NHS Primary Care Contracting Index 2

Index

Index / 2
Introduction / 3
Principles / 4
Monitoring and Development Process / 5
Mid-year Monitoring and Development Cycle / 6
Annual Monitoring and Development Cycle / 7
Monitoring and Development Process Chart / 8
Step-by-Step Process / 9
Guidance Notes / 11
Framework / 15
Patients / 16
Provision of Services / 18

Assessment Toolkit

/ 20
Section A / 20
Patients / 21
Provision of Services / 21
Section B / 22
Provision of Services / 23
Section C / 24
Patients / 25
Provision of Services / 26
Glossary of Terms / 27

NHS Primary Care Contracting Index 2

Introduction

Following the introduction of local commissioning for NHS dentistry on 1 April 2006 PCTs have a statutory responsibility to formally review the performance of NHS dental providers against the requirements of their GDS contracts and PDS agreements.

The NHS Primary Care Contracting Team (PCC) was approached by PCTs to offer a steer on good practice relating to monitoring the new contracts. As a result of these requests we have developed a comprehensive contract monitoring toolkit to support PCTs in assessing contractors’ delivery of their NHS commitment, including looking at quality. This contract monitoring tool has based primarily on the General Dental Services contract. PCTs can, however, adapt the toolkit locally to meet the requirement of monitoring PDS agreements.

The toolkit consists of a suggested process, a monitoring framework and assessment tools with workbooks covering access, governance, quality and activity/finance. For the purpose of allowing the PCT to gather evidence, each assessment tool is categorised under one of the following three sections:

Section A - information a contractor submits to the PCT following self-assessment

Section B - evidence seen by the PCT during a monitoring visit

Section C - information the PCT holds which is forwarded to the contractor prior to a monitoring visit.

It should be stressed that the toolkit is all inclusive and something which PCTs could be using over the next few years – hopefully focusing on particular workbooks (or part of workbooks) each year. In the first year in particular, PCTs should be mindful that the local contract is a new way of working for practices and should be sensitive to how the contract is working from the contractor’s perspective.

It is recommended that PCTs approach contract reviews in a supportive and developmental, rather than a confrontational way, and seek to understand how contractors are delivering the activity. Keeping monitoring to a realistic minimum in the first instance, by applying a light touch approach and using a few key areas from this overall contract monitoring framework with each practice will bring significant benefits in the longer term. Sharing the overall contract monitoring framework menu with dentists is sensible, as long as PCTs make it clear that only a small part of it will be used for monitoring each year.

Although PCTs may wish to design and implement their own contract monitoring arrangements, PCC felt that it would be helpful to develop this common resource, which could help to avoid unnecessary duplication by PCTs – particularly at a time when many PCTs are undergoing considerable change. PCTs may of course, also add any additional locally agreed monitoring criteria to the framework they feel is appropriate.

This toolkit concentrates mainly on contractual obligations although PCTs will also need to carry out monitoring in relation to clinical governance requirements. A separate clinical governance framework has been developed and is available on the PCC website – www.pcc.nhs.uk. A comprehensive assessment tool is being developed to support this and will be available shortly.

NHS Primary Care Contracting Introduction 3

Principles

Principles underpinning the contract monitoring toolkit

· Consistency

It is important when monitoring the new dental contract that PCTs take a consistent and fair approach. Monitoring the new contract for dentistry should be in line with other key workstreams and principles adopted across NHS organisations/staff groups and providers locally and nationally, and be generally the same wherever it is applied in terms of location or type of provider. This should not detract, however, from allowing some local flexibility.

PCTs can adapt this national contract monitoring toolkit locally to meet the requirement of monitoring PDS agreements.

· Collaborative/Supportive

Engagement of potential stakeholders in the development and implementation of the monitoring toolkit will be crucial in order to maximise the opportunities for quality improvements in dental services. PCTs should seek to develop and maintain a constructive relationship with all dental contractors, and are likely to find it useful to discuss monitoring plans with their Local Dental Committee.

· Clarity of purpose

Monitoring should have a clear purpose and be legally robust in order to justify PCT decisions on contract management. PCTs should approach contract monitoring with this in mind. This document should be read in conjunction with PCC’s document entitled “Hints and Tips about Dental Contract Monitoring” issued in August 2006.

PCTs should be clear about the aims and objectives of any review and ensure they are as open and transparent as possible. PCTs should provide contractors with details in advance of the scope of a review, including information about any preparation required of the contractor and who from the PCT will be attending.

PCTs may decide not to visit all practices formally in the first year, but if they do this they will have to ensure that practices understand the PCT’s reasons and criteria for taking a differential approach. Openness is a key aspect of contract monitoring.

NHS Primary Care Contracting Principles 4

Monitoring and Development Process

The NHS (General Dental Services Contracts) and (Personal Dental Services Agreements) Regulations 2005 require PCTs to carry out mid-year and annual reviews. These are very much inter-related and PCTs should follow a structured approach to the whole exercise.

This part of the document describes a typical monitoring and development cycle for both the mid-year and annual review and suggests a step-by-step process to be followed when undertaking an annual review.

The following cycles for the mid-year and annual reviews have been developed using the familiar PDSA cycle. They are designed to demonstrate not only how the monitoring review cycle may be developed internally within a PCT but also to show how the two reviews are intertwined and integral to each other. They also demonstrate how contract monitoring can be used in a supportive and developmental manner.

