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Risk
Details
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Risk Code
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Risk
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Responsible Officer
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Committee
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Issue Type
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Risk Treatment
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Current Risk Score
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Target Risk Score
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Eff. of Control
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SR13
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Not
keeping adults safe from harm and abuse
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Executive
Director Health and Adult Social Care
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Adult
Social Care Public Health Sub-Committee
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Threat
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Treat
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Revised:
Uncertain
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Causes
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•
The council has a duty to keep adults, for whom they have statutory
responsibility for, safe from harm and abuse. Brighton & Hove
City Council has a statutory duty to co-ordinate safeguarding work
across the city and the Safeguarding Adults Board. This work links
partnerships across the Police and Health and Social Care
providers.
• Under the Care Act, since 2015, the Local Authority has a
statutory duty to enquire, or cause others to enquire, if it
believes a person with care and support needs is experiencing or is
at risk of harm and abuse and cannot protect themselves.
• There has been an increase in safeguarding concerns
received, increase in complexity of adult social care packages and
unknown demand in the context of Covid-19 recovery
• There is not enough appropriate accommodation and services
in the city for those with significant and complex needs or
specific needs such as ABI, Physical Disability, Learning
Disability or Mental Health
• Due to workforce shortages in the domiciliary care market,
challenges to commercial viability and increased pressure for
council’s responsibility on quality monitoring, there is
higher risk of provider failure
• Changes to government legislation and funding, pressures on
the health and care system as a whole and pressures on resourcing
and budgets across the sector with rising costs in the provider
market
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Potential
Consequence(s)
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•
Failure to care for and safeguard adults properly could result in
death, abuse, neglect or injury to individuals.
• Failure to meet statutory duties could result in legal
challenge and reputational damage to the organisation and public
trust
• Inequalities could be created in terms of how disadvantaged
groups of our community i.e. multiple and complex needs can access
care and support services
• Provider market costs continue to rise which could lead to
overspend of budget to meet statutory responsibility
• Service users may need to move out of the city to receive
services required
• People are placed in inappropriate accommodation which may
present a danger or risk to them or others and people may not get
the appropriate services and support to address their needs
• Any failure of delivery across the health and care system
could impact on costs and pressures throughout the system and
frustrate attempts to release efficiency savings and improve system
performance.
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Existing
Controls
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First
Line of Defence: Management Controls
1. Performance management across adult social care enables a more
informed view on current activity and planning for future service
changes and reviewed monthly by Finance & Performance Board. A
BHCC Safeguarding Adults performance dashboard is provided
monthly.
2. Directorate Management Team (DMT) oversee developments and
monitor risks.
3. Brighton and Hove Safeguarding Adults Board (BHSAB) work plan
and multi-agency partnership commitment. Multi agency safeguarding
adult procedures are in place, for preventing, identifying,
reporting and enquiring into allegations of harm and abuse, in line
with Care Act requirements, endorsed by all 3 Sussex Safeguarding
Adults Boards. Front line practitioner and manager events are
provided within every Safeguarding Adults Review and our senior
management team ensure attendance for reflective and systemic
learning and engagement.
4. Dedicated resources for: safeguarding adults S.42 decision
making; oversight, specialist advice and guidance of complex people
in a position of trust; input into Domestic Homicide multi agency
review panel; co-ordination of all Deprivation of Liberty
Safeguards (DoLS) referrals in line with statutory requirements;
continuous professional development requirements in line with
Social Work Professional Capabilities Framework
5. Safeguarding referrals can be made by anyone including other
professionals, GPs, Police, neighbours, friends. Safeguarding
referrals are assessed by Social Workers.
6. BHCC Quality Monitoring Team oversee process in place to monitor
quality of adult social care providers, in partnership with NHS
Sussex and Care Quality Commission (CQC), which supports quality
and preventative safeguarding objectives. A monthly Service
Improvement Panel which is multi agency, meets to discuss emerging
themes and preventative responses and is a robust effective risk
mitigating factor.
7. A Practice Development Assurance Board is in place and meeting
monthly to consider practice development and assurance areas of
focus bringing updates from internal partners and data share.
