Case Number 6521
Request Date 05/02/2019
Completion Date 06/02/2019

 

Details of the Request

1) What is the name of: a) your trust b) the hospitals run by your trust

2) Has your trust produced a report looking at the impact on your trust and its operations in relation to the possibility of a ‘no-deal’ Brexit (EU exit) in March? If yes, please attach the report(s).

3) Is your trust currently undertaking any preparations/arrangements in relation to a no-deal Brexit in March? If yes, please give details or attach any reports produced by the trust which looks at the impact / preparations / arrangements.

4) Has the trust undertaken any reviews or risk assessments into the following areas that could be affected by a no-deal Brexit. If yes, please give details or attach reports.

  • Supply of medicines and vaccines
  • Supply of medical devices and clinical consumables
  • Supply of non-clinical consumables, good and services
  • Workforce
  • Reciprocal healthcare
  • Research and clinical trials

5) Has your trust budgeted any additional money for contingency planning for / due to the impact of the UK’s exit from the EU in March and the potential no-deal Brexit?

 

Details of the Response

1) What is the name of:

a) your trust:

Ashford & St Peter's Hospitals NHS Foundation Trust

 

b) the hospitals run by your trust:

Ashford Hospital, Surrey; St Peter's Hospital, Chertsey, Surrey

 

2) Has your trust produced a report looking at the impact on your trust and its operations in relation to the possibility of a ‘no-deal’ Brexit (EU exit) in March? If yes, please attach the report(s).

Yes, this was considered by the Private Trust Board and consequently is not publically available.

 

3) Is your trust currently undertaking any preparations/arrangements in relation to a no-deal Brexit in March? If yes, please give details or attach any reports produced by the trust which looks at the impact/preparations/arrangements.

Yes, this was considered by the Private Trust Board and consequently is not publically available.

 

4) Has the trust undertaken any reviews or risk assessments into the following areas that could be affected by a no-deal Brexit. If yes, please give details or attach reports.

Yes

 

Brexit Specific Risks - Impact & Likelihood Assessments

1. Supply of Medicines & Vaccines

Rationale for Impact and Likelihood Assessment:

Brexit ‘no deal’ poses risks to the continuity of medicines supply i.e. sufficient supply and seamless supply. This is likely as a result of the impact of a no deal Brexit arrangement on the regulation of medicines (& marketing authorisation), supply chain (for medicines that have to cross the border between the European Union and the United Kingdom) and pricing (changes in tariffs and impact on drug prices).

Disruptions to medicines supply can have major impact to patients/patient care, namely; inability to deliver care in a timely manner; interruptions to services and patient care; deteriorating of patients; inability to deliver lifesaving treatments.

  • The Impact assessment is scored at 5.

 

The current state of government Brexit negotiations presents no deal Brexit as a highly likely outcome.

  • The likelihood assessment is scored at 4.

 

Key Risks: including are there any medicines that normally run at low stock levels, and therefore have increased Brexit risk?

Changes to custom checks in the event of a no deal Brexit could extend supply chains and cause delays to delivery of medicines whose entry into the UK medicines supply market involves border entry through the ports i.e. UK imports – products not manufactured in the UK.

The following medicines or class of medicines have been identified nationally as being particularly susceptible to the no deal Brexit concerns (because they are not manufactured in the UK and are wholly imported into the UK).

  • Insulins
  • Some medicines with particularly short shelf life (some cancer medicines and radioisotopes)
  • Vaccines requiring refrigeration

List not exhaustive as there is a lack of clarity about which medical products could be affected due to the complex nature of supply arrangements. Deviation from European medicines regulation and legislation in the event of a no deal Brexit could also delay access to new medicines and their marketing authorisation in the UK.

