be signed by the Accountable Officer, the Chair of the Governing Body or the Chief Finance Officer.

In land transactions, the signing of certain supporting documents will be delegated to Managers and set out clearly in the Scheme of Delegation but will not include the main or principal documents affecting the transfer (e.g. sale/purchase agreement, lease, contracts for construction works and main warranty agreements or any document which is required to be executed as a deed).


Leeds CCG Scheme of Delegation V1 April 2018

Operational Scheme of Delegation v1 April 2018

Finance

Issue Authority Delegated To Reference Documents Eg local procedures

Budgets (NB this column to be completed when detailed procedures have been created for the newly formed Leeds CCG)

Responsibility for keeping expenditure within budget: At individual budget level (pay, non pay and income)

Budget Holder/Budget Manager

Responsibility for keeping expenditure within budget: Totality of the service area / department

Budget Holder

Responsibility for keeping expenditure within budget: Financial reserves and provisions

Chief Finance Officer (CFO)

Approval of new Budget Holders or of change to existing budget holders

CFO or Deputy CFO

Any transfer (virement) from non-pay budgets to pay budgets CFO or Deputy CFO

Transfers (budget virement) within pay and non pay budgets Up to £300k (if affordable within overall budget) – Budget Holder (where transfers between budget holders both sets of budget holders must agree)

>£300k up to £1500k - Deputy CFO

Over £1500k – CFO

Transfers from reserves – CFO

Transfers between pay and non-pay budgets are by exception and must be agreed by CFO

Maintenance/operation of bank accounts

Day to day operation of organisational bank accounts Senior finance manager in conjunction with Shared

Appendix 3



Business Services representative

Authorisation for cash limit drawdown Deputy CFO or Senior Finance Manager Corporate finance

Authorisation for cheque requests (excluding retrospective continuing healthcare claims)

up to £15,000 - Authorised Budget Holder Representative

over £15,000 by exception only – Deputy CFO

Non Pay Expenditure

Before orders are placed for goods and services the following conditions must be complied with:

Confirmation that budgetary provision is available Budget Holder/Budget Manager

Where formal competitive tendering is not required e.g. below £160,000 , then quotations must be obtained and documentary evidence kept of the following

under £10,000 a minimum of 2 written quotations;

between £10,000 and £50,000 a minimum of 3 written quotations

between £50,001 and £160,000 a minimum of 5 written quotations

For Requisitions that exceed a 12 Month Period The total value of requisitions that cover more than a 12 month period or that are open ended need to be considered as a total value, not just the cost for the 12 month period.

Budget Holder/Budget Manager Commitment of any expenditure must be in line with delegated limits stated herein

For orders in excess of £160,000 including VAT competitive tendering will apply, the form of which is dependent on the precise goods or services involved. Therefore for all tenders above £160,000 including VAT the advice of the Chief Finance Officer must be sought. Nb OJEU existing limits are £615,278 including VAT for healthcare

Budget Holder/Budget Manager All tenders awarded should be reported to the Audit Committee for information



services and £181,302 including VAT for non healthcare services Commitment of any expenditure must be in line with delegated limits stated herein

Waiving of requirement to obtain quotations and tenders Chief Officer (CO) and CFO and report to Audit Committee

Approving expenditure greater than a tender price by Up to £45k and within budget - Relevant executive Officer

Up to a maximum of £90,000 – CFO

£90,000 and above – CO and CFO

Decision to tender for new/existing service (within agreed budget) Up to £150k – Authorised Budget Manager

>£150k up to £300k – Budget Holder

>£300k up to £1500k – CO or CFO

>£1500k – CCG Governing Body

Authorisation of new contracts for non pay and subsequent variations

Up to £300k – Budget Holder

Over £300k to £1500k– CO or CFO

Over £1500k – CCG Governing Body

Annual Renewal of existing healthcare contracts Up to £1500k – Budget Holder and CFO

Over £1500k– CO and CFO

Agreement of new GP local enhanced services / GP incentive schemes Up to £750k for total scheme (up to £25k for an individual practice) – CO and CFO

>£750k for total scheme (>£25k for an individual practice) – PCCC

Running costs: Approval of supplier contracts Up to £300k – CFO

>£300k up to £1500k – CO and CFO

>£1500k – CCG Governing Body

Lease Cars Budget Holder in line with operational process

Salary sacrifice schemes CFO or Deputy CFO

Payments in line with approved healthcare contracts Budget holder or budget manager (within



delegated limits) or authorised senior finance lead on behalf of budget holder

Other contractual payments (e.g. CQUIN, reconciliation adjustments) Budget Holder or budget holder representative within delegated limits

Payments of invoices for non-contractual activity Budget holder or budget holder representative or senior finance lead in line with delegated limits

Approval of Continuing Healthcare packages and other individual care packages

Packages costing<£1.5k/week – Clinical Leads or Care Coordinators

Packages costing>£1.5k up to £2.5k/week – Clinical Service Manager or Business Manager

Packages costing>£2.5k up to £10k/week – Commissioning Lead

Packages costing >£10k/week - CO

Payment in respect of Continuing Healthcare Packages and other individual care packages

Payments for invoices by individual homes / packages up to £25k – CHC Finance Administrator

Payments for invoices by individual homes / packages up to £75k – CHC Finance Lead

Payments for invoices by individual homes / packages up to £130k – Clinical Services Manager / Business Manager

Payments for invoices by individual homes / packages >£130k up to £250k – Commissioning Lead

Payments for invoices by individual homes / packages > £250k - CO

Consultancy Expenditure (amounts refer to the cost over the duration of the contract / project)

- Prior to expenditure being committed all business cases to be submitted to NHS England via pro-forma (to be approved internally first by



CFO)[email protected] and authorised by CFO and CO in line with organisational establishment/engagement control framework

Approval of invoices/payments/raising of requisitions – running costs or where a payment is not within a signed approved healthcare contract

up to £300,000 – Authorised Budget Holder Representative (when formally delegated – by exception by Budget Holder)

up to £750,000 – Budget Holder

up to £1500,000 – CFO or CO

over £1500,000 – CFO and CO

Request for sales orders • Up to £50k - Budget Holder/ Authorised Budget Holder Representative/Finance Lead

