ITEM 14 Risk Report
North Lanarkshire Council · 21 May 2025
Back to IJB Performance, Finance and Audit Committee — 21 May 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
Page 1
REPORT Item No: Item 14. SUBJECT: Risk Management Report TO: Integration Joint Board, Performance, Finance and Audit Committee Lead Officer for Report: Claire Rae, NL HSCP Chief Officer Author(s) of Report Morag Dendy, Chief Officer / Head of Service (Performance, Planning, and Quality Assurance) DATE: 21 May 2025 1. PURPOSE OF REPORT This paper is coming to the IJB, PFA for: For approval ☒ For endorsement ☐ To note ☐ 2. ROUTE TO THE BOARD This paper has been: Prepared By: ☒ Reviewed By: ☐ Endorsed By: ☐ Morag Dendy, Chief Officer / Head of Service (Performance, Planning and Quality Assurance) 1
Page 2
3. RECOMMENDATIONS 3.1 The IJB, PFA is asked to note the contents of the presentation which includes a review of the highest rated risks within the IJB risk register and a note of those operational risks highlighted by the Heath & Social Care North Lanarkshire partnership that impact upon delivery of IJB business. 3.2 The IJB, PFA is also asked to note that an IJB Liaison session will be focused on risk to take account of and strengthen the consideration of risk through the IJB taking account of the revised approaches to risk within NHS Lanarkshire and NLC; and the refreshed governance arrangements within the UHSCP. 4. VARIATIONS TO DIRECTIONS? Yes ☐ No ☒ N/A ☐ 5. BACKGROUND/SUMMARY OF KEY ISSUES 5.1 From a good practice and sound governance perspective, all public bodies are required to identify and take account of the impact of any potential risks in delivering their business. 5.2 The IJB PFA Committee has delegated oversight and responsibility for financial and performance risks associated with the remit of the Integration Joint Board. 5.3 The following risk are currently rated as Very High on the IJB risk register. • IJB 06/21 – Prescribing Activity and Costs • IJB 01/21 – Financial Challenges • IJB 21/24- Pharmacy Pressures within Prison Services 5.4 The following risks are rated high on the IJB risk register. • IJB 04/21 - Notional Set Aside Budget • IJB 12/21 - Staff Health & wellbeing • IJB 15/22 – Cost of Living • IJB 19/23 – Service Sustainability • IJB 20/23 – Workforce Sustainability • IJB 12/22 – Unscheduled Care 2
Page 3
• IJB 23/24- Speech and Language Therapy 5.5 The High/Very High rated operational risks that have been identified as having or potentially having an impact on IJB objectives and/or delivery of services are highlighted within the Risk Overview Dashboard (Appendix 1) and Risk Register (Appendix 2). 6. CONCLUSIONS 6.1 The IJB currently has 19 risks identified on its IJB risk register with 10 risks rated as high or very high. 6.2 Risks identified by H&SC NL as potentially impacting on IJB business are highlighted in the report. 7. IMPLICATIONS 7.1 NATIONAL OUTCOMES Link(s) to National Health and Wellbeing Outcomes People are able to look after and improve their own health and wellbeing and live in good health for longer ☐ People, including those with disabilities or long-term conditions, or who are frail, are able to live, as far as reasonable practicable, independently and at home or in a homely setting in their community ☐ People who use Health and Social Care Services have positive experiences of those services, and have dignity respected ☐ Health and Social Care Services are centred on helping to maintain or improve the quality of life of people who use those services ☐ Health and Social Care Services contribute to reducing health inequalities ☐ People who use Health and Social Care Services are safe from harm ☐ People who work in Health and Social Care Services feel engaged with the work they do and are supported to continuously improve the information, support, care and treatment they provide ☐ Resources are used effectively and efficiently in the provision of Health and Social Care Services ☐ 7.2 ASSOCIATED MEASURE(S) 3
Page 4
7.3 FINANCIAL This paper has been reviewed by Finance: Yes ☒ No ☐ N/A ☐ 7.4 RISK ASSESSMENT/RISK MANAGEMENT Relevant Risk Register Details Current Risk Level Risk Owner Choose an item. 7.5 ENGAGEMENT & PARTICPATION Please tick the engagement and participation objectives that link(s) with this piece of work and provide further details regarding the engagement and participation that was undertaken. Objectives Further Details ☐ Involve stakeholders in the development work aimed at achieving the national outcomes ☐ Provide stakeholders with information on how to get involved ☐ Ensure a diverse range of engagement and participation and opportunities are in place to suit different needs ☐ Measure how well we involve community stakeholders in the planning, design and delivery of our services ☐ Provide regular feedback on how stakeholder engagement and participation is shaping and influencing service development and delivery ☐ Provide support to enable stakeholder representatives to participate meaningfully and confidently at meetings ☐ Develop participation guidelines to ensure a common understanding and set of expectations for both stakeholders and partnership staff 4
Page 5
☐ Support engagement planning and participation in localities, taking account of other engagement activity and local plans across the Community Planning Partnership 7.6 INEQUALITIES & FAIRER SCOTLAND DUTY EQIA Completed & Fairer Scotland Impact Assessment Form Completed and attached to report: Yes ☐ No ☐ N/A ☒ EQIA added to website: Yes / Date added ☐ No ☐ N/A ☒ 8. BACKGROUND PAPERS 9. APPENDICES Please include a glossary of terms if not already included. Appendix 1 – Risk Overview Dashboard Appendix 2 – Risk Register . 5
Page 6
CHIEF ACCOUNTABLE OFFICER (or Depute) Members seeking further information about any aspect of this report, please contact the following; 6
Page 7
