WA Health Clinical Risk Management Guidelines
WA Health Clinical Risk Management Guidelines
WA Health Clinical Risk Management Guidelines
Guidelines
A best practice guide
Owner: Department of Health, Western Australia
Contact: Patient Safety Surveillance Unit (PSSU)
Department of Health
189 Royal St
East Perth, WA 6004
PSSU@health.wa.gov.au
Version: 3.1
Approved by: Dr A. Koay Executive Director PSCQ
Date: 26/11/2019
Important Disclaimer:
All information and content in this Material is provided in good faith by the WA Department of
Health, and is based on sources believed to be reliable and accurate at the time of
development. The State of Western Australia, the WA Department of Health and their
respective officers, employees and agents, do not accept legal liability or responsibility for the
Material, or any consequences arising from its use.
Contents
Key Definitions 1
Introduction 2
What is clinical risk management? 2
What is risk? 3
Why manage risk? 1
Purpose of Clinical Risk Management Guidelines 2
Clinical Risk Management Process 3
Communication and Consultation 4
Step 1 – Establish the context 5
Defining the scope 5
Establish the context 5
Step 2 – Identify the risks 7
Categorisation of risk 9
Step 3 – Analyse the risks 12
Types of analysis 12
Determining the adequacy of existing controls 13
Consequences of clinical risk 14
Likelihood of the risk 15
Determining the level of clinical risk 15
Step 4 – Evaluate the risks 18
Clinical risk evaluation 18
Roles and responsibilities 18
Determining acceptability of clinical risk 18
Step 5 – Treat the risks 21
Treatment options 21
Evaluating treatment options 22
Preparing treatment action plans 23
Implementing treatment action plans 23
Monitor and review 27
Implementation of Clinical Risk Management 29
References 30
Appendix A – Glossary 31
Appendix B – Risk categories and areas of risk 34
Appendix C – Example Risk Management Measures 36
Key Definitions
The following key definitions are used in the Clinical Risk Management Guidelines:
Control A measure that maintains and/or modifies risk. Controls include, but are not limited
to, any process, policy, device, practice, or other conditions and/or actions which
maintain and/or modify risk. Controls may not always exert the intended or
assumed modifying effect.
Controls may be preventative whereby a control prevents the cause of a risk or
mitigative whereby the consequences of a risk are reduced.
Risk means the organisational structure, procedures, processes and resources needed
Management to manage clinical and corporate risk and to monitor organisation’s performance
System and outcomes.
ERMS The enterprise risk management system used by the WA health system
Risk Treatment refers to the selection and implementation of appropriate management options for
dealing with identified risk.
Stakeholders are those people and organisations who may affect, be affected by, or perceive
themselves to be affected by, the decision or activity.
Standard refers to the Australia/New Zealand Standard on Risk Management AS/NZS ISO
31000:2018.
WA health refers to the whole of the WA public health system, particularly the Department of
Health, Health Service Providers and their hospitals.
Department of refers to the system management of WA health located at Royal St, East Perth.
Health
Organisation refers to a hospital or Health Service Provider or other designated public health
provider.
1
Introduction
Why is clinical risk management important for all clinicians?
In clinical practice there are a lot of things that can contribute to effective patient outcomes.
One of the most important things is avoiding unintentional harm to the patient. Patients trust
clinicians and expect that hospitals will be safe, caring environments which will contribute
positively to improving their health, and that is why risk identification and management is so
important. Risk management often requires busy clinicians to take a step back and not just
look at the patients under their care, but also at the processes, structures and environment
within which they provide this care. This process enables staff to identify vulnerabilities and
take corrective action when they see an unsafe situation or environment.
For example, taking steps to ensure a slippery floor is dry and preventing a patient, visitor or
another staff member from falling over is as important as ensuring that the medication a
patient is taking is the correct one.
But there is this risk when the physiotherapy department operates a hydrotherapy pool.
Could a young child waiting with their parent wander into an unattended and unsecure pool
facility? What plans are in place as control measures to stop this child from drowning? Are
these adequate? What is the risk rating?
These are the type of questions that should be considered for all of our areas of clinical
practice. These guidelines will assist all clinicians to understand the importance of identifying
hazards and areas of clinical risk as we work to keep our patients safe and prevent
unintended harm.
2
Clinical risk management is part of a good clinical governance system through which
organisations are accountable for continuously improving the quality of their services and
safeguarding high standards of care. As outlined in the Clinical Governance, Safety and Quality
Policy Framework3, this is achieved by creating an environment in which there is transparent
responsibility and accountability for identifying and managing risks, issues and opportunities so
that excellence in clinical care may flourish.
What is risk?
The Australian/New Zealand Standard AS/NZS ISO 31000:2018 defines risk as the effect of
uncertainty on objectives.4 Risks are measured in terms of consequence and likelihood. Risks
can be classified into the categories as outlined in Figure 1.
Figure 1: Risk categories
As indicated in Figure 1, clinical and corporate risks can cross over and impact on both clinical
and corporate functions. The WA health system is exposed to many clinical and corporate risks
on a daily basis as can be illustrated in Appendix B – Risk Categories and areas of risks. These
risks may arise from:
3
• provision of health care and its • natural events
related activities
• political circumstances
• operational management activities
• technology and technical issues
and control
• facilities and assets management
• human behaviour
• demographic and demand factors
• commercial and legal relationships
• strategic management
It is recognised that health care is increasingly complex in its delivery, personnel, service
demand and technology pressures. As such, risk management plays a vital role supporting and
informing decision-making in providing a safe and secure environment for patients, carers and
staff.
Note, having risks is inevitable in every organisation and there can be a positive relationship
with risk. Managing risk appropriately would assist in identifying opportunities for action and
improvements.5 However from a clinical perspective, most risks, if they are realised, are
detrimental to the patient.
The successful management of clinical risk would identify issues raised from incidents or other
lessons learned, provide adequate resources to control for the causes of the risk and ensure the
prevention of adverse events. Whilst not recognised as such, clinicians are an important
component of employing risk management strategies. Their daily clinical practice is embedded
with a range of risk controls (such as policies, processes, procedures and tools) that aim to
ensure adequate practices. Managing risks lead to effectively and efficiently providing safe, high
quality care to patients.
