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Supplementary Pack 1

Argyll and Bute Council · 13 August 2026
Back to Argyll and Bute HSCP Clinical and Care Governance Committee — 13 August 2026 and its agenda

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7 August 2026 
SUPPLEMENTARY PACK 1 
ARGYLL AND BUTE HSCP CLINICAL AND CARE GOVERNANCE COMMITTEE - BY
MICROSOFT TEAMS on THURSDAY, 13 AUGUST 2026 at 2:00 PM 
I enclose herewith item 9 (DEEP DIVE REPORT – PRIMARY CARE) which was marked to follow
on the Agenda for the above meeting. 
ITEM(S) TO FOLLOW 
9. DEEP DIVE REPORT - PRIMARY CARE (Pages 3 - 58)  
Report by Head of Primary Services 
Argyll and Bute HSCP Clinical and Care Governance Committee 
James Mullins Duncan Scott
Karen Leach Graham Bell (Chair)
Evan Beswick Rebecca Helliwell
Fiona Broderick Kevin McIntosh
David Gibson Alison McGrory
Councillor Dougie McFadzean Councillor Ross Moreland
Louise Bussell   
Contact: Lynsey Innis, Committee and Democratic Services Officer  Tel:  01546 604338
Public Document Pack

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1 
Clinical and Care Governance Committee 
Date of Meeting: 13 August 2026
Title of Report: Primary Care Governance Deep Dive Report  
Presented by: Eilidh Gallagher, Head of Primary Care    
The Clinical and Care Governance Committee is asked to:
• Note the Primary Care deep dive and the baseline assurance position
against the Healthcare Improvement Scotland Clinical Governance
Standards.
• Note the proposed improvement approach, framed around what good looks
like, current strengths, areas for growth and clear escalation triggers.
• Note the limitations of assurance data across mixed delivery models,
particularly where services are delivered through independent contractor
arrangements.
• Note the remedial work underway to implement the Health and Care
(Staffing)(Scotland) Act 2019 across in-scope Primary Care services.
• Agree a twelve-month review to monitor progress against the improvement
plan and the maturation of the governance assurance framework. 
1. EXECUTIVE SUMMARY
This report presents a structured deep dive into Primary Care governance
across Argyll and Bute, aligned to the Healthcare Improvement Scotland
Clinical Governance Standards. Overall, the assessment finds that
governance arrangements are established and active across the Primary
Care portfolio, with clear evidence of improvement activity, professional
oversight and responsive management of risk. The overall assurance position
is positive but qualified: no standards are rated red, three standards show
green assurance with amber direction of travel, and four standards remain
amber due to areas requiring further development. 
Primary Care operates across a complex mixed-delivery environment,
including independent contractor services, Board-managed practices, directly
employed multidisciplinary teams, Public Dental Services, CTAC,
Vaccinations, Forensic Medicine, Sexual Health and Community Optometry.
This complexity means assurance must be drawn from multiple sources,
including contract monitoring, clinical governance, risk registers, complaints,
audit, programme boards, workforce data and service-specific reporting. 
The strongest areas of assurance are quality improvement activity, clinical
review, vaccination governance, information governance controls,
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2 
professional oversight and examples of responsive service redesign.
Standards 2, 3 and 7 are broadly positive, although each has an amber
direction of travel because data maturity, outcome measurement, access
reporting, equity analysis and integrated assurance reporting are not yet fully
developed. 
The main areas requiring improvement are leadership resilience, staffing
assurance, escalation clarity, systematic learning, education and training
compliance, patient involvement and evidence visibility. Standards 1, 4, 5 and
6 are rated amber. Key issues include completion of Health and Care Staffing
Act baseline assessments, clearer organisational mapping, stronger risk
review discipline, improved statutory mandatory and PDP compliance, earlier
community engagement in service change, and better tracking of learning
from complaints, incidents, audits and engagement. 
Several service-specific risks require continued oversight. These include
dental workforce fragility and access pressures, LARC access and
sustainability, forensic medicine documentation and Police Adastra
implementation, CTAC access and waiting-time reporting, vaccination uptake
variation, GP appraisal capacity, and the need to strengthen governance
routes for developing Sexual Health provision. These risks are recognised
and are being actively managed, but require clearer metrics, owners,
timescales and escalation triggers. 
The report concludes that the next twelve months should focus on
consolidating improvement activity into a single monitored Primary Care
governance improvement plan. This should include named owners,
timescales, RAG status, evidence requirements, reporting routes and
escalation triggers. Priority actions should focus on developing a more
integrated quality management system, improving data and dashboard
reporting, strengthening workforce and competence assurance, embedding
learning trackers, standardising engagement arrangements and ensuring
clearer accountability across the portfolio. 
In summary, Primary Care has a functioning and increasingly structured
governance framework, with many examples of good practice and active
improvement. The key requirement now is to move from multiple established
but fragmented assurance processes to a more integrated, evidence-led
governance system that provides clearer visibility of quality, safety, access,
outcomes, workforce resilience, patient experience and improvement impact. 
2. RECOMMENDATIONS
• Note the Primary Care deep dive and the baseline assurance position
against the Healthcare Improvement Scotland Clinical Governance
Standards.
• Note the proposed improvement approach, framed around what good
looks like, current strengths, areas for growth and clear escalation triggers.
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3 
• Note the limitations of assurance data across mixed delivery models,
particularly where services are delivered through independent contractor
arrangements.
• Note the remedial work underway to implement the Health and Care
(Staffing)(Scotland) Act 2019 across in-scope Primary Care services.
• Agree a twelve-month review to monitor progress against the improvement
plan and the maturation of the governance assurance framework. 
3. DETAIL OF REPORT
The Primary Care portfolio covers a broad range of services, including
General Practice (GMS), Board-managed General Practice (2C), Public
Dental Services, Community Treatment and Care (CTAC), Vaccinations,
Forensic Medicine, Sexual Health and Community Optometry.
The developing GP walk-in service in Dunoon also forms part of this wider
Primary Care portfolio and should be understood as a targeted service
innovation rather than a standalone access model. It aligns with the strategic
direction of travel set out in the Joint Strategic Plan by seeking to improve
timely access, support care closer to home, reduce avoidable pressure on
urgent and unscheduled care pathways, and test more responsive models of
multidisciplinary primary care delivery. As the model develops, it will require
proportionate governance through the Primary Care Clinical and Care
Governance and Unscheduled Care governance routes, operational
performance reporting, risk management, patient feedback and post-
implementation review. This will ensure that the service is evaluated not only
on activity and access, but also on safety, equity, patient experience,
workforce impact, sustainability and contribution to the wider transformation
of Primary Care services across Argyll and Bute.
The service areas operate across a mixed governance environment, and this
should be recognised when interpreting assurance, performance and
escalation arrangements. 
General Medical Services (GMS) practices are independent contractors
delivering services under the national GMS contract, with NHS Boards and
Integration Authorities retaining responsibilities for contract oversight, service
planning, assurance and delivery of transferred services under the 2018 GMS
contract reform and associated Memorandum of Understanding. 
Vaccination and Community Treatment and Care services sit within the wider
primary care reform programme and are predominantly NHS Board/HSCP
responsibilities. 
Governance is focused on safe delivery models, workforce competence,
clinical standards, access, audit and escalation. Some practices continue to
provide remote, rural and island services directly, with HSCP funding; in these
circumstances, governance is shared and assurance must be interpreted in
the context of the local delivery model.
Public Dental Services are directly managed NHS services providing safety-
net and specialist community dental provision, with HSCP accountability for
quality, access, workforce, risk and clinical governance. 
Forensic medical services have a specific statutory and standards-based
framework, requiring NHS Boards to provide trauma-informed, person-
centred and legally robust healthcare and forensic medical examination
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4 
services. This includes clear governance, training, documentation, evidence
handling and quality assurance requirements. Historically, services in Argyll
and Bute were delivered through contracted models, with governance
devolved through those arrangements. Following service review, some
services have transitioned to managed provision under HSCP responsibility
over the past six months. The current landscape remains mixed, with work
underway to standardise provision in line with national standards over the next
twelve months.
Community ophthalmology and optometry are delivered through a
combination of national General Ophthalmic Services arrangements,
community optometry contractors, Health Board ophthalmic lists and
increasingly enhanced community eye care pathways; governance therefore
combines national contractual and clinical requirements with Board-level
oversight of local schemes, referral pathways, quality, data and patient safety.
These differences mean that assurance must be drawn from different sources
across the portfolio, including contract monitoring, national returns,
professional standards, statutory duties, locally managed service metrics,
clinical governance reporting and exception-based escalation.
The report included in appendix 1 provides a Primary Care deep dive and
reports the framework of assurance and direction of travel to the Committee. 
Committee members are asked to consider the position and the framework
for improvement aligned to the Healthcare Improvement Scotland Clinical
Governance Standards and agree a point of review. 
4. RELEVANT DATA AND INDICATORS
Relevant data and indicators are summarised throughout the report and
include IPMF measures, workforce compliance, iMatter, absence, complaints,
adverse events, risk registers, audit activity, vaccination uptake, annual GMS
assurance returns and programme-specific reporting. 
5. CONTRIBUTION TO STRATEGIC PRIORITIES
The report supports the Service Renewal Framework and the Argyll and Bute
Joint Strategic Plan priority to provide safe, effective and person-centred care
closer to home. It also supports the development of a more consistent clinical
governance assurance framework across Primary Care.
6. GOVERNANCE IMPLICATIONS
6.1 Financial Impact
No direct financial decision is requested within this report. Financial
implications may arise from specific service developments, including
workforce contingency arrangements, dental access solutions and
managed service changes, and will be considered through the appropriate
governance routes.
6.2 Staff Governance
Staff governance implications are described throughout the report,
including staffing resilience, absence, Health and Care Staffing Act
implementation, statutory mandatory training, PDP compliance,
professional governance and organisational design. 
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5 
6.3 Clinical and Care Governance
Clinical and care governance implications are central to the report. The
proposed improvement approach will strengthen evidence visibility,
escalation, learning systems, risk management and assurance reporting
across the portfolio. 
7. PROFESSIONAL ADVISORY
Professional advice has been provided by relevant clinical, nursing, dental
and operational leads. Further professional advice will be sought as
improvement actions and service-specific developments progress.
8. EQUALITY & DIVERSITY IMPLICATIONS
Equality and diversity considerations should be built into any decisions arising
from this report, including the Rights of the Child under the UNCRC, island
impacts, Fairer Scotland duties, socio-economic impacts and protected
characteristics. 
9. GENERAL DATA PROTECTION PRINCIPLES COMPLIANCE 
No new data protection decision is requested within this report. Data and
information governance implications are described under Standard 7. 
10. RISK ASSESSMENT
Risk implications are described throughout the report and summarised
through the Primary Care risk register. Particular areas for continued review
include staffing resilience, dental access, LARC provision, forensic medical
governance, risk register review cycles and service-change engagement. 
11. PUBLIC & USER INVOLVEMENT & ENGAGEMENT
Public and user involvement is reflected through complaints learning,
community engagement, service-specific consultation and emerging Patient
Participation Group arrangements. Further work is required to standardise
proactive engagement expectations for future service-change proposals.
12. CONCLUSIONS
Primary Care has established governance arrangements across a complex
mixed delivery environment. The review provides assurance that risks are
known and actively managed, while also identifying clear opportunities to
strengthen consistency, evidence visibility, data quality, learning systems and
proactive engagement. The proposed twelve-month improvement plan will
support continued alignment with the Healthcare Improvement Scotland
Clinical Governance Standards and provide a clearer basis for future
assurance reporting.
13. DIRECTIONS 
Directions
required to
Council, NHS
Board or both.
Directions to: tick
No Directions required x
Argyll & Bute Council 
NHS Highland Health Board 
Argyll & Bute Council and NHS Highland Health Board 
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6 
14. PREVIOUS REVIEW OF THE REPORT 
Meeting  Title of report Date Output (if
relevant)     
REPORT AUTHOR AND CONTACT 
Author Name Eilidh Gallagher, Head of Primary Care
Email  Eilidh.gallagher@nhs.scot 
Appendix 1 
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Appendix 1  : Visual Governance Summary 
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8 
Appendix 2: Clinical Governance Standards Self-Assessment Summary 
1. Overview 
Standard  Position
Standard 1: Leadership and Staffing Good
Standard 2: Quality Management and Continuous Improvement Good
Standard 3: Clinical Effectiveness Good
Standard 4: Clinical Safety and Risk Management Good
Standards 5–7 In progress 
2. Summary of Key Strengths
Established governance and reporting arrangements across Primary Care
Active management of risk, complaints, incidents and service performance
Ongoing quality improvement and service redesign activity
Alignment to national standards, contracts and clinical guidance
Positive organisational culture and staff engagement
Implementation of a structured Governance Assurance Programme 
3. Key Themes Identified
Consistency
Variation in governance processes across services, including risk management, quality improvement and clinical documentation
Visibility of Evidence
Governance arrangements are in place but are not consistently documented or easily accessible
Data and Monitoring
Fragmented datasets and limited standardised indicators across services
Learning and Feedback
Learning from incidents, complaints and audits is not consistently captured, shared or tracked
Escalation and Assurance
Escalation routes are in place but require greater clarity and consistency across services 
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4. Priority Areas for Improvement
Development of a central governance repository
Standardisation of governance documentation, risk registers and SOPs
Definition of minimum datasets and core indicators
Strengthening thematic learning and feedback processes
Improved visibility and use of safety, quality and performance data
Clear escalation triggers and early warning indicators 
5. Overall Position
The self-assessment indicates that governance arrangements across Primary Care are established and functioning. The Governance Assurance
Programme provides a structured route to strengthen consistency, evidence visibility and sustainability of assurance. The current position should be
treated as a baseline from which further improvement will be delivered as the programme progresses. 