Direction from North Lanarkshire Integration Joint Board (IJB) 1 Reference Number 2 Report Title 3 Date direction issued by IJB 4 Date from which direction takes effect 5 Direction to: 6 Does this direction supersede, revise or revoke a previous direction – if yes, include reference number(s) 7 Functions covered by direction 8 Full text of direction 9 Budget allocated by Integration Joint Board to carry out direction 10 Performance Management / Governance arrangements 11 Date direction will be reviewed 7
Page 8
NL H&SCP Risk Overview Report Meeting Name – IJB, PFA Reporting Period: IJB Risk Register – May 2025
Page 9
NL HSCP IJB Risk – Dashboard March 2025 Executive Summary Risk movement since last report No Change Increase Decrease New Closed Risks with updated actions 18 1 0 19 IJB Highest Scoring Risks Risk Register Number of Risks IJB 19 NL Council 21 NHS Lanarkshire 21 NL H&SCP Risks Reported to Assurance Committees Service risks- Service level Level 3- North Health Professional/ Operational Group and Support Care and Clinical Governance Risk Overview Process NL H&SCP IJB Risk Register – IJB and IJB PFA Level 2- Core VH Pharmacy Pressures within Prison Service IJB.21/24 VH Financial Challenges IJB.01/21 VH Prescribing Activity and Costs IJB 06/21 Trend Score Risk
Page 10
Current – Veru High Target‐ Low Risk in Focus – Pharmacy Pressures within Prison Service Risk Trend Following the Prisoner Healthcare Report presented to IJB PFA on the 22nd May 2024. The IJB PFA recommended that a Pharmacy Pressure within Prison Service Risk was added to the risk register. Risk Description Risk Owner Risk Lead Pharmacy costs have traditionally been the highest area of non-pay spend nationally in all prisons. The nature of the patient cohort results in high volumes of prescribed medication for Mental Health, Pain, & Addictions purposes. There is currently a large overspend (559K reported May 2024) for the actual drugs bought and £246K associated with the management fees for the contract. MT CR Current Controls CONTROLS • Review of the dispense processes within the prison • Implementation of guidelines • Improved communication with pharmacy provider Actions ACTIONS • Prescribing Action Group re‐established to try and manage the number of items prescribed • Developmentof pain and medicine management pathways • Review of prescribing habits
Page 11
Current – Very High Target‐ Medium Risk in Focus – Financial Challenges Risk Trend No Movement Increasing financial pressures have resulted in no movement of the risk rating for this risk. Further controls and actions are currently being reviewed Risk Description Risk Owner Risk Lead Financial Challenges There are a range of financial challenges which will impact on the IJB's ability to deliver the Strategic Commissioning Plan intentions within the financial envelope available. These include: NS NS Current Controls CONTROLS 1. IJB PFA Committee. 2. IJB Chief Officer is a member of each partner's key decision-making forums. 3. Effective joint working between North and South Chief Financial Officer and both Council and NHS Finance Departments. 4. Regular budget meetings with Chief Executives and Directors of Finance. 5. Regular HSCP budget monitoring meetings across Senior Leadership Team. 6. The IJB Financial Plans have been agreed and are reviewed regularly. 7. IJB medium term financial plan 2023-26 and reserves strategy 2023-24 approved at March 23 IJB 8. Capacity plans in place to maximise efficiency. 9. IJB Integration Scheme setting out the budget recovery processes. 10. IJB Financial Regulations and financial procedures. 11. Consultation and involvement with key stakeholders including service users and carers. 12. Prescribing Quality and Efficiency Programme, SWEG, ARG and Home Support monitoring groups are in place. 13. Joint Strategic Needs Assessment and ongoing move towards preventative and anticipatory approaches. 13. Strategic Planning Group, Locality engagement sessions and Partnership Boards. 14. Effective and ongoing service user engagement, staff consultation and Trade Union liaison at strategic and local levels. 15. IJB medium term financial plan 2024-2028 including the long term outlook 2025 – 2035 approved by the IJB in March 2025. Actions ACTIONS 1. Annual budget setting processes within each of the partners. 2. HSCP participating in NHSL Sustainability and Value process 3. Partnership will also be connected to new national whole system groups around budget
Page 12
Current – Very High Target‐ Low Risk in Focus – Prescribing Activity and Costs Risk Trend No movement Consider any still ongoing, however good progress has been made regarding achievement of the prescribing target for 2024-25 Risk Description Risk Owner Risk Lead The cost of prescribing is growing due to issues in supply chains driving increased wholesaler cost of medicines, advance treatment developments resulting in the need for more expensive medications, aging population and increase in patients requiring regular medication. Medication availability has been impacted following the EU withdrawal the UK 's membership of the common regulatory bodies and EU agencies, such as the European Medicines Agency, (EMA), European Centre for Disease Prevention and Control and the European Atomic Energy Community. The risk is that this could impact on the availability of medicines, healthcare techniques and technology and in respect of the supply of medicines and medical devices, additional checks are now required at ports in the UK and the EEA before goods, including medical products, can cross the border. New customs checks are required when moving medicines between the EEA and the UK. CR NS Current Controls 1. Prescribing Quality and Efficiency Programme. 2. Prescribing Management Board functions and membership. 3. Deputy Lead Pharmacist supporting HSCP Senior Leadership Team. 4. Locality Pharmacist input. 5. Earmarked reserve established to address prescribing costs. 6. Regular HSCP monitoring. In respect of the regulation of medicines and medical devices, the Medicines and Healthcare products Regulatory Agency (MHRA) became the UK’s sovereign regulator. 