• >£50k to £250k – Deputy CFO • Over £250k - CFO

Capital Schemes / Estates

Responsibility for NHS Estate and associated capital schemes has passed to NHS Property Services

N/A

Purchase of internal fixtures and fittings – approval of requisitions By exception to be agreed by deputy CFO

Setting of Fees and Charges CFO

Engagement of bank/agency staff

Booking of Bank or Agency Staff

Budget Holder in line with organisational establishment/engagement control framework

Agreements / Licences

Preparation and signature of all tenancy agreements / licences for all staff subject to CCG Policy on accommodation for staff/operating leases/indemnity agreements/joint venture documents and service

CFO or CO

mailto:[email protected]



level agreements

Extensions to existing leases CFO

Letting of premises to outside organisations

CFO

Approval of rent based on professional assessment

CFO

Condemning & Disposal

Items obsolete, obsolescent, redundant, irreparable or cannot be repaired cost effectively; (including IT equipment)

with current / estimated purchase price of less than £50 per item

disposal of equipment (subject to estimated income of less than £1,000 per sale)

disposal of equipment (subject to estimated income exceeding £1,000 per sale)

Budget Holder Deputy CFO CFO

Losses, Write-offs & Compensation

Ex Gratia Payments CFO to be reported to Audit Committee

Losses and cash due to theft, fraud, corruption, overpayment, compensation and others except for CHC retrospective claims

Up to £150k – CO or CFO

>£150k – CCG Governing Body (all losses & payments to be reported to the Audit Committee)

Retrospective Continuing Healthcare Claims Up to £5k – Budget Holder

>50k up to £250k – CFO

>£250k – CO

Write off of debts Write off of NHS and Non NHS Debtors – CO or CFO.



To be reported to Audit Committee

Petty Cash Disbursements

a) Expenditure up to £75 per item

Budget Holder/Authorised budget holder representative in line with delegated limits Petty Cash disbursements over £75 per item are only allowed in exceptional circumstances with the prior agreement of the Chief Finance Officer, designated Deputy or Senior Finance Manager

Maintenance & Update of CCG Financial Procedures CFO

Human Resources Issues


Personnel and Pay

Authority to fill funded post on the establishment with permanent staff

Budget holder subject to finance approval

Job Description Review All requests for Job Description Review shall be dealt with in accordance with Organisational Procedure.

Agenda for Change Matching Process

Establishments Additional staff to the agreed establishment with specifically allocated finance in accordance with CCG Procedures.

Chief Finance Officer and Chief Officer Via Senior Management Team (SMT)



Pay i) Authority to complete standing data form effecting pay, new

starters, variations and leavers. ii) Authority to authorise overtime

iii) Authority to authorise travel & subsistence expenses

Budget Holder Budget Holder Senior Manager reporting to budget holder

Salary Amendment forms Budget Holder

Salary agreement/change– not covered by AfC/National T&Cs Remuneration Committee

Wage advances and unpaid leave Budget Holder in consultation with finance

Salary pay overs etc. (e.g. salary advances, tax, NI, pensions, salary sacrifice scheme invoice)

Deputy CFO / Financial Accountant / Ledger Accountant

Leave i) Approval of annual leave

ii) Annual Leave – In exceptional circumstances approval of carry forward up to maximum of 1 working week. iii) Annual Leave – In extreme cases approval of carry over in excess of 1 working week. iv) Special leave arrangements (up to a maximum of 10 days per year per employee (pro rata for part time staff))

Bereavement leave – up to 3 days (and additional days at the discretion of the Line Manager)

Compassionate leave – up to 3 days

Emergency Domestic Leave – up to 1 day

Emergency Carers/Dependant/Parental Leave – up to 1 day

Line Manager Line Manager Executive Officer

Line Manager

Line Manager

Line Manager

Line Manager Line Manager



v) Leave without pay vi) Time off in lieu vii) Maternity Leave, Adoption Leave, Maternity Support/Paternity Leave, Shared Parental Leave, Parental Leave - paid and unpaid

Line Manager

Line Manager

Automatic in consultation with HR

Sick Leave i) Extension of sick leave on half pay up to three months ii) Return to work part-time on full pay to assist recovery iii) Extension of sick leave on full pay

Line Manager in conjunction with HR On advice from Occupational Health in conjunction with HR Line Manager in conjunction with HR

Study Leave i) Study leave outside the UK ii) All other study leave (UK)

Executive Officer and Chief Officer Executive Officer and Chief Officer

Removal Expenses, Excess Rent and House Purchases Authorisation of payment of removal expenses incurred by officers taking up new appointments (providing consideration was promised at interview) i) up to £7,000 ii) over £7,000

Budget Holder and CFO Budget Holder and Chief Officer



Grievance Procedure All grievance cases must be dealt with strictly in accordance with the Grievance Procedure and the advice of HR.

Line Manager in conjunction with HR

Authorised Car and Mobile Phone Users Requests for new posts to be authorised as car users Requests for new posts to be authorised as mobile telephone users

Chief Finance Officer Budget Holder

Renewal of Fixed Term Contract

Budget Holder

Staff Retirement Policy Authorisation of extensions of contract beyond normal retirement age


Redundancy Line Manager, HR and Remuneration Committee

Ill Health Retirement Decision to pursue retirement on the grounds of ill-health


Dismissal Executive Officer or Chief Officer as per CCG’s policies

Facilities for staff not employed by the CCG to gain practical experience Professional Recognition, Honorary Contracts & Insurance of Medical Staff Work experience students

Executive officer in conjunction with HR Budget holder in conjunction with HR


Other


Authorisation of Sponsorship Deals Chair and CO

Authorisation of Research Projects Medical Director or Nursing Director

Insurance Policies CO or CFO

Patients & Relatives Complaints

a) Overall responsibility for ensuring that all complaints are dealt with effectively

b) Responsibility for ensuring complaints relating to a Executive

Office are investigated thoroughly

Executive Officers in conjunction with HR CO in conjunction with CCG Chairperson

Infectious Diseases and Notifiable Outbreaks On Call Manager or Executive Director in conjunction with Public Health England

Extended Role Activities Approval of Nurses to undertake duties / procedures which can properly be described as beyond the normal scope of Nursing Practice

Director of Nursing

Patient Services

Temporary Change

Permanent Change

Executive Officer Chief Officer


Reporting Incidents to the Police a) Where a criminal offence is suspected b) Where a fraud is involved

On Call Manager or Executive Officer Chief Finance Officer or Local Counter Fraud Specialist (LCFS)

Review of Fire Precautions

Chief Officer

Receiving Hospitality Applies to both individual and collective hospitality receipt items.

