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One year on from a major push in the NHS to embed business continuity into mainstream strategic and operational planning, what progress is being made and how do the recently announced changes in primary care configuration alter the way the NHS may approach business continuity?
According to Liza-Marie Turner, business continuity officer for NHS Salford, an area covering 230,000 people, progress has been good. The Salford programme has benefited from chief executive level support and sufficient resource investment with a dedicated role for business continuity.
In Greater Manchester there are ten Primary Care Trusts, all sharing common services and methods, which enables much closer cooperation to address business continuity issues. In this model, one of the PCTs is assigned as the ‘Lead PCT’ to ensure that the resilience agenda is progressed in each NHS Trust. Liza is the appointed business continuity officer in the Greater Manchester region and therefore able to focus solely on business continuity management (BCM) without it being part of an emergency preparedness role, which is the more common approach, where resources are not shared as in Greater Manchester.
Liza-Marie explained that the business continuity programme is structured so that there is a high level business continuity plan that sits as an umbrella over the directorate and site plans. This is the overarching incident management plan, which includes command and control information. A Business Continuity Management System framework is in place, which is ratified by the executive team and guides programme management.
Up to standard
In terms of working to standards, the PCTs in Salford have aligned themselves with the NHS variant of the British Standard for BCM, BS NHS 25999, which only varies from the original to the extent that it includes specific NHS examples to aid effective implementation. The original BS25999 is well regarded in both the for-profit and not-for-profit sectors in many countries around the world. The Department of Health has since funded development of further guidance on resilience with PAS2015. This guidance draws on existing emergency planning and BCM methodologies into a form of meta-framework on resilience.
Two key success factors in BCM are making sure those with business continuity roles are trained appropriately, and secondly raising awareness of the need for and benefit of business continuity planning across the organisation. Julie Drysdale, business continuity manager at NHS Lothian emphasises the need for a structured education programme: At Lothian they use e-learning modules for self-learning and development of all staff, with more in depth training for managers who have assigned staff and systems responsibility. For those staff with business continuity responsibilities, these are included in their role specification and appraisals.
Lothian has also set out a six-point checklist as part of their awareness raising activities:
• be aware of what your key services are
• be aware of the activities and resources to deliver these services
• be aware of local plans to recover your key services
• be aware if these plans have been exercised
• be aware of what lessons have been learnt from conducting exercises
• be aware of who is involved from your business area in business continuity plan development.
Emergency planning
One of the original reasons for emphasis on business continuity planning in the NHS related to ensuring that the NHS was able to continue to deliver its services even if impacted by the same incident that had generated the civil emergency. This has tended to explain the reason why business continuity and emergency planning functions have often been combined. However, while they share common objectives, the two disciplines are quite different.
For a start, BCM is not just about dealing with emergencies, there are plenty of other sources of disruption that are not emergency-related. This partly explains, for example, why many organisations developed pandemic plans as separate activities to business continuity programmes, rather than as incremental aspects of business continuity.
Secondly, business continuity needs to be tightly coupled with risk and crisis management and integrated within strategic and operational decision making across the organisation. Emergency planning may not be an automatic stakeholder in certain business decisions, where business continuity thinking would be essential.
For example, in looking at outsourcing, the driver for such decisions is often one of cost savings, however, such decisions are rarely cost free, and BCI research indicates that organisations that choose outsourcing experience higher levels of disruption than those that do not. By analysing activities in BCM terms, organisations can make better informed outsourcing decisions and not just bring in the BCM team to work on the recovery strategy.
Supply chain
Outsourcing is one reason why supply chain resilience is such a hot topic in BCM. Most organisations have some level of dependency on suppliers and BCM is an excellent method to identify and qualify the importance of specific suppliers, not just in terms of spend or difficulty to replace at short notice but also in terms of validating where your organisation’s needs fit in their priorities, should they face a disruption.
In Salford, supply chain is not only the pens, paper and clinical suppliers for frontline services but also the services commissioned. GP, community, dental and hospital services are commissioned by the PCT and are therefore considered as suppliers to their health economy.
GP practices
GPs are not under any obligation to have business continuity plans, a problem which has been flagged up as an issue when BCM came to prominence last year. Nonetheless, Salford NHS has undertaken a number of initiatives to get GP practices on board. According to Liza-Marie Turner one of the challenges is that many GP practices are quite small and GPs do not have the staff or time to develop BCM arrangements. Many GP practices also host other health and social care services from the same building and they may not have a good overview of how these other services may be affected by their own business continuity decisions.
Salford’s solution was to supply the GPs with a business assessment template that was based on Salford’s Business Impact Analysis. The template encouraged GPs to identify high, medium and low risks and their impact, and get them thinking about what they would do if the practice had to shut down. The template also served to prompt them to think about who they rely upon, and included a call list of emergency suppliers. Practices are also encouraged to buddy up and support each other; this approach was developed as part of the NHS Salford’s pandemic response.
Future directions for BCM
The recent government White Paper for health services has indicated that commissioning responsibility will pass largely to GP consortia, and PCTs will cease to exist from the end of March 2013. However, at time of writing the complete commissioning model is yet to be confirmed.
Community health services such as district nursing, health visiting, and podiatry are currently under transition throughout England with PCTs becoming commissioning only bodies ahead of the changes described in the White Paper. PCTs are expected to pass commissioning responsibility for all services apart from primary and highly specialised care to GP consortia. Community services across England are transferring to various settings including hospitals, mental health trusts or social enterprises.
In Salford, the majority of community services are likely to transfer to the local acute hospital. As they are a Category One responder under the Civil Contingencies Act, they already have the duty to perform BCM. Some community services in Salford are transferring to the local authority, again a Category One responder, so both of these organisations will have a duty to expand their programmes of BCM work. However, not all PCT community health care functions are transferring into a Category One organisation, which poses a degree of risk to the overall BCM picture, in regard to losing the legislative driver to maintain standards.
So the transition of PCT responsibilities to GP consortia holds a degree of risk in terms of which entity will carry the statutory obligation to implement and maintain BCM. Clearly, the successor entity will need a thorough understanding of BCM and its importance to the health economy.
Making progress
In conclusion, good progress has been made with introducing BCM into the NHS. Some of the gaps identified in the past, such as GPs practices not being obliged to have business continuity plans, are being tackled creatively with promising results.
The proposed changes to commissioning, which involve a transfer of BCM responsibilities from PCTs to GP consortia, is at first sight, a cause for concern, given the immaturity of GPs in matters related to business continuity. As the process of change unfolds in the NHS, vigilance is required to ensure that the good work and investment in BCM is not lost in transition.
For more information:
Web: www.thebci.org
Speakers from Tinder Swindler and Biohacking to Microsoft and Google Working Together to Bridge the Gap
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