7. The new trade deal contains specific clauses that mean both the UK and EEA states formally recognise each other’s good practice in medicine manufacturing. 8. To reduce the risk of divergence from the EU rules, there are three interrelated factors; the technical annexes of the new trade deal, the Northern Ireland protocol and the UK Internal Market Act. 9. The effectiveness of the Border Operating Model to import and export goods to and from the EEA, which was being implemented in stages from 2020 to minimise any risk of disruption, is still being assessed. The risk of border delays is still evident. Other measures were also implemented specifically to mitigate the risk of supplies of medicines and medical devices being disrupted. In August 2020 the UK government instructed medicine suppliers to maintain a stockpile equivalent to six weeks’ supply though the first three months of 2021. In addition, the Department of Transport has secured additional freight capacity to bring medicines into the country via other routes Actions 1. Review of Locality Prescribing Action Groups. 2. Prescribing part of NHSL Sustainability and Value structures 3. Continuation of Scriptswitch. 4. Prescribing updates being provided to IJB as per financial reports
Page 13
IJB ID Category Opened Date Description of Risk Risk level (Initial) Mitigating Controls Risk level (Current Risk level (Target) Risk Owner Risk Register Lead ce Source Next Review Date Closed Date 01/04/2021 Financial Challenges HIGH CONTROLS 1. IJB PFA Committee. 2. IJB Chief Officer is a member of each partner's key decision-making forums. 3. Effective joint working between North and South Chief Financial Officer and both Council and NHS Finance Departments. 4. Regular budget meetings with Chief Executives and Directors of Finance. 5. Regular HSCP budget monitoring meetings across Senior Leadership Team. 6. The IJB Financial Plans have been agreed and are reviewed regularly. 7. IJB medium term financial plan 2023-26 and reserves strategy 2023-24 approved at March 23 IJB 8. Capacity plans in place to maximise efficiency. 9. IJB Integration Scheme setting out the budget recovery processes. 10. IJB Financial Regulations and financial procedures. 11. Consultation and involvement with key stakeholders including service users and carers. 12. Prescribing Quality and Efficiency Programme, SWEG, ARG and Home Support monitoring groups are in place. 13. Joint Strategic Needs Assessment and ongoing move towards preventative and anticipatory approaches. 13. Strategic Planning Group, Locality engagement sessions and Partnership Boards. 14. Effective and ongoing service user engagement, staff consultation and Trade Union liaison at strategic and local levels. ACTIONS 1. Annual budget setting processes within each of the partners. 2. HSCP participating in NHSL Sustainability and Value process 3. Partnership will also be connected to new national whole system groups around budget 4. Review the Audit Scotland Bulletin released on the 6 March 2025 VERY HIGH Medium Nicola Scott Nicola Scott SLT, IJB PFA, IJB 31.01.2024 Previously IJB2, IJB7, IJB10 and IJB12. There are a range of financial challenges which will impact on the IJB's ability to deliver the Strategic Commissioning Plan intentions within the financial envelope available. These include: Reviewed and Updated May 2023. Reviewed and Updated Sept 2023. 1. The absence of a unique IJB financial settlement from the Scottish Government. 2. The IJB is dependent on funding from both partners. Reviewed and updated Jan 2024. 3. Late Scottish Government financial settlement. Reviewed and updated March 2024. 4. Budget reductions due to insufficient Scottish Government financial settlements and/or partner contributions. 5. New Scottish Government policy commitments e.g. Carers (Scotland) Act 2016. 6. Demographic growth. Review and risk increased June 2024. 7. Competing service priorities. Reviewed and no changes Sept 2024 IJB.01/ 21 Financial Strategic 8. Conflicting partner efficiency savings programs which adversely impact on the HSCP's ability to deliver services. 9. In-year cost pressures emerging due to the underachievement of planned savings, pandemics and other emerging risks which may lead to an overspend. 10. Each partner may be unable to maintain their financial contributions to the IJB in future years which would impact on frontline health and social care services. 11. The agreed transformational plans and service redesigns are not implemented in full and in line with the original implementation plan and/or do not secure the intended improvement outcomes in both performance standards and financial efficiency targets. 12. Future savings targets will continue to be challenging and are likely to impact on essential core services. Review and updated Oct 2024 Reviewed and no changes March 2025 Reviewed and no changes May 2025 13. The IJB Financial Plan cannot be adhered to and budget recovery plans fail to achieve financial balance for both partners. 14. The continuing recovery from the pandemic on the financial sustainability of external providers in particular social care providers. 15. The financial implications of the continuing impact of the pandemic on the workforce e.g. increase in sickness absence, early retirement requests and recruitment challenges. The above factors would lead to a failure to achieve the desired strategic aims and would also impact on service delivery. Prevention and Detection of Fraud, Bribery and/or Corruption There is a risk that the IJB is unable to prevent and detect fraud and corruption within services because of inadequate governance arrangements and inadequate internal control systems which could lead to financial and reputational damage. LOW CONTROLS 1. Fraud awareness e-learning. 2. National Fraud initiative. 3. Locality/SW Enablement Groups. Previously IJB6. Reviewed and updated on March 2023. Reviewed and Updated Oct 2023, (previously title ineffective governance arrangements).
