Patient Safety Commissioner for Scotland Bill

This post is welcomed and brings Scotland in line with the recommendations set out in the Cumberlege report, and the appointment of a Patient Safety Commissioner in England. Having a champion for patient safety that is independent of Government and the NHS and has statutory powers is critical to this post and the Bill lays out in part how that will be achieved.
People require a system for raising concerns and being heard and that landscape currently is complex. This role needs to engage and collaborate with existing mechanisms to address patient safety issues such as SPSP, AEM framework, SPSO and DoC and if this role can provide clarity and encourage improvement in the system, that is not only welcome, but required.
Whilst the PSC will hold boards to account we would like to see a collaborative relationship develop where the focus is on proactive improvement and a continued focus on reducing the potential for patients to be harmed. The quality and safety of care is high on the agenda and we welcome working with the PSC on systemic improvements. How boards will be held to account requires clarity.
Clarity is also required on how the PSC will interact with not only patients and patient groups but organisations such as HIS, the Ombudsman etc and how data from these organisations and from boards will be shared and used to identify improvements in a way that is not currently happening.
Welcome the broader scope of the role beyond medicines and medical devices as laid out in the Cumberlege report, although recognise that a slightly higher majority in previous consultations suggested focussing initially on medicines and medical devices. If this role is to have a system wide view the scope requires to be broader and there needs to be an understanding of the key patient safety issues within Scotland.
As the strategic plan and principles by which the PSC will work, will only be developed once the PSC is in post it is hard to comment further on the function of the role.

The PSC will require a clear understanding of patient safety and the issues within healthcare in Scotland. This will require creating a culture of safety where people feel they can speak up and understanding the barriers within the systems as to why people are not heard.
Further clarity is required on how concerns will be raised and received and the criteria by which investigations will be instigated, also considering how broader risks are identified.
The focus on listening to people is crucial to this role, giving weight to the patient voice and to patient experience can raise the profile of safety related incidents beyond that which feels like a token gesture.
Having the right team around the PSC will also be important, experts in patient safety, patient experience and patients and their representatives as well as analysis and legal experts will support the role and responsibilities. However it is important this team is built quickly and efficiently to allow the PSC to get on and fulfil the requirements of the post.

It is welcome that this post is not a regulatory post but is independent and sitting outside the NHS. Having statutory powers should allow the PSC to hold the system to account on behalf of patients and their families. How they hold them to account and how they encourage and support change to the system is detail we haven’t seen.

No comments on the appointment process.

See comments above.