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Appendix 3 : Enhanced Service Provision (25/26) 
Area List Size  
Enhanced Service
Minor
Surgery
-
Injectio
ns
Minor
Surger
y -
Invasi
ve
Minor
Surger
y -
Varico
se
Veins
& Piles
Extend
ed
Hours
Access
Palliati
ve
Care
Drug
Misu
se
Anti-
coagulati
on
Monitorin
g
IUCD
Fittin
gs
IUCD
Fitting
s –
Non
Patien
ts
Implan
ts –
Non
Patient
s
Basket
of
Servic
es
Older
Patien
ts in
Care
Home
s
Medicines
Reconciliati
on
Min
or
Injur
y
Argyll and
Bute                     90,718.00 
%
Populati
on with
access
91% 91% 13% 31% 69% 61% 87% 100% 100% 100% 93% 82% NA 11%
OLI                 
23,503 
%
Populati
on with
access
96% 95% 0% 36% 100% 91% 95% 100% 100% 100% 100% 91% NA 20%
MAKI            
21,078.00 
%
Populati
on with
access
97% 97% 6% 26% 57% 0% 99% 100% 100% 100% 92% 77% NA 26%
Cowal &
Bute            
21,598.00 
%
Populati
on with
access
88% 88% 45% 17% 31% 69% 53% 100% 100% 100% 98% 81% NA 0%
Helensburg
h & Lomond                     24,539.00 
%
Populati
on with
access
83% 83% 5% 43% 83% 78% 100% 100% 100% 100% 83% 78% NA 0% 
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APPENDIX 1  
1
Classification: OFFICIAL 
Primary Care
Clinical Governance Deep Dive
July 2026  
Argyll and Bute Health and Social Care Partnership
NHS Highland
Report author
Eilidh Gallagher, Head of Primary Care, NHS Highland
Contributors
Dr Rebecca Helliwell, Depute Medical Director
Gill Rees, Associate Director of Dentistry
Jonny Sibbring, Project Manager (Clinical Governance Recalibration Project Lead)
Stacey Keane, Dental Operations Manager
Claire Menzies, Deputy Service Manager (CTAC and Vaccinations)
Rebecca Kennedy, Acting Lead Nurse Primary Care
Marion Gillies, Forensic Medicine Service Improvement Manager
Patricia Morrison, Service Manager – Primary Care
Rowena Japp, Acting Practice Development Manager
Denise McDermott, Primary Care Modernisation Manager 
Clinical governance assurance report 
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APPENDIX 1  
2
Classification: OFFICIAL
Contents
Primary Care ................................................................. Error! Bookmark not defined.
Executive summary & assurance matrix ....................................................................... 4
1. Executive Summary .............................................................................................. 5
2. Primary Care Services - Background .................................................................... 6
2.1 Primary Care Governance Assurance Programme.............................................. 7
2.2 Clinical Governance Standards Self-Assessment ............................................... 7
Standard  1: Leadership and Staffing ............................................................................ 8
1.2 Leadership .......................................................................................................... 8
1.3 Staffing Levels .................................................................................................... 9
1.4 Organisational Culture ...................................................................................... 10
1.5 Vision and Values ............................................................................................. 10
1.6 Current Assurance ............................................................................................ 12
1.7 Areas for Growth and Next Steps ...................................................................... 12
Standard 2: Quality Management and Continuous Improvement ................................ 13
2.1 General Practice ............................................................................................... 14
2.2 CTAC and Vaccinations .................................................................................... 15
2.3 Public Dental Services ...................................................................................... 16
2.4 Forensic Medicine and Sexual Health ............................................................... 16
2.5 Current Assurance ............................................................................................ 17
2.6 Areas for Growth and Next Steps ................................................................ 18
Standard 3: Clinical Effectiveness ............................................................................... 19
3.1 General Practice ............................................................................................... 20
3.2 CTAC and Vaccinations .................................................................................... 20
3.3 Dental ............................................................................................................... 21
3.4 Forensic Medicine ............................................................................................. 23
3.5 Current Assurance ............................................................................................ 23
3.6 Areas for Growth and Next Steps ...................................................................... 23
Standard 4: Clinical Safety and Risk Management ..................................................... 25
4.1 Complaints ........................................................................................................ 25
4.2 Risk Management ............................................................................................. 27
4.3 Infection Prevention and Control ....................................................................... 27
4.4 Clinical and Care Governance .......................................................................... 27
4.5 Current Assurance ............................................................................................ 28
4.6 Areas for Growth and Next Steps ...................................................................... 28
Standard 5: Education and Training ............................................................................ 30
5.1 Mandatory Compliance – Primary Care ................................................................ 31
5.2 General Practice ............................................................................................... 31
5.3 CTAC and Vaccinations .................................................................................... 32
5.4 Dental ............................................................................................................... 32
5.5 Current Assurance ............................................................................................ 33
5.6 Areas for Growth and Next Steps ...................................................................... 33
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APPENDIX 1  
3
Classification: OFFICIAL
Standard 6: Service User and Patient Involvement ..................................................... 35
6.1 Community Engagement and Service Change .................................................. 35
6.2 Skipness and Patient Participation Group Development ................................... 36
6.3 Current Assurance ............................................................................................ 36
6.4 Areas for Growth and Next Steps ...................................................................... 36
Standard 7: Data and Information ............................................................................... 38
7.1 Information Governance and Clinical Systems .................................................. 38
7.2 Data Quality, Reporting and Assurance ............................................................ 39
7.3 Current Assurance ............................................................................................ 40
7.4 Areas for Growth and Next Steps ...................................................................... 40
8. Final Closing Statement .......................................................................................... 41
Appendix 1  : Visual Governance Summary ............................................................ 42
Appendix 2: Clinical Governance Standards Self-Assessment Summary ................ 43
Appendix 3 : Enhanced Service Provision (25/26) ................................................... 45 
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APPENDIX 1  
4
Classification: OFFICIAL
Executive summary & assurance matrix 
One-Page Primary Care Assurance Dashboard 
Overall assurance: Governance arrangements are established and active across
Primary Care. The collective position is positive but qualified: Standards 2, 3 and 7 are
broadly green with amber direction of travel without further mitigation, while Standards
1, 4, 5 and 6 remain amber due to improvement requirements around staffing,
escalation, learning, training, engagement and evidence visibility. 
Visual Assurance Profile 
Assurance category Standards Count Visual bar
Green with amber direction of travel Standards 2, 3 and 7 3 / 7 ■■■□□□□
Amber Standards 1, 4, 5 and 6 4 / 7 ■■■■□□□
Red None identified 0 / 7 □□□□□□□ 
HIS Standard Assurance
position
Key reason Top action
1. Leadership
and staffing
Amber Established leadership, but resilience, role
clarity and staffing baseline work require
completion.
Complete staffing
assessments and
organisational mapping.
2. Quality
management
Green /
Amber DoT
Quality activity is active, but whole-system
data and indicators are not yet mature.
Develop a Primary Care
quality management system.
3. Clinical
effectiveness
Green /
Amber DoT
Active redesign and clinical review, but
access and outcome measures need
strengthening.
Define clinical effectiveness
and variation measures.
4. Safety and risk Amber Controls exist but closed-loop learning and
escalation visibility require improvement.
Implement risk review
discipline and learning
trackers.
5. Education and
training
Amber Training is active, but compliance, PDPs
and competence evidence need recovery.
Agree recovery plan and
competence matrix.
6. Patient
involvement
Amber Good examples exist, but engagement is
not yet consistently early or standardised.
Create engagement
framework and feedback loop.
7. Data and
information
Green /
Amber DoT
IG controls are in place, but data maturity
and reporting consistency need
development.
Develop data improvement
plan and dashboards. 
Cross-cutting priority Relevant
standards
Twelve-month focus
Data and evidence
visibility
2, 3, 4, 7 Minimum datasets, dashboards, trend reporting and outcome
measures.
Escalation and
accountability
1, 2, 4, 6 Clear roles, escalation triggers, exception reporting and review
discipline.
Workforce and
competence
1, 3, 5 Safe staffing baseline work, competence matrix, training recovery
and resilience planning.
Learning and
improvement
2, 3, 4, 6 Learning tracker for complaints, incidents, audits, SAERs and
engagement feedback.
Community involvement 6, 3, 4 Earlier engagement, impact assessment alignment and “you said,
we did” feedback. 
Dashboard conclusion: The next twelve months should focus on consolidating
improvement activity into one monitored plan, with named owners, timescales,
reporting routes, RAG status and escalation triggers. This will support a clearer shift
from established but fragmented assurance to an integrated, evidence-led Primary
Care governance framework. 
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APPENDIX 1  
5
Classification: OFFICIAL
1. Executive Summary 
This paper presents a structured Primary Care deep dive aligned to the
Healthcare Improvement Scotland Clinical Governance Standards. The
assessment indicates that governance arrangements across Primary Care are
established and functioning, with several areas of good practice. There is
evidence of both strengths and areas that lack in maturity across the system
with opportunities identified to strengthen our assurance systems in coming
months. 
The next phase should focus on consistency, visibility of evidence, stronger use
of data, clearer escalation routes and a more systematic approach to learning
from complaints, incidents, audits and engagement. 
HIS Standard What good looks like Areas of strength Areas for growth Assurance
1. Leadership and
staffing
Clear leadership,
accountability, sustainable
staffing and professional
oversight.
Positive iMatter
position, active
organisational review
and professional lead
engagement.
Complete Health and
Care Staffing Act
baseline work;
strengthen resilience,
cross-cover and
escalation clarity.
Amber
2. Quality
management and
continuous
improvement
A whole-system approach
to planning, improving,
maintaining and assuring
quality.
Cluster quality
improvement activity
and refreshed
operational guidance.
Define minimum
datasets and quality
indicators across mixed
delivery models.
Green
3. Clinical
effectiveness
Timely, effective,
personalised and
evidence-based clinical
care.
Service redesign in
vaccinations, LARC,
forensic medicine and
enhanced services.
Dental workforce fragility
and access inequalities
require continued
mitigation.
Green
4. Clinical safety
and risk
management
Risks, adverse events,
complaints and safety
concerns are identified,
managed, learned from
and escalated.
Established reporting
routes through QPS
and clinical
governance structures.
Refresh overdue risk
reviews and strengthen
thematic learning
trackers.
Amber
5. Education and
training
Staff have the
competencies, training
and support needed for
safe, effective and
person-centred care.
Protected learning, GP
appraisal capacity,
BASICS training and
NES dental feedback.
Improve statutory
mandatory and PDP
compliance; clarify
nursing professional
structures.
Amber
6. Service user
and patient
involvement
People and communities
are meaningfully engaged
in design, delivery and
governance.
Jura engagement,
sexual health scoping
and emerging PPG
approach.
Embed proactive
engagement for future
2c and service-change
proposals.
Amber
7. Data and
information
Safe, secure information
systems that support
care, assurance and
improvement.
DPIAs, information
asset registers and
programme board
oversight of GPIT
migration.
Improve consistency of
data definitions and local
reporting for assurance.
Green 
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APPENDIX 1  
6
Classification: OFFICIAL
2. Primary Care Services - Background 
The Primary Care portfolio covers a broad range of services, including General
Practice (GMS), Board-managed General Practice (2C), Public Dental Services,
Community Treatment and Care (CTAC), Vaccinations, Forensic Medicine, Sexual
Health and Community Optometry.
The developing GP walk-in service in Dunoon forms part of the wider Primary Care
portfolio and should be considered a targeted access, prevention and service-redesign
intervention rather than a standalone model of care. It aligns with the strategic direction
set out in the Joint Strategic Plan by seeking to improve timely access, support care
closer to home, reduce avoidable pressure on urgent and unscheduled care pathways,
and test more responsive multidisciplinary models of primary care delivery. As the
model develops, governance should be proportionate to its scale, complexity and risk
profile, with clear accountability, agreed clinical parameters, operational performance
reporting, risk and issue management, patient and staff feedback, equality and access
considerations, and formal post-implementation review. Oversight should be routed
through the relevant Primary Care Clinical and Care Governance, unscheduled care
and programme-board arrangements, ensuring that emerging learning is visible,
escalated where required and used to inform wider service transformation. Evaluation
should consider not only activity and access, but also safety, equity, patient
experience, workforce impact, sustainability, interface with existing services and
contribution to the future Primary Care operating model across Argyll and Bute.
The service areas operate across a mixed governance environment, and this should be
recognised when interpreting assurance, performance and escalation arrangements. 
General Medical Services (GMS) practices are independent contractors delivering
services under the national GMS contract, with NHS Boards and Integration Authorities
retaining responsibilities for contract oversight, service planning, assurance and
delivery of transferred services under the 2018 GMS contract reform and associated
Memorandum of Understanding. 
This differs from Primary Care Board Managed services, referred to as 2c practices,
and directly employed multidisciplinary teams, where the Health Board and HSCP hold
more direct operational, clinical, staff and financial governance responsibilities. 
Vaccination and Community Treatment and Care services sit within the wider primary
care reform programme and are predominantly NHS Board/HSCP responsibilities.
Governance is focused on safe delivery models, workforce competence, clinical
standards, access, audit and escalation. Some practices continue to provide remote,
rural and island services directly, with HSCP funding; in these circumstances,
governance is shared and assurance must be interpreted in the context of the local
delivery model.
Public Dental Services are directly managed NHS services providing safety-net and
specialist community dental provision, with HSCP accountability for quality, access,
workforce, risk and clinical governance. 
Forensic medical services have a specific statutory and standards-based framework,
requiring NHS Boards to provide trauma-informed, person-centred and legally robust
healthcare and forensic medical examination services. This includes clear governance,
training, documentation, evidence handling and quality assurance requirements.