Executive officer. Declaration required in CCG's Hospitality Register

Individual Funding Requests Approve triage process and act as the decision maker at IFR Panel meetings in relation to Leeds patients

Medical Director or Associate Medical Director or other clinician nominated by the Medical Director or Chief Officer

Implementation of Internal and External Audit Recommendations Lead Manager as defined in Audit report


Primary Care Co-Commissioning (as per NHSE delegation agreement) – applies to all CCGs

Decision Person/Individual NHS England Approval Required from

General

Taking any step or action in relation to the

settlement of a Claim, where the value of the

settlement exceeds £100,000

CCG Chief Officer or Chief Finance Officer NHS England Head of Legal Services

and

Local NHS England Team Director or Director of

Finance

Any matter in relation to the Delegated Functions

which is novel, contentious or repercussive

CCG Chief Officer or Chief Finance Officer Local NHS England Team Director or Director of

Finance or

NHS England Region Director or Director of

Finance or

NHS England Chief Executive or Chief Financial

Officer

Revenue Contracts

The entering into of any Primary Medical Services

Contract which has or is capable of having a term

which exceeds five (5) years

CCG Chief Officer or Chief Finance Officer

Local NHS England Team Director or Director of

Finance


Version: Version 1.0

Ratified by:

Date ratified:

Name & Title of Originator/Author(s) Michelle van Toop, Associate Director of Procurement & Contracting (interim)

Name of Responsible Committee/Individual:

Visseh Pejhan-Sykes, Chief Finance Officer

Date issued:

Review Date: September 2018

File location: S:\Contracting (shared)\1. Contracting and guidance documents\Procurement Policy and Templates

Target Audience: All NHS Leeds CCG Employees and Members

DRAFT

PROCUREMENT

POLICY

Appendix 4

Version: 1.0 Effective Date: February 2018 Page 2 of 20

CONTENTS Page

1. Introduction 3

2. Associated Policies and Procedures 4

3. Aims and Objectives 4

4. Scope of this Policy 5

5. Accountabilities and Responsibilities 5

6. Guiding Principles 7

7. Conflicts of Interest 8

8. Compliance with Regulations 8

9. Procurement approach for sub-threshold contracts 9

10. Circumstances where competitive tenders or quotations may not be required.

10

11. Contract extensions & variations to contracts during the contract term 11

12. Partnership Agreements with Local Authorities 12

13. Other contracting models 13

14. Third Sector Providers 14

15. Contract Form 15

16. Pilot Projects 15

17. Sustainable Procurement 15

18. Consultancy Expenditure/Interim Labour 15

19. Primary care contracts 16

20. Record Keeping and Register of Procurement Decisions 16

21. Use of Information Technology 17

22. Decommissioning Services 17

23. Transfer of Undertakings and Protection of Employment Regulations (TUPE)

17

24. Complaints and Dispute Procedure 17

25. Training 18

26. Monitoring Compliance with this Policy 18

Appendix 1: Template to be used when commissioning services that may potentially

be provided by GP practices

19


1. Introduction

1.1. Procurement is a cyclical process in which goods, services and works are secured or

purchased. The process spans the whole life cycle from identification of needs, through to the end of a service’s contract or the end of the useful life of an asset. Procurement can encompass everything from repeat low-value orders, through to complex healthcare service solutions developed and delivered through partnership arrangements.

1.2. Effective procurement is an essential component of commissioning improved services and outcomes for local patients and communities and for ensuring value for money.

1.2. Procurement in the public sector is regulated by primary legislation and there are a range of procurement approaches available depending on the value of the procurement and the number of participants in the market. However The NHS Five Year Forward View and the Next Steps update published in March 2017 described a movement towards integrated care, delivered through collaboration across health and care systems. These new ways of working will require NHS Leeds CCG (LCCG) to develop new procurement and contracting models in line with guidance from NHS England.

1.3. The Public Contracts Regulations (PCR 2015) came into force on 18 April 2016 for CCGs when procuring health and care services (non-healthcare services have always been subject to PCR). These rules apply to public bodies, including CCGs, NHS England and local authorities, and have implications for the procurement of all contracts commenced after that date.

1.4. The PCR 2015 form part of the procurement landscape alongside the NHS (Procurement, Patient Choice and Competition) (No.2) Regulations 2013 (PPCCR). Made under Section 75 of the Health and Social Care Act 2012, the PPCCR apply to NHS England and CCGs and are enforced by NHS Improvement. Whilst the two regimes overlap in terms of some of their requirements, they are not the same – compliance with one regime does not automatically mean compliance with the other. NHS LCCG will ensure that it complies with

both regimes when procuring healthcare services.

1.5. The PPCCR follow a principles based approach leaving commissioners flexibility as to how best to procure and secure services in the best interests of service users. Commissioners need to comply with a number of requirements under the PPCCR to help them achieve the overall objective of securing the needs of patients and improving the quality and efficiency of services, including:

a) acting transparently and proportionately, and treating potential providers equally and in a non-discriminatory way;

b) procuring services from the providers that are most capable of delivering commissioners’ overall objective and that provide the best value for money;

c) considering ways of improving services; and

d) having arrangements in place that allow providers to express an interest in a contract.

1.4. NHS LCCG’s approach to procurement is to operate within legal and policy frameworks and where appropriate to use procurement as one of the system management tools available to achieve commissioning outcomes and increase value for money.

.


2. Associated Policies and Procedures 2.1. This policy and any procedures derived from it should be read in accordance with the

following local policies, procedures and guidance:

NHS Leeds Clinical Commissioning Group Constitution

NHS LCCG Detailed Financial Policies

NHS LCCG Scheme of Delegation

NHS LCCG Budgetary Control Framework

NHS LCCG Declaration of Interests and Potential Conflicts of Interests Policy NHS LCCG Data Protection Impact Assessment (DPIA) Policy

3. Aims and Objectives

3.1. To set out how the NHS LCCG will meet its statutory procurement requirements to

secure high-quality, efficient health care services that meet the needs of people who use those services; and

protect the rights of patients to choose who provides their health care in certain circumstances.

