TIAN Mandatory Training Benchmarking Review
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1 Addressing risk: creating value TIAN Mandatory Training Benchmarking Review October 2015
2 Background Information It was agreed at the Executive Meeting of The Internal Audit Network (TIAN) in July 2015 to undertake an exercise to benchmark Mandatory Training in NHS Mental Health Trusts. A key benefit from membership of TIAN is the ability to undertake value-adding benchmarking exercises. By drawing on the experience of member organisations, good practice and lessons learned can be shared. This paper summarises the findings of North Yorkshire Audit Services recent mandatory training benchmarking exercise. This exercise originated at the request of a client to support the drive towards achieving mandatory training targets. We would like to acknowledge all participants and thank them for the time taken to input to this exercise. Our review involved analysis of ten responses to our mandatory training questionnaire. These were received from the following Mental Health Trusts: Norfolk and Suffolk NHS Foundation Trust Humber NHS Foundation Trust Dudley and Walsall Mental Health Partnership NHS Foundation Trust Lancashire Care NHS Foundation Trust Tees, Esk and Wear Valleys NHS Foundation Trust Worcestershire Health and Care NHS Trust Coventry and Warwickshire Partnership NHS Trust Leeds and York Partnership NHS Foundation Trust Bradford District Care NHS Foundation Trust Cumbria Partnership NHS FT In addition, information from South West Yorkshire Partnership NHS Foundation Trust made publicly available on their website was included in the analysis where possible. We would also like to thank our Internal Audit colleagues who facilitated the collection of data for the benchmarking process. Purpose The overall purpose of the exercise was to identify the scope of mandatory training across a range of NHS Mental Health Trusts and the training methodologies used. The exercise also took into account any variations in targets set by Boards and the methods for calculating achievement of these targets. Responses to our survey identified a wide range of training. The report includes details of all topics considered as mandatory training in responses to our benchmarking questionnaire. 1
3 Executive Summary 1. Feedback indicated that a wide range of methodologies are being used to determine and validate the mandatory training programme. A number of our respondents identified that they used the UK Skills Training Framework for this purpose. The Framework is available to all private and NHS healthcare employers to determine and validate their mandatory training programme and has the benefit of offering a standardised interpretation of statutory and mandatory training. One of the benefits identified by the publishers of the Framework (Skills for Health) is that the Framework may enable organisations to save time and money by giving confidence to accept previous employers training and avoid overtraining of new employees. However, it should be noted that the Framework does not include Mental Health Law training. 2. Legislative/best practice guidance dictates that core mandatory training should be delivered by every organisation, yet individual Boards are responsible for deciding the level of performance they expect. Targets identified by our respondents ranged between 80% and 95% in the main, with one Trust having an implementation target of 70% which is currently under review. One Mental Health Trust has recently been challenged by the CQC as to why their mandatory training target was not 100%. 3. Organisations use a range of incentives and sanctions to improve attendance levels for mandatory training. Analysis of the methods used established that those organisations using the widest range of methodologies available achieve the higher level of success. The most popular methodology used was to withhold annual increments from those members of staff not at the top of their pay scale. Only one Trust identified that it used compliance with mandatory training as a key agenda item at performance meetings. 4. Training delivery methods varied across training topics, often using a combination of face-to-face and elearning. The use of workbooks and quiz sheets is the least popular way to support learning. elearning has become a popular method to supplement faceto-face training delivery for many topics. This may help to reduce the cost of face-toface training and offer greater flexibility to address demands on staff time. Only one organisation identified that it provides elearning facilities for every topic in their mandatory training programme. Conversely, one organisation indicated that they never used elearning as a means to deliver mandatory training. 5. Analysis of training frequencies and the employees groups attending mandatory training has identified that all our respondents have made distinctions in the frequency and requirement to attend mandatory training, based on job roles or staff groups to some degree. Topics with the most variation in the frequency of refresher training and attendance groups include Fire Safety, Infection Control, Moving and Handling and Violence and Aggression. 2
4 Findings and Analysis Our benchmarking survey was returned by ten participants from Mental Health Trusts across a broad geographic area in England. In addition, data has been obtained from South West Yorkshire Partnership NHS Foundation Trust documents that were made available to the public on their website. There has been some variance in the extent to which participants answered each question, which has been taken into consideration when presenting our findings. The findings of our analysis are detailed in the charts and commentary below. Determining and Validating Mandatory Training Programmes The purpose of mandatory training programmes is to improve the standard of care and service delivery, as well as to ensure staff and organisations are compliant with relevant regulations and guidelines. All UK organisations have a statutory requirement to comply with the Health & Safety at Work Act 1974 which states (at 2.2(c)) that an employer s duty extends to the provision of such information, instruction, training and supervision as is necessary to ensure, so far as is reasonably practicable, the health and safety at work of his employee. When determining the content of mandatory training programmes, respondents to our questionnaire indicated that they have considered a broad range of risks to the health or safety of their employees and structured the mandatory training programme to provide appropriate training to mitigate those risks. Some respondents identified more than one 3
