Health Service Guidelines (HSG)

Dear Sir or Madam,

Can you please clarify the expressed intention of Health Service
Guidelines in general terms. Who are their intended audience?

Specifically, could I please have DH guidance on HSG(94)27 as I am
confused regarding its intention, especially in the light of the
added amendment.
Many thanks.

Yours faithfully,
Dee Speers

Dear Sir or Madam,
Many thanks to WDTK for the opportunity to ask questions under FOI
and it is amazing how often the reply is usually within FOI
requirements now. But if involved in an NHS complaint as I am the
thought of starting anotherr complaint with the Information
Commissioners office is daunting.....do-able but daunting!
My reply to DH below:
Dear Mr Ward,
I am grateful for your email today, clarifying the response sent on
behalf of David Nicholson, which I did indeed receive last October
and my apologies if I have added further to the overall confusion.
Thank you for the attached copy, I appreciate your time.

However, I am still confused as to the intention of HSG(94)27 and
concur that whilst the Dept of Health did issue “guidance on the
best practice that should be followed after such an event” it is
still my understanding that whilst the paragraphs in HSG (94)27
LASSL (94) 4) to which you refer have now been superseded by the
guidance Independent investigation of adverse events in mental
health services, which was issued in June 2005..it is indeed this
superseded guidance “Independent investigation of adverse events in
mental health services” that I am quoting as the amendment to the
previous guidance and attempting to access via my MP…..am I wrong?

For ease of reference this is information from the link I am using:

http://www.dh.gov.uk/en/Publicationsands...
Which clearly states:
Independent investigation of adverse events in mental health
services
Document type: Publication
Author: Department of Health
Published date: 15 June 2005
Primary audience: Professionals
Publication format: Electronic only
Series number: HSG (94)27. Equivalent to LASS
“To quote:This guidance replaces paragraphs 33 –36 in HSG (94)
27(LASSL(94)4) concerning the conduct of independent inquiries into
mental health services

I believe my interpretation is clearly supported by online advice
that the guidance I refer to has replaced paragraphs 33 –36 in HSG
(94) 27(LASSL(94)4) the latter being issued in May 1994.

Please can you advise me if my MPs and my interpretations are
wrong? If you believe they are, then can you please identify the
wording of the original guidance and the wording of the amended
guidance for comparison purposes.

As I read it, the requested guidance clearly states (and I have
copied it directly) amongst other specifics, and I quote:

“Independent investigation of adverse events in mental health
services”
It is essential that all adverse health care events are reviewed in
such a way that lessons can be learnt (An Organisation with a
Memory and Building a Safer NHS).

This guidance replaces paragraphs 33 –36 in HSG (94) 27(LASSL(94)4)
concerning the conduct of independent inquiries into mental health
services.

1: Commissioning (and please advise: is this current guidance?)

The Strategic Health Authority (SHA) is responsible for
commissioning independent investigations and consequently the
reports generated are the property of the SHA. Commissioning in
this context refers to determining when an independent
investigation is necessary, appointing an independent investigation
team, agreeing terms of reference, publishing and distributing the
resultant report and ensuring a process for subsequent action to
address issues raised.

SHAs, Primary Care Trusts and Mental Health Trusts should come to
local agreement with respect to arrangements for funding and
supporting independent investigations.

If other agencies or partnerships will be carrying out
investigations into the same event(s), eg in the case of a death of
a child, then the agencies involved should consider if it is
possible to jointly commission a single investigation process. This
should help ensure that expertise is most appropriately used,
duplication of process is minimised and inter-agency lessons
learnt. In cases where joint commissioning occurs, then early
agreement on funding arrangements should be made.

Criteria (likewise is this current guidance?)

An independent investigation should be undertaken in the following
circumstances:

• when a homicide has been committed by a person who is or has been
under the care, i.e. subject to a regular or enhanced care
programme approach, of specialist mental health services in the six
months prior to the event.