Page 14
IJB02. 21 Financial Reputational 01/04/2021 4. Segregation of duties in relation to authorising and processing direct payments. 5 Whistle blowing policies. 6. Procurement processes and standing orders. 7. Oversight via NLC Audit and Scrutiny Panel and NHSL Audit Committee. 8. Effective governance arrangements are in place and subject to internal and external audit review. 9. IJB and IJB PFA meetings established ensuring effective oversight of financial performance. 10. The IJB does not maintain its own policies relating to the prevention and detection of fraud and error but instead depends on those in place at its partnerbodies. The IJB has a Code of Conduct in place to which members subscribe and the Members’ Registers of Interests are publicly available on the IJB’s website ACTIONS 1. Continue to raise fraud awareness through teambriefings. 2. Annual planned Procurement and Standing Financial Instructions presentations. 3. Annual review of Code of Conduct 4. Review of how Members' Declaration of Interests are collated and reviewed. 5. IJB to request Fraud prevention and detection reports from both partners for oversight at the IJB PFA. LOW LOW Claire Rae Nicola Scott SLT, IJB PFA, IJB 31.01.2025 Reviewed May 2024 Reviewed and No changes Sept 2024 Reviewed and no changes Oct 2024 Reviewed and no changes March 2025 Reviewed and no changes May 2025 01/04/2021 Notional Set‐Aside Budget VERY HIGH CONTROLS HIGH MEDIUM Claire Rae Nicola Scott SLT, IJB PFA, IJB 31.01.2025 2.There is complete transparency and ongoing dialogue between the IJB and the Health Board on the challenges associated with the implementation of the notional set-aside concept. Reviewed and Updated May 2023. 3. Bed modelling and capacity planning arrangements are in place. 4. Effective working relationships between both partners and the IJB have been established. Reviewed Oct 2023. IJB04. 21 Financial Strategic There is a risk that resources will not be transferred from Acute Services to the HSCP in line with the shift in the balance of care from residential and acute settings to community based alternatives as expected in terms of the notional set-aside concept. This includes the ongoing development of locality pathways to support maintaining people at home e.g. transitional care models. 5. Since the inception of the IJB, an agreement is in place whereby the NHSL Health Board will manage the overspend or underspend across the notional set-aside budget. This arrangement continues to be in place for 2022/23 ACTIONS 1.The Chief Officer and the Chief Financial Officer continue to raise this concern at a national level. Reviewed Jan 2024 Reviewed May 2024 Reviewed July 2024. Reviewed Sept 2024 Reviewed Oct 2024 and no changes (awaiting SG info) Reviewed March 2025 Reviewed and no changes May 2025 2. Discussions ongoing with NHSL Director of Finance around unscheduled care spend in 2023/24 and budget for 2024/25 IJB05. 21 Financial Strategic 01/04/2021 Hosted Services There is a risk of dispute between the North Lanarkshire IJB and the South Lanarkshire IJB in respect of the financial allocations underpinning the Hosted Services particularly as a result of the budget changes linked to the implementation of devolved locality models. This could impact on the ability of each IJB to achieve its commissioning intentions and may also have an adverse impact on service users across Lanarkshire. VERY HIGH CONTROLS 1. North and South IJBs aim to co-operate to ensure a pan-Lanarkshire approach is achieved across all hosted services. 2. Financial and budgetary controls. 3. Performance reports on service delivery. 4. The Hosted Services principles in respect of the management of the overspends and underspends are agreed for each financial year. MEDIUM MEDIUM Claire Rae Nicola Scott SLT, IJB PFA, IJB 31.01.2025 Reviewed May 2024 Reviewed July 2024 Reviewed Sept 2024 Reviewed Oct 2024 and no updates Reviewed March 2025 Reviewed and no changes May 2025
Page 15
01/04/2021 Prescribing Activity and Costs CONTROLS 01/04/2021 Medium VERY HIGH LOW Claire Rae Nicola Scott SLT, IJB PFA, IJB 31.01.2025 Previously IJB11. Reviewed and updated June 2023. 1.. Prescribing Quality and Efficiency Programme. IJB06. 21 Financial Operational The cost of prescribing is growing due to issues in supply chains driving increased wholesaler cost of medicines, advance treatment developments resulting in the need for more expensive medications, aging population and increase in patients requiring regular medication. Medication availability has been impacted following the EU withdrawal the UK 's membership of the common regulatory bodies and EU agencies, such as the European Medicines Agency, (EMA), European Centre for Disease Prevention and Control and the European Atomic Energy Community. The risk is that this could impact on the availability of medicines, healthcare techniques and technology and in respect of the supply of medicines and medical devices, additional checks are now required at ports in the UK and the EEA before goods, including medical products, can cross the border. New customs checks are required when moving medicines between the EEA and the UK. 2. Prescribing Management Board functions and membership. 3. Deputy Lead Pharmacist supporting HSCP Senior Leadership Team. 4. Locality Pharmacist input. 5. Earmarked reserve established to address prescribing costs. 6. Regular HSCP monitoring.In respect of the regulation of medicines and medical devices, the Medicines and Healthcare products Regulatory Agency (MHRA) became the UK’s sovereign regulator. 7. The new trade deal contains specific clauses that mean both the UK and EEA states formally recognise each other’s good practice in medicine manufacturing. 