«Updated on 28 July 2015 Foreword This document has been produced by the Department for Work and Pensions (DWP) to provide guidance for providers ...»
4.3.10. Providers with HPs who specialise in one area of assessment only will also be able to seek approval from DWP to carry out face-to-face consultations, paper-based reviews or terminal illness. In these cases, HPs must show an ability to consistently apply the competence standards in their area by achieving the following
number of consecutive Grade A audit results at Stage 4:
• 5 reports following a face-to-face consultation; or
• 5 Terminal Illness (where descriptor advice is provided).
4.3.11. Providers must supply DWP with evidence demonstrating that the HP has achieved the required standard. The CMO reserves the right to not approve an HP if he has any concern that an individual does not satisfy one or more of the required criteria, regardless of the actions or views of the provider.
4.3.12. Until Full Approval is given by DWP, HPs will remain subject to 100% quality audit.
Submitting HPs for approval 4.3.13. When the provider is satisfied that the HP has successfully completed all four stages of the approval process the following
information should be sent to DWP:
• The AP’s assurance that the relevant register has been checked for that HP’s profession, they can confirm that they are registered and have two years post-registration experience
4.3.14. The CMO will review the HP’s papers and approve them, if all is in order. DWP will maintain a database of approved HPs. If the status of the HP changes, the AP should advise DWP as soon as possible.
Maintenance of Approval 4.3.15. The HP’s on going Approval is dependent upon the HP undertaking PIP assessment work for the provider and fulfilling the following criteria:
4.3.16. Providers should keep records for each HP containing all information relating to quality – for example, on training, CPD, quality monitoring, rework and complaints.
Revocation of Approval 4.3.17. The CMO reserves the right to suspend or revoke Approval – both Provisional and Full Approval – at any time where there is concern that an individual may no longer satisfy one or more of the required criteria. This is at the discretion of the CMO and is irrespective of any action that providers are undertaking.
4.3.18. Providers must consider whether the circumstances surrounding any revocation of Approval warrant them informing the HP’s professional body.
4.3.19. Revocation of an HP’s Approval should routinely be sought for a
number of reasons:
4.3.20. More information on these areas is covered below.
4.3.21. Providers should inform the DWP CMO where any of the above apply, together with any relevant documentation.
Poor Performance 4.3.22. Where there is evidence that the required standards are not being consistently met, this should be drawn to the HP’s attention without delay. Appropriate feedback should be given.
4.3.23. Providers should have guidance and processes in place to address issues with an HP’s performance, including issues of productivity, reliability, quality of outputs and complaints. This may include formal retraining or periods of supervised practice where necessary. Work should be kept under review until evidence of consistent improvement is obtained. If this does not occur, then formal Revocation must be sought.
Temporary Unavailability 4.3.24. The Temporary Unavailability of an HP to carry out PIP assessments will require action by providers in relation to that HP’s Approval.
4.3.25. If the Temporary Unavailability is for a period of less than 3 calendar months, the HP may resume their normal duties afterwards.
4.3.26. If the Temporary Unavailability is for a period of more than 3 but less than 6 months, the HP should be subject to targeted quality audit on their return to ensure the required standards are being met.
The number of assessments audited will be at the discretion of the provider.
4.3.27. If the Temporary Unavailability is for a period of more than 6 but less than 12 months, the provider should suspend the HP from carrying out assessments, seek revocation of approval from DWP and return the HP to Stage 4 of the approval process, requiring them to undergo audit. As per Stage 4, the HP will be required to achieve 5 consecutive grade A reports produced following both face-to-face consultations and paper-based reviews.
4.3.28. If the Temporary Unavailability is for a period of more than 12 calendar months, providers should immediately suspend the HP from carrying out PIP assessments and seek Revocation of Approval from DWP. To carry out PIP assessments in the future, the HP must go through the full Initial Approval process again.
Mandatory Training Missed 4.3.29. If an HP fails to undergo a module of mandatory training, providers should normally suspend the HP from carrying out PIP assessments as soon as the time limit for taking the training expires.
4.3.30. Should the HP not take steps to complete the required training in an appropriate timeframe, providers should approach the Department to have the HP’s Approval revoked.
Permanent Unavailability 4.3.31. Revocation of Approval on the grounds of Voluntary Permanent Unavailability may take place where HPs no longer wish to carry out PIP Assessments – for example, due to retirement, ill-health or resignation. The HP concerned should inform the provider of their intent who should then seek the revocation of Approval from DWP.
4.3.32. Revocation of Approval on the grounds of Involuntary Permanent Unavailability may take place where HPs are no longer able to carry out PIP Assessments – for example, due to an upheld serious complaint, a conviction for a serious crime or due to the imposition of sanctions by a professional body.
4.3.33. In these circumstances providers should immediately suspend the HP from carrying out PIP assessments and seek Revocation of Approval from DWP.
