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Feedback Document for PPG July 2018


The Patient Participation Group (PPG) was unhappy with the language used within the letter to patients issued on 17.04.18 which was produced with support from West Hampshire Clinical Commissioning Group Communications Team ( In particular the PPG felt the last paragraph was ambiguous. They have specifically requested clarification on the following points to help patients understand our current situation:

Query from PPG

Reference "leverage the capabilities across the wider Living Well Partnership (LWP)" refers to:

  • ​Sharing of reception resource when St Luke’s and Botley were struggling to cover shifts through holiday and absence
  • A LWP locum Nurse holding respiratory clinics at St Luke’s and Botley
  • A LWP locum Advance Nurse Practitioner (ANP) supporting same day service at St Luke’s
  • LARC (Long Acting Reversible Contraception) for St Luke’s and Botley patients being provided via Ladies Walk surgery
  • Support from LWP GP's with Minor Operations clinics
  • LWP GP cover for key clinical sessions
  • Additional admin support being seconded from LWP
  • Triage being reviewed across sites
  • A CQC action team made up of LWP Partners and staff from multiple LWP locations 

1. What does "special measures" actually mean?

​​This terminology comes from the Care Quality Commission. Inspection report and refers to the inadequacies of key lines of enquiry resulting in a breach notice being served. The new LWP structure that has been implemented, empowers us to address and resolve these issues using shared services across the group.

CQC defines ‘special measures’ as - The special measures process is designed to ensure there is a timely and coordinated response where we judge the standard of care to be inadequate.

The purpose of special measures:

We want to ensure that services found to be providing inadequate care do not continue to do so. Therefore we have introduced special measures. The purpose of special measures is to:

  • Provide a clear timeframe within which providers must improve the quality of care they provide or we will seek to take further action.
  • Provide a framework within which we use our enforcement powers in response to inadequate care and work with, or signpost to, other organisations in the system to ensure improvements are made.
  • Ensure that providers found to be providing inadequate care significantly improve.

 2. What does it actually mean for the surgery to be "part of the Living Well Partnership" in real terms - they are seeking an assurance that CQC fully understand this too, as they have determined from CQC report that this did not seem clear.

​​There was concern from LWP and the PPG that the original CQC report contained a misinterpretation of the relationship between St Luke’s and Botley and LWP. This was challenged following both the first and second reports, in March and July 2018. Following finalisation of the second report, we have been advised by the CQC that they have made partial amendments to the phraseology used in the report, whilst changes to the registered status of St Luke’s and Botley following the merger, are concluded.

In real terms, the merger has involved the previous partners of St Luke’s and Botley becoming partners of LWP as a whole. All 14 Partners now have shared responsibility for the delivery of contracts for both Southampton and West Hampshire CCG’s.

Following the merger, a new organisational structure has been implemented whereby individuals or teams manage functions across LWP as a whole. E.g. we have one clinical Prescribing Lead for LWP; we have one team that manages Performance across LWP; we have one combined Central Services Team responsible for HR, facilities and finance for all practices within LWP.

3. There is a real concern within Botley that this branch surgery will close - reassurances required (this was provided verbally at meeting but they are looking for ways that this message can be communicated to the wider patient population group.

At this point there is no intention to close the Botley branch surgery. This is a branch of the main St Luke’s site and like other branch sites; it is vulnerable when resource is stretched. It is not viable to operate the branch site at times when the clinical resource is required at St Luke’s , but we are making every effort to ensure that Botley remains open during agreed times.

Our new LWP Nursing Services Lead (Abi Nelson) has provided the following up-date in relation to nurses working on-site without a GP present: “I have now clarified with the Medical Defence Union (MDU) that we are not insured for nurses to perform any invasive procedures including blood tests, smears, injections and ear irrigations without a GP present on site.  The underwriters have clarified that an Advanced Nurse Practitioner is not sufficient and we would be operating outside of MDU requirements.

The Nursing & Midwifery Council (NMC) requires all nurses to be covered by professional indemnity insurance in order to remain on the register. This means we need to ensure any clinic hours that are booked without a GP on site are filled with non-invasive appointments such as BP's / Asthma checks etc”. 

In addition, our same day / urgent care service, to which our ANPs are crucial, is operated from our main St Luke’s site on a daily basis, so we need to ensure sufficient ANP support is provided for this.