8. To reduce the risk of divergence from the EU rules, there are three interrelated factors; the technical annexes of the new trade deal, the Northern Ireland protocol and the UK Internal Market Act. 9. The effectiveness of the Border Operating Model to import and export goods to and from the EEA, which was being implemented in stages from 2020 to minimise any risk of disruption, is still being assessed. The risk of border delays is still evident. Other measures were also implemented specifically to mitigate the risk of supplies of medicines and medical devices being disrupted. In August 2020 the UK government instructed medicine suppliers to maintain a stockpile equivalent to six weeks’ supply though the first three months of 2021. In addition, the Department of Transport has secured additional freight capacity to bring medicines into the country via other routes. Reviewed and Updated (risk increased) October 2023. Reviewed Jan 2024 Reviewed June 2024. Reviewed July 2024. Reviewed Sept 2024 Reviewed October 2024 no changes Reviewed March 2025 Reviewed and no changes May 2025 ACTIONS 1. Review of Locality Prescribing Action Groups. 2. Prescribing part of NHSL Sustainability and Value structures 3. Continuation of Scriptswitch. 4. Prescribing updates being provided to IJB as per financial reports IJB07. 21 Financial Strategic 01/04/2021 Third and Voluntary Sector There is a risk that Third Sector organisations in North Lanarkshire are vulnerable because of the lack of certainty in respect of long-term funding security. This uncertainty has the potential to lead to service instability, recruitment and retention challenges and an increasing reliance on statutory services. HIGH CONTROLS 1. Third Sector Interface represented on key strategic groups. 2. Community capacity building and carer support infrastructure embedded across North Lanarkshire. 3. Community capacity building is regularly reviewed. 4. Maximising funding opportunities for the third and voluntary sector will continue to be progressed. ACTIONS 1. The annual HSCP funding which is directed to the third sector is recurring funding. Funding will be confirmed each year in line with the agreement of the IJB Financial Plan and subject to the Scottish Government financial settlements for future years. 2. Updated SLA with VANL nearing completion LOW LOW Claire Rae Nicola Scott SLT, IJB PFA, IJB 31.01.2025 Previously IJB16. Reviewed April 2024. Reviewed July 2024 Reviewed and no changes Sept 2024 Reviewed March 2025 Reviewed and no changes May 2025
Page 16
20 c IJB.10. 21 Financial Strategic 01/04/2 Ineffective Governance Arrangements 1. There is a risk that the intensity of the required response to Covid-19 may have resulted in a failure of governance impacting on the effectiveness of the IJB decision-making, IJB directions to partners and IJB oversight of operational service delivery Routine governance processes 2. New or amended legislation and Scottish and UK Government guidance may not be adopted effectively and timeously. 3. There is no / limited public access to IJB and PFA meetings during the period of the pandemic, in line with Public Health advice. 4. Ineffective information governance controls could lead to data breaches and an impact on the General Data Protection Regulations. 5. Communications with employees, patients and service users may be ineffective. MEDIUM CONTROLS 1. National Networks are established which are providing the framework to support a national approach where appropriate. 2. Public Health advice and support is in place. 3. Increased numbers of agile workers and increased number of laptops/tablets. 4. Continued working from home arrangements supported by the roll out of MS Teams / Zooms. Regular updates on the guidance for the use of MS Teams / Zoom Meetings is circulated. A blended approach to home/work-based working is being developed going forward. 5. Risk registers are in place for the IJB and each partner. Each partner has a specific HSCP Covid-19 Risk Register in place. LOW LOW Claire R Nicola S SLT, IJB PF 31.01. Reviewed and updated June 2023. Reviewed and updated Oct 2023. Reviewed and updated Jan 2024. 6. There will require to be changes to the working environment including remote working and working from home. 6.The IJB and both partners aim to comply with the European Working Time Directive (WTD) and minimise the risk of all staff working beyond 48 hours per week, in particular front-line service delivery. As a result of the withdrawal from the European Union, the WTD ceased to apply to the United Kingdom at the end of the transition period (31 December 2020). However, the UK's Working Time Regulations which implement the EU Working Time Directive will continue to apply ae ott A, IJB 25 Reviewed and Risk level lowered June 2024. 7. There is a reduced ability to protect the wellbeing of employees, patients and service users. 8. There may be adverse media coverage locally, a loss of public confidence and reputational damage. 7. Back to Basics exercise has helped to focus on the underpinning governance requirements across the whole HSCP 8. Staff health and wellbeing is a key priority for both partners and all key stakeholders. The commitment to staff health and wellbeing is being actively promoted through all available forums. Reviewed and no changes Sept 2024 9. IJB Governance reporting reviewed and associated documents updated. 10. Recent review of Internal Audit team programme of work and participation in the IJB. 11. Review of IJB / PFA self assessment session Review March 2025 Reviewed and no changes May 2025 IJB.11 21 Performance 30/07/2021 Oversight of Performance Activity There is a risk that the IJB is not provided with adequate or sufficient performance information to enable it to discharge its scrutiny and oversight role; make informed decisions and recommend remedial actions to address any performance concerns. LOW CONTROLS Regular (quarterly) reports on the IJB performance framework, providing updates on areas for improvement, remedial actions (and timescales) and updates on performance issues previously reported. Chief Executive Performance Review arrangements. Hosted Services Performance Review arrangements. Sector/Locality Performance Review arrangements. LOW LOW Claire Rae Morag Dendy SLT, IJB PFA, IJB 31.01.2025 Reviewed May 2024. Reviewed June 2024. Reviewed and no changes Sept 2024 Review March 2025 Reviewed and no changes May 2025 IJB.12. 