3.2 To set out the approach for facilitating fair, robust and enforceable contracts that provide value for money and deliver required quality standards and outcomes, with effective performance measures and contractual levers. (This document is not intended to be a detailed procedure manual. A separate Procurement Procedure Manual will be produced by March 2018 following consultation with relevant stakeholders.)

3.4. To enable early determination of whether, and how, services are to be opened to

competition, to facilitate transparent and fair discussion with existing and potential providers and thereby to facilitate good working relationships.

3.5. To enable NHS LCCG to demonstrate compliance with the principles of good procurement

practice in accordance with the EU Treaty Principles of:

equal treatment;

non-discrimination;

proportionality;

transparency; and

mutual recognition.


4. Scope of the Policy 4.1. As far as it is relevant, this policy applies to all NHS LCCG procurements (clinical and

non-clinical). 4.2. This policy must be followed by all NHS LCCG employees including staff on temporary or

honorary contracts, representatives acting on behalf of NHS LCCG including staff from member practices, and any external organisations acting on behalf of NHS LCCG including other CCGs, EMBED and NHS Shared Business Services.

5. Accountabilities & Responsibilities

5.1. Governing Body responsibility The Governing Body has the ultimate responsibility for ensuring that NHS LCCG meets its statutory requirements when procuring goods and services, including healthcare services. The governing body must be transparent when making decisions to procure and be the authorising body for awarding a contract once an appropriate process has been completed. When considering options for procurement the Governing body will follow the guidelines set out by NHS England and Crown Commercial Services

https://www.gov.uk/guidance/transposing-eu-procurement-directives.

5.2 Lead Responsibility

Overall responsibility for procurement within NHS LCCG rests with the CFO however individual managers will be responsible for recognising when a commissioning decision may have potential procurement implications and for seeking appropriate procurement support. Commissioning Managers are responsible for ensuring that they plan their commissioning decisions in sufficient time to carry out the required procurement process.

5.3. Procurement support

Where it is required and considered appropriate procurement support will be provided by either: NHS Shared Business Services; or } (or their successor contractors Kier Business Services Ltd (EMBED). } subject to contract)

In the case of collaborative or partnership projects where NHS LCCG is not the sole or

lead commissioner, procurement support arrangements will be agreed in consultation with the Lead Commissioner or Commissioning Partners on a case by case basis. This may involve support being provided by another CCG, Leeds City Council, or an independent procurement support service. Whenever external procurement support is provided by any organisation, NHS LCCG will have systems in place to assure itself that the supporting organisation’s business processes are robust and enable the organisation to meet its duties in relation to procurement.

5.4. Authority

https://www.gov.uk/guidance/transposing-eu-procurement-directives


NHS LCCG will remain directly responsible for:

Approving the procurement route;

Signing off specifications and evaluation criteria;

Signing off decisions on which providers are taken through to the Invitation to Tender (ITT) stage following a pre-qualification process (where appropriate)

Making final decisions on the selection of the preferred provider.

Arrangements for delegation of authority to officers are set out in the Operational Scheme of Delegation, in the event of any discrepancy between this Procurement Policy and the Scheme of Delegation, the latter document will take precedence.

5.5 Engagement

NHS LCCG is committed to engaging relevant stakeholders in all aspects of procurement

and encourages their engagement in the design and co-production of services.

The CCGP recognises that the engagement of clinicians, patients and public in designing

and procuring services results in better services. Business processes will therefore require

evidence of engagement for business cases to be approved. This will ensure that

procurement of services is informed by authentic and meaningful engagement.

In accordance with the NHS Constitution pledge, all staff will be engaged in changes that

affect them.

5.6 Collaboration

NHS LCCG is committed to operating in a sustainable environment where all opportunities

for efficiencies and economies of scale are considered and, were applicable applied. This

includes the sharing of operational resources or commitment to specific joint

projects/contracts across Leeds and the wider West Yorkshire footprint where this serves

the best interest of the Leeds population. The move towards further integration will

necessitate the development of new types of contracts for accountable care models and the

CCG will follow guidance from NHS England on their application.

5.7 ISAP

As the NHS LCCG moves towards commissioning integrated care systems, some of

these complex contracts may include such a significant scope of services that the

CCG’s ongoing role will change. For example, the commissioner may take a more

strategic role, establishing different relationships with neighbouring CCGs, the local

authority and providers, and enable these bodies to carry out commissioning activities

on its behalf. NHS LCCG will apply the NHS England Integrated Support and

Assurance Process (ISAP) where applicable to ensure that future arrangements are

robust and viable and that the NHSLCCG continues to deliver its statutory functions

effectively.

5.8 Equality Impact Assessment:

All public bodies have statutory duties under the Equality Act 2010. The NHS LCCG aims to


design and implement services, policies and measures that meet the diverse needs of our

service, population and workforce, ensuring that none are placed at a disadvantage against

others. NHS LCCG will ensure, when applying this policy that it complies with its duties

under the Equality Act 2010 and does not discriminate on grounds of race, colour, age,

nationality, ethnicity, gender, sexual orientation, marital status, religious belief or disability.

5.9 Risk Management

When carrying out procurement activity, NHS LCCG will ensure that it plans adequate

measures to identify and manage risk.

6. Guiding Principles

6.1. In accordance with the NHS LCCG’s Constitution, when procuring health care services, NHS LCCG is required to act with a view to:

Securing the needs of health care service users

Improving the quality of the services, and

Improving the efficiency with which services are provided

6.2. NHS LCCG is required and committed to:

acting in a transparent way, including maintaining suitable records of key decisions

relating to procurement, sharing information on future procurement strategies, and

the use of sufficient and appropriate advertising of tenders.

ensuring that procurement processes are proportionate to the value, complexity and

risk of the services to be procured.

treating providers equally and in a non-discriminatory way by not treating a single

provider, or type of provider, more favourably than any other provider in particular

on the basis of ownership.

