IPAS Centres Fall Below Standards for Risk Management as over 60% deemed not compliant by HIQA

Introduction

Risk management is a critical component in ensuring the safety and well-being of residents in International Protection Accommodation Services (IPAS) centres. Recent HIQA inspection reports have highlighted significant shortcomings in risk management practices within IPAS centres, exposing residents to potential harm.  Of the 18 inspection reports currently published, 61% of centres were deemed not compliant with risk management, and 33.3% partially compliant. Among the high-risk issues are the absence of a risk management framework, lack of risk registers, no overarching risk management policy to guide staff, ineffective self-identification of risks, and not completing risk analysis or assessments of all risks. Not only are residents being exposed to potential harm but your reputation as a safe, well managed IPAS service is at risk. 

This article delves into the risk management requirements set out in the National Standards for accommodation offered to people in the protection process and contrasts them with the major risk management concerns identified by HIQA inspectors. By exploring these discrepancies, we aim to shed light on the urgent need for improvements in risk management practices within IPAS centres to ensure the safety and well-being of all residents. Additionally, we outline HCI’s Risk Management Programme for IPAS centres which will guide you towards full regulatory compliance for risk management.

Risk Management Requirements for IPAS Centres

Below is a breakdown of the risk management requirements set out in the National Standards for accommodation offered to people in the protection process.

THEME 1: GOVERNANCE, ACCOUNTABILITY AND LEADERSHIP

Standard 1.2 The service provider has effective leadership, governance arrangements and management arrangements in place and staff are clearly accountable for areas within the service.

1.2.13. Risk management.

• The service provider has a risk management framework and supporting structure in place for the identification, assessment and management of risk in the service.
• Risks are reviewed at management and staff meetings and a risk register is regularly updated.
• There are systems in place to effectively manage risk, including child protection risks, and a designated person(s) to contact in an emergency.

THEME 3: CONTINGENCY PLANNING AND EMERGENCY PREPAREDNESS

Standard 3.1: The service provider will carry out a regular risk analysis of the service and develop a risk register.

3.1.1 Identifying risk.

• The service provider carries out a risk analysis of the service and identifies potential risks that would compromise the provision of the service.
• The actions identified to mitigate the risk are assigned to a specific individual and monitored to ensure implementation.
• This risk register is reviewed and updated on a regular basis and actions identified to mitigate the risk.
• The risk register is provided to the Department of Justice and Equality and as part of the inspection process, and is available to its agents and inspectors, and the Office of the Ombudsman.

Summary of Major Risk Management Concerns in IPAS Centres

While the National Standards outline comprehensive requirements for risk management, the reality within IPAS centres, as observed by HIQA inspectors, reveals significant gaps. The following summary highlights the areas requiring immediate attention.

• Although a risk assessment system was in place, the inspectors identified risks that were not assessed, recorded or managed appropriately.
• While there was a register of some potential risks in the centre (such as compliance risks and fire safety risks), these had not been evaluated in any depth and consequently records of control measures contained limited information and were poorly defined.
• Some potential risks in the centre, in relation to resident safety, had not been identified. Additionally, other known risks in the centre had not been assessed and staff were uncertain as to how they were to manage them.
• The continuity of the service and contingency planning for staffing or an emergency situation had not been addressed in risk assessments reviewed during the inspection.
• There was an ineffective risk management system in place in the centre which had not considered many of the risks relating to the health, safety, welfare and human rights of residents.
• There was an absence of a risk management framework to guide staff members and managers on how to appropriately identify, assess, manage, and report risks.
• The risk register in use in the centre was inadequate and the inspectors found that numerous risks had not been identified or assessed by the service provider.
• The service provider could not effectively self-identify risks, hazards, and areas that required improvement.
• The risk management system in place in the centre was found only to consider some limited health and safety and organisation or corporate-related risks.
• The provider had not completed a risk analysis for the centre to identify, assess, or control risks and hazards that may compromise the safety and wellbeing of residents and the quality of service provision.
• The service provider had not put in place an effective risk management framework and policy.
• While the health and safety statement listed regular fire drills as a control measure, the inspectors found that there were only two records of completed fire drills in the previous five-year period. Multiple residents told inspectors that they had not been informed about evacuation plans in the event of an emergency. Moreover, some residents had additional support needs and would require assistance during evacuations and emergencies, however, there was an absence of comprehensive risk assessments on these matters.
• There was no risk register and the service provider had not completed a risk analysis or assessment of all risks and hazards that may compromise the safety and wellbeing of residents and the quality of service provision.
• There were no assigned owners allocated to some identified individual risks on the risk register.
• The risk management system was not effective and the risk management policy was not sufficiently detailed to guide the staff team in the management of risk.
• The risk register did not contain details of all risks in the service.
• The service provider had not completed a risk analysis or assessment of all risks in the centre.
• There was no overarching risk management policy to guide the staff team in the identification, assessment and management of risk. There was no risk register and not all risks relating to residents had been recorded and assessed.
• While regular fire drills took place, the risk relating to residents not responding to the fire alarm needed to be assessed.
• There were also no arrangements in place for information about incidents to inform risk management practices or to learn from these incidents as part of continual quality improvement to enable effective learning and reduce the likelihood of reoccurrences.
• There were no risk assessment and management policies and procedures in place for dealing with situations where the safety of residents may be compromised.