21 Performance 30/08/2021 Staff Health & Wellbeing There is a risk to the delivery of the Strategic Commissioning Plan as a result of sustained pressures on staff availability due to additional pressures associated with Covid 19, current sickness absence levels and potential for further staff redeployment due to winter planning contingency arrangements. MEDIUM CONTROLS Strategic Staff Health & Wellbeing Committee established reporting to NLC & NHSL corporate management teams. Range of support services available both nationally and locally e.g Occupational Health, Spiritual care, Psychological Services, national wellbeing hub (www.PRoMIS.scot.uk). Rest & Recuperation areas identified. Peer Support Networks established Well established Occupational Health supports available to support staff sickness. ACTIONS Short Life Working Group for wellbeing with targeted approach for immediate actions including Staff Health & Wellbeing Champions, access to online supports, access to Occupational Health Services, helpline established and dedicated resource identified for wellbeing officers to be recruited. Funding received by Scottish Government specifically targeting staff wellbeing programmes and supports. Local plans for use of funding being developed. Managers supporting & encouraging staff to take planned leave/use full leave allocation HIGH low Claire Rae Claire Rae SLT, IJB PFA, IJB, SC&CG, AH&SC 31.01.2025 Reviewed and Updated May 2023. Reviewed and updated Dec 2023. Reviewed May 2024. Reviewed Sept 2024 Review March 2025 Reviewed and no changes May 2025
Page 17
021 30.08.21 Care Homes HIGH CONTROLS medium medium Claire Rae Joanne Jenkins IJB, PF&A, SLT, SC&SC, A H &SC 31.01.2025 Reviewed and updated Oct 2023 Establishment of Care Home Assurance Team. IJB.13. 2021 Performance Inability of care homes to sustain service due to staffing and cost pressures resulting in closure to new placement and closure of care homes. This may increase delayed discharge numbers putting additional pressure on acute site capacity and impacting on recovery. Escalation Process in place. National protocol to support discharge of Covid 19 patients in place. ACTIONS Public Health teams providing guidance on infection control. Care Home assurance team undertaking support visits to all care homes & action plans in place for each care home. All care homes advised to use PPE in line with national addendum. Development day on 12th May 23 to agree structures and approach for year ahead Reviewed May 2024. . Reviewed Sept 2024 Review March 2025 Reviewed and no changes May 2025 CAMHS CONTROLS Prioritisation of referrals; all referrals vetted daily with urgent referrals prioritised Commenced programme of work and implementation of a more structured partnership approach through Choices & Partnership Approach (CAPA) service model, with tier 1 & 2 referred through 3rd sector and interfacing with North & South Education Departments Secured significant national investment to fully implement new service model Active review of skill mix to utilise medical staff only when required for highly complex patients Reviewed and Updated May 2023. Reviewed and updated Dec 2023. Reviewed and risk level lowered May IJB.14. 2022 Strategic & Performance 30.04.22 There is a risk that the CAMHS service cannot meet the increasing clinical demands due to a significantly high number of cumulative staff vacancies for both clinical and non-clinical posts and challenges recruiting to new posts identified through the national recovery and renewal fund. This is impacting on community, in- patient and out- patient care with the potential to adversely affect response time to referrals; longer waiting times; poorer outcomes; delays in redesign and reputation of the IJB. VERY HIGH Vacancy gap analysis with active recruitment commenced. Expected to have recruited 75% of gap by end of May 2023 Continuous review and validation of the waiting list Waiting list validation exercise completed in April 2022 with reduction in list by 16% CAPA appointments begin on 1st May 2023 - first cycle (16wks) nearing completion Monthly monitoring at board Incremental implementation of the new service model Performance monitoring through the programme board CAHMS IT Board in train to plan and oversee implementation of SCI gateway for referrals Waiting list initiative commenced Udston opened for patients September 2022 Upgrade to North physical infrastructure agreed. Close working with health improvement and GP reps Medium Medium Claire Rae Morag Dendy IJB,PF&A, SLT 31.01.2025 2024. Reviewed and no changes Sept 2024 Reviewed and no change March 2025 Reviewed and no changes May 2025 05.09.22 Cost of Living HIGH CONTROLS High Medium Claire Rae Claire Rae SLT, IJB 31.01.2025 Reviewed and Updated May 2023. NLC Silver command group stood up focused on cost of living IJB.15. 2022 Strategic & Performance There is a risk that the IJB's Strategic Commissioning Plan will be unable to be delivered or not have the desired impact due to the cost of living rises being faced by residents across North Lanarkshire, leading to a further widening of the inequality gap, reduced quality of life and increased health and social care demand due to individuals and families having insufficient funds to support basic requirements such as food and heating. NHSL commenced review through CMT Population Health Committee to review activity around cost of living NLC approved cost of living contract increases in May 2023 ACTIONS Survey of NLC hybrid workers to see if home working remains financially viable Business case being developed to expand 'support for people' arrangements used in pandemic to support resident access to welfare rights and other supports 3% increase in individual budgets to support service users to maintain current levels of supports at higher cost Reviewed Oct 2023. Reviewed May 2024. Reviewed Sept 2024 Reviewed March 2025 Reviewed and no changes May 2025 Recommendation from adult social work, care and wellbeing committee to review all charges to service users and wider cost. 05.09.22 National Care Service HIGH CONTROLS Low Low Diane Fraser Claire Rae SLT, IJB PFA, IJB, ASW C&W B 31.01.2025 Reviewed and Updated May 2023. IJB.16. 2022 Strategic There is a risk that the ongoing work around a National Care Service could destabilise current service delivery due to significant change activity, time demands around the co-design process, staff uncertainty and partner organisations having to focus inwardly due to the impact of change leading to an impact on the ability to deliver the significant ongoing change programmes already approved by the IJB and the Strategic Commissioning Plan for 2023-26. NLC establishing NCS working groups Key HSCP leads involved in national developments Ongoing progress updates to IJB and IJB PFA ACTIONS IJB response submitted on proposed Bill Strong partnership links into working groups at Chief Officers, Chief Finance Officers and Social Work Scotland groups SG/COSLA working groups being established - local reps nominated for each National Advisory Group being established. Reviewed and Updated Oct 2023. Reviewed and Updated May 2024 Reviewed Sept 2024 Reviewed Oct 2024 no changes Reviewed March 2025
