On your marks!

30 Oct 2019

Jeremy Hunt, when he held the position of Health & Social Care Secretary, published a letter to independent hospitals on 8 May 2018 urging them to “get their house in order and improve safety."  One of the triggers for this was the Care Quality Commission (CQC) identifying that a third of independent hospitals “required improvement” as they demonstrated poor practice and unsafe care.

The Independent Healthcare Providers Network (IHPN) has now produced a Medical Practitioners Assurance Framework (2019) which has been described by Chair, Sir Bruce Keogh as the equivalent of firing “a starting gun …to improve care and confidence in the private sector.” A link to this framework is provided here.

In the introduction, Sir Bruce references The King’s Fund’s (2012) three lines of defence against serious quality failures in healthcare:

  1. Frontline professionals – clinical and managerial
  2. Boards and senior leaders who are to be accountable when things go wrong
  3. External structures/systems to assure the public as to quality e.g. CQC, GMC, etc.

The framework identifies 11 key expectations, including:

  • Ward to Board Clinical Governance structure
  • A Practising Privileges template
  • Standardisation of Practising Privileges and a similar approach to employed medical practitioners

The focus of the framework is to show providers ‘what good looks like’ and to reflect the cultural change in healthcare to being more transparent and open. 

The four sections of the framework can be summarised as follows:

Clinical governance:

Recognition that the Board are responsible for the quality of clinical care.

Achieved via appointment of non-executive director, national lead, responsible officers.


Monitoring safety quality and improvement:

Knowledge of clinical governance, data collection and analysis with a lessons learned strategy.



Whole practice appraisal:

Focus is the appraisal based GMC model to analyse the complete practice of every practitioner irrespective of where they are employed with information being shared by practitioners.


Raising and responding to concerns:

NHS and private communications at an early stage.


Since leaving his Cabinet role, Jeremy Hunt has launched a charity (October 2019) to monitor patient safety, and is Chair of Patient Safety Watch.  The human cost of an unsafe healthcare system means that safest delivery must remain a priority for all, whether NHS or private. This framework is an important start – but the finish line remains some way off.

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Disclaimer: This document does not present a complete or comprehensive statement of the law, nor does it constitute legal advice. It is intended only to highlight issues that may be of interest to clients of BLM. Specialist legal advice should always be sought in any particular case.

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