Historically, services in Argyll and Bute were delivered through contracted models, with
governance devolved through those arrangements. Following service review, some
services have transitioned to managed provision under HSCP responsibility over the
past six months. The current landscape remains mixed, with work underway to
standardise provision in line with national standards over the next twelve months.
Community ophthalmology and optometry are delivered through a combination of
national General Ophthalmic Services arrangements, community optometry
contractors, Health Board ophthalmic lists and increasingly enhanced community eye
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APPENDIX 1  
7
Classification: OFFICIAL
care pathways; governance therefore combines national contractual and clinical
requirements with Board-level oversight of local schemes, referral pathways, quality,
data and patient safety. These differences mean that assurance must be drawn from
different sources across the portfolio, including contract monitoring, national returns,
professional standards, statutory duties, locally managed service metrics, clinical
governance reporting and exception-based escalation. 
A visual summary is provided in appendix 1 to explain the differential delivery methods.
2.1 Primary Care Governance Assurance Programme
Within the past six months, Primary Care has commenced a structured Governance
Assurance Programme aligned to the Healthcare Improvement Scotland Clinical
Governance Standards. The programme provides a consistent and proportionate
approach to assessing governance arrangements, evidencing assurance and
identifying improvement priorities across the portfolio.
The programme is being delivered in phases across the seven standards. Each phase
reviews current arrangements, identifies what good looks like, confirms areas of
strength, defines areas for growth and agrees the evidence required to support ongoing
assurance. This is supported by development of a central governance repository,
clearer ownership and improved visibility of governance documentation.
As of July 2026, detailed review work has been completed for:
• Standard 1: Leadership and Staffing
• Standard 2: Quality Management and Continuous Improvement
• Standard 3: Clinical Effectiveness
• Standard 4: Clinical Safety and Risk Management
Work will continue across the remaining standards during 2026/27. Outputs will inform
a single improvement plan and support a sustainable governance assurance
framework for Primary Care.
2.2 Clinical Governance Standards Self-Assessment
As part of the Assurance Programme, a structured self-assessment has been
undertaken to establish a baseline view of current governance arrangements across
Primary Care. The assessment has been used to identify strengths, gaps and
improvement priorities rather than to provide a static compliance statement.
The review confirms established assurance across several domains, particularly
governance reporting, quality improvement activity, professional oversight and
responsive risk management. It also highlights the need to improve consistency,
evidence visibility, data quality and systematic learning across the portfolio.
The remaining standards will be assessed as the programme progresses. Findings will
be consolidated into a single improvement plan with defined owners, timescales and
reporting routes.
A summary of the self-assessment outcomes completed to date is provided in
Appendix 2 with each pillar explored in depth throughout the body of this report.  
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Standard  1: Leadership and Staffing 
Standard 1: Leadership and Staffing asks us to ensure that services have effective
leadership and oversight, including staffing levels, to support the effective planning and
delivery of services.
HIS Standard 1 requirement Current assurance RAG Action required
Clear leadership and
oversight of healthcare
services.
Leadership structures are established, with
bi-monthly senior management team
meeting inclusive of multiprofessional
oversight and engagement. Organisational
review is underway to address portfolio
complexity.
Amber Complete organisational
mapping, confirm
responsibilities and
strengthen escalation
routes.
Appropriate and sustainable
staffing and skills mix in line
with the Health and Care
(Staffing)(Scotland) Act 2019.
Workforce investment has strengthened
capacity, but baseline assessments are
required for CTAC, Vaccinations, 2C
General Practice and Dental Nursing teams
in line with the Act.
Amber Complete baseline staffing
assessments and agree
reporting arrangements
through professional
governance routes.
Workforce resilience plans
and monitoring.
Absence is monitored and mitigations are
discussed through daily management
arrangements, but dental staffing fragility
continues to affect continuity.
Amber Progress locum dental
bank proposal and define
contingency arrangements
for high-risk services.
Values-based, person-
centred and trauma-informed
leadership.
iMatter results show a positive culture, with
a 75% response rate and engagement
index of 79. Further work is needed on
involvement in decision-making.
Green Use the iMatter action
plan to strengthen staff
involvement and monitor
progress over twelve
months.
Clearly communicated vision
aligned to national priorities.
Service leadership is aligned to HSCP and
national priorities, but clearer articulation of
responsibilities and escalation routes is
required across the portfolio, with intent to
design a five-year delivery plan to achieve
the wider vision of the Joint Strategic Plan.
Amber Use organisational review
outputs to agree and
communicate a unified
vision, responsibilities and
escalation framework. 
1.2 Leadership 
A small senior management team, mostly AFC Band 7 and above, supports the
portfolio. Limited administrative capacity creates risk given the breadth of services.
Leadership focuses on strategic decisions, operational management and improvement,
with bi-monthly SMT oversight aligned to HSCP and national priorities. Senior leaders
work with clinical and administrative teams to maintain governance and safe, effective,
person-centred care. 
A key risk is the limited leadership and support structure for Sexual Health and
Forensic Medical Examiner services. This, alongside siloed portfolios and service
complexity, has prompted an organisational review focused on sustainability,
development opportunities and role diversity. Discussions remain at an early stage and
will progress through agreed policies, decision points and oversight arrangements. 
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Figure 1: A&B Primary Care Organisational Structure (April 2026) 
FT = Fixed Term
1.3 Staffing Levels 
High-quality care depends on adequate staffing. Workforce growth since 2024 and
97% permanent employment provide assurance on stability and continuity, but small
specialist teams remain vulnerable to absence, vacancies, single points of failure and
limited cross-cover. 
Primary Care: Headcount and WTE by date 
While the workforce growth is encouraging, an oversight was identified in
implementation of the Health and Care (Staffing)(Scotland) Act 2019, as Primary Care
was initially treated as out of scope in A&B. CTAC, Vaccinations, 2C General Practice
and Dental Nursing teams are in scope, requiring baseline assessments, clinical
judgement tools and common staffing methods to be developed over the next twelve
months. 
Supplementary staffing has totalled 2,178 hours since January 2026, mainly for
vaccination campaigns. This appears appropriate for predictable peaks, but should be
monitored to ensure it is not masking underlying capacity gaps in small teams. 
Primary Care: Absence Statistics (1) 
In 2026, sickness absence accounts for 36% of working days lost, or 540 days by
June. Most absence is short term, and reduced long-term sickness in March is positive.
The key issue is the operational impact on small teams, where even short-term
absence can affect capacity, continuity and access. Absences continue to be managed
within Once for Scotland Policies with reasonable adjustments applied to support staff
to return to work when safe to do so. 
Primary Care: Absence Statistics (2) 
Dental services remain at particular risk from absence, with recent rates affecting
clinical service delivery. The impact is amplified by a small workforce and limited cover.
June trends are more reassuring, but continued oversight is needed due to the impact
of short-notice cancellations on access, experience and equity. Mitigation is monitored
through management processes and Datix. 
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Dental Services: Absence Statistics
1.4 Organisational Culture 
Organisational culture is a strength. The iMatter response rate of 75% and engagement
index of 79 indicate positive staff engagement during a period of redesign, workforce
pressure and organisational review. 
However, 13% of staff did not feel involved in decision-making, which is a material
improvement signal. In small specialist teams, involvement supports psychological
safety, change readiness, retention and early risk identification. The iMatter action plan,
once developed with local teams, will likely focus on communication, involvement and
feedback loops. 
Local discussion has identified governance risks around continuity, cross-cover,
managerial roles and escalation. These can delay decisions, reduce local autonomy
and increase reliance on a small number of senior staff. Organisational mapping and
change work is therefore being progressed to support risk mitigations. 
Effectiveness will be measured by improved accountability, cross-cover, peer support
and staff confidence, monitored through iMatter, risk review, SMT oversight and team
feedback. 
1.5 Vision and Values 
Primary Care’s developing vision aligns with the Argyll and Bute HSCP Joint Strategic
Plan 2026–2031, prevention, early intervention, person-centred care, improved access
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and sustainable care closer to home. The key challenge is translating this intent into an
operating model staff, partners and communities can recognise in practice. 
Self-assessment shows a clear values-based direction: more collaborative, transparent
and relationship-based working; stronger professional and operational leadership;
active listening to staff, patients and communities; and better use of governance, data
and learning. The critical dependency is embedding this consistently in decisions,
priorities, engagement and escalation across all delivery models. 
Draft objectives are set out below but still require Chief Officer review and senior
management approval. Until confirmed, teams may continue to interpret priorities
differently, particularly where service pressures, workforce constraints and contractual
responsibilities compete. 
The direction is well aligned to national and local priorities, but now needs clearer
articulation across Primary Care, linked to team roles, professional responsibilities,
escalation routes and the five-year Joint Strategic Plan delivery plan. Without this, the
vision risks remaining aspirational rather than operational. 
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1.6 Current Assurance 
Assurance for Standard 1 is proposed as amber. There is evidence of established
leadership arrangements, positive organisational culture, active professional oversight
and responsive management of emerging workforce risks. The amber rating reflects
the scale and complexity of the portfolio, the need to complete baseline staffing
assessments under the Health and Care (Staffing)(Scotland) Act 2019, and the
requirement to strengthen clarity around roles, responsibilities, escalation routes and
cross-cover arrangements. 
The current position provides reasonable assurance that risks are known and being
actively managed, but further work is required to move from responsive oversight to a
more consistent, documented and sustainable leadership and staffing framework. The
organisational review, iMatter action planning, professional nursing structure review
and staffing act implementation work provide the key improvement routes over the next
twelve months. 
1.7 Areas for Growth and Next Steps 
Area for growth Why this matters Next step RAG
Health and Care
Staffing Act
implementation
Baseline assessments are
required for in-scope services
to evidence safe staffing and
support statutory reporting.
Complete baseline assessments for
CTAC, Vaccinations, 2C General
Practice and Dental Nursing teams
and agree reporting routes through
professional governance.
Amber
Leadership
structure and
portfolio resilience
Current portfolios are complex
and some specialist areas
have limited leadership
resilience and cross-cover.
Progress organisational review,
clarify managerial and professional
responsibilities, and define cross-
cover arrangements for high-risk
services.
Amber
Escalation routes
and decision-
making clarity
Staff need clear routes for
operational, professional and
clinical escalation to support
timely decision-making and
reduce ambiguity.
Develop an organisational map with
responsibilities, escalation triggers
and peer support networks, and
communicate this across teams.
Amber
Staff involvement
and culture
iMatter results are positive, but
a proportion of staff reported
limited involvement in
decision-making.
Use the iMatter action plan and
organisational change discussions to
strengthen staff involvement,
feedback loops and shared
ownership.
Green
Vision and
communication
The developing Primary Care
vision is aligned to the Joint
Strategic Plan, but requires
clearer articulation across
services and teams.
Agree and communicate the Primary
Care vision, objectives and values
through the organisational review and
five-year delivery planning process.
Amber 
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Standard 2: Quality Management and Continuous Improvement 
Healthcare Improvement Scotland defines Standard 2 as requiring clinical services to
implement a whole-system approach to plan, improve, maintain and assure safety and
quality. Within Primary Care, this must be interpreted through the mixed governance
environment described in the opening section of this paper. As a result, quality
management cannot rely on a single assurance route; it must draw together contract
monitoring, cluster quality improvement, annual assurance returns, complaints and
adverse event learning, operational performance, audit activity, professional oversight
and programme board reporting. 
HIS Standard 2
requirement
Current assurance RAG Action required
Actively monitor the
quality of clinical
care they deliver
through established
governance and
oversight
frameworks
Quality is monitored through HSCP
performance arrangements, IPMF
measures, clinical governance reporting,
annual GMS assurance returns, payment
verification visits, complaints returns,
cluster activity and operational oversight.
Green Continue to develop
meaningful indicators,
improve consistency of
reporting and strengthen
links between
performance data,
governance review and
improvement action.
Have a system to
receive applications
for tests of change
Cluster quality improvement provides an
established route for tests of change and
local improvement activity within General
Practice. A refreshed cluster operational
guide supports roles, reporting routes
and alignment with clinical governance.
Green Finalise the protocol for
non-engagement in
cluster quality activity
and ensure tests of
change are recorded,
monitored and shared
through cluster and
governance routes.
Use data and
intelligence to
monitor and improve
the safety and
quality of their
clinical services
Data is used through IPMF reporting,
GMS annual returns, assurance visits,
complaints, audit activity and programme
reporting. However, datasets remain
fragmented across mixed delivery
models and CTAC access and waiting-
time data is not yet standardised. There
is limited evidence of longitudinal data
monitoring, which necessitates a cultural
shift and restructuring of reporting
frameworks.
Amber Define minimum datasets
and core quality
indicators, modernise
IPMF measures and
develop a consistent
approach to CTAC
access and waiting time
reporting.
Work collaboratively
with other
organisations to
share learning and
improve safety and
quality of care
Collaborative improvement is evident
through GP cluster working, LMC
engagement, dispensing network
development, prescribing improvement
activity, cervical screening work and links
to wider NHS Highland ITR scoping.
There is less evidence of collaboration
with research teams or quality
improvement systems.
Green Continue to use cluster,
LMC, NHS Highland and
programme board routes
to share learning, reduce
unwarranted variation
and strengthen whole-
system improvement.
Implement a whole-
system evidence-
based quality
management
system.
A developing quality management
approach is in place through
performance reporting, cluster
improvement, assurance returns, audit,
complaints learning and programme
oversight, but it is not yet fully
standardised across all portfolio areas.
Amber Develop a more explicit
quality management
system for Primary Care,
with agreed evidence
requirements, reporting
cycles, learning routes
and escalation triggers
across all services. 