1
Purpose of Clinical Risk Management Guidelines
The primary focus of the Clinical Risk Management Guidelines (CRM Guidelines) is to provide
context and examples to illustrate how to apply risk management in a clinical setting. While the
CRM Guidelines have been written for service managers, safety, quality and risk
officers/coordinators/managers as well as staff involved in the risk management of day-to-day
operations of clinical services, the CRM Guidelines are relevant to all health employees to
understand and employ within comprehensive clinical governance system. It is acknowledged
that there is significant overlap between clinical and corporate risk within health
services/hospitals and a consistent and co-ordinated approach should be maintained.
The information and examples included in the CRM Guidelines are intended to highlight that risk
management is being undertaken by all health employees every day and is fundamental to
maintaining safe, high quality care. The examples that have been included were chosen from
recognised high risk areas but have been (in certain cases) extrapolated to the worst-case-
scenario for the purpose of demonstrating the application of risk principles. The risk
management processes and suggested tools in the CRM Guidelines are designed to support
structured clinical judgement so staff are better placed to make well informed decisions and
plans for the safe delivery of care to patients. The information, examples and tools provided do
not replace the requirement for clinical judgement and the examples do not encompass the
subjective nature of clinical scenarios.
The CRM Guidelines expand upon and underpin the overarching mandatory requirements in the
Clinical Governance, Safety and Quality Policy Framework3, the Risk, Compliance and Audit
Policy Framework6 and the Information and Communications Technology (ICT) Policy
Framework7.
The CRM Guidelines are closely related to the Clinical Incident Management Policy, Guideline
and Toolkit documents in that they may complement but not replace one another. The clinical
risk management processes outlined correspond to the clinical incident management processes
in ensuring the embedding of recommendations and prevention of further incidents.
The success of WA health’s approach to clinical risk management depends on the support and
commitment of the Health Service Boards, Chief Executives and the hospital/health service
executive teams with the active involvement of all staff including medical, nursing and allied
health professionals. Hospital/health service managers need to ensure that the contents of this
Guideline are disseminated, understood, implemented and maintained at all levels of the
organisation. Comprehensive but streamlined and coherent risk management systems,
underpinned by clear accountability arrangements throughout the organisational structure, must
also be established within each health service provider.
The specific details and processes for how to identify, register, escalate and manage risks will
be outlined by each health service provider, contact your local Risk Coordinator for more
information.
2
Clinical Risk Management Process
An overview of the structured and systematic risk management process as detailed by the
Australian/New Zealand Standard AS/NZS ISO 31000:2018 Risk Management4 is shown in
Figure 2. The risk management process outlined is intended to be an integral part of any
organisation’s practices and be applicable to all contexts. As such, clinical risks can be
managed using the 5 steps that are:
• Step 1: Establish the context
• Step 2: Identify risks
• Step 3: Analyse risks
• Step 4: Evaluate risks
• Step 5: Treat risks
Additionally, the overall processes of ‘Communication and Consultation’ and ‘Monitor and
Review’ should be included during all stages of the risk management process.
All organisations should record their risks and management activities in a Risk Register.
Figure 2: Risk Management Process4
RISK ASSESSMENT
The following sections will detail each process/step and provide tips/examples and case studies
of how to apply the process in a clinical setting.
3
Communication and Consultation
For clinical risk management to be successful, continuous communication and consultation with
the relevant staff, patients and families need to be in place at every step of the process.
Without an effective communication and consultation process, stakeholders will not be aware of
why clinical risk management strategies and policies have been developed and implemented.
Neither will they understand their individual roles and responsibilities for clinical risk
management.
All WA health staff have the responsibility to identify risks, manage them and when required,
report them to their manager for assessment and/or treatment. Many clinical risks may not be
raised or escalated to the next level of management as they can be adequately managed using
the controls that have been identified and implemented.
Clinical risk management should not be a stand-alone process outside of the normal
management activities of staff.5 Each step of the clinical risk management process should be
incorporated into the daily activities of all health employees.
4
Step 1 – Establish the context
Aim: To determine the objectives and goals against which risks will be identified and managed.
This step involves identifying the goals, objectives, strategies, scope and parameters of the
activity, or part of the organisation to which the clinical risk management process is being
applied. The process should be undertaken with full consideration of the need to balance costs,
benefits and opportunities. As outlined in Figure 1, there are risks at the strategic, operational
and project levels. Each level should be considered in regard to the context when applying
clinical risk management.
5
Some examples of matters to consider when establishing the internal context include:
• Whether the culture of your organisation has already embraced risk management
concepts and strategies?
• What financial resources are available to conduct the risk management process?
• Is there support from all the key internal stakeholders? If not, why not?
• What awareness is there of risk management principles and what tools are available to
facilitate the process?
One of the key stakeholders is the Health Service Provider Board. The Board will set overall
goals, objectives, values, policies and strategies along with the organisational risk appetite.
This will assist management to define the criteria by which the organisation determines whether
or not risk is acceptable and forms the basis of controls and management options.
6
Step 2 – Identify the risks
Aim: To identify all the risks associated with achieving the objectives identified in Step 1.
A systematic process is required to comprehensively identify all clinical risks within a
hospital/health service. Over time, all clinical risks at the State, health system, organisational,
business unit, team or patient level need to be identified, assessed, treated and monitored. To
start the process of identifying clinical risks, it is necessary for the hospital/health service to
identify and prioritise internal and external clinical risks that may pose a threat.