Page 18
Risk in the NLC risk register closed in February 2025 Reviewed in May 2025 and current risk reduced to LOW 05.09.22 Unscheduled Care Very High CONTROLS High Medium Claire Rae Claire Rae SLT, IJB PFA, IJB 31.01.2025 Care Home Assurance Group and associated supports for care homes through liaison service, IPC advice and support, risk assessment for onward movement of patients etc. Reviewed and Updated in June 2023. Care at Home Assurance group and associated activity to try to support and sustain independent sector provision NHS CMT and Covid response group oversight of performance Reviewed Oct 2023 Daily PDD meetings to review every planned supported discharge and delayed discharge Reviewed Jan 2024. IJB.17. 2022 Strategic & Performance There is a risk that we cannot sustain whole system patient flow through peak winter pressures due to increased front door demand; hospital workforce capacity; delays in onward movement of patients due to care home capacity/outbreaks and care at home capacity; and community health and social care workforce capacity leading to reduced ability to meet 'routine' and increasing bed demand for more unwell patients, deteriorating delayed discharge performance and an inability to recover services. Operation Flow now underway to ensure whole system approach to unscheduled care/delayed discharge challenges Expansion of Home Support service Roll out of Home Assessment Teams across all 6 Localities New CSW roles in District Nursing teams to proactively support Care Managed patients Additional Nursing capacity in District Nursing Teams Expansion of Equipment and Adaptation Service to support rapid access in community Reviewed and risk level reduced May 2024. Reviewed Sept 2024 Reviewed Oct 2024, no changes Reviewed March 2025 Expansion of H@H service (hours of provision as well as moving to support discharges as well as admission prevention) Expansion of Integrated Rehabilitation Teams in all six Localities to support rehab in the community and reduce long-term service demand Regular Firebreaks across the system Task and Finish groups now established to roll out the key actions agreed through the Operation Flow programme (Phase 2 to be completed by Sept 23) Reviewed and no changes May 2025 05.09.22 Community Alarms There is a risk that the community alarm system will be destabilised due to the national change from analogue to digital telephony by 2025, leading to community alarm users not getting a response when required. HIGH CONTROLS Medium Low Diane Fraser Claire Rae SLT, IJB PFA, IJB, ASW C&W B 31.01.2025 Reviewed and updated June 2023. Working group established to coordinate all activity Oversight through Home Support Programme Board Reporting to Adult Social Work, Care and Wellbeing Committee Reporting to IJB Reviewed Oct 2023. Reviewed Jan 2024. IJB.18. 2022 Strategic and Performance ACTIONS NLC Committee approval to purchase 1000 digital alarms so the service can support any imminent changes over to digital in individual areas Reviewed April 2024. Reviewed Sept 2024 Reviewed Oct 2024 NLC part of SG once for Scotland procurement process for a new digital alarm receiving center Reviewed March 2025 Communication out to all community alarm service users Instructions issued to all community alarm service users on how to do test calls to ensure alarms are operational Reviewed and no changes May 2025 Engagement with telecommunication suppliers to ensure sight of roll out plans across NL Call-off direct award using third party Framework for Digital ARC and purchase of digital dispersed alarm units agreed at Adult Care and Social Work Committee in May 2025
Page 19
27/02/2023 Service Sustainability High CONTROLS High Low Claire Rae Claire Rae SLT, IJB PFA, IJB 31.01.2025 Reviewed and Updated May 2023 IJB PFA Committee. IJB.19. 2023 Performance Due to competing service priorities and workforce/ operational and financial challenges there is a risk that the IJB will be unable to implement the strategic plan/commission plan. Failure to achieve the desired strategic aims of the IJB poses a risk on operational service delivery and the achievement of financial balance and patient safety IJB Chief Officer is a member of each partner's key decision-making forums. Effective joint working between Chief Financial Officer and both Council and NHS Finance Departments. Regular budget meetings with Chief Executives and Directors of Finance. Regular HSCP budget monitoring meetings across Senior Leadership Team. The IJB Financial Plan is regularly reviewed and agreed. Capacity plans in place to maximize efficiency. Consultation and involvement with key stakeholders including service users and carers. Joint Strategic Needs Assessment and ongoing move towards preventative and anticipatory approaches. Strategic Planning Group, Locality engagement sessions and Partnership Boards. Effective and ongoing service user engagement, staff consultation and Trade Union liaison at strategic and local levels. Reviewed and Updated Oct 2023. Reviewed and updated Jan 2024. Reviewed April 2024. Reviewed Sept 2024 Reviewed Oct 2024 Reviewed March 2025 Reviewed and no changes May 2025 ACTIONS Sustainability plans to be reviewed regularly Re-introduction of scrutiny panels Improve linkage across all risk registers (tiers 1 to 3, council and NHS) to help ensure areas of concern are identified and reviewed regularly. Review of reporting process into IJB to ensure continuous review of services/ service developments. Development of the programme of work to ensure regular reporting structure in place for service review. Operation Flow Task and Finish Groups analyzing service challenges and implementing phased changes to support winter pressures and beyond. IJB.20. 