Current quality management provides reasonable assurance that improvement activity
is active, visible and increasingly structured. Established routes include IPMF reporting,
clinical governance, GP clusters, annual GMS returns, payment verification, complaints
returns and programme oversight, demonstrating strengths in local improvement,
collaboration and responsiveness. 
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The key assurance gap is that these arrangements are not yet a mature whole-system
quality management system. IPMF performance in quarter 3 of 2025/26 was 67%, with
four metrics on track and two off track; however, current indicators do not yet give a full
view of quality, access, outcomes, equity, patient experience or sustainability. New
indicators are therefore being progressed with the Planning Team for delivery within
next twelve months. 
2.1 General Practice 
General Practice quality improvement is delivered mainly through GP clusters,
supported by the refreshed Argyll and Bute GP Cluster Operational Guide. This sets
out roles, reporting and escalation, aligning cluster activity with Primary Care clinical
governance and national priorities. It provides a key improvement infrastructure within
a contractor-led environment where direct operational levers are limited. 
Variable cluster engagement remains a governance risk because clusters are the main
route for General Practice quality improvement, peer learning and tests of change. A
non-engagement protocol has been developed and recently ratified which will provide a
staged, supportive process with review periods and escalation routes where required. 
The table below shows active improvement work across dispensing, prescribing,
cervical screening, workload transfer and medical recall. The next step is to link each
workstream to measurable aims, outcomes, learning routes and escalation where
progress is delayed. 
Topic Lead Remarks Status
Dispensing Network  Dr Alida McGregor
(Clinical Lead)
Reviewing practice,
protocols, financial
sustainability and
governance
arrangements for
dispensing practices with
the establishment of an
A&B wide dispensing
network to share
learning, adverse event
outcomes and best
practice
In Development,
administrative
support allocated
and stakeholders
engaged
Prescribing Practices Dr Brian McLaughlin
(Clinical Lead)
2c prescribing audit and
improvement project to
deliver pharmacotherapy
review, streamline
prescribing practices
within formulary and
In progress, key
stakeholders
engaged
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reduce unnecessary
costs
Cervical Screening Dr Rob Waddingtong Ongoing project with
LMC to boost uptake
rates across the
localities
In Progress, data
metrics to be
reviewed
Secondary Care >
Primary Care workload
Transfer
Dr Rob Waddington PQLs to collate and
review common themes
and workload impact
associated with
secondary care
requests.
Engaged with NHSH
ITR (Integrated
Treatment Rooms)
scoping work to
consider scalability
and funding options
for A&B
Medical Recall Reviews Dr Claire Harris Review of recall system
on EMIS and overriding
med review by
dispensing staff. Multiple
systems issues identified
and learning /
improvement ongoing
80% of med reviews
completed
Quality Improvement Programmes 
Cluster working is a strong improvement mechanism, but contracted delivery limits
routine access to comparable quality, access, outcome and patient experience data.
This creates an assurance gap: the HSCP can evidence improvement infrastructure
and contract compliance, but has a less complete view of comparative performance
across practices. Developing national work to establish a minimum dataset should
inform local learning and improvement and strengthen quality improvement
programmes in the future. 
GMS practices also provide assurance through annual returns, payment verification
visits and complaint returns. These confirm core contractual requirements, including
access, opening hours, equality and diversity, Disclosure/PVG compliance and GDPR
assurance. They are important but largely self-assessed, annual and compliance-
focused, so do not provide a full view of quality, outcomes, equity or improvement over
time.
Assurance Returns : GMS  24/25 
In 2024/25, one practice did not submit assurance documentation due to extenuating
circumstances. Local communication provided sufficient assurance at the time;
however, this highlights the need for a documented escalation and exception process
when routine returns are incomplete. 
The LMC and Primary Care Management Team are developing an annual review
process between practices and the HSCP. This should better connect contract
assurance with clinical governance. Until a formal framework is in place, there remains
limited ability to take a consistent, evidence-based view of service delivery, experience,
access, learning and improvement across practices. 
For executive assurance, timeliness is the key issue. Annual returns are necessary but
insufficient for in-year quality management, and self-reporting by practices limits
independent scrutiny. Work is required to establish improvement metrics that should
therefore be reported through clinical governance, cluster and management forums,
with emphasis on trends, exceptions, impact and learning rather than activity alone.
2.2 CTAC and Vaccinations 
Annual Returns Complaint Returns Payment Verification 
96%  96% 3 visits concluded
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CTAC quality management is supported by local governance, patient safety systems,
workforce assurance, audit and learning. These arrangements provide assurance that
quality issues are identified and managed, but wider limits in standardised primary care
datasets mean local intelligence is not yet consistent or comparable enough for a
mature quality management system. 
There is no single mechanism for measuring CTAC access and waiting times because
clinical and scheduling systems vary across sites. This limits assessment of
effectiveness, equity and improvement opportunity. Pressures and delays are
monitored operationally and reported through the Primary Care Modernisation
Programme Board, but strategic assurance requires more consistent reporting on
access, demand, capacity and outcomes. 
The CTAC service specification has recently been reviewed and is pending final
ratification via programme board, this is an opportunity to modernise delivery, align
activity with prevention and long-term outcomes, and address recognised gaps. The
revised specification defines service standards, data requirements, escalation triggers
and reporting routes so quality can be assessed consistently across localities. 
2.3 Public Dental Services 
Public Dental Services are directly managed NHS services, providing a clearer line of
operational, clinical, workforce and quality governance than independently contracted
General Dental Services. 
Quality management is supported through Public Dental Service management
meetings, Datix, health and safety assurance, complaints review, team-lead escalation,
QPS reporting and professional dental leadership. 
The service contributes to prevention and population health through Oral Health
Improvement, Caring for Smiles, Childsmile and the National Dental Inspection
Programme. March 2026 reporting showed continued activity in care home training,
fluoride varnish, health visitor referral follow-up and inspection outcomes, including
80% of inspected Primary 1 children and 79% of inspected Primary 7 children with no
obvious decay experience. 
The main quality risk is workforce fragility and its impact on access, continuity and
utilisation. Prolonged staffing challenges, unplanned absence, vacancies in Oban and
Campbeltown, and difficulty securing Dental Officer cover are affecting delivery.
Mitigations are active, including a proposed dental locum model, a Dental Professional
Oversight Group, regular service management oversight and service-model work for
orthodontics, Tiree and mobile dental provision. 
Mobile dental provision remains a significant equity issue, as the previous unit has
been out of service since 2018, reducing local access for remote and island
communities. A shared capital bid with Highland HSCP is progressing for a towable
mobile dental trailer. Overall, governance routes are established and risks are known,
but stronger capacity modelling, utilisation reporting, locality waiting-time data,
workforce contingency and escalation thresholds are needed to move from reactive
management to a more mature quality system. 
2.4 Forensic Medicine and Sexual Health 
Forensic Medicine and Sexual Health sit within a more specialised governance context,
with particular requirements for clinical documentation, legal defensibility, trauma-
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informed care, prescribing governance, pathway clarity, training, data quality and
escalation. Both areas are moving through active service redesign, with quality
management increasingly being strengthened through revised service specifications,
standard operating procedures, clinical leadership, professional oversight and
structured review. However, both areas also illustrate the wider challenge identified in
this deep dive: quality assurance is improving, but it remains dependent on
standardising documentation, data capture and reporting across mixed delivery
arrangements. 
In Forensic Medicine, the transition of Cowal custody healthcare from contracted
arrangements to managed service provision has created a stronger quality
management route. Provision of daytime services transitioned on 1 April 2026 and out-
of-hours services from 1 June 2026, with training delivered to clinicians, further
sessions planned, and service specifications being refreshed in line with Police
Scotland changes. A final draft Forensic Medical Examiner service specification has
also been developed to align provision with current policing arrangements, facilities,
professional expectations and safe delivery requirements. This is a clear area of
strength because it moves the service from historic contract-based provision towards a
more standardised and clinically governed model. 
The key quality gap is clinical records, auditability and inspection readiness, which has
been captured on the service level risk register. The June 2026 Primary Care Risk
Register notes variable Police Adastra use across custody healthcare, creating risks for
inspection compliance, record access, documentation quality, audit, patient safety and
Board assurance. Interim inspection-readiness processes, high-risk mitigations,
standardised documentation and audit arrangements are planned, with full Police
Adastra use targeted by December 2026 and Cowal/Oban implementation by August
2026. Assurance should remain amber until documentation and system alignment are
complete. 
Sexual Health quality management is developing through service redesign, with
recognised long-term reduced provision affecting access and patient experience.
Interim arrangements, including the Cowal LARC clinic model, have been implemented
within the last month to maintain local access. Ratified SOPs for the Phase 1 soft
launch set out eligibility, access, documentation, escalation, capacity management,
data capture, prescribing queries and early review. This provides controlled clinical
assurance, but a transitional plan is needed for a more sustainable and cost-effective
future model. 
Overall, Forensic Medicine and Sexual Health show active quality management and
improvement momentum through refreshed specifications, managed-service
development, SOPs, training, professional engagement and emerging data capture.
Key areas for growth are documentation standards, Adastra implementation, audit
capability, sexual health demand modelling, workforce planning and consistent
governance reporting. These areas should remain amber within Standard 2 while
systems to evidence quality across all sites and pathways mature.
2.5 Current Assurance 
Assurance for Standard 2 is proposed as amber for data maturity and system
consistency. There is evidence of established quality management and improvement
activity across the portfolio, including GP cluster quality improvement, refreshed
operational guidance, annual assurance returns, payment verification, complaints
returns, collaborative improvement with the LMC, responsive operational oversight,
programme board reporting and emerging service specification work across CTAC,
Public Dental Services, Forensic Medicine and Sexual Health.
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The current position provides reasonable assurance that quality and improvement
activity is active, visible and increasingly structured. However, further work is required
to move from multiple functioning assurance processes to a more integrated whole-
system quality management approach. The key areas for growth relate to defining
minimum datasets, improving timeliness and consistency of in-year intelligence,
strengthening CTAC access and waiting-time reporting, improving outcome
measurement for quality improvement workstreams, developing locality-level dental
capacity and waiting-time data, completing Adastra implementation and audit readiness
in Forensic Medicine, and embedding sustainable quality reporting for Sexual Health. 
2.6 Areas for Growth and Next Steps 
Limited longitudinal data monitoring shows the need to strengthen reporting culture,
human factors awareness and reporting frameworks. 
Area for growth Why this matters Next step RAG
Whole-system
quality
management
system
Quality activity is established but
remains distributed across
several assurance routes, which
limits a single portfolio-wide view
of quality, safety, access,
outcomes and learning.
Develop an explicit Primary Care
quality management system with
agreed evidence requirements,
reporting cycles, learning routes
and escalation triggers across all
services.
Amber
Minimum datasets
and quality
indicators
Fragmented data limits the ability
to compare quality, access,
outcomes, equity and patient
experience across mixed
delivery models.
Define minimum datasets,
modernise IPMF indicators and
agree core quality measures for
directly managed, contracted and
shared-delivery services.
Amber
GP cluster
engagement and
annual review
framework
Cluster working is the main
quality improvement mechanism
in General Practice, but variable
engagement and annual
compliance-focused returns limit
continuous assurance.
Finalise the non-engagement
protocol and develop an annual
practice review process with the
LMC that links contract assurance,
quality improvement and clinical
governance.
Amber
CTAC access and
waiting-time
reporting
Different scheduling and clinical
systems limit formal assessment
of access, equity, demand,
capacity and improvement
opportunity.
Use the CTAC service
specification review to define
service standards, access
measures, data requirements,
escalation triggers and reporting
routes.
Amber
Public Dental
Services capacity
and utilisation
Workforce fragility, absence,
clinic cancellations and locality
variation affect access, equity,
continuity and patient
experience.
Progress the dental locum bank
proposal, strengthen capacity
modelling, improve locality-level
waiting-time and utilisation
reporting, and agree escalation
thresholds.
Amber
Forensic Medicine
documentation and
audit readiness
Variation in Police Adastra use
creates risks to documentation
quality, record accessibility,
inspection compliance, audit
capability, patient safety and
Board assurance.
Complete interim inspection-
readiness processes, standardise
documentation and audit
arrangements, and progress full
Police Adastra implementation
across custody healthcare areas.
Amber
Sexual Health
sustainable quality
model
Interim arrangements are
clinically controlled, but reduced
provision and changing access
routes require a sustainable
model with clear demand,
workforce and outcome
reporting.
Develop a transitional plan for a
sustainable and cost-effective
Sexual Health model, including
demand data, referral routes,
patient feedback, workforce
requirements and governance
reporting.
Amber 
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Standard 3: Clinical Effectiveness 
Healthcare Improvement Scotland defines clinical effectiveness as timely, effective,
person-centred and evidence-based care. In Primary Care, assurance must be drawn
from multiple sources across independent contractor, directly managed, business-to-
business and HSCP-led services, including contract review, service specifications,
clinical guidance, audit, uptake data, complaints, adverse event learning, workforce
capacity, professional oversight, access, redesign and measurable improvement. 
Primary Care services are actively reviewing clinical effectiveness and responding to
gaps, with strengths in service redesign, vaccination governance, enhanced service
review, managed service development, forensic medicine improvement and use of
audit and clinical guidance. The key gap is inconsistent evidence across services on
outcomes, locality access, patient experience and formal audit cycles. The next step is
to link redesign more clearly to outcomes, access equity, workforce resilience and
patient experience. 
HIS Standard 3
requirement
Current assurance RAG Action required
Deliver timely,
effective,
personalised and
evidence-based
care and treatment.
There is evidence of active clinical
review, service redesign and use of
clinical guidance across General
Practice enhanced services,
Vaccinations, CTAC, Public Dental
Services, Forensic Medicine and
Sexual Health. However, timeliness and
equity are affected by workforce
fragility, LARC provision gaps, dental
access pressures and variable locality-
level data.