In the delivery of health care, WA health may be exposed to different types of risks, for
example:
• operational risks such as clinical services and procedures, clinical management process
failures, or lack of training and compliance with credentialing requirements
• legal risks such as complaints, medico-legal liability or statutory liability
• political or strategic risks such as organisational governance or State/Federal legislation
or regulations
• financial risks such as resource allocations, budget and resource management
• technology risks related to the procurement, development, deployment and use of ICT
systems/applications
Identification of clinical risk requires staff to have a thorough understanding of the following
components:
The main cause of the clinical risk that has the • e.g. main cause: similar/look-alike
packaging on medications dispensed
potential to result in harm. from a hospital’s pharmacy
The other causes (what and why) for the presence • e.g. storage of the medications, training
of the clinicians involved, lack of
of the clinical risk or hazard of the event occurring. checking processes
Identification of the potential result or outcome of • e.g. clinical incident where the patient is
the clinical risk on the organisation or its harmed from being administered the
stakeholders. wrong medication
When and where the clinical risk or hazard could • e.g. during the dispensing of medication
in the pharmacy or administration of the
occur. medication to the patient in the ward
7
In order to ensure that each organisation engages in an effective process of clinical risk
identification, the following strategies should be followed:
• Examine all causes of clinical risk from the perspective of all stakeholders, both internal
and external. By identifying each clinical risk cause, the organisation can consider the
contribution that each cause and its control/s makes to the likelihood and the
consequences of the risk (see Step Three). Possible methods of identifying clinical risks
are outlined in Figure 3.
• Clinical risk identification should be integrated into all new project scoping, assessment
and change management activities.
o For example, clinical risks should initially be identified in new business cases for
ICT projects or medical equipment to be procured. In addition, the Patient Safety
Risk Assessment (PSRA) process and document is incorporated in the ICT
Governance Policy and the ICT Project Management lifecycle. A PSRA must be
completed during the project initiation phase for every ICT project that impacts,
either directly or indirectly, on patient data.
• Access good quality information which will assist the service unit/team in understanding
their risks. The information should be relevant, comprehensive, accurate and timely. The
results of this assessment should be recorded. This can include data that has been
generated by the service unit/team themselves or from others.
o For example, the Patient Safety Dashboards produced by the Patient Safety
Surveillance Unit, provide data on the number and trends of clinical incidents by
themes/categories (National Safety and Quality Health Service Standards have
been included). Priority areas for risk assessment could be drawn from reviewing
the types of clinical incidents with high volume, such as falls, medication, obstetric
and mental health areas. The quarterly CIMS Check Up reports highlight a key
area that provides further data and insight into topics such as clinical handover
and deterioration.
o For example, the health service trends and important topic areas can be further
investigated by reviewing audit data collected from the service unit/team to identify
specific risks that are relevant.
o For example, accreditation data, reports and recommendations (including National
Safety and Quality Health Service Standards) are great sources of information as
they provide health service providers with an organisation-wide framework to
ensure the delivery of safe, high quality patient centred health care.
• Employ various methods of identifying risks and make sure to include all relevant
stakeholders to comprehensively identify risks.8 It may be necessary to draw from
experience, knowledge and expertise from outside (including patients and their family
and carers) as well as inside the immediate treating team/unit/division.5
o For example, patients of concern that are identified as high risk during the clinical
handover process draws on a range of information from various stakeholders.
o For example, the evaluation of comorbidities plays a major role in considering the
cumulative risk to the patient if they proceed with medical treatment (such as
surgery).
8
o For example, the consideration of risks in relation to providing clinical care to
specific patient groups such as patients living with mental illness or cognitive
impairment and patients from Aboriginal and Culturally and Linguistically Diverse
(CaLD) backgrounds may require involvement from a range of parties.
Figure 3: Possible methods of identifying clinical risks
Categorisation of risk
Risk categories are used to examine common types of risk across an organisation. The same
categories should be used across WA health, for both clinical and corporate services. A range
of risk categories that should be considered is available in Appendix B. The categories in the
table can assist in prompting risk identification as some examples of at risk areas are also
provided.9 Risk categories also assist in the analysing and reporting of risk but note that they
are different to the consequence categories that are used to analyse risks and will be explained
in the following section, Step 3 – Analyse the risks.
9
Case Study 1 – Identifying risks in orthogeriatric ward
A service area within St Nowhere Hospital is undertaking an Annual Quality Plan review and is
considering risks.
Ward manager/coordinator may undertake a quality walk around. This could include talking to
patients and staff, mapping the clinical pathways and activities that are undertaken and/or
gathering relevant stakeholders for a brainstorm.
Data or other information that could identify risks include:
• Clinical registry information (e.g. Hip Fracture data collection) and the gaps or
benchmarks that are being met/not met
• Clinical incident and audit data from that ward
• Accreditation reports
• Patient feedback and experience data including complaints
• Reported environmental hazards and near misses
• Occupational Health & Safety incidents including manual handling injuries
• Surgical site infection (SSI) surveillance data
• Hand hygiene compliance data
Upon review of the data and potential sources of risk, some risks identified could include:
1. Failure to provide appropriate care to prevent geriatric patients falling before or after
surgery.
This could be caused by:
A. Inadequate staffing levels
B. Environmental hazards
C. Lack of appropriate equipment
D. Patients’ frailty and/or confusion
E. Patients’ pre-or post-operative pain and discomfort
F. Inadequate or inaccurate falls risk assessment
And could result in a consequence of increased length of stay, serious harm or death.
10
2. Failure to provide safe patient care for the prevention of health care associated infections.
This could be caused by:
A. Inadequate cleaning of environment/equipment/patient
B. Poor Hand Hygiene
C. Poor aseptic technique
D. Inadequate patient nutrition
E. Evidence-based strategies to prevent SSI not implemented
And could result in a consequence of a health care acquired infection with an increased
length of stay, serious harm or death.
Reminder
Hospitals/health services must communicate and consult with internal and external
stakeholders and monitor and review clinical risk processes and outcomes at each step of the
clinical risk management process.
11
Step 3 – Analyse the risks
Aims: To determine the effectiveness of any controls and to undertake research about the risk
to support evaluating its risk rating.
A systematic analysis of the health system, organisational, business unit and team
environments should be undertaken to understand the nature of risk and to identify tasks for
further action. Specifically, the objectives of clinical risk analysis are to identify the nature of the
risk and its characteristics including where appropriate the level of risk.