In addition, PCTs have a responsibility for assessing and managing risk within the new dental contract and for dealing with suspicions or allegations of fraudulent activity. This is obviously a very sensitive issue and it is therefore important that any work undertaken is carried out in a comprehensive, integrated and professional manner

The NHS Business Services Authority (BSA) through the Dental Practice Division (DPD) and the Counter Fraud and Security Management Division (CFSMD) can provide critical support and advice. The DPD and CFSMD work together to routinely review risk areas, data trends and other concerns that may indicate an underlying problem and will be proactive in sharing their findings with PCTs.

PCTs may also contact the BSA if they have concerns about their providers for support and advice.

More information about the roles and responsibility of the DPD’s Information and Risk Management Service can be found at www.dpb.nhs.uk and details of the work the CFSMD carries out across the NHS can be found at www.cfsms.nhs.uk

Mid-year Monitoring and Development Cycle

NHS Primary Care Contracting Monitoring & Development

Process

Annual Monitoring and Development Cycle

These points are explained in further detail in the Step-by-Step process contained within this monitoring tool

Monitoring and Development Process Chart

NHS Primary Care Contracting Monitoring & Development

Process

Step-by-Step Process

The annual contract monitoring process follows a logical step-by-step path. These steps are designed to guide you through the process and are by no means prescriptive or exhaustive.

Planning

Step one. Undertake a risk assessment using the contract monitoring framework to establish and prioritise which of the four areas, or part of the areas, (Governance, Activity & Finance, Quality and Access) will be monitored each year. (The workbooks have been designed to be used either as a whole document or to allow PCTs to select the areas to be monitored.)

Step two. Once the areas to be monitored have been established and any local monitoring criteria have been added (optional), it is recommended that the PCT discuss its monitoring plans with the Local Dental Committee (LDC).

Step three. The PCT should develop internal processes to ensure any data required to support the monitoring process is available at the time of the annual review.

Step four. Develop and agree the process that will be followed. The process should include responsibility for the process, timescales, identifying who will be involved with the review and ensuring there is capacity within the PCT.

Step five. Obtain Board approval for the chosen monitoring tool and monitoring process.

Step six. Share and explain the monitoring tool and process with all of the General Dental Practitioners (GDPs) in your area. Issue guidance to all GDPs about how the process will work, what you will be monitoring and the timescales.

Step seven. Prioritise the Contractor reviews using data from the mid-year review, the complaints department, clinical governance and dental surgery visits.

Step eight. Schedule the review visits with the Contractor.

Doing

Step one. Collect and collate all of the evidence that is available from within the PCT, the NHS BSA (Dental Practice Division) or other professional bodies. Populate Section C of the monitoring workbook for each contractor.

Step two. Send Section A of the monitoring workbook (for completion) and Section C (for comments) to the Contractor, allowing ample time to return prior to the visit.

Step three. Once Sections A and C of the workbook have been returned to the PCT, analyse the information and circulate to all members of the review team. This information will form the basis of the agenda for the review visit with the Contractor. It is recommended that you share the documentation with the Contractor prior to the visit.

Step four. Conduct the review visit and complete Section B of the monitoring workbook.

Step five. Analyse the data from all three sections of the workbook and write a draft report, which should be sent to the Contractor and members of the review team for factual validation.

Step six. Once the draft report has been validated - finalise the report and send a copy to the Contractor.

Step seven. Write an overall summary report of all reviews and present to PCT Board.

Step eight. Request feedback on the monitoring process from the Contractor.

Studying

Step one. Review and reflect the outcomes of the review visit and the feedback from the Contractor within the PCT.

Step two. Identify any areas for development that may have been highlighted by the report and discuss these with the Contractor. These areas could be either with the individual Contractor or more generic areas that can be addressed at PCT level.

Step three. Identify any areas of concern highlighted by the reports.

Step four. Review the monitoring process.

Acting

Step one. Draw up an action plan to address areas for development and any training needs and discuss these areas with the Contractor and LDC.

Step two. Report all areas of concern to the appropriate departments for action, as necessary.

Step three. Feed the conclusion of the monitoring process into the PCT’s future investments and strategic planning, as appropriate

Step four. Modify the monitoring process, if necessary, and prioritise the areas for future review.

NHS Primary Care Contracting

Dental Contract Monitoring Framework

Guidance Notes

The Framework

Whilst it is important that the whole contract monitoring process is open and transparent, it is not necessary for PCTs to send a copy of the whole contract monitoring framework to every dentist. It is intended as a guide for PCTs to use in their own organisations. However, where the PCT does decide to share the whole monitoring toolkit, it is recommended that the PCT sets it into the appropriate context making it clear that only a small part of it will be used for monitoring each year.

The framework is based on the standard General Dental Services Contract and has five main elements. The elements are: Clause, Explanation, Suggested Evidence, Assessment and Type. See the diagram below for an overview of the elements.

1. Section of Contract: This title bar refers to the section of the General Dental Services Contract from which the Clause has been taken. It has been included for ease of reference.

2. Clause: Each clause within the GDS contract that requires an action by the Contractor has been included within the monitoring framework. It is these clauses that form the basis of the monitoring tool.

3. Explanation: This is a brief explanation of the clause.

4. Suggested Evidence: These are the suggested measures that could be used by the PCT to determine if the Contractor is complying with the terms of their contract.

5. Assessment: For the purpose of allowing the PCT to gather evidence, the suggested evidence has been divided into Sections A, B or C. These letters denote how and when the suggested evidence may be gathered.

A. This evidence will be gathered when the dentist completes the self-assessment workbook. It is recommended that this data is collected and analysed prior to the review visit.

B. This is the supporting or physical evidence that would need to be seen or discussed with the Contractor during the review visit.