Amber Strengthen clinical
outcome, access and
patient experience
measures across priority
services, with clear
escalation where access or
effectiveness is
compromised.
Ensure clinical
services are
delivered in line with
current evidence,
professional
standards and
national guidance.
Vaccination delivery is supported by
PGDs, audit, training and national
programme oversight. Forensic
Medicine service specifications and
documentation standards are being
refreshed. Dental, LARC and enhanced
service models are under review to
improve alignment with current
standards and local need.
Green Continue service
specification refresh, PGD
audit, professional
oversight and contract
review, ensuring changes
are reported through
clinical governance routes.
Use clinical audit,
quality improvement,
adverse event
learning and
complaints to
improve clinical
outcomes.
Audit activity is evident in vaccination
programmes, PGD compliance,
prescribing, cervical screening,
medication review and forensic
documentation improvement.
Complaints and adverse event learning
inform service changes, but evidence of
closed-loop clinical outcome
improvement is not consistent across all
services.
Amber Develop a stronger clinical
audit and outcomes tracker
that records improvement
aim, baseline, action,
outcome, learning and
reporting route.
Identify and address
unwarranted
variation in clinical
care, access and
outcomes.
Variation is recognised across LARC
provision, dental access, vaccination
uptake, CTAC access reporting,
orthodontic provision in and forensic
medicine documentation. Mitigations
are active, but comparative data is not
yet sufficiently mature to quantify and
track variation consistently.
Amber Define priority variation
measures and report them
through governance,
including locality access,
waiting time, uptake,
cancellation and clinical
outcome data where
available.
Ensure service
redesign improves
effectiveness,
quality, access and
sustainability.
There is active redesign across Cowal
LARC, managed forensic medicine,
Public Dental Services, mobile dental
provision, orthodontics, vaccinations
and enhanced services. The direction of
travel is positive, but some redesign
remains dependent on workforce,
Amber Ensure all redesign
proposals include clinical
effectiveness measures,
workforce assumptions,
patient impact, equality
impact, sustainability
assessment and post-
implementation review.
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funding, system configuration and data
maturity. 
3.1 General Practice 
General Practice clinical effectiveness is supported through enhanced service review,
LMC engagement, quality improvement, contract monitoring and new or revised
service models. In quarter 4 of 2025/26, the Primary Care team reviewed enhanced
service contracts and access equity, identifying opportunities to improve access,
reporting, assurance and financial sustainability. Appendix 3 details the 25/26
enhanced service provision across Argyll and Bute. 26/27 provision will be reviewed
following the cycle of annual contract renewal. Revised contracts are progressing to
address gaps, including ring pessary and Long-Acting Reversible Contraception
provision. New services have also been developed in recognition of access gaps and
over reliance on secondary care pathways where primary care could offer a viable local
alternative such as the provision of ring pessary services. 
The key strength is that enhanced service review is being used to respond to clinical
need and support care closer to home, particularly in remote, rural and island
communities. Caution should be applied in expecting uniform access, as wider
secondary care service provision creates resilience and influences the context of local
community needs. Equally, clinical effectiveness cannot be assessed through contract
existence alone; future contracts will include clear measures of access, activity, uptake,
patient experience, equity, outcomes and escalation triggers where provision becomes
fragile. 
Cowal LARC provision is a specific risk following GP withdrawal from enhanced service
contracts, creating a short-term local access gap and increased travel for some
patients. While contractual access is recorded as 100% across the locality, enhanced
service arrangements present limitations in how this translates into real-term access to
care. A practice may opt in to a service, but the level of delivery required is not always
determined within contracting arrangements. These limitations will also be considered
as the enhanced service contract review progresses. 
In relation to LARC access, interim signposting is in place and a managed service
model has been developed at Cowal Community Hospital as a short-term intervention
to maintain access. However, this model is not viable as a long-term service model
from a financial or workforce perspective. Assurance remains amber until the model is
implemented, evaluated and supported by demand, capacity, governance and patient
feedback data. 
3.2 CTAC and Vaccinations 
The Vaccination Transformation Programme provides a strong example of clinical
effectiveness across Argyll and Bute. The programme enables standardised delivery of
national vaccination programmes through defined clinical models, approved Patient
Group Directions, routine audit, infection prevention and control assurance, trained
staff and dedicated data-quality monitoring. These arrangements provide assurance
that vaccination delivery is aligned to national clinical guidance and that errors, trends
and learning are identified and managed. 
The critical issue is uptake and variation. National data shows declining vaccination
uptake at several age points, and Argyll and Bute performance has been variable in the
most recent reporting period, although it often reaches 95%. There has been a noted
reduction in 12-month uptake across the HSCP. This does not indicate a failure of
governance, but it does require active clinical effectiveness oversight because reduced
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uptake can affect population health outcomes and health inequalities. Uptake rates
should therefore continue to be monitored through vaccination oversight groups, with
targeted improvement activity where variation or decline is identified. 
CTAC clinical effectiveness is more difficult to evidence because access, waiting time
and outcome data are not yet consistently captured across all localities. The service
specification review provides an opportunity to define the clinical effectiveness
measures that matter most, including access, demand, capacity, chronic disease
monitoring, procedure completion, patient experience and escalation triggers. 
Table 4 : Argyll and Bute primary and booster immunisation uptake rates by financial year 
Audit activity is undertaken where appropriate, including: 
• Random audits of childhood and core vaccination programmes 
• Patient Group Direction (PGD) audits to provide assurance of correct
authorisation, use and compliance 
These processes provide assurance of safe and effective practice and support
continuous learning, rather than functioning as formal performance metrics. 
3.3 Dental 
Public Dental Services demonstrate clear clinical purpose, with safety-net and
specialist community provision, oral health improvement encompassing national
Reducing Inequalities programmes, inclusive of Childsmile, Caring for Smiles alongside
the Dental Outreach Programme, delivered by means of Service Level Agreement in
conjunction with NES and the University of Glasgow contributing to prevention, access
and population health. The service has evidence of preventative impact, including oral
health improvement activity and National Dental Inspection Programme results
showing high proportions of inspected children with no obvious decay experience. 
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KPI 2025/26 Performance Key Findings
Measure 1 –
Delivery of
National Oral
Health
Improvement
Programmes
85% of planned activity delivered
(1,529 of 1,800 activities).
Quarterly performance: Q1 85%,
Q2 73%, Q3 88%, Q4 92%.
Performance improved throughout the year,
with the highest level of delivery achieved in
Q4. Priority national programmes, particularly
Childsmile, were maintained across Argyll &
Bute despite operational pressures.
Measure 2 –
Fluoride
Varnish Follow-
up
3,983 children received fluoride
varnish. 690 children (17.3%)
were identified as requiring follow-
up dental appointments. Quarterly
referral rates ranged from 14.8%–
20%.
Referral rates remained relatively stable
throughout the year, demonstrating
consistent identification of children requiring
further dental care. Delivery of the fluoride
varnish programme was maintained despite
workforce challenges. 
National Dental Inspection Programme latest figure. In 2025/26 caries experience
overall has increased however, the percentage of children with untreated dental caries
has decreased. This demonstrates a need to further improve prevention strategies and
engagement but it does indicate access to dental services has increased. 
Indicator Outcome
P1 oral health Increased from 73% (2023/24) to 80% (2024/25) (+7 percentage points).
P7 oral health Increased from 76% (2023/24) to 79% (2024/25) (+3 percentage points).
Overall 1,308 children were inspected across Argyll & Bute, demonstrating continued
improvement in children's oral health and providing valuable intelligence to
target future Oral Health Improvement interventions. 
Overall performance remained strong despite ongoing workforce and geographical
challenges. The Oral Health Improvement Team delivered 85% of planned activity
during 2025/26, with performance improving from 73% in Quarter 2 to 92% in Quarter 4
through effective prioritisation and collaborative working. National Childsmile
programmes and fluoride varnish delivery were maintained across Argyll & Bute,
ensuring continuity of key preventative services. These efforts have contributed to
improved oral health outcomes, with the 2024/25 National Dental Inspection
Programme reporting 80% of Primary 1 children and 79% of Primary 7 children free
from obvious dental decay, demonstrating continued improvement from the previous
year. 
The principal clinical effectiveness risk is workforce fragility and its direct impact on
access, continuity and utilisation. Recruitment challenges, unplanned absence, clinic
cancellations, reduced clinical capacity and extended waiting times are affecting the
ability of the service to convert available workforce and estate into reliable patient
access. Clinic utilisation has fallen to around 50%, which is a significant clinical
effectiveness concern because it indicates a mismatch between need, capacity,
staffing resilience and appointment use. 
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There is evidence of active mitigation. A locum dental bank proposal is progressing,
professional oversight has been strengthened, service-model reviews are underway in
relation to orthodontics, Tiree and mobile dental provision, and a shared capital bid is
progressing for a towable mobile dental trailer. These are appropriate responses, but
the service will remain amber until workforce contingency, capacity modelling,
utilisation reporting and locality-level waiting-time monitoring are sufficiently mature to
demonstrate improved access and outcomes.
3.4 Forensic Medicine 
Forensic Medicine has historically been delivered through business-to-business
contracts with General Practitioners with specialist training. A comprehensive service
review in 25/26 identified clinical risks relating to documentation, variation from national
target operating models, training, oversight and auditability. In response, a targeted
contract review and service redesign programme is underway. 
The transition of Cowal custody healthcare from contracted provision to a managed
service model provides positive assurance. The model improves clinical oversight,
reporting capability, financial efficiency and consistency of governance. Refresher
training in clinical practice and Police Adastra has been delivered to Cowal providers,
with further training planned across the HSCP. Service specifications are being
refreshed in line with Police Scotland changes and national expectations. 
The critical assurance gap remains documentation and audit readiness. Variation in
Police Adastra use creates risk to clinical record quality, inspection compliance, audit
capability and Board assurance. The direction of travel is positive, with implementation
and standardisation work planned, but clinical effectiveness should remain amber until
documentation standards, audit processes, training compliance and system use are
embedded across all custody healthcare areas. 
3.5 Current Assurance 
Assurance for Standard 3 is amber for access equity, outcome measures and
workforce-sensitive services. There is clear evidence of clinical review, service
redesign, professional oversight, vaccination governance, enhanced service review
and forensic medicine improvement, with the portfolio responding to gaps through
alternative delivery models. 
Clinical effectiveness is actively managed, but evidence remains inconsistent across
services and localities. Priorities include outcome measures, access equity, patient
experience, locality variation, dental workforce resilience, LARC sustainability, CTAC
reporting, vaccination uptake and forensic medicine documentation and audit
readiness.
3.6 Areas for Growth and Next Steps 
Area for growth Why this matters Next step RAG
Clinical
effectiveness
measures
Current assurance is often based
on activity, service redesign and
professional judgement rather
than consistent outcome, access
and patient experience
measures.
Define core clinical effectiveness
measures for priority services,
including access, uptake,
outcomes, patient experience and
escalation triggers.
Amber
LARC access and
sustainability
Withdrawal from enhanced
service contracts has created a
local access gap in Cowal and
increased travel burden for
patients.
Implement and evaluate the Cowal
managed service model, including
demand, capacity, clinical
governance, uptake, patient
Amber
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feedback and sustainability
measures.
Public Dental
Services workforce
and utilisation
Workforce fragility, absence and
clinic cancellations reduce
access, continuity and clinical
capacity, with particular impact
on remote and island
communities.
Progress the locum dental bank,
strengthen capacity modelling,
monitor utilisation and waiting
times, and agree escalation
thresholds for access risk.
Amber
Mobile dental and
island access
Loss of the mobile dental unit
has reduced local NHS dental
access for remote and island
communities and contributes to
inequity.
Progress the shared capital bid for
a towable mobile dental trailer and
define service model, staffing,
governance and utilisation
measures.
Amber
Vaccination uptake
and variation
Declining or variable uptake may
affect population health
outcomes and widen inequalities
if not actively monitored and
addressed.
Continue uptake monitoring
through vaccination oversight
groups and develop targeted
improvement activity where age-
point, locality or population
variation is identified.
Amber
CTAC clinical
effectiveness
reporting
Access, waiting time, demand,
capacity and outcome data are
not yet consistently captured
across all sites.
Use the CTAC service
specification review to define
effectiveness measures and
routine reporting for access,
activity, outcomes and escalation.
Amber
Forensic Medicine
documentation and
audit readiness
Variation in clinical records and
system use limits assurance on
documentation quality, inspection
readiness and clinical audit
capability.
Complete Police Adastra
implementation, standardise
documentation and audit
processes, and monitor training
compliance across custody
healthcare areas.
Amber
Enhanced service
contract review
Enhanced services support care
closer to home, but effectiveness
is not always evidenced through
consistent access, uptake,
quality and outcome measures.
Ensure future enhanced service
reviews include clinical
effectiveness indicators, equity
analysis, patient impact and post-
implementation review.
Amber 
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Standard 4: Clinical Safety and Risk Management 
Healthcare Improvement Scotland defines clinical safety and risk management as
systems to identify, assess, manage, learn from and escalate risks, adverse events,
complaints and safety concerns. In Primary Care, assurance is drawn from multiple
routes, including Datix, complaints, SAERs, risk registers, IPC audits, service
governance meetings, contractor assurance, programme boards and professional
escalation. The key question is whether these processes operate as one coherent
system that captures harm, embeds learning, reduces recurrence and escalates risk
proportionately. 
Current safety and risk arrangements are established and functioning, with strengths in
complaints handling, adverse event review, IPC audit, QPS reporting, risk register
review, dental governance, SMT oversight, clinical governance and emerging out-of-
hours governance. However, learning and escalation are not yet consistently visible
across the portfolio. Risks are known and managed, but thematic learning, overdue risk
reviews, exception reporting and evidence of closed-loop improvement need further
strengthening. 