Clinical risk analysis involves consideration of the sources of clinical risk, their consequences
and the likelihood that those consequences may occur. Factors which affect consequences and
likelihood are also identified. To calculate the risk level of an activity, elements of clinical risk are
considered individually and then combined to create a risk level, using the following formula:
The depth of analysis should be determined by the complexity of the activity and the availability
of information/data to aid the risk analysis process.
Measurement and ranking of clinical risks is undertaken using the Risk Assessment Tables for
the WA Health System10 . The tables include the:
1. Consequences Rating Table
2. Likelihood Rating Table
3. Risk Level Matrix Table
4. Aggregate Controls Assessment Table
5. Risk Acceptance/Tolerance Criteria Table
6. Specific Risk Criteria
Types of analysis
There are three methodologies that could be used to calculate the ‘consequence’ and
‘likelihood’ of the risks: quantitative, qualitative and semi-qualitative.
(a) Quantitative methodology: can be the most accurate method of collecting information.
For example, data may be available to define quantitative risk levels for a particular
medical procedure or define the likelihood and consequences of a disease developing in
particular circumstances.
Some examples of quantitative methods of analysing risk include:
• descriptive statistics such as • life-cycle cost analysis
frequencies, cross tabulations, • fault tree and event tree analysis
percentages and rates
• consequence analysis
• probability analysis
• statistical/numerical analysis
• simulation/computer modelling
12
• decision trees • influence diagrams.
(b) Qualitative methodology: relies on a manager using his/her experience, judgement and
intuition to calculate the level of risk based on their knowledge. Examples of qualitative
methods, include:
• structured interviews/questionnaires • evaluation using multi-disciplinary groups
• specialist and expert judgement • bench-marking
• peer review and/or discussion • qualitative mapping
• networking with industry and • structured interviews with experts in the
professional associations area of interest.
• brainstorming
Where a qualitative methodology is to be used to identify the level of clinical risk, managers
should ensure that they have a sound understanding of their organisation’s risk criteria and
organisational context, and find the closest match in the descriptions in the Risk Assessment
Tables for the WA Health System10
(c) Semi-quantitative methodology: allocates numbers to qualitative work rankings such
as high, medium or low. The rankings should be shown against an appropriate numerical
scale, which allows the information to be processed quantitatively.
If using a semi-quantitative approach, it is important that managers do not interpret the results
to a finer level of precision than is actually contained in the initial word ranking. Also, assessors
should not use the numbers to give an appearance of precision where it does not exist.
Where a qualitative methodology is to be used to identify the level of clinical risk, managers
should ensure that they have a sound understanding of their organisation’s risk criteria and
organisational context, and find the closest match in the descriptions in the Risk Assessment
Tables for the WA Health System10
13
For each control category there should be an organisational list of existing controls that can
comprise policies, guidelines and tools. For example, the development of a comprehensive care
plan based on integrating screening, assessment and risk identification processes is a control
for the risks associated with the care of the patient. Examples of WA Health clinical controls are
outlined in Appendix D. When analysing a risk, each control in place for that risk may be
assessed using the control effectiveness guidance in Table 1.
To determine the aggregate effectiveness of the controls that are in place refer to Table 4 in the
Risk Assessment Tables for the WA health System. Controls are rated as:
• Excellent
• Satisfactory
• Marginal or
• Weak
Controls that are assessed as below a satisfactory rating should be improved.
Once the adequacy of the controls has been analysed, the calculation of the current risk rating
can be completed by scoring the consequence and likelihood of that risk.
The level of clinical risk is defined by the relationship between the consequence and likelihood
applicable to each of the risks identified. The Consequence Rating Table 1 is used to identify
the worst, realistic , primary consequence(s) should an incident occur given the existing level of
controls.4,10
14
Using the 1-5 rating category from the Consequences Assessment Table, the best fit is then
chosen. Note it is not necessary to address each consequence category within the table.
However there may be multiple consequence categories applicable to this risk. Where this
occurs, it is important to assess each consequence individually.
Where there are multiple consequence categories and their likelihood rating identified for a risk,
the highest risk ranking should be chosen as the overall risk rating for the risk.
15
Case Study 2 a) – Analysing risks to sole practitioners in home visits to a patient
A Hospital in the Home (HiTH) nurse could not tend to a patient at home due to an
aggressive, large dog in the front yard of the patient’s house having no alternative way to
contact the patient within the house. This experience was raised to the HiTH Manager with
the nurse’s concern for the patient who needed care after day 3 from a Total Hip
Replacement. A number of staff have been in similar situations.
The Controls Assessment was rated as Marginal because the limited controls did not address
all of the causes of the risks and there was no periodic review of the controls.
Considering the controls, the Consequence Category was identified as: Health impact on
patients (HP) and Health Impact on Staff or Others (HS).
The Health Impact on the Patients (HP) was assessed as Level 3 (Moderate) because an
additional moderate level of care would be required for the patient (with an extension of their
length of stay/care required between 72 hours to one week)
The Health Impact on Staff (HS) was assessed as Level 3 (Moderate) because staff who
were injured would require time off work between 1 week and 1 month.
The likelihood of the risk was assessed as Level 4 Likelihood (Likely) because the HiTH
Manager and team approximated that the frequency of failure to attend to a patient was 1 in
100 episodes of care.
The Risk Rating was then calculated as: 3x4=12 being HIGH
16
This case study example will be continued in the following steps of evaluating and treating the
risk outlined in the following sections.
Reminder
Hospitals/health services must communicate and consult with internal and external
stakeholders and monitor and review clinical risk processes and outcomes at each step of the
clinical risk management process.
17
Step 4 – Evaluate the risks
Aims: to assess what action the level of risk determined in Step 3 requires, including the
evaluation to determine if treatments should be developed and/or the risk should be escalated.