Bridging the Gap Between the National Standards and Current Practice

HCI’s Risk Management Programme for IPAS Centres

HCI is at the forefront supporting IPAS centres to implement risk management systems that guarantee regulatory compliance. As part of our ongoing programme you will have access to a dedicated Quality and Safety Specialist who has expert knowledge and understanding of the risks and challenges faced by IPAS centres. We will support you to conduct comprehensive risk assessments, complete a detailed risk register with well-defined controls, and develop and implement a risk management policy and procedure and training programme to guide staff to effectively implement the risk management framework.

Our Risk Management Programme will give you confidence that you know what your risks are, comprehensive risk assessments have been completed, detailed records are kept, and staff are managing risks effectively.  With our support you will achieve full regulatory compliance for risk management.

Key Components of the Risk Management Programme

Quality and Safety Expertise

Our Quality and Safety Specialists are actively supporting IPAS centres to build Quality and Safety Management Systems to meet and exceed regulatory requirements. Our experts have a deep understanding of the types of risks that IPAS centres face, coupled with extensive experience in working with a wide range of health and social care services to implement regulatory and best practice requirements. We utilise our extensive experience to support you to implement risk management measures that will exceed HIQA’s requirements.

Risk Assessments

Through our ongoing work with IPAS centres and extensive review of the National Standards for accommodation offered to people in the protection process, HCI has developed a suite of potential Corporate and Service Provision risks applicable to IPAS centres. As part of our Risk Management Programme, our Specialists will visit your centre and conduct comprehensive risk assessments. We will review documentation, speak with your staff and residents and observe practice. From this assessment we will gain a deep understanding of what your risks are, determine your risk level and identify what controls are required.

IPAS Risk Register

The risks identified during the risk assessment will be recorded and managed centrally in an electronic Risk Register. HCI’s Risk Register is a user-friendly web-based risk register, which supports the effective oversight and ongoing management of Corporate and Service Provision risks within your IPAS centre.

Our Risk Register allows you to:

• Easily record, assess, manage and monitor risks from a centralised location.
• View a high-level dashboard overview of risks in the centre.
• View the complete history of a risk since it was created
• Search and filter risks
• Assign risk responsibilities to specific staff members
• Staff can view their risk responsibilities
• Access to data which can be reviewed at Management Meetings
• Improves decision making and protects your service
• Demonstrate good governance and oversight of the risks within the service
• Achieve regulatory compliance

IPAS Risk Management Policy

HCI will work with you to develop a comprehensive Risk Management Policy and Procedure which will support the implementation of a risk management framework that is integrated throughout the service. This policy will effectively guide your staff through the identification, assessment, treatment, monitoring and reporting of risks on a strategic, organisational, and individual level to ensure the quality and safety of the support provided to residents.

IPAS Identifying, Addressing and Responding to Existing and Emerging Special Reception Needs Policy and Procedure

In addition to the overarching Risk Management Policy, HCI will develop a policy to identify, address and respond to existing and emerging special reception needs. This policy will support your service in managing individual resident risks, specifically identifying resident special reception needs and vulnerabilities.

IPAS Risk Management Training

Our comprehensive Risk Management Training will support your staff in understanding the regulatory requirements around risk management and give them the tools to implement a risk management model that is both proactive and responsive in its applications. The training incorporates the identification, assessment, treatment, monitoring and reporting of risks. Your staff will be able to identify risks, carry out risk assessments, apply risk rating, and mitigate risks through the use of controls and develop risk registers that support these processes.

Conclusion

The findings from the HIQA reports underscore a pressing need for comprehensive and effective risk management systems in IPAS centres. Adhering to the National Standards, which emphasis a robust risk management framework, is essential for safeguarding the health, safety, and well-being of residents. Implementing detailed Risk Management Policy, conducting risk assessments, maintaining an up-to-date risk register, and ensuring regular reviews and updates can significantly mitigate and control risks. By addressing these deficiencies, you can enhance your service quality, ensure regulatory compliance, and foster a safer living environment for all residents.

HCI’s Risk Management Programme is comprehensive and guarantees compliance for risk management. With our support you can be assured that you know what your risks are, compressive risk assessments have been undertaken, staff have a best practice Risk Management Policy to guide them, staff are educated and trained on how to implement the risk management framework, and Management have access to a risk register where all risks can be easily recorded, managed and monitored effectively.  By partnering with HCI, you can transform your risk management practices, ultimately providing a secure and supportive environment for all residents and achieve regulatory compliance.

For more information on our IPAS Risk Management Programme contact HCI at 01 629 2559 or info@hci.care.