6.3. NHS LCCG is required and committed to commissioning services from the providers that:

are most capable of delivering to the quality and efficiency required

provide the optimum value for money

6.4. NHS LCCG is required and committed to act with a view to improving quality and efficiency in the provision of services. The means of doing so will include:

Providing the services in an integrated way (including with other healthcare services, health related services, or social care services as part of an accountable care system)

enabling providers to compete to provide the services

allowing patients a choice of provider of the services

7. Conflicts of Interest.

7.1 For all procurement projects and decision making events, all members present must

declare any interest or perceived conflict of interest in relation to the topic being discussed.


7.2 Potential conflicts of interest will be managed appropriately to protect the integrity of NHS LCCG’s contract award decision making processes and the wider NHS commissioning system. This is to ensure public confidence and to protect the CCGP and GP practices from any perceptions of wrong-doing.

7.2. General arrangements for managing conflicts of interest are set out in NHS LCCG’s Constitution. This section describes additional safeguards that NHS LCCG will put in place when commissioning services that could potentially be provided by GP practices and/or other system partners.

7.4. Where any practice or system partner representative on a decision-making body has a

material interest in a procurement decision, those practice representatives will be excluded from the decision-making process. See Section 19 of this policy for further details relating to GP Practices and GP Federation.

7.5 When contracting for integrated care models and/or accountable care systems NHS LCCG will take reasonable steps to ensure that competition is not distorted by allowing system partners who may tender for contracts access to information not available to other potential bidders and/or providers.

8. Compliance with Regulations

8.1 NHS LCCG and/or its agents will comply with EU and UK legislation and NHS LCCG’s

Detailed Financial Policies, Budgetary Control framework and Scheme of Delegation for

the procurement of all goods and services, including healthcare services.

8.2 BREXIT: There is no official government statement yet regarding to the impact of BREXIT

on EU and UK Public Procurement policy. Unless PCR 2015 is repealed this legislation

will remain in force even after the UK leaves the European Union. NHS LCCG will update

this section of the policy once information is available.

8.3 National Health Service Act 2006 Section 242 (Public Involvement and Consultation)

requires commissioners of healthcare services to consult patients and the public- directly

or through representatives. - in relation to service planning, development and

consideration of service changes and decisions that affect service operation.

8.4 The Health and Social Care Act 2012 empowers CCGs to commission healthcare

services for local populations. The duties of CCGs are set out in section 3 of the National

Health Services Act 2006 with updated amendments and regulations in section 13 of the

Health and Social Care act 2012.

8.5 Commissioners must comply with the NHS (Procurement, Patient Choice and

Competition) (No.2) Regulations 2013. (PPCCR) where objectives include patient

experience, outcomes and improved efficiency. These regulations (implemented under

Section 75 of the Health and Social Care Act 2012) place requirements on commissioners

to ensure that they adhere to good practice in relation to procurement, do not engage in

anti-competitive behaviour and protect the right of patients to make choices about their

healthcare. These regulations give NHS Improvement the power to enforce these

regulations rather than the courts.

8.6 The Public Contracts Regulations 2015 (PCR 2015) Regulations 74-76 require healthcare

services with a lifetime value of £615,278 or above to be advertised Europe-wide via


OJEU (the Official Journal of the European Union) and in the UK via Contracts Finder.

Under these regulations, healthcare services (classified as health, social or other

services) may be procured using the “Light-Touch-Regime.” (LTR)

8.7 PCR 2015 also stipulates specific procurement processes that must be followed for other

goods and services over a lifetime value of £181,302 including VAT (for sub-central

authorities)

8.8 The OJEU Thresholds stated in paragraph 8.6 and 8.7 are current as at January 2018.

They are generally recalculated every 2 years and are communicated via a Procurement

Policy Note (PPN) on the www.gov.uk website

8.9 Other legislation relevant to this procurement policy includes:

Local Government Act 1999. If a CCG is co-commissioning with the Local Authority,

Section 3(1) of this Act sets out a duty of consultation.

Competition Act 1998

Public Services (Social Value) Act 2012. Commissioners are required to consider

how the services they commission and procure might improve the economic, social

and environmental well-being of the area.

Equality Act 2010- Section 149.

Freedom of Information Act (2000)

NHS LCCG will comply with the requirements set out in the Freedom of Information

Act 2000 (Legislation .gov.uk, 2000) whilst conducting procurements. As part of this,

information regarding individuals and organisations involved within the procurement

process will be protected during all stages of the process. On commencement of

the procurement process, NHS LCCG will make potential bidders aware of the

requirement for the CCGP to comply with the Act.

9. Procurement approach for sub-threshold contracts.

9.1. For goods and services with an aggregate value below the thresholds stated in

paragraphs 8.6 and 8.7 the following rules will apply in accordance with the organisational scheme of Delegation:

Under £10,000 a minimum of 2 written quotations must be obtained

Between £10,000 and £49,000 a minimum of 3 written quotations must be obtained

Between £50,000 and £160,999 a minimum of 5 written quotations must be obtained. All contracts must be subject to NHS Standard Terms and Conditions which must be stated with the specification and, although the quotations do not need to be in a specific format, a Request For Quotation (RFQ) template is available from the Finance & Contracting Department to ensure consistency.

For procurements in excess of £160,000 competitive tenders must be sought, the form of which is dependent on the precise goods and services involved. Therefore, for all tenders above £160,000 the advice of the Deputy CFO must be sought and commissioning managers must ensure that they allow sufficient time to conduct an

http://www.gov.uk/


appropriate process.

9.2 Where open quotations or tenders are sought below the OJEU thresholds then the opportunity should be published on Contracts Finder instead of, or in addition to, other portals or sites for contracts over the value of £25,000. This does not apply where RFQs have been sent to specific providers in accordance with paragraph 9.1

10. Circumstances where competitive tenders or quotations may not be required

10.1 NHS LCCG is committed to ensuring that services are procured in accordance with legislation. In limited circumstances the need to request quotations or competitive tenders may be waived. Regulation 32 of the PCR 2015 and the NHS LCCG scheme of delegation outline the following circumstances where contracts may be awarded without a full tender exercise:

10.1.1 in very exceptional circumstances where the Chief Officer and Chief Financial Officer decide that formal tendering procedures would not be practicable or the estimated expenditure or income would not warrant formal tendering procedures, and the circumstances are detailed in tender waiver and reported to the Audit Committee;

10.1.2 where the requirement is covered by an existing contract;

10.1.3 where national or local framework agreements are in place and have been approved by the Governing Body, NHS England or Crown Commercial Services;

10.1.4 where a consortium arrangement is in place and a lead organisation has been appointed to carry out tendering activity on behalf of the consortium members;

10.1.5 where the timescale genuinely precludes competitive tendering. NB failure to plan the work properly would not be regarded as a justification for a tender waiver;

10.1.6 where specialist expertise or technology is required and is available from only one source and this has been evidenced by market consultation;

10.1.7 when the task is essential to complete the project, and arises as a consequence of a recently completed assignment and engaging different consultants for the new task would be inappropriate; or

10.1.8 there is a clear benefit to be gained from maintaining continuity with an earlier project. However in such cases the benefits of such continuity must outweigh any potential financial advantage to be gained by competitive tendering.