Risk evaluation and prioritisation involves comparing the level of risk found during the analysis
step with previously established risk criteria and developing a prioritised list of risks for further
action. A decision should be made for the risk treatment options include:
a) Avoid the risk
b) Improve risk controls
c) Share or transfer the risk
Decisions concerning risk acceptability and risk treatment may be based on clinical, operational,
technical, financial, legal, social, humanitarian or other criteria. These often depend on an
organisation’s internal policy, goals, objectives and the interests of stakeholders.
18
• the opportunities presented outweigh the threats to such a degree that the risk is
justified. For example surgical interventions will always be associated with high risks so it
is important to ensure that all controls (e.g. surgical checklists) are in place and operating
to prevent or mitigate causes and effects of all known risks.
If the clinical risks are not considered as being acceptable to the organisation, the activity/event
should be avoided or additional treatments added. The clinical risks to be avoided or treated
should then be prioritised for appropriate management action under the organisation’s strategic
clinical risk management and operating plans in the next step.
The Controls Assessment was rated as Marginal because the limited controls did not address
all of the causes of the risks and there was no periodic review of the controls.
Considering the controls, the Consequence Category was identified as: Health impact on
patients (HP) and Health Impact on Staff or Others (HS).
The Health Impact on the Patients (HP) and Staff (HS) was assessed as of Level 3
(Moderate) because an additional moderate level of care would be required for the patient
(with an extension of their length of stay/care required between 72 hours to one week) and
staff who were injured would require time off work between 1 week and 1 month.
The likelihood of the risk was assessed as Level 4 Likelihood (Likely) because the HiTH
Manager and team approximated that the frequency of failure to attend to a patient was 1 in
100 episodes of care.
The Risk Rating was then calculated as: 3x4=12 being HIGH
Evaluating the risk score of 12 against the Risk Level Matrix- Table 3 the risk was High which
is generally considered intolerable. Risk Tables 5 and 6 guide decisions on risk acceptance/
tolerance.
Controls should be at least Satisfactory (in step 3, the controls were rated as Marginal) and
improved to an Excellent rating as soon as practicable and monitored.
The risk was listed on the hospital’s risk register and escalated to the Chief Executive (the
appropriate Tier 2 equivalent executive as outlined in the hospital’s guidelines) to review,
address the next steps and monitor the risk.
This example will be continued onto Step 5 – Treat the risk in the following section.
19
Key questions in analysing and ranking risks
• What is the acceptable level of clinical risk?
• What level of clinical risk am I delegated and authorised to accept?
• If I cannot accept the clinical risk who can I refer it to for action?
• What are the potential positive and/or negative results of treating a clinical risk?
• What is the priority of the clinical risks (e.g. high, medium, low)?
• Is immediate action required?
• Who do I communicate the results to?
Reminder
If you rely on other stakeholders to operate a control that you rely on to keep your risk ranking
low, then you must communicate with those stakeholders on a regular basis.
Hospitals/health services must communicate and consult with internal and external
stakeholders and monitor and review clinical risk processes and outcomes at each step of the
clinical risk management process.
20
Step 5 – Treat the risks
Aim: to develop cost effective options for treating those risks that have been evaluated as being
unacceptable in Step 4.
Risk treatment involves identifying the range of options for treating risk, assessing those options
and preparing and implementing risk treatment action plans. Where risks cannot be accepted a
treatment option may involve avoiding the risk, improving the risk controls or sharing or
transferring the risk. Each treatment option should be evaluated for effectiveness. A
combination of options may be considered.
Treatment options
Clinical risk treatment is concerned with options to treat the risks that were deemed as not
acceptable to the organisation. Treatment options available may include:
(a) Avoiding the activity/event associated with the unacceptable risk
A health service provider may avoid the clinical risk by deciding either not to proceed with an
activity that contains unacceptable risk, choosing an alternative activity that has less risk for the
organisation, or choosing an alternative less risky methodology or process to complete the
desired activity.
It should be noted that clinical risk management is not an exercise in risk avoidance.5 There are
circumstances in which the health service provider may choose to retain and manage the risk,
simply because it is the organisation best equipped (in terms of specialist staff and resources)
to do so. In such circumstances, the health service provider should implement appropriate risk
management processes and work practices to reduce the consequence and/or likelihood of
harm to individuals or loss to the organisation.
(b) Reduce the risk by improving controls
Reducing the level of risk involves the reduction of the likelihood or consequences of risk, or
both. Hospitals/health services may reduce the likelihood of clinical risk through enhancement
of existing controls or additional controls. Examples of how health service providers may reduce
risk include revision of documented policies and procedures, quality assurance, training,
supervision and environmental monitoring.
21
Example for introducing a preventative control
• To reduce the risk of treating the wrong patient when two or more patients in a ward have the
same surname a local “PATIENT WITH THE SAME NAME IN WARD" cautionary card must be
applied to each patient's health care record. Alerts must also be applied to all ward bed lists and
other patient documentation while both patients remain in the ward. The patient’s given name
should also be printed on these cards.
It should be noted that there is often a compromise between the level of risk and the cost of
reducing those risks to an acceptable level. Any number of decision points need to be
considered, including:
• a satisfactory (but not optimum) solution
• the most cost-effective solution
• the accepted practice (industry norm, evidence-based best practice)
• the best achievable result (given current technology and resources)
• the absolute minimum result that can be accepted.5
(c)Transferring the clinical risk
Transferring the clinical risk may involve sharing the risk with another party. As a general
principle, risks can be transferred by contract, legislation or administrative processes to another
party. For a clinical risk, this could take the form of transferring the activity completely to another
hospital or provider.
22
Selection of the most appropriate treatment option will require health service providers to
evaluate the cost of implementing each option against the benefits that may be derived from it.
Evaluating the risk score of 12 against the Indicative Risk Ranking and Criteria Table
(Appendix C), the risk was High and intolerable/unacceptable.
Controls must be at least Satisfactory (in step 3, the controls were rated as Marginal) and
need to be improved to an Excellent rating as soon as practicable.
The risk was listed on the hospital’s risk register and escalated to the Director of Community
Services (the appropriate Tier 3 equivalent manager as outlined in the hospital’s guidelines)
to review, address the next steps and monitor the risk.
