Concerns around governance and oversight at the headquarters of the British Pregnancy Advisory Service have been raised in a report by the Care Quality Commission (CQC).
The independent charity provides termination of pregnancy and other services at 27 registered locations and 22 satellite locations across England, Scotland, and Wales.
Last year, the CQC inspected 12 of the BPAS registered locations, in line with its regulatory responsibilities for England only. The inspections took place between April and December 2022 as part of a planned and risk-based assessment programme.
Although several positive factors were noted in the reports, some concerns were also identified around leadership and governance arrangements. The specific concerns noted were:
- Governance arrangements were not sufficiently robust or effective to always identify concerns and risks, whilst not all notifiable events were reported in line with mandatory legal reporting regulations
- The correct legal documentation was not always completed before surgical termination of pregnancy
- Systems to safely prescribe, administer, and record medicines were not always in line with national regulations and guidance
- Women did not always receive care in a timely way to meet their needs
As a result of those local inspections, the regulator carried out a reactive 'provider well-led' assessment of the BPAS's administrative offices in Warwick. Over the course of 2 days in early February, inspectors examined performance data, quality audits, board papers, internal reports, and complaints records, as well as interviewing senior managers.
Service Delivery and Managerial Oversight
The review found a strong organisational focus on service delivery, which was reflected in the provider's online client satisfaction survey where 98% of respondents indicated they would recommend BPAS to someone who needed similar care. It also found that leaders were aware of the importance of honesty and transparency if incidents occurred, and the importance of staff knowing they could speak up without fear of retribution.
However, on the negative side, it found that the BPAS lacked any system to track risks across the organisation, and no clear standard route by which local risks could be escalated to top management. It also found no clear standard route for escalating risks at a local level to be escalated to the executive team.
The organisation's policy on risk notification was found to be "confusing" and could indicate that not all local service managers understood their legal responsibility to submit statutory notifications to the regulator, whilst incident reporting systems were "complex" and did not contain sufficient clinical input to identify themes and trends that could support service improvements.
The report found processes in place to monitor and manage the quality of patient care, but these were "not always effective" and had led to some local managers adopting their own operating procedures.
Action Needed at Corporate Level
Carolyn Jenkinson, deputy director of secondary and specialist healthcare at the CQC, said they had seen "positive action" taken by local BPAS services to make improvements, but that work "must now be supported by action at a corporate level to ensure that senior management and members of the Board have true oversight and that robust governance arrangements are in place".
Responding to the report, the BPAS said it had cared for a record number of women over the last 3 years, including during the COVID-19 pandemic, and the "intense" pace of change had put pressure on the organisation. "After a period of significant growth at a service level, we are now focused on ensuring that our policies, procedures, and structures are fully suited to the size and scale of the charity we have become," it pledged in a statement.
The charity said it accepted the need, as highlighted by the regulator, "to ensure we have clear and effective governance and oversight of our services across the UK".