10.2 The waiving of competitive tendering procedures should not be used to avoid competition or for administrative convenience or to award further work to a provider originally appointed through a competitive procedure (unless in the case of 8 above.) In any event the tender waiver must comply with Regulation 32 of the Public Contracts Regulations 2015.

10.3 In any of the circumstances detailed in paragraph 10.1.1 to 10.1.8 a Tender waiver Form must be completed by the Commissioning Manager and approved by both the CFO and CO. Signed forms should then be sent to the Head of Governance. The same process will be used to waive the request for quotations.

10.4 Tender waiver forms over a value of £160,000 will be sent to the Audit Committee for noting. In addition tender waivers over the EU Threshold usually require the publication of a Voluntary Ex-Ante Transparency (VEAT) notice in the OJEU prior to the award. The


advice of the Deputy CFO must be sought in these circumstances.

11. Contract Extensions and Variations to contracts during the contract term

11.1 In accordance with regulation 72 of the PCR 2015, contracts over the EU Threshold may only be varied in the following circumstances:

11.1.1 where modifications have been provided for in the original procurement documents and/or would not alter the nature of the contract.

11.1.2 where the modification is less than 10% of the value of the contract and does not change the nature of the contract.

11.1.3 for additional services or supplies by the original contractor that have become necessary and were not included in the initial procurement and where a change of contractor:

cannot be made for economic or technical reasons such as requirements of

interchangeability or interoperability with existing equipment, services or installation

procured under the initial procurement, or

would cause significant inconvenience or substantial duplication of costs for the

NHS LCCG,

In the above circumstances any increase in price must not exceed 50% of the value

of the original contract

11.1.4 where all of the following conditions are fulfilled:

the need for modification has been brought about by circumstances which a diligent contracting authority could not have foreseen;

the modification does not alter the overall nature of the contract;

any increase in price does not exceed 50% of the value of the original contract

11.1.5 Where a new contractor replaces the original contractor e.g. in the case of a merger or takeover.

11.2 Modifications to contracts over the EU Threshold may also require completion of the

tender waiver process and the publication of a Voluntary Ex-Ante Transparency (VEAT)

notice in the OJEU prior to the award. The advice of the Deputy CFO must be sought in

these circumstances.

11.3 Contracts cannot be extended unless there is provision in the original procurement

documents to do so or one of the provisions of Regulation 72 applies. A new procurement

procedure is required for any contract variations or extensions except in the

circumstances outlined in paragraph 11.1 above.

12. Partnership Agreements with Local Authorities

12.1 National Policy and local strategies both promote the increased integration of health and social care services however new models of contracting for care, including Accountable Care organisations (ACOs), Multispecialty Community Providers (MCPs) and Primary &


Acute Care Systems (PACS), still need to be procured in the same way as lead provider contracts. Alternatively several other mechanisms exist to support joint commissioning of services across health and social care such as:

12.2 Section 75 (S75) Partnership Agreements

Section 75 of the NHS Act 2006 sets out a number of powers that support partnership and

joint commissioning across health and social care. Key provisions of the act allow NHS

Bodies and Local authorities to establish pooled budgets, and also allow for the delegation

of certain statutory functions from one partner to the other through a lead commissioning

arrangement.

Section 75 powers are intended to be used where partnership arrangements are likely to

lead to improvements in the delivery of NHS and Local Authority functions.

Although functions can be delegated, each partner remains liable for their own statutory duties.

12.3 Section 256 (S256) Agreements

S256 Agreements were established through the NHS Act 2006 and allow NHS

commissioners to make payments to Local authorities towards any Local Authority

expenditure which in the opinion of NHS LCCG would have an effect on the health of

individuals, or which would have an impact on, or be affected by, NHS commissioned

services, or are otherwise connected with other NHS functions.

They are payments to a local authority to support specific services, projects, capital costs,

or other local authority activities which have a benefit for the NHS. However these

agreements do not involve the transfer of any statutory health functions to the local

authority.

S256 Agreements are not subject to formal procurement processes, as NHS LCCG is not

directly commissioning or contracting for goods or services in this instance. However

S256 agreements must comply with any relevant Directions published by the Secretary of

State.

Section 256 specifies two prescribed documents to be completed when making the agreement:

(i) A Certificate of Expenditure (annual voucher) (ii) Memorandum of Agreement

12.4 Better Care Fund

In addition to the two types of partnership agreements described above, the Better Care Fund (BCF) is a nationally mandated pooled budget across health and social care. The BCF is intended to promote further integration and support delivery of improved outcomes across health and social care to achieve the National Conditions and Local Objectives. It is a requirement of the BCF that NHS LCCG and the Council establish a pooled fund for this purpose. The BCF is not ‘new money’ and represents the summation of existing


pooled and aligned budgets along with all existing local and national transfers from health to social care. The Leeds City Council and the NHS LCCG currently use a Framework Partnership Agreement relating to the commissioning of health and social care funding. The Partners have entered into the Agreement in exercise of the powers referred to in Section 75 of the NHS Act 2006 (2006a) and/or Section 13(2) and 14(3) of the NHS Act 2006 as applicable.

NHS LCCG will ensure it adheres to any current and updated National Policy and Guidance on the Better Care Fund.

13. Other Contracting Models

13.1 Spot Purchasing

From time to time there will be the need to spot purchase contracts for particular individual patient needs or for urgency of placements requirements at various times. At these times, a competitive process may be waived using the same process described in paragraphs 10.2 to 10.4.

