Who guards the guardians?

Though it has been a couple of millennia since Juvenal raised this & while in theory there currently exist safeguards to prevent mistakes or wrongdoing, they seem to be observed more in the breach than in spirit. A very short query for the DoH who seem to find nothing wrong with investigations being conducted by or discussed with the very people involved with the behaviour under investigation.

A HSJ report on the internal Commercial Directorate investigation into the ill-fated Atos Origin diagnostics contracts claims that the investigation was conducted by Richard Dale, Medical Director of the Commercial Directorate. My information, from official sources within the Commercial Directorate, was that the audit (& not investigation) was being conducted by Dr Erika Denton, National Clinical Lead for Diagnostic Imaging at the Department of Health, and consultant radiologist at Norfolk and Norwich University Hospital Trust who is one of the clinical advisors to the CD. I am not aware of there having been an investigation into the process of approval for & award of the contract under question.

According to the response to my request for information under the Freedom of Information Act, the process for approval of IS contracts is as follows:

As previously advised, all schemes follow the Department’s approvals process. This includes approval of the Full Business Case (FBC) by the Commercial Directorate’s Deal Execution Group (DEG) and the IS Procurement Board (ISPB). Each of the DEG and the ISPB has clinical representation from a different clinical expert than the Scheme’s clinical SME. In the case of the ISPB, the clinical representative is the Clinical Director for the Commercial Directorate.

In the case of this particular contract, the CD have been unwilling to confirm for the record whether the clinical SME for the schemes approved the FBC. If he / she did not do so, the manager of that department is next in line to sign off the FBC, the manager in this case being Richard Dale in his role as Clinical Director.

As previously advised, the diagnostic schemes were then subject to review by the Department’s Capital Investment Branch and the schemes were approved by the Department’s Finance and Investment Director.

Ultimate approval for the two diagnostics schemes rests with the Department’s IS Programme Board (this is distinct from the IS Procurement Board) and the Director General of the Commercial Directorate.

In other words, no external clinical scrutiny.

This is an excellent non-response showing how to diffuse responsibility for an act among a large group of impressive sounding people but in actual practical terms meaning very little.

Given the process of approval for the contract was directly supervised by the same person who then investigated it, I have to ask, do the DoH expect us to be impressed with just how thoroughly any investigation would have been conducted?

One Response to “Who guards the guardians?”

  1. FrontPoint Systems Ltd » Blog Archive » Anatomy of a cockup Says:

    [...] After-all it is not as if you have to actually answer for your mistakes. [...]

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