HIS Standard 4
requirement
Current assurance RAG Action required
Identify, assess and
manage clinical
safety risks across
services.
Risks are captured through the Primary
Care risk register, local team review,
SMT oversight, Datix, complaints, SAER
processes, QPS reporting and service-
specific governance routes. However,
some risk reviews have expired due to
staff absence, and risk maturity varies
between service areas.
Amber Complete overdue risk
reviews, strengthen
routine review discipline
and confirm escalation
thresholds for high-risk
services.
Learn from
complaints, adverse
events, incidents
and near misses.
Complaints, Datix and SAER processes
are active. Examples of learning include
changes to 2C dispensing storage
arrangements, follow-up arrangements
for patients affected by locum provision,
and dental extraction risk counselling.
However, learning trackers are still
developing and thematic learning is not
consistently visible.
Amber Implement portfolio-wide
learning trackers that
record theme, action,
owner, timescale,
outcome, evidence of
improvement and route for
shared learning.
Escalate safety
concerns through
appropriate clinical
and governance
routes.
Escalation routes exist through local
management, Primary Care SMT, QPS,
clinical governance, SLT and Board
routes where required. Out-of-hours
governance arrangements are being
developed through a dedicated
operational group aligned to Pan-
Highland assurance.
Amber Implement standardised
exception reporting and
ensure escalation routes
are documented,
understood and used
consistently across directly
managed, contracted and
B2B services.
Maintain safe care
environments
through infection
prevention and
control
arrangements.
Routine SICP audits are undertaken
across services, with an annual audit
schedule and monthly audit activity in
line with national requirements. Findings
and actions are followed up locally.
Green Formalise IPC reporting
metrics through clinical
and care governance so
that trends, exceptions
and actions are visible at
portfolio level.
Ensure significant
adverse events are
reviewed and
learning is shared.
Two SAERs are ongoing in relation to
primary care provision and are being
managed in line with relevant A&B
policies and frameworks. Learning will
be shared through clusters and clinical
governance once reviews are complete.
Amber Track SAER actions
through governance routes
and ensure learning is
shared across clusters,
services and professional
groups once reviews are
concluded. 
4.1 Complaints 
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Complaints provide an important safety and experience signal. Average monthly
complaints are around two per service, or three for 2C practices. Volumes rose in
February and March 2026, mainly linked to Skipness Satellite Surgery service
changes, before returning to usual levels in April. The earlier increase should still be
treated as an early warning on service change, communication and community
confidence. It should be noted that the data presented below is reflective of the 25/26
data set, the process of pulling the information required manual extraction, further
repeat of the exercise has been limited due to the transition to Healthcare Guardian
although the active complaints position continues to be kept under review at
operational level. 
Primary Care performance broadly aligns with 2024/25 national complaints metrics.
Upheld complaints can reflect transparent scrutiny and learning, but the higher upheld
ratio in dental services needs further review. Only 8% of dental complaints were not
upheld, with another 8% still open, which may indicate responsiveness or recurring
issues in delivery, communication, expectations or documentation, active monitoring
and oversight is ongoing to track any notable trends and ensure a proportionate
response. 
Two Primary Care SAERs are ongoing and being managed under Argyll and Bute
policies. Learning should be shared beyond the service or locality involved, through
clusters, clinical governance groups and relevant professional groups once reviews are
complete. 
Table 4: Primary Care 12 Month Complaint Position 
Table 5: National Complaints Performance 24/25 
Complaint themes mainly relate to resolution times, communication, quality of care,
and attitude or manner. These reflect the interface between operational pressure,
patient expectations, access constraints and communication quality. Remedial action is
taken case by case, with staff supported to reflect on learning and improvement.
Complaint Type Fully Upheld (%) Partially Upheld (%)
S1 39.6 13.8
S2 21.4 40.3
S2 escalated 27.8 32.2
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Complaints learning is informing operational change, including safer 2C dispensing
storage, follow-up for patients affected by locum provision, movement toward a salaried
GP workforce, and amended dental extraction risk counselling. These examples show
learning is acted on, but a portfolio-wide learning tracker is needed to evidence
completion, embedding and sustained impact.
4.2 Risk Management 
The Primary Care risk register is the main portfolio route for recording and monitoring
clinical, operational and service risks. It is reviewed bi-monthly at Primary Care SMT,
with additional local team review and new risks added as identified. This provides
visibility of risk and an established route for oversight and escalation. The programme
of governance review has highlighted that while most areas hold their own local risk
registers, not all operational services do, which is a gap. This is being addressed as a
matter of urgency. 
A risk register alone is not sufficient assurance. Key tests are timely review, current
mitigations, completed actions, reassessed residual risk and escalation when risk
appetite is exceeded. Two portfolio areas currently have expired reviews due to staff
absence, creating an assurance gap until risks are updated and review discipline is
restored which is being progressed actively via interim cover arrangements. 
Cross-portfolio risks include dental workforce fragility, LARC access, forensic
documentation and Adastra implementation, CTAC access data, GPIT migration,
engagement and service-change communication. These risks are known and
mitigated, but require consistent escalation triggers and exception reporting so service-
level pressures are escalated when wider action is needed.
4.3 Infection Prevention and Control 
Infection prevention and control assurance is supported through routine audit of
Standard Infection Control Precautions across all Primary Care services. There is a
defined annual audit schedule, with specific SICPs audited monthly in line with national
requirements. Audit findings and actions are monitored and followed up where
required, providing assurance of safe care environments. 
This is a relative area of strength within Standard 4 because there is an established
audit cycle and local follow-up. The area for growth is the visibility of this assurance at
portfolio level with one 2c Practice having failed the most recent audit. An improvement
plan with associated actions is in place to achieve the required standard in coming
months with oversight in place via our professional nursing structure. 
Formal reporting metrics through clinical and care governance would strengthen the
ability to identify trends, outliers, recurring actions and service-level variation. This
would also support the wider Standard 2 requirement for a more integrated quality
management system. Adjustments are being made to the standard Primary Care
Clinical and Care Governance agenda and paper templates to maximise reporting
visibility which will be concluded within three months. 
4.4 Clinical and Care Governance 
All portfolio services have defined clinical governance reporting and escalation routes.
General Practice, Dental Services, CTAC and Forensic Medicine quality and risk are
overseen through Primary Care governance structures, with escalation to SLT and
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Board routes where required. As Sexual Health develops, its clinical scrutiny and
oversight route will be explicitly confirmed to ensure consistent assurance. 
Out-of-hours governance is being strengthened through a dedicated Operational Group
aligned to the Pan-Highland OOH Urgent and Unscheduled Care Assurance
Framework. The group will oversee workforce capacity, rota performance, service
pressures, risks and contractor engagement, with clearer escalation and exception
reporting. This is important given contractor dependence, remote and rural fragility, and
service continuity risks. Operationally, it should be noted that GP OOH does not sit
within the primary care portfolio however reporting metrics are being routed via our
governance for assurance and oversight, this is a developing picture and processes
and reporting structures need to be strengthened through iterative improvement cycles.  
4.5 Current Assurance 
Assurance for Standard 4 is amber. Safety and risk arrangements are established
through complaints handling, adverse event review, Datix, QPS reporting, IPC audit,
clinical governance, SMT oversight, dental governance and emerging out-of-hours
governance. These controls show that risks are known and actively managed. 
The amber rating reflects system maturity, not absence of control. Further work is
needed on risk review discipline, learning trackers, thematic analysis, IPC trend
visibility, SAER action tracking, exception reporting and consistent escalation across all
delivery models. Standard 4 is functioning but needs stronger evidence of closed-loop
learning and risk escalation for full assurance.
4.6 Areas for Growth and Next Steps 
Area for growth Why this matters Next step RAG
Risk register
review discipline
Expired risk reviews reduce
confidence that scores, mitigations
and escalation routes reflect the
current position.
Complete overdue reviews, confirm
risk owners and introduce routine
exception reporting for overdue or
high-scoring risks.
Amber
Portfolio-wide
learning tracker
Complaints, Datix and SAER
learning is active but not
consistently visible, tracked or
evidenced across the full portfolio.
Develop a learning tracker
recording theme, action, owner,
timescale, outcome, evidence of
improvement and sharing route.
Amber
Thematic
complaints
analysis
Complaint themes provide
important signals on
communication, access, quality of
care and service-change impact.
Introduce quarterly thematic review
of complaints, including upheld
dental complaints, Skipness
service-change feedback and 2C
locum-related concerns.
Amber
Significant
adverse event
review learning
SAER learning must be shared
beyond the immediate service to
reduce recurrence and support
portfolio-wide improvement.
Track SAER action plans through
governance routes and share
learning through clusters,
professional groups and clinical
governance forums.
Amber
Infection
prevention and
control reporting
Local audit activity is established,
but portfolio-level trend, exception
and action visibility is limited.
Develop formal IPC reporting
metrics for clinical and care
governance, including trends,
exceptions, completed actions and
unresolved risks.
Green
Out-of-hours
exception
reporting
OOH services rely on business-to-
business arrangements and
require clear escalation for rota,
workforce and service continuity
pressures.
Establish the OOH Operational
Group, agree standardised
exception reporting and confirm
escalation routes into Pan-Highland
assurance structures.
Amber
Sexual Health
governance
route
Service redesign and interim
provision require explicit clinical
scrutiny, escalation and assurance
arrangements.
Confirm the governance route for
Sexual Health developments,
including SOP review, clinical
oversight, risk escalation and
patient feedback.
Amber
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Closed-loop
improvement
evidence
Actions are being taken, but
evidence of completion, impact
and sustained improvement is not
consistently captured.
Require action logs for complaints,
incidents, audits and risk actions to
include completion evidence and
post-action review.
Amber 
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Standard 5: Education and Training 
Healthcare Improvement Scotland defines education and training as ensuring staff
have the knowledge, skills, competence, supervision and development support needed
for safe, effective, person-centred care. In Primary Care, this applies across a mixed
workforce, including directly employed teams, Board-managed practice staff, Public
Dental Service staff, GPs, appraisers, trainees, advanced practitioners, contracted
providers and business-to-business models. The key assurance question is whether
learning needs are identified, recorded, delivered, monitored and linked to safe service
delivery, governance and workforce sustainability. 
The current position provides partial assurance. Strengths include protected learning, 
BASICS training, advanced practice assurance, Public Dental Service student training
and SMT workforce governance reporting. However, statutory mandatory training and
PDP compliance remain below the level expected for a mature system and there is a
recognised risk in relation to GP appraisal capacity. There has been a reduction in
mandatory training compliance following the Once for Scotland module refresh, which
is understandable, but recovery plans, trajectories and exception reporting remain
active to ensure full assurance can be achieved. Standard 5 should therefore remain
amber. 
HIS Standard 5
requirement
Current assurance RAG Action required
Ensure staff have the
knowledge, skills and
competence required
to deliver safe,
effective and person-
centred care.
Protected learning, BASICS training,
advanced practice assurance, PGD
training, professional oversight and
local service-specific development
activity provide evidence that learning
is active across the portfolio. However,
competence assurance is not yet
consistently recorded across all teams
and service models.
Amber Develop a portfolio-wide
training and competence
matrix for directly managed
services, including role-
specific requirements,
professional oversight and
review frequency.
Identify and meet
learning and
development needs
through appraisal,
supervision and PDP
processes.
PDP compliance is comparatively
strong within the HSCP context but
remains below desired levels, with
Primary Care reported at 30.6% and
Dental at 59.3%. This limits assurance
that learning needs are consistently
identified and followed up.
Amber Set a PDP recovery
trajectory, require exception
reporting through SMT and
ensure line managers use
PDPs to identify
development, wellbeing
and service-risk themes.
Monitor statutory
mandatory training
compliance.
Statutory mandatory compliance
reduced following the Once for
Scotland nine-module refresh. Current
compliance is 43% for Primary Care
and 66% for Dental, compared with
previous higher levels.
Amber Agree a recovery plan for
statutory mandatory
training, including target
dates, monthly monitoring,
escalation for non-
compliance and support for
teams affected by workload
pressure.
Support clinical and
professional
development across
mixed workforce
models.
GP protected learning funding, GP
appraisal capacity, NES dental student
training and advanced practice
assurance are established. However,
governance differs across
independent contractor, directly
managed and training-placement
models.
Amber Map professional
development routes across
GMS, 2C, CTAC,
Vaccinations, Dental,
Sexual Health and Forensic
Medicine, identifying gaps
in oversight and escalation.
Ensure education
and training supports
service resilience
and safe delivery.
BASICS training has strengthened
emergency response capability in 2C
practices, and advanced practice
assurance supports safe role scope.
However, workforce fragility in small
teams means training gaps can
directly affect service continuity.
Amber Link training risks to
workforce resilience
planning, cross-cover
arrangements and the
Primary Care risk register
where competence gaps
affect service delivery. 
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5.1 Mandatory Compliance – Primary Care 
Primary Care is showing improvement in mandatory training and appraisal compliance.
Since January 2026, focused work has supported staff and leaders to complete these
core governance requirements. While meaningful appraisal and staff development
should be embedded in day-to-day practice, the increase in formal compliance is
encouraging. Local action plans are in place to sustain progress and meet the
Executive Team’s March 2026 compliance trajectory through to March 2027. 
Primary Care Statutory Mandatory Compliance (June 2026) 
Primary Care Appraisal Compliance (June 2026) 
5.2 General Practice 
Continuing Professional Development within GMS practices is supported through a
designated protected learning fund, with practices guided to use available resources
regularly. This provides an important development route within the independent
contractor model and supports clinical learning, peer discussion and quality
improvement. However, because allocation and prioritisation of funding are determined
by individual practices, the HSCP has limited direct control over the consistency of
learning uptake, themes or impact. The assurance opportunity is to strengthen the link
between protected learning, cluster priorities, annual practice review, contract
assurance and identified governance risks. 