8. Learning from Safeguarding Adult Reviews (SARs), monitored
through SARs subgroup of BHSAB and a dedicated Safeguarding Lead
post who ensures we are involved in responding, liaising and
prompting other internal partners and in contributing to learning
and development within our system. Accessibility to service
provision is a key consideration in learning from SAR, systemic
change where needed and improvement for adults experiencing risk
and disadvantage at the fore of the shared multi agency
approach.
9. Homelessness Transformation Programme
10. Housing Allocations Policy framework
11. The Health and Wellbeing Strategy is delivering the Joint
Strategic Needs Assessment on people with multiple and complex
needs as part of its Living Well and Ageing Well Workstreams.
The Changing Futures Programme (Sussex wide) is in place with
external partners and organisations to consider this area and
systemic change, development and training needs to bring the system
together to consider development needs in this area.
12. Provider failure business continuity plans are in place
13. Provider partnership working through forums, working groups and
partnership boards
Second Line of Defence: Corporate Oversight
1. Pan Sussex Safeguarding Adults procedures group - robust
partnership group producing specialist procedural guidance across
the Sussex area and protocols and meets quarterly with working
groups between to complete multi agency tasks together.
Strong multi agency working together is featured consistently and
is Sussex wide so takes a broader view. Protocols and
guidance designed and issued is often across the County which
provides a stronger collaborative approach.
2. Health & Wellbeing Board oversees Joint Health &
Wellbeing Strategy and BHSAB annual report.
3. Adult Social Care & Pub Health Subcommittee oversees
effective social care commissioning.
4. Care Governance Board oversees quality monitoring of care
services and attended by CQC.
5. Learning Disability Governance Group ensures robust links
between directorates for LD services.
6. Service Improvement Panel – with multiagency partners,
including CCG, to share inspection results, complaints and other
issues for care provider quality.
7. Mental Health Oversight Board
8. Housing Committee
9. Strategic Accommodation Board meets to focus on vulnerable
adults and children within the housing strategy
10. Homelessness Reduction Board (HRB) promotes reduction and
prevention of homelessness, it is chaired by the Chair of the
Housing Committee.
11.
Prevent Board
12. Practice Development Assurance Board meets monthly to focus on
Social Work Quality Assurance. The Principal Social Worker
chairs this and the Safeguarding Adults Lead will attend on
Safeguarding assurance matters.
13. The Audit & Standards (A&S) Committee reviewed SR13 in
April 2022.
Third Line of Defence: Independent Assurance
1. For the council's in-house registered care services Care Quality
Commission (CQC) Inspections on an on-going regular
basis.
2.
CQC's programme of inspections of all registered care providers are
published weekly and available on CQC's website www.cqc.org.uk.
These are monitored for local relevance by the council's Quality
Monitoring team.
3. Brighton & Hove Safeguarding Adults Board (BHSAB) is
independently chaired and meets quarterly with the three statutory
agencies for city wide safeguarding assurance. The subgroups
are always attended by HASC. The Safeguarding Lead is a
member of the SAR panel (multi agency, chaired by independent
sector) where referrals for reviews are discussed in
depth. Input is provided in a robust manner for all
reviews and related pieces of work for example multi agency audits
and action plan reviews required by SAB.
4. Internal Audit
* 2022/23: Care Payments (Reasonable
Assurance)
*
2021/22: HASC Modernisation Programme (Reasonable Assurance),
Direct Payments (Partial Assurance), Home Care (Reasonable
Assurance)
* 2020/21: Hospital discharge arrangements
(Reasonable Assurance), Care System Replacement Project –
Eclipse (Reasonable Assurance)
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Risk
Action
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Responsible
Officer
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Progress
%
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Due
Date
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Start
Date
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End
Date
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Ensure
there are appropriate services and support for people with care
needs in the city
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Assistant
Director of Commissioning and Partnerships
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50
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31/03/24
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18/11/21
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31/03/24
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Comments:
There
are a number of projects currently underway to recommission a range
of services including care homes, home care & extra care,
supported living, community support, mental health provision and
equipment services. These contracts are due to be over the
next 24 months. There is specific work being completed to
understand the need in the city and engage with key stakeholders.