Administrative processes 4.3.34. The detailed administrative processes to support the Approval and Revocation requirements have been shared separately with providers.
4.3.35. Providers must maintain a database detailing approvals / revocations of approval. The database content must be agreed with the Department and shared with it on request.
4.4. Quality Audit 4.4.1. Providers are required to put in place the following processes for
auditing the quality of assessments:
4.4.2. Audit has a central role in ensuring that decisions on benefit entitlement, taken by DWP, are correct. It supports this by confirming that independent HP advice complies with the required standards and that it is clear and medically reasonable. It also provides assurance that any approach to assessment and opinion given is consistent so that, irrespective of where or by whom the assessment is carried out, claimants with conditions that have the same functional effect will ultimately receive the same benefit outcome.
4.4.3. Assessments reports subject to audit will be examined and graded
A, B and C based on the following guidelines:
4.4.4. More detailed guidance on how reports should be audited and the criteria to be used are set out in section 4.6.
4.4.5. The Department also recommends that providers undertake additional audit activity to ensure quality standards are being met,
Lot-wide audit 4.4.6. Lot-wide audit is an audit of a controlled random sample from across each contract Lot, feeding in to routine performance reporting to DWP. Forms PA5 and PA6 are not included in the lot-wide sample.
4.4.7. Providers must develop a system for random sampling which must be agreed with DWP. The sample should include terminal illness, paper-based review and consultation outputs.
4.4.8. The lot-wide audit sample size must be selected using the Lancaster model which has been designed in conjunction with DWP analysts.
The model produces an appropriate sample size to specified margins of error. The model and guidance on its use have been supplied to providers separately.
4.4.9. Providers’ targets are:
Approval-related audit 4.4.10. During Stage 4 of the HP approval process HPs should be subject to 100% audit to ensure that they are consistently able to apply the competence standards (see 4.3.9).
New entrant audit 4.4.11. Once an HP has been approved, the Department recommends that they continue to be subject to regular audit until the provider is satisfied that consolidation of skills has been achieved. The frequency and volume of monitoring should be determined by providers.
Rolling audit 4.4.12. Rolling audit is an audit of the work of each HP on a regular basis to assess the quality of their work on a continuing basis, ensure maintenance of standards and for on going approval.
4.4.13. The Department recommends that providers ensure that an appropriate proportion of an HP’s assessments are subject to audit in every three month period. The number of cases that will need to be subject to rolling audit may be affected by the number of examples of that HP’s work which have formed part of other audit activity – for example, cases selected as part of the lot-wide audit.
Some HPs will not need rolling audit at all because they are regularly audited in random or targeted audit activity.
Targeted audit 4.4.14. Targeted audit is audit activity triggered where a quality, rework or complaint issue has been identified to establish whether there is evidence of an on going problem or where it is felt that auditing should be carried out to ensure the required standards are met.
4.4.15. Targeted audit is carried out at the discretion of providers or at the request of DWP – for example, where rework volumes are significantly high indicating problems with quality, or where successful appeals indicate that the evidence was insufficient.
Experience of auditors 4.4.16. Providers should put in place processes to ensure that individuals carrying out audit activity are Approved HPs and have the requisite skills, knowledge and experience to carry out their roles. Where possible, they should have been carrying out PIP Assessments for a minimum of 12 months.
Live cases 4.4.17. Unless there are extenuating circumstances, audit activity should be carried out while cases are “live” and before they are submitted to DWP. As such all audit activity should be carried out swiftly to avoid delay to the case.
4.4.18. If a case is identified as requiring amendment after it has been returned to DWP, as the advice may be misleading, contact should be made with the relevant CM.
Feedback 4.4.19. Providers should put in place processes to ensure that appropriate feedback is given to HPs as a result of auditing.
Alteration of C grade reports 4.4.20. Where assessments have been graded as C grade, remedial activity should be taken before the case is submitted to DWP. Where possible, this activity should be taken by the HP who carried out the original assessment.
4.4.21. Any changes made to clerical forms should be justified, signed and dated. It should be made clear that any changes are made as a result of audit activity.
4.4.22. Where necessary a new report form should be completed.
Maintaining records 4.4.23. Providers should keep records of all audit activity described in this section, including iterations of all audited reports. These records should be retained for a minimum period of two years.
4.5. Quality Audit Criteria 4.5.1. These audit quality requirements apply to cases audited under lotwide audit and approval-related audit. However, providers may wish to use the same criteria for other audit activity, such as rolling and targeted audit.
Areas to be audited 4.5.2. When auditing cases, providers should look at the entire case at the point at which it is finalised and due to be returned to the Department, considering both the final output and the processes followed.
4.5.3. Reports should be audited in four areas:
4.5.4. Attributes break the areas down into subcategories that must be considered.