The HSCP employs several GP Appraisers with an allocated sessional commitment to
deliver 132 appraisals per year. There are currently 142 GPs registered on the
performers list who require appraisal, meaning that 10 are currently unallocated.
Additional appraisal sessions are provided on an ad hoc basis, although there is a
noted uncontrolled spend attached. This indicates a manageable but important
capacity gap. Appraisal is a professional governance requirement and should be
treated as a core assurance function rather than an optional development activity. A
more controlled plan is required to match appraisal demand, capacity and cost. 
Educational initiatives are advancing across Board-managed practices and the wider
multidisciplinary workforce. Recent BASICS training within 2C practices has
strengthened capacity to respond to emergencies and supports safe delivery in remote
and rural localities. The Isle of Gigha will operate as a 24/7 BASICS Fixed Resource
Model, while Muasdale and Southend has been operating as a fixed resource site
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during core operating hours from 1 April. This is a clear strength because it links
training directly to service resilience and urgent response capability. The critical
requirement is to ensure that competence, refresher training, equipment readiness and
operational learning are monitored through the relevant governance routes. 
5.3 CTAC and Vaccinations 
A risk relating to nursing management structure has been identified, prompting
corrective measures to formally align employed practice nurses with the CTAC and
Vaccinations professional nursing framework. Organisational change discussions will
consider this risk and should establish profession-specific line management structures
that secure appropriate CPD, leadership and oversight of staff training. This is an
important governance issue because unclear professional lines can weaken
competence assurance, supervision, role development and escalation. 
Targeted work has been undertaken to ensure Primary Care Advanced Nurse
Practitioners are professionally compliant and competent across the four pillars of
advanced practice. This includes assurance of postgraduate education, role scope and
clinical competence, supported by appropriate governance and professional oversight
arrangements. This provides positive assurance for advanced practice roles, but the
same level of explicit competence mapping should be extended, proportionately, to
other clinical roles where service delivery depends on defined skills, authorisation or
clinical protocols. 
Vaccination training and competence are supported through programme-specific
requirements, PGDs, audit activity, infection prevention and control processes, and
national programme guidance. This provides a strong assurance route for safe
vaccination delivery. The area for growth is to ensure that evidence of training,
authorisation, refresher requirements and audit learning is consistently visible within
the wider Primary Care governance framework rather than held only within programme-
level arrangements. 
5.4 Dental 
Dental workforce metrics are monitored separately and show partial recovery.
Appraisal compliance has improved to 50%, but remains below the executive trajectory
of 60% by September 2026, with further improvement required to reach the subsequent
milestones of 80% by December 2026 and 95% by March 2027. 
Statutory mandatory training compliance is also showing recovery following the
reduction associated with the Once for Scotland module refresh, but the position
remains an assurance gap until sustained improvement is evidenced. The key issue is
not simply compliance performance, but whether local action plans, protected learning
time, monitoring and escalation are sufficiently robust to deliver the agreed trajectory
and ensure staff have the required development, competence and governance support. 
Dental Appraisal Compliance
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Dental Statutory Mandatory Compliance 
Dental education is supported in collaboration with NHS Education for Scotland. A NES
visit took place on 30 April 2026 to review the final year dental student Outreach
Training Programme, delivered with the University of Glasgow Dental Hospital and
School. The reviewers provided positive external assurance. No recommendations
were raised, and feedback highlighted the safe working environment, clinical
governance arrangements and student experience. This indicates that the training
environment is well supported and provides an important contribution to workforce
development. 
The assessment should, however, be balanced against wider service pressures. The
Public Dental Service remains affected by workforce fragility, reduced clinical capacity
and access pressures, which may affect supervision capacity and the sustainability of
training placements if not actively managed. Continued partnership with NES and the
University should therefore focus not only on enhancing student experience and
recruiting unregistered patients, but also on ensuring that training activity is aligned
with workforce planning, clinic utilisation, patient access and service resilience. 
5.5 Current Assurance 
Assurance for Standard 5 is proposed as amber. There is evidence of active education
and training arrangements across the portfolio, including protected learning, GP
appraisal capacity, BASICS training, advanced practice assurance, vaccination training
and audit, and positive external feedback from the dental student Outreach Training
Programme. These arrangements demonstrate that education and training are valued
and are supporting safe service delivery in several areas. 
The amber rating reflects the inconsistency of evidence and compliance rather than the
absence of training. Statutory mandatory and PDP compliance remain below desired
levels, training and competence evidence is not consistently visible across all directly
managed services, professional development routes vary across mixed delivery
models, and workforce fragility increases the impact of training gaps. The executive
assessment is that Standard 5 is functioning but requires stronger recovery planning,
competence mapping, exception reporting and linkage between training risk and
service resilience.
5.6 Areas for Growth and Next Steps
Area for growth Why this matters Next step RAG
Statutory
mandatory
training recovery
Current compliance is below
desired levels following the Once
for Scotland module refresh,
creating an assurance gap for safe
and compliant service delivery.
Agree a recovery plan with targets,
monthly monitoring, team-level
exception reporting and escalation
for persistent non-compliance.
Amber
PDP compliance
and learning
needs
PDP completion remains below
desired levels, limiting assurance
that learning, wellbeing and
Set a PDP improvement trajectory
and require managers to report
completion, themes, barriers and
Amber
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development needs are
consistently identified and followed
up.
actions through SMT workforce
governance.
Portfolio-wide
competence
matrix
Training and competence
requirements vary across CTAC,
Vaccinations, 2C, Dental, Sexual
Health and Forensic Medicine, and
are not yet consistently visible.
Develop a role-based competence
matrix covering statutory,
mandatory, clinical, professional
and service-specific requirements.
Amber
GP appraisal
capacity and
cost control
Appraisal demand exceeds
allocated capacity, creating a small
but important gap and uncontrolled
ad hoc spend.
Review GP appraisal demand,
sessional capacity, allocation
process and financial controls, with
a clear plan to cover unallocated
appraisals.
Amber
Nursing
professional
governance and
CPD
Unclear nursing management and
professional structures can
weaken supervision, training
oversight, role development and
escalation.
Use organisational change work to
confirm professional line
management, CPD oversight and
training escalation routes for
practice nurses, CTAC and
Vaccinations.
Amber
Training linked to
service
resilience
In small specialist teams, training
gaps can directly affect continuity,
cross-cover and patient access.
Link training risks to workforce
resilience plans, the risk register
and cross-cover arrangements for
high-risk services.
Amber
Vaccination
training visibility
Vaccination training, PGD
authorisation and audit
arrangements are active but may
not be visible within the wider
Primary Care governance
framework.
Report programme-level training,
PGD audit and learning through
Primary Care governance routes at
agreed intervals.
Green
Dental training
sustainability
Dental student training is
externally well assured, but
workforce fragility may affect
supervision capacity and service
access.
Link dental training governance to
workforce planning, recruitment,
utilisation and access monitoring.
Green 
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Standard 6: Service User and Patient Involvement
Healthcare Improvement Scotland defines service user and patient involvement as
systems that meaningfully involve people, carers and communities in designing,
delivering, reviewing and improving clinical services. In Primary Care, this is particularly
important because local service changes can significantly affect access, confidence,
travel, continuity and perceived equity, especially in remote, rural and island
communities. The key assurance question is whether involvement is early,
proportionate, inclusive, linked to equality and human rights duties, and used to shape
decisions before implementation. 
The current position provides partial assurance. Strengths include targeted Jura
engagement, Sexual Health scoping, emerging Patient Participation Group
arrangements, complaints learning and use of Healthcare Improvement Scotland
guidance. However, engagement is not yet consistently embedded early in service-
change design. Recent engagement in Skipness demonstrates that, even where
decisions are justified by safety or workforce issues, timing, framing and
communication can materially affect community confidence and perceived legitimacy.
Standard 6 should therefore remain amber until a clearer engagement framework,
earlier impact assessment and stronger feedback loops are embedded. 
HIS Standard 6
requirement
Current assurance RAG Action required
Involve people and
communities in the
design, delivery and
improvement of
services.
Engagement has informed the Jura out-
of-hours model, Sexual Health scoping,
Skipness discussions and emerging PPG
arrangements. However, engagement is
not yet consistently embedded at the
earliest stage of service-change planning.
Amber Develop a Primary Care
engagement framework setting
out when and how people, carers
and communities should be
involved in service design and
review.
Ensure engagement is
inclusive and
proportionate to the
impact of service
change.
Public Health support has been secured
for Sexual Health scoping to include
young people, and Jura engagement
reflected remote island need. However,
service-change engagement has varied
across localities and proposals.
Amber Use proportionate engagement
plans for all material service
changes, including affected
groups, equality impacts, island
impacts and communication
routes.
Use patient experience,
complaints and
feedback to inform
improvement.
Complaints, community feedback and
engagement events are used to inform
service responses, including Skipness
and 2C service-change learning.
However, learning is not yet consistently
captured in a portfolio-wide tracker.
Amber Link engagement feedback and
complaints themes to the
proposed learning tracker and
report actions through clinical
governance routes.
Ensure children, young
people and seldom-
heard groups are
considered where
services affect them.
Sexual Health scoping includes Public
Health support and funding to involve
young people, aligning with UNCRC
expectations. This is a clear strength, but
it should become routine where service
changes affect children or young people.
Green Embed UNCRC, equality, island
and Fairer Scotland
considerations into engagement
planning and Integrated Impact
Assessment processes.
Provide clear
communication and
feedback to
communities about
decisions and changes.
Communications have been developed
for Jura, Skipness and service-specific
changes, but the Skipness experience
shows that timing and perceived
responsiveness can affect community
trust.
Amber Develop a standard
communication and feedback
approach for service change,
including “you said, we did / we
cannot because” feedback and
escalation for community
concern. 
6.1 Community Engagement and Service Change 
Meaningful community involvement is essential to quality, equity and clinical
governance. Primary Care uses complaints, lived experience, local engagement and
service-specific consultation to inform improvement, but engagement is not yet
consistently embedded at the start of service-change planning. 
On Jura, engagement shaped the revised GP Out-of-Hours model launched on 1 April
2026, informing access, pathways and communications. This is a strong example of
proportionate, locality-specific engagement supporting safe and sustainable service
redesign.
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Sexual Health scoping in Cowal and Helensburgh includes Public Health support and
funding to involve young people, helping align future service design with UNCRC
expectations and local need. 
Earlier engagement with some 2C practice communities may have reduced concern
around potential changes and mergers. The key learning is that service changes
affecting access, continuity or local identity should include an early engagement plan,
even where the operational rationale is clear.
6.2 Skipness and Patient Participation Group Development 
Skipness is the most significant recent engagement issue. The visiting clinic was
paused immediately due to safety concerns, to meet employer responsibilities and
ensure safe working arrangements. Although the decision was justified, the sudden
pause caused significant community concern and highlighted the need for clear,
compassionate and timely communication when local access changes. 
Discussions with Healthcare Improvement Scotland and local councillors are ongoing,
and a Skipness community engagement event has taken place. The learning is wider
than one locality: service changes made for safety, workforce or sustainability reasons
can still affect trust if communities cannot clearly understand the rationale, describe
impact and influence future options. 
The proposed Patient Participation Group for Skipness and the wider Carradale/Kintyre
Medical Group population is a positive step from reactive engagement to continuous
dialogue, and one which requires further thought to scale across wider areas. Its
success will depend on clear remit, realistic expectations, inclusive membership,
transparent communication and a route for feedback to influence planning and
governance. 
6.3 Current Assurance 
Assurance for Standard 6 is proposed as amber. There is evidence of meaningful
engagement in specific areas, including Jura out-of-hours redesign, Sexual Health
scoping, Skipness engagement, complaints learning and emerging Patient Participation
Group arrangements. These examples show that the portfolio recognises the
importance of community voice and is able to adapt engagement approaches to local
circumstances. 
The amber rating reflects inconsistency and reactive rather than proactive plans, rather
than absence of involvement. Engagement is not yet systematically embedded in all
service-change proposals, feedback loops are not consistently documented, Integrated
Impact Assessments are not yet routinely linked to engagement planning, and learning
from Skipness needs to be translated into a standard approach for future service
changes. The executive assessment is that Standard 6 is active but requires a more
consistent, earlier and better-evidenced engagement framework to provide full
assurance.
6.4 Areas for Growth and Next Steps
Area for growth Why this matters Next step RAG
Primary Care
engagement
framework
Engagement is currently
evident in some service
changes but is not yet
standardised across the
portfolio.
Develop a Primary Care engagement
framework setting out engagement
triggers, impact levels, approval routes,
communication expectations and
governance reporting.
Amber
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Early
engagement in
service change
Communities are more
likely to understand and
support change when they
are involved before
decisions are perceived as
fixed.
Require every material service-change
proposal to include an early engagement
plan before implementation, unless
immediate safety action is required.
Amber
Skipness
learning
The Skipness experience
highlights the impact of
immediate service change
on community trust,
confidence and perceived
access equity.
Complete a lessons-learned review and
incorporate findings into the engagement
framework, communication templates and
service-change checklist.
Amber
Patient
Participation
Group
development
PPG arrangements can
support continuous dialogue
but require clarity of remit
and governance
connection.
Establish the Skipness/Carradale/Kintyre
PPG with terms of reference, inclusive
membership, agreed communication
routes and reporting links to service
planning.
Amber
Integrated
Impact
Assessment
alignment
Equality, island, socio-
economic and children’s
rights considerations need
to be embedded in
engagement planning.
