Response To NHS England’s Statement Dated 11/05/21 In Light Of The StopSIM Coalition’s Concerns Regarding The High Intensity Network (HIN) And Serenity Integrated Mentoring (SIM)

On 21.4.21 we, the StopSIM Coalition, released our first Statement expressing our concerns about the rapid roll out of SIM across NHS England.  We have since published a series of detailed statements expressing our concerns in relation to data protection, human rights, a lack of patient public involvement and the absence of an ‘evidence base’. On 11.05.2021 we received a response from Claire Murdoch (National Mental Health Director for NHS England and NHS Improvement) and Tim Kendall (National Clinical Director for Mental Health NHS England and NHS Improvement). An extract from this statement reads as follows: 

Firstly, I would like to clarify that NHS England and NHS Improvement (NHSE/I) does not mandate the ‘SIM’ model and at this time is not formally endorsing or promoting its spread. In light of the concerns raised about how the model is being implemented the National Clinical Director for Mental Health will write to all Medical Directors (MDs) of NHS Mental Health Trusts to ask them to review the implementation of the SIM or similar models where they have been adopted locally. The aim of the review is to ensure that any service being provided is:

a) in line with our Long-Term Plan ambitions for expanding and improving community services for adults with severe mental illnesses – please see further detail below;

b) in line with NICE guidelines for patients with personality disorder and self-harm care;

c) in line with patient confidentiality and data sharing law; and

d) to ensure that the approaches in place do not compromise patient safety or human rights.” [1]

We are reassured that NHS England have acknowledged our concerns and are planning to take actions in response. We agree, a review is essential in order to address concerns and in order to take robust actions as appropriate. However, we remain concerned that this response does not appropriately reflect the urgency and magnitude of the issues we have highlighted. As outlined in our initial consensus statement, an independent investigation centrally coordinated is necessary.  This would avoid duplication and promote efficiency and partnership working when reviewing concerns about what was an NHS England endorsed initiative. We reiterate our requests to NHS England: 

  • Halt the rollout and delivery of SIM with immediate effect, as well as interventions operating under a different name, which are associated with the High Intensity Network (HIN).
  • Conduct an independent review and evaluation of SIM in regards to its evidence base, safety, legality, ethics, governance and acceptability to service users.

The concerns we, the StopSIM Coalition, have highlighted are not localised or specific to individual NHS trusts. Rather, these relate to the national implementation of SIM which has been endorsed by NHS England.  Although the statement issued yesterday reads “NHS England and NHS Improvement (NHSE/I) does not mandate the ‘SIM’ model and at this time is not formally endorsing or promoting its spread”, we consider past involvement to remain of significant relevance.  The model has been endorsed by several key individuals[2] from NHS England, and there is evidence that NHS England has encouraged the widespread rollout of the model nationally[3]. As stated in the SIM Business Case document[4], SIM was reviewed in 2016 by a team led by Sir Bruce Keogh (former Clinical Director of NHS England) who concluded it was “ready and fit”[5] for national implementation across the NHS; this review is not in the public domain. Subsequently, SIM was supported by the NHS Innovation Accelerator Programme between 2016 – 2018, and was selected as one of seven programmes for “national adoption and spread” across the Academic Health Science Network (AHSN) in partnership with NHS England[6]. SIM’s selection by the NHS Accelerator Programme was confirmed in NHS England’s response to the StopSIM Coalition: 

“The model was selected to be part of the NHS Innovation Accelerator programme in 2018 and supported by the Academic Health Sciences Network (AHSN) as a 2-year programme with the aim of improving care for an under-served group of patients who experience poor outcomes.”[7]

On conclusion of the AHSN national programme in March 2020, AHSN state:

“…there were approximately 20 teams live across the country, offering a SIM model or similar. There are several similar models that have been established across England. At the end of March 2020, this equated to approximately 270 service users having been supported by a SIM model during the two-year period.”[8]

Furthermore, within the governance structure of SIM London, there are two Strategic Delivery Boards to which relevant London Mental Health Trusts have membership, but the boards are directly commissioned by NHS England[9]. There is a need for further clarity about why SIM has been continued beyond this 2-year period. However, accountability for SIM’s “national adoption and spread” through the NIA and the AHSN, and therefore its continued implementation lies with NHS England[10]. This supports our call for a centrally coordinated investigation and independent review of SIM. 