Upon consideration of the risk with the HiTH Manager and team, it was approved by the
Director of Community Services to treat the risk by improving the controls rating to Excellent
by introducing and closely monitoring the following controls:
• Develop a home visiting policy and guidelines to outline the agreed, standard
procedures for staff to undertake before, during and after visiting a patient at home.
The procedures include:
o Staff to carry out a risk identification and assessment of the home visit (using
the home visit risk assessment tool) prior to arranging the home visit with the
patient.
If patient was referred, the referring person should be queried about the
client and others in the home.
23
o The visit should be classified as high risk if the patient is unknown to the HiTH
staff or certain criteria are highlighted during the risk assessment.
o For high risk home visits, an action plan should be developed with input and
approval from the HiTH manager and two staff members are to attend the home
visit.
o Staff to arrange an appointment for a home visit with the patient and should
routinely ask about pets or other safety issues at the home. Ask patient to
secure the pet if staff feel uncomfortable or if patient indicates that pet may be
disruptive.
o Create system and processes for the HiTH manager to monitor the movements
and safety of staff whilst visiting patients, including notification via mobile once
the staff member has started and finished the home visit.
o Provision of a mobile phone to staff during home visits. Ensure phone is
charged, unlocked and has emergency contacts programmed in speed dial.
o Staff to call before the home visit to reconfirm with patient about the home visit
and prepare them with an estimated time of arrival.
o Once home visit is completed, return to HiTH office and update the risk
assessment and other patient records to reflect experience. If there are issues
that were identified, notify the HiTH manager and any other staff members that
may attend the home visit in the future.
• Education regarding the policy and guideline requirements is to be scheduled regularly
for all HiTH staff upon induction and throughout each year.
• Regular (quarterly) review and audits of the compliance and knowledge of the
procedures.
These controls are now considered Satisfactory and reduce both the likelihood and
consequences of the risk. The subsequent risk rating is now calculated as Level 2 (minor
consequence) x Level 3 (possible likelihood) = Level 6 risk (Medium Risk).
This risk is now tolerable to the organisation if the controls are maintained and reviewed
frequently and the risk is reviewed at least annually.
24
Case Study 3 – Clinical risk management process for risk in Obstetrics Unit
A busy Obstetrics Unit has had a number of clinical incidents related to neonatal harm
evidenced by low Apgar scores and unexpected still births. Multiple Midwives have expressed
their concerns to the Obstetrics Head of Department.
The Aggregate Controls Assessment was rated as Marginal because not all causes have
corresponding controls in place.
The Consequence Category was identified as: Health impact on Patients (HP).
The Health Impact on the Patients (HP) was assessed as of Level 5 Consequence
(Catastrophic) and Level 4 Likelihood (Likely).
This can be assessed by using data from the Clinical Incident Management System (CIMS)
on the severity of neonatal harm (especially reviewing SAC1 incidence).
The Risk Rating was then calculated as: 5x4=20 being EXTREME.
This level of risk was deemed not acceptable to the organisation and further resources would
be made available to treat the risk.
A decision was made that women with high risk pregnancies should be transferred to deliver
their babies at a nearby, specialist facility. This would immediately reduce the risk from being
25
rated Extreme down to the next level of High. Consequence still assessed as Level 5
(Catastrophic) but Likelihood being reduced to Level 3 (Possible) so the risk rating would be
5x3 = 15 being HIGH.
Additional Treatment Action Plan (TAP) items that were implemented so that the controls
would be assessed as Satisfactory and included:
1. The introduction of a Maternity Observation Chart to prompt early recognition of clinical
deterioration.
2. All obstetric staff to attend an Advanced Fetal Monitoring Training.
3. Midwifery rosters to recognise the need for two midwives to check CTG traces.
Implementation of these TAPs need to be reviewed (at a specific time period) in order to
reassess the risk score and the successful treatment of the risk.
Reminder
Hospitals/health services must communicate and consult with internal and external
stakeholders and monitor and review clinical risk processes and outcomes at each step of the
clinical risk management process.
26
Monitor and review
It is the responsibility of the health service provider’s executive team to monitor and evaluate all
aspects of the organisation’s clinical risk management framework including, accountability
arrangements, development, implementation and utilisation of clinical risk management policies
and processes, training and professional development for staff, clinical and organisational
outcomes and internal audit findings.4,5
Health service providers should develop and apply mechanisms to evaluate the outcomes and
impact of risk management systems at all levels of the organisation. The organisation should
develop and implement performance indicators to demonstrate the effectiveness of the
organisation’s risk management performance.11,12 Appendix E provides example measures that
can be utilised for the implementation of a risk management strategy. Additionally, reviews by
independent bodies may assist health services to monitor, review and report on performance
and achievement of expected outcomes to stakeholders and to identify areas of concern that
need to be addressed.
Line managers in the clinical organisational structures should periodically review their risks in
the Enterprise Risk Management System and include their status with commentary on any
significant risk issues in the reporting frameworks as outlined by the health service provider.
Reporting of significant risk should escalate through existing structures in accordance with
management responsibilities as outlined by each health service provider.
In order to review risks, controls need to be reviewed. Assurance that controls are operating as
described is important to maintain confidence about the level of risk that is being accepted.
27
Case study 4 – Learning from experience and monitoring in a United Kingdom Primary
Care Trust13
The Lincolnshire South West Teaching Primary Care Trust established a ‘learning from
experience’ group (LEG). This group was established in the context of large reform program
where the accountability of safe, efficient and effective health services was shifted to the local
chief executives’ responsibility and clinical governance was a large focus. This parallels with the
current WA health environment.
The LEG was established after an executive identified that despite a wealth of data being
collected on clinical governance, each was being dealt with in silos. The group incorporated a
multidisciplinary and varied cross section of members who met monthly to review all complaints,
incidents, feedback/calls to patient advice and liaison services and any other relevant
information, including patient surveys and national reports. The LEG aimed to and succeeded
in bringing key stakeholders from various committees and areas together to discuss and share
problems, opportunities, potential problems and develop solutions in a proactive and holistic
way.