Align engagement plans with Integrated
Impact Assessment requirements,
including UNCRC, island impacts, Fairer
Scotland duties and protected
characteristics.
Amber
Young people’s
involvement in
Sexual Health
Sexual Health service
design affects young people
and must reflect rights-
based, accessible and
confidential care
expectations.
Continue Public Health-supported
engagement with young people and use
findings to inform the Sexual Health
service model and SOP review.
Green
Feedback loops
and “you said,
we did” reporting
Communities need to see
how feedback has been
considered, including where
requests cannot be met.
Introduce a standard feedback process for
service-change engagement, including
“you said, we did / we cannot because”
summaries.
Amber
Portfolio-wide
learning from
engagement
Engagement learning is
valuable but not yet
consistently captured or
shared across services.
Add engagement themes and actions to
the portfolio learning tracker and report
through clinical governance and SMT
routes.
Amber 
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Standard 7: Data and Information  
HIS defines data and information as the systems supporting safe, effective, person-
centred care through accurate records, secure governance, reliable systems and
meaningful reporting. In Primary Care, multiple clinical systems are used across
services, so assurance must cover both safe information handling and whether data is
accurate, accessible, comparable and useful for care, improvement, risk management
and executive assurance. 
There is reasonable assurance on information governance, with DPIAs, information
asset registers, retention, archiving and GPIT oversight in place. However, data
maturity is uneven: controls are stronger than routine use of data for quality, access,
outcomes, equity and trend reporting. Standard 7 is green for core information
governance, with amber direction of travel for data quality, interoperability and
assurance reporting. 
HIS Standard 7
requirement
Current assurance RAG Action required
Maintain accurate,
accessible and
secure clinical
records.
Clinical systems are in place across
services and DPIAs, information asset
registers, retention and archiving
arrangements support safe
management of records. However,
system variation creates
inconsistency in record visibility, data
extraction and reporting.
Green Maintain DPIAs, information
asset registers and retention
processes, and strengthen
standardisation of record-
keeping expectations across
service areas.
Use data and
information to
support safe,
effective and
person-centred
care.
Data is used through IPMF,
vaccination uptake, complaints,
adverse events, GMS returns,
workforce metrics, audit and
programme reporting. However, data
is not yet consistently available across
all services to evidence access,
outcomes, equity or improvement over
time.
Amber Define minimum datasets and
dashboard requirements for
priority services, with focus on
access, outcomes, equity,
demand, capacity, learning
and improvement.
Ensure clinical
systems are
reliable and
support continuity
of care.
GPIT migration to nationally hosted
Vision is being managed through NHS
Highland eHealth and GPIT
Programme Board oversight. Rollout
was paused following concerns about
degraded performance and loss of
access, then resumed with improved
user experience.
Amber Continue GPIT migration
oversight, ensure issues are
escalated through Digital
Governance and Programme
Board routes, and capture
service impact, downtime and
learning.
Support
appropriate
information sharing
across services
and governance
routes.
Information governance arrangements
are in place across managed and
contracted services, but data sharing
remains complex across independent
contractor, directly managed and
business-to-business models.
Amber Clarify information-sharing
expectations across service
models and ensure SOPs,
service specifications and
contracts include
proportionate data and
reporting requirements.
Use data to
support assurance,
improvement and
decision-making.
Data supports some assurance
reporting, but the paper identifies
repeated gaps in CTAC access data,
dental utilisation and waiting times,
forensic Adastra use, clinical
effectiveness metrics and
engagement learning.
Amber Develop a Primary Care data
improvement plan linked to
the Quality Management
System, including data
definitions, reporting
frequency, owners and
escalation triggers. 
7.1 Information Governance and Clinical Systems 
Several clinical record systems are used across the Primary Care portfolio. Data
Protection Impact Assessments are in place for clinical systems within managed and
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contracted services. Information asset registers, retention arrangements and archiving
processes are in place in line with local policies. These arrangements support safe and
appropriate storage, sharing and use of personal data and provide reasonable
assurance that the core information governance infrastructure is established. 
The critical issue is that safe data handling does not, by itself, provide assurance that
data is sufficiently usable for clinical governance. Across the paper, several standards
identify data gaps that affect assurance, including CTAC access and waiting-time
reporting, dental utilisation and locality-level waiting-time data, forensic medicine
documentation and audit readiness, clinical effectiveness outcome measures, training
compliance recovery trajectories, and engagement learning. These gaps are not simply
technical issues; they affect the ability of the system to identify variation, evidence
impact, monitor improvement and escalate risk in a timely way. 
A national reprovisioning exercise is underway across General Practice, with practices
migrating to a nationally hosted Vision environment. NHS Highland eHealth is
facilitating the migrations. Concerns about degraded performance and loss of access
led to a temporary pause in rollout in February. The pause was agreed by the NHS
Highland GPIT Programme Board following consultation with National Services
Scotland, suppliers and local GP groups. The migration has subsequently resumed
with improved user experience reported. Ongoing escalation will be provided to the
Digital Governance Board and the Programme Board as required. 
This is a positive example of system risk being identified, escalated and managed.
However, GPIT migration remains an important assurance issue because clinical
system performance directly affects continuity of care, data quality, prescribing, record
access, workload and user confidence. Future reporting should therefore capture not
only migration progress, but also service impact, downtime, issue resolution, practice
experience and learning for future system changes. 
7.2 Data Quality, Reporting and Assurance 
Data is used across the portfolio for performance management, workforce governance,
risk management, complaints, adverse events, vaccination uptake, audit activity,
annual GMS assurance returns, programme reporting and service-specific review. This
provides a broad evidence base for governance and assurance. However, the data is
currently fragmented across multiple systems and service models, and it is not yet
consistently structured around common definitions, reporting cycles or outcome
measures. 
The most significant assurance limitation is that the portfolio cannot yet consistently
demonstrate trends over time across all priority services. This limits the ability to
identify deterioration early, compare variation across localities, quantify the impact of
service redesign, evidence improvement and provide concise executive assurance.
The issue is particularly visible in CTAC access reporting, dental capacity and
utilisation, forensic medicine documentation and audit readiness, Sexual Health
demand modelling and clinical effectiveness measures. 
A Primary Care data improvement plan should therefore be developed as part of the
wider quality management system. This should define minimum datasets, common
definitions, dashboard requirements, reporting frequency, owners, data sources,
assurance routes and escalation triggers. The aim should be proportionate: not every
service requires the same level of data collection, but high-risk or high-impact services
should have clear, timely and reliable information to support decision-making.
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7.3 Current Assurance
Assurance for Standard 7 is proposed as green for core information governance, with
an amber direction of travel for data maturity and assurance reporting. Strengths
include established DPIAs, information asset registers, retention arrangements,
archiving processes, GPIT Programme Board oversight, Digital Governance Board
escalation and evidence that system risks are identified and acted upon. 
The green assurance position reflects the presence of core controls for safe and lawful
information management. The amber direction of travel reflects the fact that data is not
yet consistently used to support whole-system assurance, improvement and decision-
making across all Primary Care services. The executive assessment is that Standard 7
is compliant and controlled from an information governance perspective, but requires a
more systematic data improvement approach to support mature clinical governance.
7.4 Areas for Growth and Next Steps
Area for growth Why this matters Next step RAG
Primary Care
data
improvement
plan
Data gaps are recurring across
Standards 2–6 and limit
assurance on access,
outcomes, equity, learning and
improvement.
Develop a Primary Care data
improvement plan linked to the Quality
Management System and governance
assurance programme.
Amber
Minimum
datasets and
definitions
Inconsistent definitions make it
difficult to compare services,
track variation or provide
executive assurance.
Define minimum datasets and
common definitions for priority
services, including access, demand,
capacity, outcomes, patient
experience and learning.
Amber
Dashboard and
reporting routes
Assurance is currently
distributed across different
returns, programme reports
and local systems.
Develop proportionate dashboards for
high-risk or high-impact services and
agree reporting routes through SMT,
clinical governance and programme
boards.
Amber
GPIT migration
oversight
System performance affects
continuity of care, record
access, prescribing, workload
and user confidence.
Continue GPIT Programme Board
oversight and report migration
progress, downtime, issue resolution,
service impact and learning through
digital governance routes.
Amber
CTAC access
and waiting-time
data
Lack of standardised data limits
assurance on equity, demand,
capacity and effectiveness.
Use the CTAC service specification
review to define access, waiting-time,
demand, capacity and outcome
reporting requirements.
Amber 
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8. Final Closing Statement 
This deep dive provides collective assurance that Primary Care governance
arrangements are established, active and broadly aligned to the Healthcare
Improvement Scotland Clinical Governance Standards. The review identifies clear
strengths across leadership and professional oversight, quality improvement
infrastructure, clinical service redesign, risk management, education and training,
patient and community engagement, and information governance. It also demonstrates
that assurance is not uniform across the portfolio, reflecting the complexity of mixed
delivery models, including independent contractor, directly managed, shared-delivery
and business-to-business arrangements. 
The overall assurance position is therefore reasonable but qualified. Standards 2, 3
and 7 provide broadly green assurance, with amber direction of travel where data
maturity, system consistency, access equity and outcome measurement require further
development. Standards 1, 4, 5 and 6 are assessed as amber, reflecting the need to
strengthen safe staffing implementation, leadership resilience, escalation routes,
closed-loop learning, training compliance, competence assurance, and earlier, more
consistent service-user and community involvement. This does not indicate an absence
of governance controls; rather, it highlights the need to move from established but
sometimes fragmented arrangements to a more integrated, evidence-led and
sustainable governance assurance framework. 
Priority actions are being identified into a single improvement plan with named owners,
timescales, reporting routes, RAG status and escalation triggers for delivery over the
next twelve months. The key actions include completing Health and Care Staffing Act
baseline assessments; finalising organisational mapping and escalation arrangements;
developing a whole-system Primary Care quality management system; defining
minimum datasets and dashboards; strengthening CTAC, dental, forensic medicine
and sexual health reporting; implementing learning trackers for complaints, Datix,
audits and SAERs; improving statutory mandatory training and PDP compliance;
developing a portfolio-wide competence matrix; embedding early engagement and
Integrated Impact Assessment requirements into service-change planning; and
strengthening the use of data to evidence access, outcomes, equity, patient experience
and improvement over time. 
The Clinical and Care Governance Group is asked to note the assurance provided,
endorse the proposed areas for growth, and support a twelve-month review of
progress. This will allow the group to confirm that improvement actions are being
delivered, risks are being escalated appropriately, and the Primary Care governance
assurance framework is maturing in line with the HIS standards and the strategic
ambition to deliver safe, effective, person-centred and sustainable care closer to home.  
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Appendix 1  : Visual Governance Summary 
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Appendix 2: Clinical Governance Standards Self-Assessment Summary 
1. Overview 
Standard  Position
Standard 1: Leadership and Staffing Good
Standard 2: Quality Management and Continuous Improvement Good
Standard 3: Clinical Effectiveness Good
Standard 4: Clinical Safety and Risk Management Good
Standards 5–7 In progress 
2. Summary of Key Strengths
Established governance and reporting arrangements across Primary Care
Active management of risk, complaints, incidents and service performance
Ongoing quality improvement and service redesign activity
Alignment to national standards, contracts and clinical guidance
Positive organisational culture and staff engagement
Implementation of a structured Governance Assurance Programme 
3. Key Themes Identified
Consistency
Variation in governance processes across services, including risk management, quality improvement and clinical documentation
Visibility of Evidence
Governance arrangements are in place but are not consistently documented or easily accessible
Data and Monitoring
Fragmented datasets and limited standardised indicators across services
Learning and Feedback
Learning from incidents, complaints and audits is not consistently captured, shared or tracked
Escalation and Assurance
Escalation routes are in place but require greater clarity and consistency across services 
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4. Priority Areas for Improvement
Development of a central governance repository
Standardisation of governance documentation, risk registers and SOPs
Definition of minimum datasets and core indicators
Strengthening thematic learning and feedback processes
Improved visibility and use of safety, quality and performance data
Clear escalation triggers and early warning indicators 
5. Overall Position
The self-assessment indicates that governance arrangements across Primary Care are established and functioning. The Governance Assurance
Programme provides a structured route to strengthen consistency, evidence visibility and sustainability of assurance. The current position should be
treated as a baseline from which further improvement will be delivered as the programme progresses. 
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Appendix 3 : Enhanced Service Provision (25/26) 
Area List Size  
Enhanced Service
Minor
Surgery
-
Injectio
ns
Minor
Surger
y -
Invasi
ve
Minor
Surger
y -
Varico
se
Veins
& Piles
Extend
ed
Hours
Access
Palliati
ve
Care
Drug
Misu
se
Anti-
coagulati
on
Monitorin
g
IUCD
Fittin
gs
IUCD
Fitting
s –
Non
Patien
ts
Implan
ts –
Non
Patient
s
Basket
of
Servic
es
Older
Patien
ts in
Care
Home
s
Medicines
Reconciliati
on
Min
or
Injur
y
Argyll and
Bute                     90,718.00 
%
Populati
on with
access
91% 91% 13% 31% 69% 61% 87% 100% 100% 100% 93% 82% NA 11%
OLI                 
23,503 
%
Populati
on with
access
96% 95% 0% 36% 100% 91% 95% 100% 100% 100% 100% 91% NA 20%
MAKI            
21,078.00 
%
Populati
on with
access
97% 97% 6% 26% 57% 0% 99% 100% 100% 100% 92% 77% NA 26%
Cowal &
Bute            
21,598.00 
%
Populati
on with
access
88% 88% 45% 17% 31% 69% 53% 100% 100% 100% 98% 81% NA 0%
Helensburg
h & Lomond                     24,539.00 
%
Populati
on with
access
83% 83% 5% 43% 83% 78% 100% 100% 100% 100% 83% 78% NA 0% 
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