Application of the Patient Safety Incident Response Framework (PSIRF) principles is mandatory for all health services contracted under the NHS Standard Contract. This includes all aspects of NHS-funded healthcare provided by organisations that are not NHS trusts or foundation trusts, including some services delivered by primary care and NHS funded care delivered by independent organisations.

Health care delivery across the NHS in England is very complex, and the nature of a service in terms of its risk profile, cost, size, geography, and complexity, for example, will have a bearing on the way PSIRF is applied and operationalised.

The FAQs below are based on the questions that have been asked about applying PSIRF in non-NHS trust organisations. They should be read in conjunction with the wider PSIRF guidance and help clarify how PSIRF principles can be applied proportionately across the variety of services and commissioning structures within the NHS.

Patient Safety Incident Response Framework principle 1: Compassionate engagement and involvement of those affected by patient safety incidents

1.1. Does each provider site need a trained engagement lead?

The Patient Safety Incident Response Standards specify the training required in relation to PSIRF. This includes training for those who lead on engaging with those affected by patient safety incidents.

Providers and commissioners should work together to develop the most appropriate model for their services. 

For example, it may not be feasible to have a trained engagement lead at site level for smaller organisations. Where this is the case, organisations can consider working with other/larger organisations (particularly those they may provide services for) to explore how patient safety incident response resources may be shared.

Commissioners can support the development of expertise in patient safety incident response at system or place level that smaller providers may utilise.

In some organisations the engagement lead and the learning response lead may be combined into one role.

Patient Safety Incident Response Framework principle 2: Application of a range of system-based approached to learning from patient safety incidents

2.1. Does each independent provider site need a trained learning response lead?

The Patient Safety Incident Response Standards specify the training required in relation to PSIRF. This includes training for those who lead on engaging with those affected by patient safety incidents.

Providers and commissioners should work together to develop the most appropriate model for their services. 

For example, it may not be feasible to have a trained engagement lead at site level for smaller organisations. Where this is the case, organisations can consider working with other/larger organisations (particularly those they may provide services for) to explore how patient safety incident response resources may be shared.

Commissioners can support the development of expertise in patient safety incident response at system or place level that smaller providers may utilise.

In some organisations the engagement lead and the learning response lead may be combined into one role.

2.2. Do all providers need to adopt the PSIRF learning response toolkit?

The PSIRF learning response toolkit contains the preferred response methods. Standard 15.6 in the Patient safety incident response standards document states that ‘National tools (or similar system-based tools) are used, and guides followed for learning response methods’ (p11).

In addition, while the SEIPS framework is the system-based framework endorsed by PSIRF other system-based frameworks exist. Organisations can use their preferred system-based framework alongside relevant training in how to apply their selected framework. Root Cause Analysis is no longer the preferred approach.

Significant Event Audits can be used as a proportionate response when applied in a way that enables an exploration of the complex context of a safety event, incorporating consideration of system factors.

Patient Safety Incident Response Framework principle 3: Considered and proportionate responses to patient safety incidents

3.1. Do patient safety policies need to be site specific?

An organisation may wish to develop a site-specific policy OR an overarching/organisational policy. As described in our policy template, the policy could link to policies in place already, such as the safety event / incident reporting policy, risk management policy etc. or a single overarching policy for safety management across the organisation or site. 

Organisations, in discussion with relevant commissioners, may agree to adapt the national policy template to ensure it is proportionate to the organisation. In some contexts, it may be more appropriate to adapt existing documentation to demonstrate how an organisation meets patient safety incident response standards rather than developing a new policy.

3.2. Do patient safety plans need to be site specific?

Patient safety incident response planning activity will depend on the nature/structure of services offered. Options for creating a plan include, but are not limited to:

• creating an overarching patient safety incident plan across an entire organisation
• creating plans held at division/speciality/site level
• working collaboratively with organisations from the same sector to develop one plan (e.g., a plan for a certain type of care or service across a particular area)
• working collaboratively with organisations as part of a system or place to develop a plan as part of system working (e.g., a plan for provision of XXX within XXX system)

It is important that patient safety incident response planning activity is proportionate to each organisation. This means the nature of service in terms of risk, cost, size, geography, and complexity, will have a bearing on the way patient safety incident response planning is conducted.

Those responsible for the patient safety incident management of each site must know how to access relevant planning and policy documentation and know how to apply it.

NHS England’s Patient Safety Incident Response Plan template is available on the NHS England website.

3.3. Do patient safety plans need to be site specific?

As described in the PSIRF preparation guide providers should engage with both internal and external stakeholders in their efforts to transition to PSIRF and in the development, maintenance, and review of their patient safety incident response plan.

Internal stakeholders include representatives from different clinical services/divisions and clinical and non-clinical staff (e.g., governance, safeguarding, HR, and organisation development). Where in place, patient representatives (i.e. Patient Safety Partners) should be invited to be part of ongoing PSIRF work.

External stakeholders include patient groups and patient and public representative organisations (e.g., Local Healthwatch). Coroners and the Care Quality Commission (CQC) relationship owners should be engaged at the earliest opportunity.

Providers should ensure stakeholders are diverse and understand the PSIRF (and how it will change any existing approaches), how they can be involved in the transition process, and how they can be kept updated.

Patient Safety Incident Response Framework principle 4: Supportive oversight focused on strengthening response system functioning and improvement

The PSIRF Oversight roles and responsibilities specification notes that commissioners ‘have a responsibility to establish and maintain structures to support a co-ordinated approach to oversight of patient safety incident response in all the services within their system’ (p13). 