5 method to determine the topics covered in the mandatory training programme. The graph above shows the spread of risks and information considered. As expected, the most frequently used methodologies include reference to legislative/best practice guidance and advice from specialist advisors. The graph above shows a range of methodologies used by our respondents to validate their Mandatory Training Programme. The UK Skills Training Framework is available for use by all NHS organisations and has recently been upgraded to include selected clinical/care subjects. A number of our respondents are registered with the UK Skills Training Framework. The Framework is clearly a popular methodology for validating the mandatory training programme and identifying potential savings in training costs for new recruits. However, it is a generic programme for use by private and NHS organisations, and does not include items of training required specifically by Mental Health Trusts. 4
6 A recent CQC Inspection at a Mental Health Trust reported that The Trust did not ensure that staff received mandatory training including Mental Capacity Act and Deprivation of Liberty Standards... and Mental Health Act training. This requirement is not reflected in the UK Core Skills Training guidance. Those respondents to our questionnaire who have not already included Mental Health Law and associated topics in their mandatory programme may wish to consider whether these topics should be delivered as mandatory elements in their training programme to ensure that consistency of practice can be maintained and evidenced to the CQC. 5
7 Subject Matter Experts (SMEs) should receive both local and national guidelines and updates in their area of specialism. Working with SMEs is a vital element when ensuring that the Training Needs Analysis accurately reflects legislative requirements, and different levels of training for employees in different staff groups. The Training Needs Analysis may include different levels of training for staff members with different exposure to risk. Performance Targets The graph above shows the level of mandatory training performance monitored by the Board for the organisations in our sample. One organisation has used a 70% implementation target, which is currently under review, and is likely to increase in future years. The term mandatory training can often cause confusion as it implies that all staff should attend. However, it may be made up of core training for all employees and role specific training for individual staff groups. An analysis of staff completing mandatory training in the topics identified through our questionnaire has confirmed that a wide range of mandatory training is delivered to specific employee groups. 6
8 Target achievement levels for mandatory training are set by individual Boards. The Royal College of Nursing states that Mandatory training is that determined essential by an organisation for the safe and efficient running in order to reduce organisational risks and comply with policies, government guidelines. Individual Boards may agree aspirational or challenging targets to drive the organisation forward or realistic and achievable to ensure compliance with the target set as indicated in the surveys received. The graph above shows that the majority of respondents have set an aspirational target as per the rationale they have identified in the completed surveys. Where our respondents have indicated that aspirational targets have been set these have been identified as between 80% to 95%. One Mental Health Trust has recently been challenged by the CQC as to why the mandatory training target monitored by the Board was not 100%. As identified earlier, the organisation that set an implementation target (70%) is keen to revise that target to be more challenging in future years. The graphs above shows the rationale behind the target set, and whether those targets were achieved or not. As you will see, setting an aspirational or realistic target does not necessarily indicate the level of success that will be achieved. 7
9 The way that performance targets are calculated may offer some insight into why performance targets are not always achieved. A range of different methodologies appear to be in use, as can be seen in the graph above. Organisations should ensure that the method they use to monitor mandatory training performance is robust, that it both reflects the number of employees required to undertake the training and the timescales for refresher training. Improving Attendance Levels Although performance targets have not been met in more than half of the organisations responding to our questionnaire, only two respondents identified that they used sanctions to encourage employees to keep their mandatory training up to date. Sanctions at both organisations involved the non-payment of annual increments for those eligible employees. All our respondents indicated that they use initiatives in an attempt to improve compliance with mandatory training targets. Interestingly, those initiatives identified included the withdrawal of annual increments, something that was considered as a sanction by two organisations. One organisation had an aspirational target of 85%, which was achieved in 2014/15. This is what they had to say: XXXX offers a variety of training initiatives including onsite team training, corporate sessions, e-learning and bespoke training days to meet the needs of specialist teams. 8
10 Three other Trusts all have targets of 95%. They have used a range of methodologies to help improve the level of attendance. Use of e-learning and sending out reminders. Loss of increment if not compliant. Key agenda item at performance meetings. Funding for external courses will not be approved unless mandatory training is up to date. Reduce the withdrawal rate by applying a rule to ESR - no withdrawal 5 days prior to course starting. Comments received from other organisations were: reminders sent to staff detailing what subjects they are out of date with along with booking information. Staff can also enter their employee number into a system available on Connect and look up to see what they are in or out of date with in relation to mandatory training. Take training out to bases and combine some sessions. Encourage E-learning. reminders are sent to staff detailing their compulsory training status. Monthly compliance and DNA reports are sent to management. Annual refresher days. Team based sessions. Looking at introducing e- learning champions. Study Leave approval dependent on MT compliance. Built into appraisal. Ongoing streamlining of a regional project and a current internal review / project. We have an action plan in place to increase compliance with mandatory training 9
