HRPTS Alert List Checks and Controlled Drugs Governance Questionnaire

Overview

Under the Controlled Drugs (Supervision of Management and Use) Regulations (Northern Ireland) 2009 (as amended), Controlled Drugs Accountable Officers (CDAOs) have statutory responsibilities to assess, investigate and take appropriate action in response to concerns relating to the management and use of controlled drugs. These responsibilities extend to agency staff, locum practitioners, trainees and other relevant individuals working under arrangements with a designated body.

This questionnaire is to seek information from Healthcare Professional Directors and Human Resources Directors regarding the arrangements in place within your organisation for:

• Checking all agency, locum, self-employed and other non-substantive healthcare staff against the Regional HRPTS Alert List, maintained by Recruitment Shared Services (RSS), before they undertake work in any Trust setting; and
• Managing, investigating and sharing information relating to concerns involving controlled drugs (CDs) where the individual is not directly employed by an HSC Trust.

Trust CDAOs have highlighted a number of challenges in managing controlled drug-related concerns involving non-substantive staff. In particular, issues have arisen regarding responsibility for investigations, barriers to effective information sharing, limited access to investigation outcomes from external organisations and regulators, and the potential for individuals subject to well-founded concerns to continue working across multiple settings without consistent oversight or safeguards.

The key themes identified include:

• Investigation Responsibility: Uncertainty regarding which organisation should lead investigations involving non-substantive staff, the investigative processes to be followed, and arrangements for documentation, information sharing and implementation of outcomes.
• Information Sharing: Limitations in the legal and operational mechanisms available for sharing information with employment agencies, training organisations and other non-designated bodies.
• Access to External Investigation Outcomes: Difficulties obtaining relevant investigation reports or outcomes from regulators and employing organisations, particularly where individuals are employed through agencies.
• Patient Safety and System Risk: Concerns that individuals who are the subject of well-founded controlled drug concerns may continue to work across multiple healthcare settings without appropriate restrictions, oversight or risk management measures.

To support the development of a consistent regional approach and identify opportunities for improving patient safety and governance arrangements, we would be grateful if you could provide information on the arrangements currently in place within your organisation in relation to the following questions.