• when it is necessary to comply with the State’s obligations under
Article 2 of the European Convention on Human Rights. Whenever a
State agent is, or may be, responsible for a death, there is an
obligation on the State to carry out an effective investigation.
This means that the investigation should be independent, reasonably
prompt, provide a sufficient element of public scrutiny and involve
the next of kin to an appropriate extent.

• 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 remain concerned that Care Programme Approach (CPA), Crisis
Resolution Teams, Early Intervention Services, collection of
suicide audit data and incorrect reporting and investigating of
‘Adverse Incidents’(AI) ‘Serious Adverse Incident(SAI) ‘Serious
Untoward Incidents’ (SUI) are still weak across many trusts. I
still maintain that if as the guidance recommends “It is essential
that all adverse health care events are reviewed in such a way that
lessons can be learnt” that this is the ideal opportunity to use
the recommended National Patient Safety Agency Root Cause Analysis
(RCA)Toolkit and carry out a line by line investigation into WLMHT
understanding of its own robust policy, which must be a cause for
concern given that the Healthcare Commission (HC) upheld my
complaint and launched a full investigation into patient safety at
West London Mental Health Trust (WLMHT).

Do you think maybe the guidance is not being interpreted by SHA and
Trusts as it should be?

Kind regards

Dee Speers

Yours sincerely,

D. Speers

Dear Sir or Madam,

Please pass this on to the person who conducts Freedom of
Information reviews.

I am writing to request an internal review of Department of
Health's handling of my FOI request 'Health Service Guidelines
(HSG)'.

A full history of my FOI request and all correspondence is
available on the Internet at this address:
http://www.whatdotheyknow.com/request/he...

Specifically:
1)I would like to know what is the Dept of Health's expressed
intention for HSG(94)27 as an amendment to previous DH guidance?
2)How is the amended HSG guidance intended to be interpreted by
Strategic Health Authorities?
3)How does the DH ensure clarity of interpretation matches guidance
intention?

Yours sincerely,

D. Speers

Dear Sir or Madam,

Further to my recent request for an Internal review into HSG(94)27,
I'm afraid I omitted to say exactly why I am not satisfied with the
DH respone.

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 implementiong this
particular HSG or DH are not fully aware of the potential
misunderstandings of the HSG amendment's intention.

Please pass this on to the person who conducts Freedom of
Information reviews as I previously stated I am writing to request
an internal review of Department of Health's handling of my FOI
request 'Health Service Guidelines (HSG)....with ref to HSG(94)27
in particular.

A full history of my FOI request and all correspondence is
available on the Internet at this address:
http://www.whatdotheyknow.com/request/he...

With thanks

Yours sincerely,

D. Speers

Dear Sir or Madam,
many thanks for responding to my request for information about
matters of concern re Coronial Reform.....which does not form part
of my concerns re clarity of purpose of Health Service Guidelines.

My sincere apologies, as I appear to have sent my enquiry re
Coroners and Justice Bill this to the wrong dept and I thank you
for forwarding this, I appreciate your time.

However, as this response does not address HSG, I am therefore
still seeking an internal review of DH response to my questions on
HSG with ref to HSG(94)27 in particular.

Many thanks and once again my apologies for any confusion.

Yours sincerely,

D. Speers

Dear Sir or Madam,

Thank you for your responses and please note my email to Joanne
Miles,Customer Service Centre
Department of Health... addressing the fact that some information
online may need to be addressed. The information online is my
contact with my MP and not related to my HSG online enquiry via
WDTK. It also contains the contact details of my MP (which as he
may not have given his permission to put his comments on a public
site may need to be addressed?)

Yours sincerely,

D. Speers

Dear Sir or Madam,

Thank you for your responses and please note my email to Joanne
Miles,Customer Service Centre
Department of Health... addressing the fact that some information
online may need to be addressed. The information online is my
contact with my MP and not related to my HSG online enquiry via
WDTK. It also contains the contact details of my MP (which as he
may not have given his permission to put his comments on a public
site may need to be addressed?)

Yours sincerely,

D. Speers