4.What "support" is the practice receiving and from whom whilst we are in "special measures"?

  • ​​Internal LWP support (as previously identified)
  • CCG support by way of regular resolution and support meetings, assistance with our infection control audit and the work required as a result of this, the sanctioning of Ladies Walk as a branch site of St Luke’s and Botley to allow specified clinics for patients to be held there (LARC's as explained above) and access to the CCG communications team. We hope to be able to provide copies of the partner approved patient communications to the PPG prior to general release. The CCG are also offering support with our Complaints and Significant Event reporting processes.
  • A request for a Premises Improvement Grant (via CCG) has also been submitted, to assist in the funding of the additional works identified, following the initial CQC inspection. We have of course already funded some of the more immediate and necessary work such as electrical circuit and water hygiene testing, for example.

5. The PPG require a full up-date on the merge process to-date, progress made against plans / timescales.

The merger that took place in October 2017 was a Partnership merger and not a merging of the "J" codes (A “J” code is a way of identifying different practices – St Luke’s and Botley have a different “J” code to the Southampton sites within the LWP Group.) LWP will continue to work across J codes and CCGs.

The practical benefits of the merger include combined resource, expertise and ability to work more efficiently in areas such as IT and HR. Staff and clinicians have access to the clinical records across all sites, which again provides efficiencies and centralises many of our clinical and business functions. In a short time, we have noticed the benefit of sharing nursing and GP resource that has started already. Some patients may be familiar now with Dr Hughes, Dr Freeman, Dr Sanford and Dr Davies, each of whom has held clinics at St. Luke’s and Botley.

6. A full explanation regarding the commentary in CQC report referring to "above average exceptions"

"Exception reporting" occurs when a patient has been invited on three separate occasions to attend a clinical review (such as an Asthma review) and has declined to attend or has simply not responded. St Luke’s and Botley had a slightly higher than average exception reporting rate for asthma and COPD specifically (St Luke’s and Botley: 14.4% compared with local average of 12.1% and WHCCG average of 11.5%). CQC requested evidence to support our exception figures, which was provided by records of invitation letters sent and decline slips received. Whilst exception reporting figures are largely outside of our control, we are making every effort to improve the figures by:

  • creating an overarching Performance team to manage this function across all sites;
  • implementing a revised patient recall process across LWP; and
  • improving patient education and communications, via the posters on display at main surgery sites, to encourage attendance.
  • Improving telephone systems in recognition that some patients may have failed to respond due to difficulty getting through to the surgery.

We are also reviewing our appointment provision to accommodate these chronic disease management appointments and have recently secured the services of an additional locum nurse to hold weekly respiratory clinics.

7. The PPG raised the expectation documented in PPG minutes dated 27.3.18 that they would be invited to join in and contribute to our CQC working group, to support the practice.

It is not appropriate for non-staff members to attend CQC meetings. We apologise for any previous misunderstanding on this point. Key up-dates will be provided following each CQC Inspection report published.

8. The PPG would like the webpage up-dated to reflect above once clarification has been agreed and they wish to participate in the wording of the revised up-date displayed. They feel an up-date on the outcome of the DPA breach needs to be incorporated too. They mentioned that they feel that the practice would benefit from promoting our positive response to this CQC inspection by joining local social media / facebook / twitter.

An up-date will be provided following the publication of the second CQC report and the West Hants CCG Communications team will assist with the wording of this. We hope to be in a position to provide the PPG with advanced sight of this, once the statement has been approved by the Partnership.

Information regarding the previous Data Protection Act breach in February was up-dated on the website. This was reported to the ICO (Information Commissioner's Office) in accordance with LWP guidelines and it was recognised that this failing was due to human error. Revised internal procedures have been implemented to avoid repetition and this matter is concluded.

Social media is something we would like to consider in future but we recognise that it requires close monitoring and regularly updating. At present, our priority is to centralise and update our websites and this work is currently underway. 

We recognise the importance of our recent CQC inspection, which highlighted many positive aspects including the delivery of high quality patient care and the time and care shown by staff. We hope to portray this in the up-dates that we provide, which will also highlight the improvements implemented to enhance our overall service delivery.


If you have any concerns or questions, please contact the surgery on


This document has been produced by the PPG chair Teresa Griffin, and PPG secretary Carol Duncan in conjunction with LWP’s Operations Director, and Patient Services Manager on the 4th July 2018.

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