In England, the Civil Contingencies Act 2004 (CCA), 1 National Health Service (NHS) Standard Contract Service Conditions, 2 (pp. 45-47) and NHS England Emergency Preparedness, Resilience and Response (EPRR) framework 3 require NHS-funded organizations to be able to respond to emergencies for the provision of health care. The CCA defines an emergency as:
An event or situation which threatens serious damage to human welfare in a place in the United Kingdom … if it involves, causes or may cause … loss of human life, human illness or injury, … or disruption of services relating to health. 1 (s. 1)
NHS England is the Commissioning Board for NHS services in England. Its EPRR annual assurance guidance 4,5 states that it has a statutory requirement to assure formally the NHS in England’s readiness to respond to emergencies. This assurance is the highest level of quality control of EPRR for the NHS in England. It informs the level of confidence the United Kingdom Government has that the NHS will be able to provide health care during emergencies.
NHS England sets Core Standards for EPRR 6 for NHS services in England. NHS England’s assurance of 2021-2022 4 aimed to fulfill the above statutory requirement by asking each NHS organization to self-assess its compliance with these standards and to have a “confirm and challenge” meeting with its Local Health Resilience Partnership (LHRP). NHS England would then facilitate a “confirm and challenge” process between the LHRP, an NHS England regional EPRR team, and the NHS England national EPRR team.
An NHS organization could assess itself as being fully compliant with the Core Standards if it were fully compliant with 100% of the standards, substantially compliant if it were fully compliant with 89 to 99% of the standards, partially compliant if it were fully compliant with 77 to 88% of the standards, and non compliant if it were fully compliant with less than 77% of the standards.
Methods
Study Setting and Design
This was a review of NHS England’s EPRR annual assurance for the years 2021-2022.
In England, there were 124 NHS trusts that provided general hospital accommodation and services in relation to accidents or emergencies during the period of assurance. 7 The study size was determined by the number of these trusts. The study timing was the first complete annual assurance after the national incident level for the NHS coronavirus disease (COVID-19) response was reduced from level 4 to level 3 in March 2021.Reference Willett and Groves 8
The primary outcome of interest was the quantity of information regarding applicable Core Standards held by NHS England at the end of the EPRR annual assurance. Secondary outcomes were variations between the number of applicable Core Standards and information held by NHS bodies about the number of applicable Core Standards.
Approval for this review was not required by the Research Ethics Committee at University Hospitals Sussex NHS Foundation Trust.
Patient and Public Involvement
No patient or public involvement was reported.
Data Collection
The applicable Core Standards were viewed on NHS England’s website. 6 Requests were made under the Freedom of Information Act via the WhatDoTheyKnow website to NHS England for the total number of applicable Core Standards for EPRR for 2021–2022, excluding those standards that were part of the “Deep Dive,” for each of the 124 trusts. 9 Requests were staggered to stay within the cost limit of 18 person-hours of work per request.
For each trust where the record of the total number of applicable Core Standards provided by NHS England varied most greatly from the correct number of applicable Core Standards, the same request was made to the NHS Integrated Care Board (ICB) holding the information for the LHRP responsible for that trust. 10
Results
NHS England held the requested information for 101 of the 124 trusts. 9
There were 46 applicable Core Standards.6 For 88 trusts, NHS England recorded the correct number of applicable Core Standards. For 9 trusts, NHS England recorded 64 applicable Core Standards. For 4 trusts, NHS England recorded 69 applicable Core Standards.
The numbers of applicable Core Standards recorded by the ICBs responsible for the 4 trusts with the greatest variation from the correct number of Core Standards are shown in Table 1.
Table 1. Trusts for which NHS England recorded 69 applicable Core Standards
Discussion
This review suggests that NHS England did not successfully perform its EPRR annual assurance in 2021–2022 as described in its guidance applicable at that time.4 In particular, the successful performance of stages 3 and 4 of the assurance (confirm and challenge of the process by regional and national EPRR teams, respectively) is not consistent with not recording the correct number of applicable Core Standards for over a quarter of the NHS trusts. If the correct number of standards was not recorded for those NHS trusts, then it would not have been possible to calculate correctly their percentage compliance with them.
NHS England might benefit from reviewing how it implements its EPRR annual assurance guidance to improve the quantity and quality of information it holds at the end of this assurance.
Limitations
It was not possible to explore the reasons for variations between the number of applicable Core Standards and information held by NHS bodies about the number of applicable Core Standards.
Conclusion
NHS England’s EPRR annual assurance is the highest level of quality control of EPRR for the NHS in England. It informs the level of confidence the United Kingdom Government has that the NHS will be able to provide health care during emergencies. The first complete assurance after the COVID-19 pandemic national response resulted in correct data not being recorded for over a quarter of NHS trusts which provided general hospital accommodation and services in relation to accidents or emergencies.
This review may also be of interest to other state-level bodies that rely on high-level assurance of their ability to provide health care during emergencies.
Abbreviations
- CCA
-
Civil Contingencies Act 2004;
- EPRR
-
Emergency preparedness, resilience, and response;
- ICB
-
Integrated Care Board;
- LHRP
-
Local Health Resilience Partnership;
- NHS
-
National Health Service.
Author contribution
William Wetherell is the sole contributor to this manuscript.
Funding statement
This review received no specific grant from any funding agency in the public, commercial, or not-for-profit sectors.
Competing interest
The author is a bank employee of University Hospitals Sussex NHS Foundation Trust and has no other competing interest.
Ethical standard
This review is a quality improvement project and so approval was not required by the Research Ethics Committee at University Hospitals Sussex NHS Foundation Trust (https://www.uhsussex.nhs.uk/research-and-innovation/information-for-researchers-and-healthcare-professionals/is-my-study-research/).
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