28
Implementation of Clinical Risk Management
Implementation of clinical risk management programs at all levels of the organisation is a
challenge for all clinicians and managers alike. The challenge for management is to support and
encourage prudent clinical risk management by:
• communicating and demonstrating support for clinical risk management
• trusting and empowering all staff to identify, analyse, report and manage risks
• acknowledging, rewarding and empowering good clinical risk management practices
• identifying and managing systemic problems as they occur
• encouraging organisational learning
• developing positive strategies to reduce the likelihood of recurrence of the problem
and/or consequences rather than responding by introducing restrictive controls.5
Health service providers are required to develop and implement arrangements to ensure that
clinical risk management becomes an integral part of the planning and management processes
and general culture of the organisation. Enabling strategies may include:
• communicating the hospital’s/health service’s clinical risk management arrangements
throughout the organisation
• assigning responsibility for managing clinical risk at all levels of the hospital/health service
e.g. outline a checklist of responsibilities by management level for self-assessment and
planning as can be viewed in the Victorian Clinical Governance Policy Framework14
• ensuring that all staff have the necessary knowledge and skills needed to manage clinical
risks, e.g. incorporating clinical risk management into internal orientation, staff development
and training programs
• providing appropriate support and expertise to those responsible for managing clinical risks
• ensuring that an accurate and complete record of risks and risk management activities are
maintained in the Enterprise Risk Management System (ERMS) which is supported by a
regular review process
• ensuring that the expected outcomes of the clinical risk management framework are
monitored and reported to the hospital’s/health service’s senior management for review
• ensuring that systems for staff rewards, recognition and sanctions include clinical risk
management
• ensuring that internal reviews and evaluation, such as internal audit, clinical audit and
incident monitoring and reporting take account of the organisation’s philosophy towards
clinical risk management.
As outlined throughout the CRM Guidelines, the involvement and commitment of all clinicians
through to managers, executives and Health Service Boards is key to ensuring clinical risk
management is embedded within the organisation’s culture, structure and processes.
29
References
1. Reason J. Human Error. Cambridge University Press; 1990.
2. Boland B. In: Clinical Risk Assessment and Management for Individual Service Users -
Policy and Procedures. 2010
3. Clinical Services and Research Division DoH. In: Clinical Governance, Safety and Quality
Policy Framework. 2016 Department of Health WA.
4. Standards Australia/Standards New Zealand Standard Committee. In: AS/NZS ISO
31000:2009, Risk Management-Principles and Guidelines. 2009 1
5. RiskCover. In: Western Australia Government Risk Management Guidelines. September
2014
6. Deaprtment of Health. Risk Management Policy 2019 MP 0006/16
7. Office of the Deputy Director General DoH. In: Information and Communications Technology
Policy Framework. 2016
8. Potts HWW, Anderson JE, Colligan L, Leach P, Davis S, Berman J. Assessing the validity of
prospective hazard analysis methods: a comparison of two techniques. BMC Health Services
Research [Article]. 2014;14(1):1-17.
9. NSW Health Legal and Regulatory Services. In: Risk Management - Enterprise-Wide Risk
Management Policy and Framework - NSW Health. 2015
10. Risk Assessment Tables for the WA Health System. 2019
11. Briner M, Kessler O, Pfeiffer Y, Wehner T, Manser T. Assessing hospitals' clinical risk
management: Development of a monitoring instrument. BMC Health Services Research
[Article]. 2010;10:337-347.
12. Azami-Aghdash S, Tabrizi JS, Sadeghi-Bazargani H, Hajebrahimi S, Naghavi-Behzad M.
Developing performance indicators for clinical governance in dimensions of risk management
and clinical effectiveness. International Journal for Quality in Health Care [Article].
2015;27(2):110-116.
13. Hart E, Huddleston A, Smith J. Learning from experience: a case study of clinical
governance in action. Quality in Primary Care [Article]. 2006;14(1):29-32.
14. Victorian Government. In: Victorian clinical governance policy framework - A guidebook.
2009. Melbourne, Victoria: Statewide Quality Branch, Rural and Regional Health and Aged Care
Services.
1 The Standard was updated in 2018. This document underwent minor updates in 2019 but a full review of the
revised 2018 Standard was not undertaken at this time.
30
Appendix A – Glossary
Adverse event is a clinical incident where an injury/harm is caused by medical management or
complication thereof, instead of the underlying disease. It results in an increase in the level of
care and/or prolonged hospitalisation and/or disability at the time of discharge. Medical
management refers to management under health care services.
Clinical incident an event or circumstance resulting from health care provision (or lack thereof)
which could have or did lead to unintended or unnecessary physical or psychological harm to a
patient. Clinical incidents include:
• Near miss: an incident that may have, but did not cause harm, either by chance or through
timely intervention.
• Sentinel events: a subset of serious clinical incidents that has caused or could have caused
serious harm or death of a patient. It refers to preventable occurrences involving physical or
psychological injury, or risk thereof.
Claim means any approach for compensation made via legal means to a hospital or health
service.
Cost refers to a measure of activities both direct and indirect, involving any negative impact,
including time, money, labour, disruption, goodwill, political and intangible losses.
Control A measure that maintains and/or modifies risk. Controls include, but are not limited to,
any process, policy, device, practice, or other conditions and/or actions which maintain and/or
modify risk. Controls may not always exert the intended or assumed modifying effect.
Controls may be preventative whereby a control prevents the cause of a risk or mitigative
whereby the consequences of a risk are reduced.
Department of Health refers to the management of WA Health located at Royal St, East Perth.
ERMS is the enterprise risk management system used by the WA health system.
31
Loss means any negative consequence, financial or otherwise.
Organisation refers to a hospital or Health Service Provider or other designated public health
provider.
Risk Management System means the organisational structure, procedures, processes and
resources needed to manage clinical and corporate risk and to monitor organisation’s
performance and outcomes.
Risk Analysis means a systematic use of available information to determine how often
specified events may occur and their likely consequences. The purpose of risk analysis is to
identify the causes, effects and magnitude of risk and provide a basis for risk assessment and
risk treatment.