2023 Workforce Sustainability It is becoming increasingly difficult to recruit to particular roles across Health and Social Care. Gaps in the workforce can result in reduction of service provision, increase in staff workload and inability to deliver the strategic plan. Following EU withdrawal there is no longer the free movement of labour between the UK and EEA countries. All workers arriving from the EEA and non-EEA countries are subject to the same immigration rules.The new points-based immigration system makes exceptions for the majority of health care professionals with an NHS job High CONTROLS All successful Health and Care Worker Visa applicants are exempt from the Immigration Health Surcharge, a one-off charge levied against arriving migrant workers as part of the visa application process. The system has been designed to make international recruitment into health and social care roles more straightforward for employers and employees alike. These changes to immigration rules are in law as part of the Immigration and Social Security Co-ordination (EU Withdrawal) Act 2020. As such, from 1 January 2021, they apply to all workers arriving to work in the NHS or adult social care. All workers from EEA nations who are already resident in the UK had until 30 June 2021 to apply for the EU Settlement Scheme which will guarantee their right to work in the UK indefinitely. In respect of the mutual recognition of professional qualifications, professional regulatory bodies are working with the UK government to review future registration requirements for those with qualifications gained in the EEA and decide what they will be from January 2023. High Medium Claire Rae Claire Rae SLT, PFA, IJB 31.01.2025 Updated May 2023 Reviewed and updated Oct 2023.
Page 20
GH offer and for qualified social workers via a new fast-track visa route, known as the Health and Care Worker Visa. There are however no exceptions made for other social care roles, such as care workers.The Mutual Recognition of Professional Qualifications Directive is an EU-wide directive that allows professional regulators in all member states to automatically recognise professional qualifications. The UK government has decided to continue recognising qualifications gained in the EEA for at least two years after the transition period ends. This however is not a reciprocal and there is no guarantee that qualifications gained in the UK will be accepted by professional regulators in EEA nations. Development of the Care Academy Dedicated HR support identified in NHSL and NLC to support key priority areas of recruitment such as Mental Health and Home Support ACTIONS Annual workforce plan being prepared NHSL programme underway to support international recruitment On the day recruitment events being trialed in Home Support Use of university status being explored following positive gains in Podiatry and Psychological Therapies recruitment Recruitment of 15 Modern Apprenticeships within the H&SCP working within Business Admin, Comms and Health Care Support. Reviewed and updated Jan 24 Reviewed April 2024. Reviewed Sept 2024 Reviewed March 2025 Reviewed and no changes May 2025 IJB21.24 Financial Jun-24 Pharmacy Pressures within Prison Service Pharmacy costs have traditionally been the highest area of non-pay spend nationally in all prisons. The nature of the patient cohort results in high volumes of prescribed medication for Mental Health, Pain, & Addictions purposes. There is currently a large overspend (559K reported May 2024) for the actual drugs bought and £246K associated with the management fees for the contract. High CONTROLS Review of the dispense processes within the prison Implementation of guidelines Improved communication with pharmacy provider ACTIONS Prescribing Action Group re-established to try and manage the number of items prescribed Development of pain and medicine management pathways Review of prescribing habits Very High Low Claire Rae Claire Rae IJB PFA, IJB 31.01.2025 Added to register June 2024 and reviewed Sept 2024 Reviewed March 2025 Reviewed and no changes May 2025 IJB23.24 Performance Speech and Language Therapy (SLT) Service High CONTROLS 1. Good communication processes, and the sharing of information and practical learning online have been established and will be further developed as service improvement work progresses. 2. Service model review to ensure that future TrakCare builds on local learning and builds on organisational learning from other builds. Forward planning for inclusion in the AHP Hub model will proceed in parallel to these TrakCare developments. 3. Revised workforce planning, incorporating the best-practice and learning from other areas who have specialist children’s health services units. 4. The professional relationships between service and university have already been improved and we have academic representation that actively contributes to both our Workforce Planning and Service Improvement Steering Group. ACTIONS 1. Working with university colleagues to identify new practitioners who have expressed their desire to work in Lanarkshire on registration. This allows us to maximise and enhance opportunities for placement, improvement projects and induction planning, ensuring that we present ourselves as an area that is not only welcoming but committed to the ongoing development of individuals and the service 2. Work with professional colleagues to ensure that all activity is aligned to direct and/or indirect pursuit of meeting the SLT waiting time target. 3. Transition from restrictive locality models for managing the waiting list. High Low Claire Rae Claire Rae IJB PFA, IJB 31.01.2025 Added to the register August 2024. Reviewed Oct 2024 Reviewed March 2025 Reviewed and no changes May 2025 Jul-24 There is a risk that the SLT service cannot meet the increasing clinical demands with variance in waiting list length by area, continued challenges around the recrutiment and retention of new colleagues, funding streams from Local Authority being reduce therefore reducing staff WTE.