 

Mitigation:

  1. Optimise business as usual stock levels and review of stockholding (note: national guidance not to stockpile locally)
  2. Managing current stocks and prioritising supply to patients/service areas
  3. Engagement with local clinical teams on the use of substitutes and identifying alternatives if there are shortages
  4. Contacting NHS supply chain, wholesalers, manufacturers regularly to determine stocks, obtain clarity on supply arrangements and resolve supply concerns
  5. Setup an active record of drug shortages and supply issues on the Trust pharmacy web page and provide regular updates.
  6. Establish ‘Surrey ICS pharmacy no deal Brexit planning group’ to manage the impact within Surrey. The proposed will deliver
    • weekly teleconference calls to share intelligence around supply problems
    • recommend alternatives if there are shortages
    • identify vulnerable groups who may be disproportionally adversely affected and plan for mitigation
    • identify any local issues and solutions that should be escalated to NHS E/I & others
  7. Assurance from DSHC and Association of British HealthTech Industries (ABHI) of holding more than 6 weeks national stockpile of medicines in the system as part of contingency plans in case imports from the EU through certain routes are affected.
  8. Assurance from DSHC of prioritising arrangements for the air freight of medicines in case imports from the EU through certain routes are affected

 

2. Supply of Medical Devices & Clinical Consumables

Rationale for Impact and Likelihood Assessment:

There is a potential for shortages of critical Medical Devices & Clinical Consumables due to increased time for imports to clear customs in the Brexit no deal situation. The Trust and NHS, should not stock pile for the following reasons:

  • The Trust have been advised by NHSI directly not to stock pile
  • This creates risk for the wider NHS
  • Added cost
  • Risk of supplies going out of date
  • Lack of space

 

Given we cannot stock pile then the risk sits with our suppliers, in two key areas:

  • Products (EU) from NHSSC (NHS Supply Chain).
  • Products coming

The risk to the NHS supply chain generally is that there could be added days of delay to clear customs.

Disruptions to Medical Devices & Clinical Consumables supply can have a major impact to patients/patient care and could interrupt services and patient care, the current state of government Brexit negotiations presents no deal Brexit as an unlikely outcome.

  • The likelihood assessment score is therefore scored: 4.
  • The Impact assessment is scored at 5.

 

Key Risks: including are there any medical devices/consumables that normally run at low stock levels, and therefore have increased Brexit risk?

Some higher value medical devices come from the EU; there could be some delay on products / services which we procure directly from EU suppliers, our current major and important suppliers are all covered by central government plans so there is little we can control directly. NHSSC is also covered by central plans as are our two further main wholesalers (Squadron and Bunzl). Our nutritional feeds supplier (Nutricia) is covered by government plans so requires no direct contact. We have no critical suppliers in this area that require direct contact at this point given the six week government supply arrangements.

 

Mitigation:

NHSI have advised that port channels (priority lanes) for clinical goods coming from EU will be kept clear and given priority, all of our major and important suppliers are covered by government supply arrangements which leaves little to be done: the Trust should however continue to closely monitor the situation.

 

3. Supply of Non-Clinical Goods and Services

Rationale for Impact and Likelihood Assessment:

There is a potential for shortages of Non-Clinical Goods and Services due to increased time for imports to clear customs in the Brexit no deal situation. We, the Trust and NHS, should not stock pile for the following reasons:

  • We have been advised by NHSI directly not to stock pile
  • This creates risk for the wider NHS
  • Added cost
  • Risk of supplies going out of date
  • Lack of space

 

Given we cannot stock pile then the risk sits with our suppliers, in two key areas:

 

3. Products (EU) from NHSSC (NHS Supply Chain).

 

4. Products coming

The risk to the NHS supply chain generally is that there could be added days of delay to clear customs.

Disruptions to Medical Devices & Clinical Consumables supply can have a major impact to patients/patient care and could interrupt services and patient care, the current state of government Brexit negotiations presents no deal Brexit as an unlikely outcome.

  • The likelihood assessment score is therefore scored: 4.
  • The Impact assessment is scored at 4.

 

Key Risks: including are there any non-clinical goods that normally run at low stock levels, and therefore have increased Brexit risk?

There could be some delay on products / services which we procure directly from EU suppliers, our current major and important suppliers are all covered by central government plans so there is little we can control directly. NHSSC is also covered by central plans as are our two further main wholesalers (Squadron and Bunzl). The Trust has no critical suppliers in this area that require direct contact at this point given the six week government supply arrangements.

 

Mitigation:

NHSI have advised that port channels (priority lanes) for clinical goods coming from EU will be kept clear and given priority, all of our major and important suppliers are covered by government supply arrangements which leaves little to be done: The Trust should however continue to closely monitor the situation.