Risk Appetite The nature and extent of the risks the governing body is prepared to accept to
meet objectives.
Risk Assessment refers to the processes used to determine risk management priorities by
evaluating and comparing the level of risk against organisational standards, predetermined
target risk levels or other criteria.
Risk Identification refers to the process of determining what can happen, why and how.
Risk Level The risk level is determined by multiplying the consequence rating by the likelihood
rating to achieve a risk level from 1 (Low) to 25 (Extreme).
Risk Management refers to the systematic application of management policies, procedures
and practices to the task of identifying, analysing, assessing, treating, monitoring and
communicating risk.
32
Risk Reduction means the selective application of appropriate techniques and management
principles to reduce either the likelihood of an occurrence or its consequences, or both.
Risk Retention means the intentional or unintentional retention of responsibility for the loss, or
financial burden, associated with a risk, within the organisation.
Risk Treatment refers to the selection and implementation of appropriate management options
for dealing with identified risk.
Risk Transfer means shifting responsibility or burden for loss to another party through
legislation, contract, insurance or other means. Risk transfer also refers to shifting a physical
risk or part thereof elsewhere.
Stakeholders are those people and organisations who may affect, be affected by, or perceive
themselves to be affected by, the decision or activity.
Standard refers to the Australia/New Zealand Standard on Risk Management AS/NZS ISO
31000:2018.
Treasurer’s Instruction refers to Treasurer’s Instruction 825: Risk Management and Security
(formerly Treasurer’s Instruction 109: Risk Management).
Treatment Action Plan (TAP) refers to the plan that is developed and reviewed during the risk
treatment process of selecting and implementing the appropriate actions for dealing with
identified risk. TAPs should include detail on the risk owner, proposed actions, resource
requirements, timeframes and effect of the treatment on the risk.
WA Health refers to the whole of the WA public health system, particularly the Department of
Health, Health Service Providers and their hospitals.
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Appendix B – Risk categories and areas of risk
Best practice in risk identification requires the categorisation of risks to both instigate identifying
risks and also reporting of risks. If a risk has aspects that relate to more than one category, the
predominant category is recorded on the risk register.
This list has been extracted in its entirety from the NSW Enterprise-Wide Risk Management
Framework9.
34
Risk category Examples of sources of risks
Emergency • Business continuity planning, • Natural disasters, (e.g. Extreme weather
Management management and resilience event)
• Infectious disease outbreaks, including • Man-made disasters (e.g. widespread
emerging infectious diseases, and other power failure, explosion)
biological threats • Chemical, radiation or hazardous
• Drinking water, pharmaceutical, food or material incident
other contamination
Legal • Litigation • Contract management
• Commercial and legal management • Intellectual property
• Regulatory Compliance
Finance • Fraud • Public liability
• Medical indemnity insurance and • Administration, including
Treasury managed fund accommodation, payroll and transport
• Operational budgets and financial and travel
performance requirements under Service • Commercial income
Agreements • Procurement of goods and services,
maintenance and contracts management
Work Health & • Workplace health and safety • Workers compensation and injury
Safety • Contractor non compliance management
Environmental • Air quality, heating, noise, lighting and • Waste management
radiation • Cleaning services
• Hazardous substances and dangerous • Infection control
good
Leadership & • Complaints and compliments • Monitoring performance
Management management • Performance Management
• Credentialing and delineation of clinical • Political circumstances
privileges • Professional development and Mentoring
• Economic circumstances • Reputation and image
• Effective Leadership • Resource accountability
• Enquiries and ministerials • Service Agreement requirements
• External and internal auditing • Strategic and operational planning
• Governance structures, delegations and • Succession planning
financial management
• Legislative compliance
Community • Access to services • Consumer engagement and
Expectations • Consumer feedback, cultural and special empowerment, and stakeholders
needs, planned and delivered in expectations
partnership with patient rights and • The right care and services – including
responsibilities the protection of children – provided in
the right setting within appropriate
timeframes
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Appendix C – Example Risk Management Measures
This example provides some suggestions for a risk management strategy plan and relevant measures to monitor compliance.
Establish scope and Risk management will be incorporated into all normal business activities Biennially All staff Board
organisation including planning, operational processes and reviews.
objectives/activities
Risk Management A review of the framework every two years allows the organisation to Biennially Safety, Quality, Board
Strategy/Framework continually improve its processes without deviating too far from the policy Risk Committee
and procedures
Risk Management A review of the policy every year allows for any changes to be Annually Safety, Quality, Board
Policy and guidelines incorporated and keep the information as updated as possible. Risk Committee
Risk Assessments Formal risk assessment workshops will be undertaken as part of the Annually All Safety, Quality,
annual business plan cycle, new initiatives, budget bids etc. units/divisions Risk
Committee
Roles and Review assignment of roles and responsibilities quarterly during the Quarterly All
responsibilities reporting cycle. If responsibilities for risks, controls or treatments have units/divisions
changed, they will be reflected in the reports.
Risk Management Risk register review and related reporting to internal hierarchies (e.g. Quarterly All Board
Reporting Managers-Executive Directors/Heads of Department-Chief Executive- units/divisions
Committees-Board).
Treatment Action Plans TAPs should be reviewed regularly by the risk, control and treatment Quarterly All Safety, Quality,
owners but are only reported on a quarterly basis. units/divisions Risk
Committee
Compliance and testing Declarations are submitted quarterly and undergo a testing process to Quarterly Risk Safety, Quality,
determine the quality of the report and level of compliance manager/team Risk
Committee
36
Monitor and review Lessons learned to be identified via audits and other processes to Quarterly Risk Safety, Quality,
continuously improve on risk management processes manager/team Risk
Committee
Training and education Risk workshops/training packages provided and presented to all staff Bi- Risk Safety, Quality,
annually manager/team Risk
Committee
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Document Control
Version Date Amendment details
2.5 16/8/2016 Final
3.1 26/11/2019 Minor update to align with
Risk Assessment Table
changes October 2019
38
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