Simplyhealth Clinical Governance Policy

Clinical Governance Policy

1. Purpose

This clinical governance policy provides an overview of Simplyhealth’s approach to clinical governance; a guide to the procedures in use; and details about the management structures that oversee these arrangements.

2. Scope and application

This policy applies to everyone at Simplyhealth, whether permanent, temporary, voluntary or contractors, and extends to all parts of Simplyhealth’s business.

3. Outcomes

Clinical Governance is a framework through which healthcare providers are accountable for continually improving the quality of their services and safeguarding high standards of care by creating an environment in which excellence in clinical care will flourish. There are three main attributes of effective clinical governance:

• Recognisable high standards of care

• Transparent responsibility and accountability for those standards

• An ethos of continuous improvement

Clinical governance refers to the structures, policies, and processes that an organisation has in place to manage the quality of the services it provides or commissions. The clinical governance arrangements that exist in any organisation must be appropriate and proportionate to its role in the provision, commissioning, or otherwise funding healthcare services. This policy sets out Simplyhealth’s approach to clinical governance, covering both the Healthplan and Denplan areas of the business.

For the purposes of this policy clinical governance includes the following components:

Image description: A diagram representing the six components of clinical governance: education and training, clinical audit, clinical effectiveness, research and development, openness, and risk management.

The effectiveness of Simplyhealth’s internal clinical governance and that of the services it provides, or commissions will be assessed against these components.

4. Our approach to Clinical Governance

Simplyhealth undertakes to implement clinical governance effectively and will therefore ensure the following:

• clear ownership of clinical governance oversight within Simplyhealth

• effective oversight and reporting of clinical risks across the Group

• effective oversight and reporting of the quality and effectiveness of our services across the Group

• that good clinical governance drives a focus on the quality, safety, and effectiveness of our products both in their development and delivery

• that our people are adequately trained and understand clinical governance

• that clinical governance oversight is embedded within key processes in the Group

• that clinical governance is understood from Board level to all areas of the business.

5. Roles and Responsibilities

The responsibilities for Clinical Governance are assigned to specific people and groups within Simplyhealth. These are outlined below:

The Board

The Board oversees clinical governance for the organisation and is accountable for ensuring that effective clinical governance processes, procedures and policies are in place. It is also accountable for ensuring clinical governance is taken into account in its decision making and that it is aware of any clinical governance risks or issues in relation to the decisions it takes. The Board is also accountable for ensuring that it is assured that the clinical services provided, commissioned, or otherwise funded by Simplyhealth are delivered to high clinical standards and internal clinical governance processes are effective.

Risk and Capital Committee

The Risk and Capital Committee provide Board level oversight of clinical risks and acts as the point of escalation for issues and risks identified by the Clinical Governance Committee , using the clinical risk management process. A clinical risk report will be shared with the Risk and Capital Committee as appropriate.

Clinical Governance Committee

The Clinical Governance Committee oversees the clinical risk and adherence to the clinical governance policy across the organisation. The committee will review and inform on any areas of clinical risk within the business, agreeing on relevant actions to facilitate continuous improvement.

Clinical Teams (Service and Product)

The Clinical Services Team alongside the Clinical Product Team are responsible for the oversight and implementation of effective clinical governance across Simplyhealth. Ensuring appropriate systems and controls are in place to manage clinical risks and obtain appropriate assurance on the quality, safety, and effectiveness of the clinical services Simplyhealth provides, commissions or otherwise funds.

The teams will:

• support the business in implementing effective clinical governance processes and embedding the clinical governance principles in all areas of Simplyhealth. This will ensure our products are safe, appropriate and effective in their development and delivery.

  
  

• review and monitor clinical risks across all Simplyhealth products. Maintain a record of the specific risks being monitored by the team and ensure effective actions are in place to manage risks in line with Simplyhealth’s stated risk appetite, and that risks are escalated to the Clinical Governance Committee.

  
  

• ensure there is a culture of continuous improvement and an understanding of current clinical standards and emergent good practice. This understanding should be applied to ensure up to date clinical standards are being maintained by our clinical service providers.

  
  

• encourage a culture where clinical governance is considered by decision makers and included in established frameworks, with relevant and timely input requested when there are changes to an existing product or when considering a new product or service.

  
  

• ensure there is an appropriate framework in place for the cascade of clinical information across Simplyhealth to appropriate people, to support staff competency, encourage consistency, and ensure the continuous improvement of processes. Periodically review the framework to ensure it remains appropriate and effective.

  
  

Leadership Responsibilities

Executive owner: Tom Perkins

Operational owner: Catherine Rutland

Business Areas

Each Business Area is responsible for the day-to-day implementation of clinical governance best practice where relevant for their business area.

This includes:

• ensuring clinical governance processes and principles are embedded in our business practices

• access the support and advice of the Clinical teams at key decision-making milestones

• initial and ongoing assessment of the clinical impact and risks of proposed programmes, projects, procurement, and product development

• incorporation of clinical risks into management and maintenance of risk registers

• identification of appropriate mitigations or remedial actions in response to clinical risks or gaps in assurance

• escalation of any significant, new, or different risks and gaps in assurance to the Clinical Services and Product Teams

• ensure clinical best practice is encouraged in all Simplyhealth products and services

• supporting the ethos and implementation of continuous improvement

• provide data and reports that enable clinical governance processes, practices, and effectiveness to be assessed in all six clinical governance components.

Service providers, contractors, and suppliers

Simplyhealth will require our service providers, contractors, and suppliers to meet adequate clinical governance standards. Denplan member dentists are expected to uphold the terms of our membership agreement with them. All providers of clinical services should demonstrate and evidence that their clinical governance policy and procedures are effective in safeguarding our customers and the users of their services. Additionally, they should provide assurance of the quality and effectiveness of their services as and when requested by Simplyhealth. Specific contractual terms and conditions will be developed that reflect the nature of the service provider, contractor, or supplier in order to ensure Simplyhealth are able to implement this policy and provide evidence to support its effectiveness.

Individual responsibility

All our people, whether permanent, temporary or contractors are responsible for ensuring that they are aware of and comply with the requirements of this policy and the procedures and guidelines produced to support it. Where trained individuals fail to adhere to the organisation’s policy and procedures, disciplinary action may be taken.

6. Training and guidance

Simplyhealth recognise that the implementation of this policy is dependent on our people being aware of its content and appropriately trained to comply with it. Simplyhealth will train our people in how to adhere to our procedures and will be provided with supplementary role-specific guidance and training where necessary.

All our people will receive general awareness training on induction and annually so that they have an understanding of the principles of clinical governance. This training will help ensure that our people are aware of our clinical governance policy and how to identify and raise concerns about the clinical standards of the services Simplyhealth commission. In addition, Simplyhealth will provide specific, role-related training for the following people:

• The Board

• Exco and Senior leaders

• Risk and Assurance

• Procurement and Contract teams

• Product managers

• Clinical Services and Product

Compliance with clinical governance policy and associated procedures will be monitored and additional support and training provided where issues are identified.

7. Compliance and review

The Clinical Services and Product Teams will monitor compliance with this policy and its effectiveness on a quarterly basis within the Clinical Governance Committee meetings.

The Clinical Governance Policy will be reviewed every three years, taking into account any changes in legislation and include any learnings and recommendations.