In other regions, SIM (or services under alternative names) are governed by NHS Mental Health Trusts which, as secondary care, are commissioned by local Clinical Commissioning Groups (CCGs)[11]. Whilst CCGs hold responsibility for the services they commission[12], It remains the statutory duty of NHS England “to oversee assurance of CCGs in their commissioning role”[13]. Therefore it is the ultimate responsibility of NHS England to uphold assurance and accountability that locally commissioned health providers operate in a manner which upholds statutory duties and safeguarding legislation.[14] In this regard, we consider it insufficient to ask individual trusts to conduct reviews without a more robust and centrally coordinated investigation given the severity of concerns about SIM. 

NHS England additionally has a statutory duty to comply with relevant legislation and uphold the NHS values, as outlined in the NHS Constitution[15]. Under the Health and Social Care Act (2012)[16], NHS England is obligated to continually drive improvements in the quality of care provision with a focus on safety, clinical effectiveness and patient experience.[17] Additionally, NHS England has legal responsibility for monitoring the quality of all providers of NHS funded care[18]. NHS England must uphold accountability under the Equality Act (2010)[19] and NHS Act (2006)[20] to advance equality, eliminate discrimination and reduce health inequalities[21]. In relation to this, we understand it to be the responsibility of NHS England to take robust action in relation to HIN/SIM where these statutory duties appear to be contravened. We re-emphasise our call as the #StopSIM Coalition for an Independent investigation to mitigate bias and subjectivity.

To conclude, we consider multiple local reviews insufficient in light of the following:

  • HIN/SIM’s rapid rollout and implementation was initially facilitated and resourced by NHS England. 
  • SIM is directly commissioned by NHS England in some areas. 
  • NHS England retains accountability and responsibility for safeguarding and overseeing local CCGs commissioning contracts.[22] 
  • NHS England has statutory and legal duties which it must uphold.
  • Due to the severity of risk posed to service users under SIM, we consider a centrally coordinated investigation of urgent importance. 

We reiterate our call to NHS England to:

  • Halt the rollout and delivery of SIM with immediate effect, as well as interventions operating under a different name, which are associated with the High Intensity Network (HIN).
  • Conduct an independent review and evaluation of SIM in regards to its evidence base, safety, legality, ethics, governance and acceptability to service users.

In solidarity,

The #StopSim Coalition

Copied to:
Sir Simon Stevens, CEO – NHS England, Lord David Prior, Chair – NHS England, Claire Murdoch, National Mental Health Director – NHS England, Martin Hewitt, Chair – National Police Chiefs’ Council, Sir Tom Winsor, Her Majesty’s Inspectorate of Constabulary and Fire and Rescue Service.

References:

  1. NHS responses were received via email to StopSIM Coalition on 11 May 2021.
  2. Commissioning in Numbers. High Intensity Network [Internet]. Slide 15. Available from:  https://highintensitynetwork.org/img/resources/COMMISSIONING_IN_NUMBERS_v4.pdf [accessed 11 May 2021].
  3. For instance, see Contact us, High Intensity Network [Internet]. Dr Geraldine Strathdee OBE, ‘Project Mentor and SIM London Clinical Consultant’. Available from: https://highintensitynetwork.org/contact [accessed 11 May 2021]. See also Professor Peter Fonagy, Programme Director for Mental Health and Behaviour Change at UCL Partners. ‘Mental health – developing, testing and spreading what works’. UCL Partners [Internet]. 2018. This source states ‘as one of the 15 Academic Science Health Networks (AHSNs) in England, we are working as part of a national programme to spread the Serenity Integrated Mentoring (SIM) model’. Available from: https://uclpartners.com/blog-post/mental-health-developing-testing-and-spreading-what-works/ [accessed 11 May 2021]. A number of London AHSNs also adopted SIM for delivery and spread in 2018; see SIM London: Support for a better life. Health Innovation Network, South London [Internet]. 2020. pp. 7-8. Available from: https://healthinnovationnetwork.com/wp-content/uploads/2020/10/SIM-London-End-of-Year-Report-2020FINAL.pdf [accessed 11 May 2021].
  4. SIM and High Intensity Network Business Case [Internet], p. 3. Available from: https://highintensitynetwork.org/img/resources/SIM_and_High_Intensity_Network_-_Business_Case_(Commissioner)_v4.docx [accessed 11 May 2021].
  5. SIM and High Intensity Network Business Case [Internet], p. 3. Available from: https://highintensitynetwork.org/img/resources/SIM_and_High_Intensity_Network_-_Business_Case_(Commissioner)_v4.docx [accessed 11 May 2021]; see also SIM London: South London and  & Maudsley NHS Foundation Trust Operational Delivery Guide [Internet]. 2018. Section 1, ‘Project Overview’, 2. ‘Directive to Spread SIM – Sir Bruce Keogh, Clinical Director of NHS England, p. 5.  Available from: https://healthinnovationnetwork.com/wp-content/uploads/2018/06/SIM-Operational-Delivery-Guide.docx [accessed 4 May 2021].
  6. National Programmes and Priorities: Our shared priorities across the national AHSN Network. The AHSN Network [Internet]. Available from: https://www.ahsnnetwork.com/about-academic-health-science-networks/national-programmes-priorities [accessed 12 May 2021].
  7. NHS responses were received via email to StopSIM Coalition on 11 May 2021.
  8. Serenity Integrated Mentoring (SIM). The AHSN Network [Internet]. Available from:   https://www.ahsnnetwork.com/about-academic-health-science-networks/national-programmes-priorities/serenity-integrated-mentoring [accessed 12 May 2021].
  9. SIM London: Support for a better life. Health Innovation Network, South London [Internet]. 2020. pp. 7-8. Available from: https://healthinnovationnetwork.com/wp-content/uploads/2020/10/SIM-London-End-of-Year-Report-2020FINAL.pdf [accessed 11 May 2021]. 
  10. SIM London: Support for a better life. Health Innovation Network, South London [Internet]. 2020. pp. 7-8. Available from: https://healthinnovationnetwork.com/wp-content/uploads/2020/10/SIM-London-End-of-Year-Report-2020FINAL.pdf [accessed 11 May 2021].
  11. About CCGs. NHS Clinical Commissioners [Internet]. Available from: https://www.nhscc.org/ccgs/ [accessed 11 May 2021].
  12. Safeguarding Children, Young People and Adults at Risk in the NHS: Safeguarding Accountability and Assurance Framework [Internet]. p. 13. Available from: https://www.england.nhs.uk/wp-content/uploads/2015/07/safeguarding-children-young-people-adults-at-risk-saaf-1.pdf [accessed 11 May 2021].
  13. Safeguarding Children, Young People and Adults at Risk in the NHS: Safeguarding Accountability and Assurance Framework [Internet]. p. 22. Available from: https://www.england.nhs.uk/wp-content/uploads/2015/07/safeguarding-children-young-people-adults-at-risk-saaf-1.pdf [accessed 11 May 2021].
  14. Accountability in the UK Healthcare System: An Overview. US National Library of Medicine [Internet]. Healthc Policy. 2014 Sep; 10(SP): 154–162. Available from: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4255578/ [accessed 11 May 2021].
  15. Handbook to the NHS Constitution for England. Department of Health and Social Care; Public Health England [Internet]. Available from: https://www.gov.uk/government/publications/supplements-to-the-nhs-constitution-for-england/the-handbook-to-the-nhs-constitution-for-england#:~:text=Statutory%20duties&text=NHS%20bodies%2C%20providers%20of%20primary,least%20once%20every%2010%20years [accessed 11 May 2021].
  16. Health and Social Care Act. Legislation.gov.uk [Internet]. 2012. Available from: https://www.legislation.gov.uk/ukpga/2012/7/contents/enacted [accessed 11 May 2021].
  17. NHS England – Board Paper. NHS England [Internet]. 2018. p. 2. Available from: https://www.england.nhs.uk/wp-content/uploads/2018/03/10-pb-28-03-2018-system-quality-v2.pdf [accessed 11 May 2021].
  18. NHS England – Board Paper. NHS England [Internet]. 2018. p. 7. Available from: https://www.england.nhs.uk/wp-content/uploads/2018/03/10-pb-28-03-2018-system-quality-v2.pdf [accessed 11 May 2021].
  19. Equality Act 2010. UK Public General Acts. Legislation.gov.uk [Internet]. Available from:  https://www.legislation.gov.uk/ukpga/2010/15/contents [accessed 11 May 2021].  
  20. National Health Act 2006. UK Public General Acts. Legislation.gov.uk [Internet]. Available from:   https://www.legislation.gov.uk/ukpga/2006/41/contents [accessed 11 May 2021]. 
  21. Guidance for NHS Commissioners on Equality and Health Inequalities Legal Duties. NHS England [Internet]. 2015. pp. 5, 7-8, 11-13, 18-20. Available from: https://www.england.nhs.uk/wp-content/uploads/2015/12/hlth-inqual-guid-comms-dec15.pdf [accessed 11 May 2021].
  22. Safeguarding Children, Young People and Adults at Risk in the NHS: Safeguarding Accountability and Assurance Framework [Internet]. p. 22. Available from: https://www.england.nhs.uk/wp-content/uploads/2015/07/safeguarding-children-young-people-adults-at-risk-saaf-1.pdf [accessed 11 May 2021]. 

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