Room 317 Richmond House
79
Whitehall
London SW1A 2NL
Telephone: 020 7210 5000
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Email: [email address]
To:
[email address]
20
August
2009
Dear Ms Speers
FREEDOM OF INFORMATION ACT (FOIA): REQUEST FOR INTERNAL REVIEW:
DH CASE REFS: 401847; 406900; 428130: 428129
Thank you for your emails dated 27 & 30 March in which you requested an internal
review of your previous correspondence concerning the health service circular HSG
(94) 27. I apologise for the delay in responding to you.
You requested in your email dated 27 March:
“Specifically, 1) I would like to know what is the Department of Health’s expressed
intention for HSG (94) 27 as an amendment to previous DH guidance? 2) How is the
amended guidance intended to be interpreted by Strategic Health Authorities? 3)
How does the DH ensure clarity of interpretation matches the guidance intention?
You subsequently wrote again on 30 March:
“As the response information I have received from DH is contra to the information I
have received from the Strategic Heath Authority. I am now trying to fully clarify the
specific point's of HSG (94)27, which I believe are causing the confusion of intention
of purpose. As I see things either the SHA are not fully implementing this particular
HSG or DH are not fully aware of the potential misunderstandings of the HSG
amendment's intention. “
On the points you raised in your email dated 27 March as set out above. Your email
followed Dominic Ward’s letter to you dated 6 March in which he had explained the
Department of Health’s position on these points outside of the provisions of the
Freedom of Information Act (FOIA), but from a policy perspective.
You wrote again on 6 June about a wide range of issues on suicide prevention policy,
including the HSG (94) 27 in which you explained:
“1) I understand that HSG(94)27 was specifically amended to ensure
that all access criteria for Independent Investigation into Adverse
Incidents in Mental Health service were clearly understood. What
was Dept of Health intention with specific reference to #3 in
HSG(94)27 and can I have a copy of the HSG guidance on HSG(94)27?
2) How many times since the HSG (94)27 amendment, has #3 access
criteria on 'suicide clusters' as being possible indicators of
significant system failure" been used?
3) If Suicide and injury of undetermined intent mortality rate is
one of the NHS Vital Signs and is set as a national priority for
local delivery but is due to be fully withdrawn by 2011, then what
replaces this national and local priority?”
The Department of Health wrote to you again on 9 July to explain that
“The revision to the section of HSG (94)27 on adverse event inquiries aimed
to give additional guidance on the circumstances in which an independent
investigation might be appropriate and also on the processes for establishing
such an investigation. HSG (94)27 confirms: “Where the SHA determines that
an adverse event warrants independent investigation, for example if there is
concern that an event may represent significant systemic service failure, such
as a cluster of suicides.” I can confirm that HSG (94)27 is in the public
domain, and that it is on the DH website, along with the amendment
document:
http://www.dh.gov.uk/en/Publicationsandstatistics/Lettersandcirculars/Healths
erviceguidelines/DH_4104914
Further information regarding inquiries after homicides or suicides is also
available form the National Patient Safety Agency website:
http://www.npsa.nhs.uk
This information is given in accordance with S21 of FOIA, which enables us to
refer requestors directly to information, which is reasonably accessible to
them by other means. Turning to your enquiry about how many times since
the HSG (94)27 amendment, has #3 access criteria on 'suicide clusters' as
being possible indicators of significant system failure" been used, - the
department does not routinely collect copies of independent investigation
reports or information on the commissioning of such reports. We therefore do
not hold data on how many reports have been commissioned into clusters of
suicide.
We understand the rest of your enquiry to fall outside the terms of FOIA, in
that it cannot be answered from recorded information. However, given that
the issues which you raise here have been fully covered by the Department in
previous correspondence, I can confirm that we can add nothing to the
information which has been previously given.
I am sorry to be unable to be more helpful.” The internal review into the handling of your previous correspondence is
complete.
I can confirm that it is for Strategic Health Authorities, Trusts and Primary
Care Trusts to interpret the HSG (94) 27 circular & accompanying guidance
locally, taking into account any other circumstances as appropriate.
Turning to your question “If Suicide and injury of undetermined intent mortality
rate is one of the NHS Vital Signs and is set as a national priority for local
delivery but is due to be fully withdrawn by 2011, then what replaces this
national and local priority?” There are no plans to develop a further suicide
prevention strategy for England. The current target runs to 2011 but suicide
prevention will remain a vital aim for public health and mental health services.
The infrastructure remains in place for coordinated suicide prevention
measures to continue to be taken in partnership with other agencies at local
and national level.
I should re-iterate what we had explained in our 9 July letter (as above) in that
the rest of your enquiry falls outside the terms of FOIA, and that it cannot be
answered from
recorded information. However, given that the issues you
raise have been covered by the Department in previous correspondence, I
can confirm that we can add nothing more to the information, which has been
previously given.
If you are not content with the outcome of your complaint, you may apply
directly to the Information Commissioner’s Office (ICO) for a decision.
Generally, the ICO cannot make a decision unless you have exhausted the
complaints procedure provided by the Department. The ICO can be
contacted at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Yours sincerely,
TONY DOOLE
Senior Casework Officer
Freedom of Information Team