We have recently reviewed feedback from the service user and carers
surveys and action plans are being developed. The Authorisation
Panel meets once a week and consists of staff across Adult Social
Care and the commissioning and assessment teams meet regularly to
understand any current gaps in services and where further
commissioning activity is required.
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Ensure
there is appropriate accommodation and support for vulnerable
homeless and rough sleepers
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Assistant
Director Housing Needs and Supply
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50
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31/03/24
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18/11/21
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31/03/24
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Comments:
Our
Rough Sleeper and Single Homeless Service continues to support
vulnerable homeless and rough sleepers across the city.
In the latest Rough Sleeper count, which took place in November
2021, 37 people were found sleeping rough. This is down 57%
compared to the 2019 count.
The service is currently providing 891 bed spaces to vulnerable
homeless and rough sleepers, and the majority of these bed spaces
are in supported accommodation where residents receive additional
support with their needs, such as mental health.
Alongside this the service is also:
• Increasing its Housing First stock to 90 units
• expanding its team of Welfare Officers to support people in
emergency accommodation
• purchasing 30 new homes for rough sleepers as part of its
Rough Sleeper Accommodation Programme (RSAP)
• leasing 30 properties from private landlords for rough
sleepers with a lower level of need
• working with No Second Night Out and Off the Street Offer
providers to help rough sleepers into settled accommodation
• continuing to deliver the Rough Sleeper Initiative (RSI) and
revising our Homelessness and Rough Sleeping Strategy Action
Plan
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High
quality social work is provided to ensure that adults are
effectively safeguarded
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Principal
Social Worker
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75
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31/03/24
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18/11/21
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31/03/24
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Comments:
The
Practice Development and Assurance Board (PDAB) has been
operational since December 2021. The Board is responsible for
the oversight of all practice assurance and development needs,
including the monitoring of training targets and identification of
emergent gaps and need.
A
new audit framework to evaluate the quality of social work/practice
interventions has been developed. Practice audits will evaluate
quality across a range of statutory care and support planning
interventions. Audit outcomes will inform future practice
development and assurance needs. Practice Audits for Q3 2022 have
been completed as part of piloting the new framework and will
report through the Practice Development and Assurance Board in
February 2023. The new practice audit framework will go live
across all adult social care assessment services from January 2023.
Audits will be conducted within agreed targets and will continue to
report through PDAB and DMT on a quarterly basis to ensure that
targets are met and that actions are agreed to support practice
improvement where necessary.
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Provide
assurance and support to reduce the risk of provider failure in the
city
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Assistant
Director of Commissioning and Partnerships
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90
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31/03/24
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18/11/21
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31/03/24
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Comments:
Provider
failure plans have been updated and signed off by BHCC and NHS
Sussex. Alongside this continued governance arrangements are in
place through the use of incident management meetings and the role
of our public health and quality monitoring and commissioning teams
to support providers both in terms of covid related activity and
ongoing provider quality issues. The Care Governance Board also
provides strategic oversight of quality and provider failure issues
jointly with health partners and regulators of services.
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Provide
assurance of safeguarding adults arrangements across the council
and with our partners
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Safeguarding
Lead
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58
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31/03/24
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01/04/21
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31/03/24
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Comments:
Risk
Response Actions:
1. Ensure meaningful learning across the directorates and
with our partners from Safeguarding Adults Reviews, Domestic
Homicide Reviews, Coroners inquests and case reviews
Dec 22 – 75% completed. All work of the BHSAB continues
with the Local Authority a statutory partner. The James SAR
(ABI) action plan/Reg 28 progress continues to present some more
challenges areas (ABI commissioning pathway for SW undertaking MCA
Mental Capacity Act Assessment) being taken forward by the
Safeguarding Adults Lead over a period of months and being
escalated through the SAB and ICB. This is now progressing to
a multi-agency round table discussion with specialist ABI partners,
supported by workforce development team which is positive
progress. SAR Andrew (LD) has been completed and cross
directorate action planning completed with a high level of
meaningful engagement and actions from LD assessment and provider
services. SAR Craig is in progress and nearing conclusion
having held a learning event well attended by HASC safeguarding,
assessment services and Principal Social Worker. The thematic
SAR regarding women with multiple and complex needs has been
completed and is nearing action plan stage and links to the JSNA
and changing futures programme who have successful started a
multi-disciplinary team in assessment services to work with people
with multiple and complex needs where significant complexity
factors and challenges exist, this is beneficial as supports access
for this service user group and acknowledges the complexity.