It will be expected that these contracts will undergo best value reviews to ensure that NHS

LCCG is getting value from the contract. Value for money should be assessed by the manager with responsibility for signing off the spot purchasing agreement or individual service agreement, and then reviewed annually.

Sign off of spot purchase agreements should follow the Detailed Scheme of Delegation. In

all cases the NHS LCCG should ensure that the provider is fit for purpose to provide the particular service. The process will follow EU and UK Public Procurement rules and NHS LCCG’s Financial Policies and Scheme of Delegation as appropriate.

13.2 Framework Agreements

Framework agreements are pre-tendered agreements which are established in compliance with the PCR2015 and which, once established, can be used by NHS LCCG to purchase certain products and/or services without the need to carry out a full procurement process.

A framework can be established:

By NHS LCCG for its own use

By another CCG, Contracting Authority or central purchasing body such as the Crown Commercial Service.

Various existing frameworks are available for NHS LCCG to use such as the Crown Commercial Service (CSS) to purchases goods or services without a full local tender. Each framework will have its own ordering process to follow but the timescales and transaction costs are usually far lower than running a full procurement. The terms and conditions applicable to any subsequent call-off contract are defined by the particular framework agreement and may not be compatible with the NHS standard contract and therefore advice must be sought from the framework owner prior to conducting a mini-competition.

13.3 Any Qualified Provider (AQP)

AQP describes an approach for contracting for services whereby


Providers qualify and register to provide services via an assurance process that tests providers’ fitness to offer NHS-funded services.

The CCG sets local pathways and referral protocols which providers must accept

Referring clinicians offer patients a choice of qualified for the service being referred to

Competition is based on quality, not price. Providers are paid a fixed price determined by a national or local tariff.

With the AQP model, for a prescribed range of services, any provider that meets criteria for entering a market can compete for business within that market. Under AQP there are no guarantees of volume or payment, and competition is encouraged within a range of services rather than for sole provision of them.

The AQP model promotes choice and contestability, and sustained competition on the basis of quality rather than cost. A service that is contracted through the AQP model may not need to be tendered using the full EU process although it must be advertised appropriately and potential service providers will need to be qualified/accredited. The NHS LCCG will consider PCR 2015 in relation AQP contracts and will have due regard at all times to the EU Treaty principles of non-discrimination, equal treatment, transparency, mutual recognition and proportionality when applying the AQP Procedure.

13.4 Grants

Where third sector organisations provide healthcare services, the NHS LCCG may elect to provide funding through a grant agreement. Use of grants can be considered where:

NHS LCCG is only making a partial contribution to the costs of a service (e.g. where a service is also supported by charitable donations or other funding streams)

Funding is provided for development or strategic purposes

The provider market is not well developed

The services are innovative or experimental

Where funding is non-contestable (i.e. only one provider)

Grants will not be used to avoid competition where it is appropriate for a formal procurement to be undertaken.

NHS LCCP will follow NHS England Grant Agreement Guidance on the use of the draft model Grant Funding Agreement although the model grant agreement is non-mandatory and is for local adaptation as required.

14. Third sector providers and support for campaigns

14.1 NHS LCCG will support the Governments attempts to increase activity in third sector providers and small and medium enterprises. NHS LCCG will ensure that no organisation is discriminated against. NHS LCCG will act transparently and not request disproportionate demanding information, therefore reducing the barriers to entry. Commissioning Managers should refer to the Commissioning Code of Practice.

14.2 Where NHS LCCG wishes to support a local or national campaign (e.g. through the purchase of campaign media) the Scheme of Delegation will apply in the same way as for the purchase of goods and services. The authorising Budget Holder must satisfy themselves that the campaign is compatible with the NHS LCCG commissioning strategy and that it conforms to the relevant NHS policies (e.g. in terms of branding, information governance etc.)


15. Contract Form 15.1 NHS LCCG will ensure that, where appropriate, the NHS Standard Contract will be used

for all contracts. Where a framework agreement has been used the terms and conditions of contract will usually be those of the specific framework.

15.2 In exceptional circumstances, such as where a joint contracting arrangement is led by the

local authority, the NHS LCCG may agree to be party to a different form of contract. 15.3 NHS LCCP will ensure that a standard Grant Agreement document will be used to record

the provision of grants to third parties which will contain the provisions upon which the grant is made.

16. Pilot Projects 16.1 Pilot Projects may be commenced in circumstances where clinical outcomes are not

known or when outputs cannot be predicted. Pilot projects must comply with EU and UK Procurement regulations.

17. Sustainable Procurement 17.1 NHS LCCG recognises the impact of its purchasing and procurement decisions on the

regional economy and the positive contribution it can make to economic and social regeneration.

17.2 Wherever it is possible, and does not contradict or contravene NHS LCCG’s procurement

principles or applicable legislation and guidance, NHS LCCG will work to develop and support a sustainable local health economy.

18. Consultancy expenditure/Interim Labour 18.1 Approval to engage an interim manager, consultant or consultancy company for any

reason must be obtained in advance in accordance with Appendix 1 of the NHS LCCG Budgetary Control Framework.

18.2 In addition to 18.1 NHSLCCG is expected to secure advance approval from NHS England before engaging or continuing to employ off-payroll staff (including consultancy staff) who meet the following criteria:

Cost greater than £600 per day (excluding VAT and expenses)

Are engaged for a period greater than six months; or

Are in roles of significant influence (e.g. Accountable Officers and Directors).

19. Primary Care Contracts. 19.1 NHS LCCG will comply with the Primary Medical Care Policy and Guidance published by

NHS England with regard to the procurement and award of primary care contracts; in

particular in relation to whether a competitive process is required.


19.2 The template included at Appendix 1 will be completed as part of the planning process for

all services that may potentially be provided by GP Practices/GP Federation (either as a

successful bidder in a competitive procurement process, as one of several qualified

providers through an Any Qualified Provider (AQP) approach, or via a non-competitive

process from GP Practices).

19.3 This template should be completed by the commissioning team responsible for proposing

the service or the service change/development. The completed template will be used to

provide assurance to the NHS L CCGP Governing Body that proposed services meet

local needs and priorities and that robust processes have been followed in selecting the

appropriate procurement route and in addressing potential conflicts.