 

4. Workforce

Rationale for Impact and Likelihood Assessment:

During any transition period, free movement remains and international recruitment from EU nations can continue, but we have experienced a reduction in the numbers of applicants from EU recently.

EU staff (both current and new) will need to apply to the EU Settlement scheme to live and work in the UK.

We will need to ask staff for proof of right to work in line with future immigration policy. For EU staff, this will mean proof of settled or pre-settled status under the EU settlement scheme. This will be necessary from the end of the transition period. In the event of no deal Brexit, we expect free movement to remain in place for a period of time but we have no more detail on this. Mutual Recognition of Professional Qualifications (MRPQ) Directive provides a reciprocal framework of rules which enables EEA and Swiss nationals to have their professional qualifications recognised in a state other than the one in which the qualification was obtained. This will no longer apply after the exit date if no deal is agreed.

  • Likelihood assessment = 4
  • The Impact assessment is scored at 5.

 

Key Risks: including whether there any workforce issues specific to your Division, and therefore has an increased Brexit risk?

We experience vacancies due to low domestic supply of clinical staff (nursing and medical particularly) and rely on being able to recruit internationally, including the EU. Therefore Brexit has reduced our supply of staff.

c.10% of our staff are EU nationals. This is c 400 staff. We rely on these staff and we need a pipeline of EU staff to remain open.

 

Mitigation:

Widely publicise the EU settlement scheme and support staff to apply with android phone, intranet site, designated email address and designated Assistant Dir of HR as nominated workforce lead. Increase domestic recruitment where possible and focus on alternative staffing measures such as role redesign and alternative clinical roles. Engage management to review their staffing profiles in their areas and to engage with their EU staff to understand their intentions about remaining in the UK. Notify applicants with EEA or Swiss qualifications who are in our recruitment pipeline that any applications for a qualification to be recognised under the Mutual Recognition of Professional Qualifications (MRPQ) Directive should be made before 30 March. Applications made after this date will be subject to the new system of recognition, subject to Parliament’s approval, and we do not know the detail of this.

 

5. Reciprocal Healthcare (Overseas visitors)

Rationale for Impact and Likelihood Assessment:

The risk for the reciprocal healthcare arrangements and the charging of overseas patients who are not eligible for funded NHS treatment will be more significant in the event of a no-deal. This could impact in all non-residents being chargeable regardless of the current EHIC process and reciprocal arrangements. Additional risk surrounds the eligibility of existing EU nationals residing in this country and their on-going eligibility for funded NHS care. There has been no current guidance on the potential options but there is significant risk to the current processes and the potential need to review in light of Brexit arrangements and the uncertainty surrounding this.

  • Likelihood assessment is scored at level 3
  • The Impact assessment is scored at 3

 

Key Risks:

Change to current processes and larger impact on the overseas charging resulting in workforce implications

  1. Uncertainty in the options going forward so unable to plan for current scenarios
  2. Impact of a no deal on reciprocal arrangements not only within the EU but other arrangements currently in place e.g Australia
  3. Unknown impact on current EU citizens resident in the UK and whether the eligibility based on residency will change
  4. Risk of a two-tiered system based on people resident prior to Brexit (in both a deal and no-deal scenario) and post Brexit and the additional work that may involve in managing two processes

 

Mitigation:

Difficult to currently mitigate for this area as there is no indication of the options and guidance has not been released nationally for this area. Until such guidance is released the processes will be implemented as currently but all overseas visitors and those are able to demonstrate residency will be warned that the impact of Brexit on eligibility is not clear and this may impact future eligibility for funded NHS care.

 

6. Research and Clinical Trials

Rationale for Impact and Likelihood Assessment:

No immediate risks identified.

  • Longer term potential impact to funding (likelihood assessed =2)
  • The Impact assessment is scored at 4.

 

Key Risks:

Longer term funding for Research

 

Mitigation:

Await DH further guidance

 

5) Has your trust budgeted any additional money for contingency planning for/due to the impact of the UK’s exit from the EU in March and the potential no-deal Brexit?

No