Updates for HASC directorate will be fed into the Practice
Development Assurance Board and Safeguarding Development Group to
ensure awareness engagement in SAB partnership development work and
collaborative oversight. The Brighton and Hove SAB have co
funded a SAR review in East Sussex regarding a young adult, with a
transitions theme which is very relevant to safeguarding in our
area and of useful learning. An increase of SAR referrals
continues to be noted locally showing an increased awareness of
this process, HASC are engaging with all review referrals and the
SAR process via the safeguarding adults lead, providing summaries
of information where needed.
The Directorate has developed an internal safeguarding development
meeting held with the Principal Social Worker Safeguarding Adults
Lead and Social Work Practice Managers on a monthly basis and
therefore increased oversight of SAR referrals and any areas we can
respond to proactively is occurring. % Safeguarding outcomes
met is now a corporate KPI which is monitored by the Performance
Lead and Safeguarding Adults Lead with engagement from front line
teams a key aspect to this measure. Engagement actions with
all operational front line social work teams are being completed by
the Safeguarding Adults Lead and improvements to the eclipse
database are actions which are being brought in to enhance the
reporting and accuracy of this data and its narrative.
2.
Provide Assurance that mandatory PREVENT training is embedded in
all training induction and development plans within the
organisation to support effective identifiers and that the referral
pathway is known
Dec 22 - 30%. Strategic training updates on this area are included
in a set of workforce development mandatory training dashboards
(quarterly) % accessed training remains low but efforts will
continue to monitor this and work on improvements regarding take
up. Communication messages (learning and development and in
the loop newsletters) have requested staff completion and
highlighted the mandatory nature of this training completion and
request). Training levels remain low and have not increased
significantly. Oversight of this is currently significantly
reduced as the training accessed is picked up via the Learning
Gateway which has recently been decommissioned in September.
A variety of improvement measures have been completed in 2022 so
far, for example a pathway for Prevent information coming into HASC
has been mapped out by the Safeguarding Adults Lead with key
internal stakeholders in recent months and is in place. This
month this pathway has been reviewed following feedback from the
Prevent Lead, which increases the expertise involved in oversight
of Prevent information leaving and coming into the directorate at
front line operational level. The Channel Lead has provided
bespoke training sessions on Prevent to front line assessment teams
identified by the Safeguarding Adults Lead which will raise the %
training completed figures and importantly, awareness. A
Prevent and Safeguarding chapter has been written by the
Safeguarding Adults Lead and is now included in the Sussex wide
safeguarding adults procedures which should support multi agency
awareness of this important area.
3. Provide Assurance that recognising reporting and
responding to abuse and neglect is embedded and that safeguarding
training (appropriate to role and task) is being provided to staff
across the organisation and offered to partners
Dec 22: 45% ongoing monitoring of uptake of safeguarding training
is in place within the organisation and continues to be offered to
all staff in applicable roles, and to partners, for example causing
others training and basic awareness, with refreshers offered
proactively by workforce development for front line assessment
social work staff. Oversight of this is currently significantly
reduced as the training accessed is picked up via the Learning
Gateway which has recently been decommissioned in September.
4. Seek Assurance and post acute COVID review to assure there is a
comprehensive clear Disclosure and Barring Service (DBS) check and
recheck process in place which reduces risk to the organisation and
to the community
Dec 22: Oversight of DBS rechecks is in place in Human
Resources.
5. Ensure effective partnership working across directorates and
with external partners to deliver a robust supportive and safe
process for the Ukrainian Refugee Hosting Scheme
Dec 22 - Since April 22 HASC have actively supported since the
development and design of new processes, working with all partners
to support the scheme and meet local authority responsibilities,
including where potential risk issues and concerns arise regarding
hosts either pre placement or once guests are in situ. Safeguarding
concerns are picked up proactively with multi agency working groups
and collaborative partnership working is strong.
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