19.4 It is intended that completed templates will be made publicly available via the NHS LCCG

website. Where appropriate, commissioning decisions related to Enhanced services from

GP Practices may also be referred to the local overview and scrutiny committee for

consideration.

19.5 Where any practice representative on a decision- making body has a material interest in a

procurement decision, those practice representatives will be excluded from the decision-

making process. This includes where all practice representatives have a material interest,

for example where NHS LCCG is commissioning services on a single tender basis from all

GP Practices in the area.

19.6 Rules relating to quoracy in these and other circumstances are set out in the NHS LCCG

Constitution.

20 Record Keeping and Register of Procurement Decisions 20.1 In accordance with the PPCC Regulations (2013) about record keeping the NHS LCCG

will:

publish details of all contracts they award (Regulation 9(1) via Contracts Finder and/or OJEU as appropriate

record how any conflicts of interest have been managed (Regulation 6(2); and

maintain details of how a contract award complies with their duties relating to effectiveness, efficiency and improvement in the quality of services and the delivery of services in an integrated way in the National Health Service Act 2006 (Regulation 3(5) of the PPCC Regulations).

20.2 NHS LCCG will maintain a Register of Procurement Decisions taken, either for the

procurement of a new service, any extension or material variation of a current contract: This will include

The details of the decision;

Who was involved in making the decision

A summary of any conflicts of interest in relation to the decision and how this was managed by the NHS LCCG; and

The award decision taken 20.3 The register of procurement decisions will be held and maintained by the Head of

Corporate Governance & Risk and will include a list of all current and future


procurements. Decisions will be added to the register as quickly as possible after they are made.

20.4 The Register of Procurement Decisions will be made available to the public by placing it

on the NHS LCCG external website.

20.5 A Contracts Register will be maintained centrally by the Contracting Department as well as a copy of all NHS LCCG contracts.

21. Use of Information Technology 21.1 NHS LCCG will require providers of procurement support to offer appropriate information

technology systems to administer the procurement process – such as e-tendering and e-evaluation systems. These are intended to assist in streamlining LCCG procurement processes whilst at the same time providing a robust audit trail.

22. Decommissioning Services

21.1 The need to decommission contracts can arise through termination of a contract due to

performance against the contract not delivering the expected outcomes, expiry of a contract and/or a commissioning decision that the contracted services are no longer required. Where services are decommissioned, NHS LCCG will ensure where necessary that contingency plans are developed to maintain patient care. Where decommissioning involves Human Resource issues, such as TUPE issues, then providers will be expected to cooperate and be involved in discussions to deal with such issues.

23. Transfer of Undertakings and Protection of Employment Regulations (TUPE) 23.1 These regulations apply when there are transfers of staff from one legal entity to another

as a consequence of a change in employer. This is a complex area of law which is continually evolving. NHS LCCG will follow the relevant Government guidance such as the Cabinet Office Statement of Practice (COSOP) Staff Transfers in the Public Sector January 2000 (Revised December 2013) (Cabinet Office, 2013).

23.2 It is the position of NHS LCCG to advise potential bidders that whilst not categorically

stating TUPE will apply, it is recommended that they assume TUPE will apply when preparing their bids, and ensure that adequate time is built into procurement timelines where it is anticipated that TUPE may apply.

24. Complaints and Dispute Procedure 24.1 NHS LCCG’s approach to contestability means that it is likely to pursue a wide range of

competitive procurements to secure new and existing services. 24.2 NHS LCCG will utilise its dispute resolution processes to address and resolve any

complaint received from either bidders/contractors or a member of the public

25. Training 25.1 All NHS LCCG staff and others working with NHS LCCG will need to be aware of this

policy and its implications. It is not intended that staff generally will develop procurement expertise, but they will need to know when and how to seek further support.


25.2 All NHS LCCG Procurement & Contracting staff should be appropriately qualified. NHS LCCG will provide appropriate training to enable Procurement & Contracting staff to undertake their duties in accordance with the Regulations and recognised best practice.

25.2 All commissioning staff throughout NHS LCCG should have sufficient knowledge about

procurement to know when to seek help when they encounter related issues; they must also be able to give clear and consistent messages to providers and potential providers about NHS LCCG’s procurement intentions in relation to individual service developments.

26. Monitoring Compliance with this Policy 26.1 This Policy will be reviewed every three years. 26.2 In addition it will be kept under informal review by the Deputy CFO, to ensure that

changes can be made and approved rapidly following any further developments or the publication of new or updated regulations and/or guidance.

26.3 Effectiveness in ensuring that all procurements comply with this Policy will primarily be

achieved through review by the CFO.


Appendix 1 Template to be used when commissioning services that may potentially be provided by GP practices

Part 1: Questions applicable for all procurements

Service

Question Comment & supporting evidence

How does the proposal deliver good or improved

outcomes and value for money - what are the

estimated costs and estimated benefits?

How does the proposal reflect NHS LCCG’s

commissioning priorities?

How have you involved the public in the decision to

commission this service?

What range of health professionals have been

involved in designing the proposed service?

What range of potential providers have been involved

in considering the proposals

How have you involved your Health and Well-Being

board? How does the proposal support the priorities

in the Joint Health and Well-being Strategy?

What are the proposals for monitoring the quality of

the service?

What systems will there be to monitor and publish

data on referral patterns?

Have all conflicts and potential conflicts of interests

been appropriately declared and entered in registers

which are publicly available?

Why have you chosen this procurement route?

What additional external involvement will there be in

scrutinising the proposed decisions?

How will NHS LCCG make its final commissioning

decision in ways that preserve the integrity of the

decision making process?


Part 2: Additional Questions for Single Tenders (direct award) or AQP – where national tariffs do not

apply


How have you determined a fair price for the

service? (*Delete if tariff set prior to advertising)

Part 3: Additional Question for AQP only (where GP practices are likely to be qualified providers)


How will you ensure that patients are aware of

the full range of qualified providers from whom

they can choose?

Part 4: Additional Questions for Single Tenders from GP providers


What steps have been taken to demonstrate

that there are no other providers that could

deliver this service?

In what ways does the proposed service go

above and beyond what GP practices should be

expected to provide under their core primary

care contract?

What assurances will there be that GP practice is

provided high-quality services under the GP

contract before it has the opportunity to provide

any new services?