11 The loss of annual increments appears to be a popular methodology for improving the level of compliance with mandatory training, whether it is considered to be a sanction or an initiative to improve attendance levels. But what about those experienced employees at the top of their pay scale who fail to complete the required level of training? Only one organisation has identified that they include mandatory training performance as a key agenda item at performance meetings. All Trusts should take account of setting the tone at the top and consider what sanctions or encouragement they can use for experienced employees who fail to attend mandatory training events. Training Methods A variety of methods to deliver training are available to organisations. These can include face-to-face training, elearning, workbook based, on the job training and other methods. The graph below outlines the variety of methods of delivery used by organisations across all training topics identified by respondents to our questionnaire. 10
12 The use of elearning has become a popular methodology for delivering mandatory training to support face-to-face training. This may be to reduce training costs or to increase flexibility in training delivery to take account of shift patterns and availability of staff. There are clear benefits in terms of the time and resource needed, but organisations should seek assurance that any risks in relation to training being undertaken as a group effort, or on behalf of others have been mitigated. The use of work books and/or quiz sheets does not appear to be a popular method for delivery of training. However, as with elearning, there is a risk that workbooks may be completed jointly, or on behalf of others. Assurances should be sought that the risks of this occurring have been mitigated when adopting this training methodology. Frequency of Training A basic analysis was undertaken to identify refresher rates for mandatory training, as can be seen below. One respondent did not identify any training refresher rates. Four respondents identified that training refresher rates varied in relation to specific job roles or staff groups. Opportunities to differentiate the frequency of training by specific staff groups appears most evident in the following subject areas: 11
13 Violence and Aggression Moving and Handling Infection Control Fire Safety. Trusts may wish to review their Training Needs Analysis in more depth to ensure that the frequency of training delivered is adequate and appropriate to the risks identified for specific staff groups in their own organisation. Methods used to ensure that mandatory training is relevant to all staff groups may be undertaken by using a range of methods, as seen in the graph below: The use of training evaluation forms to obtain feedback from employees will quickly identify those members of staff who feel that attendance at mandatory training events is not useful to their role or staff group. Additional feedback from managers and subject matter experts should also be considered before any changes are made to the frequency of training, or a curriculum review that can be used to target elements of training to specific employee groups. Other methods of checking the appropriateness of training identified by respondents included: Mandatory training defines training that is mandatory for every role in the organisation. We have eight core areas, fire, information governance, health and safety, manual handling, infection control, safeguarding adults, safeguarding children and equality & diversity. We have a wider framework of essential training which defines training that is role specific. Completion of Core Skills Training is role specific and is assessed on an ongoing basis, taking into account both local and national policy. 12
14 Who Attends Mandatory Training? The requirements to attend compulsory training is another area for review by organisations when considering the Training Needs Analysis for training topics, where staff may have high, medium or low exposure to risk. The graph below shows an analysis of staff members who are required to attend mandatory training for the core training topics. Whilst it can be seen that there is some consistency in practice, variations are particularly evident in the following areas: Violence and Aggression Mental Health Law (incorporating the Mental Capacity Act and DoLS) Resuscitation Variations in the delivery of these topics may be as a result of the lack of separation into high, medium and low risk exposure to risk for employees in those topic areas. However, the analysis does show that these may be areas that Trusts wish to review in more depth to ensure that the depth of training delivered is adequate, and appropriate to the risks identified in their own organisation. 13
15 Conclusion It is recommended that organisations undertake a self-assessment of their mandatory training programmes to assure themselves that their mandatory training programmes are appropriate and proportionate. Some questions that the organisation could use to confirm and challenge are: W hen did your organisation last review the content of its core mandatory training programme to challenge its appropriateness and compliance with the new CQC inspection regime for NHS Mental Health Trusts? W hen did your organisation review the split between mandatory training for all staff, and priority training to be targeted for specific staff groups W hen did your organisation last review the update/refresher training requirements for its mandatory training programme? W hen did your organisation last review the methodology for calculating the level of compliance with mandatory training topics? S hould the mandatory training performance target for your organisation be more challenging to reflect the requirement for all employees to attend? W hen did your organisation last review the steps it could take to improve attendance at compulsory training events and reduce the number of late cancellations or non-attenders? In particular what steps can be taken to ensure that employees at the top of their pay scale set an example to new recruits and less experienced staff? W hen did your organisation last review its Training Needs Analysis for employees in different risk groups? Is there any scope to amend mandatory training requirements for groups of staff in identified roles or posts that have a low exposure to risk? 14
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