The oversight specification outlines five responsibilities for commissioners: 

1. collaborate in the development, maintenance and review of provider patient safety incident response policies and plans
2. agree patient safety incident response policies and plans
3. oversee and support effectiveness of systems to achieve improvement following patient safety incidents
4. support co-ordination of cross-system learning responses
5. share insights and information across organisations/services to improve safety

4.1. To what extent should NHS commissioners be engaged in planning?

The engagement of relevant NHS commissioners in the development and agreement of an organisation’s patient safety incident response policy and plan is essential. The extent commissioners are engaged in planning may be different in different contexts.

Below are some examples of the different contexts and approaches that may apply. The most important step is to establish and then maintain ongoing discussions.

Providers with a single commissioner

A relevant lead or leads from the provider and commissioner should liaise and agree an approach to enable collaboration in the development, maintenance and review of the patient safety incident response policy and plan. In some circumstances there may only be one paying commissioner but, due to the location of service sites (which may be across different integrated care systems), there may need to be engagement with other commissioners who have an interest in the content of the policy and plan. This should be considered on a case-by-case basis.

Providers with multiple commissioners

There are different approaches providers can consider depending on existing relationships and connections with commissioning teams.

1. Working with a lead commissioner to support PSIRF planning

If providers already have a lead commissioner, this commissioner may be the primary point of contact for developing and agreeing the patient safety incident response policy and plan. Even where there is a lead commissioner to support this work, it is important to ensure that other commissioners have an opportunity to be involved in the development process and have sight of draft policies and plans so they can add comments and raise queries as needed.

In some cases, it may not be a previously assigned ‘lead commissioner’ but another commissioner who (because of capacity or experience, for example) offers to be the key point of contact to PSIRF preparation, including development and agreement of the patient safety incident response policy and plan. As above, other commissioners would need to be given an opportunity to engage in the process.

2. Working with multiple commissioners to support PSIRF preparation.

If providers wish to work with all or multiple commissioners, it may help to develop an engagement plan. This may include identifying and writing to/emailing all commissioning teams and inviting them to a collaborative event/webinar to discuss the work underway to support the transition to PSIRF. As part of this you can talk about how to manage certain aspects of the process (e.g., agreement of relevant documentation) and potentially seek support through a smaller PSIRF working group.

4.2. What is the NHS commissioner role after transition to PSIRF?

Providers and commissioners will need to consider which commissioner is best placed to fulfil day-to-day oversight responsibilities. These include:

• overseeing and supporting the effectiveness of systems to achieve improvement following patient safety incidents
• supporting co-ordination of cross-system learning responses
• sharing insights and information across organisations/services to improve safety

Depending on the context, these roles may be best fulfilled locally for each site location regardless of whether a provider has an organisation wide plan and/or used a lead commissioner model to agree transition to PSIRF.

4.3. What if a provider is unable to identify a lead commissioner?

Providers wishing to identify a lead commissioner to develop and agree their patient safety incident response plan should work collaboratively across their network to identify a lead commissioner.

This might take some time given current pressures and restructures across the commissioning landscape and may involve communicating with a significant number of commissioners.

If a lead commissioner is not forthcoming the provider should consider developing their patient safety incident response plan through proportionate engagement across the breadth of their commissioning organisations. Where this proves prohibitive, the independent provider should note in their patient safety incident response plan that despite best endeavours, commissioner engagement has not been forthcoming and make clear that the plan has been finalised from the provider perspective only.  This can be updated in future iterations of the plan when a lead commissioner has been agreed.

4.4. What training is required for those in PSIRF oversight roles?

Those in oversight roles must have training and competencies as described in the PSIRF standards.

Given the pace of transition to PSIRF, it is recognised that the required training might not be in place ahead of an organisation’s initial transition. This should be recognised with a documented plan in place (e.g., within the organisation’s patient safety incident response plan) to ensure training and competency standards are met within a reasonable timeframe. 

Additional questions

A1. How can providers access necessary PSIRF training?

Those leading on learning responses, engagement with those affected by patient safety incidents, and in oversight roles related to patient safety incident response, require specific training as outlined in Table A1 in our Patient safety incident response standards. 

Oversight training is required for those fulfilling the roles outlined in our Roles and responsibilities specification. This includes board members within independent providers that fulfil the roles of the PSIRF executive leads. 

Levels 1 and 2 of the patient safety syllabus can be accessed via e-learning for health. An NHS email address is not required. 

The Health Services Safety Investigations Body (HSSIB) offer PSIRF training covering ‘A systems approach to learning from patient safety events’ free of charge to the independent sector. Other HSSIB courses can be procured – see their prospectus for more information.

Training can also be procured via suppliers on our training procurement framework. Suppliers on the framework have been assessed against criteria to ensure they have relevant skills and experience and deliver content in line with PSIRF requirements.

When/if procuring training, organisations may wish to consider the options below. Alternative approaches may also be possible if agreed with the relevant commissioner: 

• contacting the relevant commissioner for networking opportunities within local systems to procure training together and reduce cost
• sharing learning response resources (e.g., trained learning response leads) centrally

Training can also be offered in-house by those who meet standard 5.1. within our standards document.

A2. How can non-commissioned providers access training?

Some providers such as some Air Ambulance services that are not commissioned via the NHS Standard Contract (and are not required to implement PSIRF contractually) and some social care providers, are keen to align with PSIRF principles and training requirements. These providers can access HSSIB’s training covering ‘A systems approach to learning from patient safety events’ free of charge as well as level 1 and 2 of the patient safety syllabus.

Other training can be delivered through the means described in question A1 above.

Publication reference: PRN01160