Dear Mrs Connor Response to Regulation 28 Report following the Inquest into the death of Mrs A O'Donnell I am writing to set out the Trust's response to the Regulation 28: Report to Prevent Future Deaths, dated 3 November 2021, which was issued following the inquest into the death of Mrs Angela O'Donnell. I would like to begin by extending our deepest condolences to the family of Mrs O'Donnell. We fully appreciate that this has been, and will remain, an extremely difficult time. Whilst we appreciate that you make clear in your report that your enquiry did not find that there were any failings which had a causative impact on Mrs O'Donnell's death, we do appreciate that the issues raised will be a concern to the family of Mrs O'Donnell. I hope that our response provides assurance to both you and Mrs O'Donnell's family that the Trust is looking seriously at how to address these issues. You summarise your concerns arising out of the evidence you heard at the inquest as follows: 'Wexham Park Hospital, along with many hospitals nationally, has a serious problem with staffing shortages in many areas, including nursing. As such, they have little choice but to use large numbers of agency nurses to fill those gaps in the short term. This is a picture which is reflected up and down the country .... This is a complex and national issue, but it is the important responsibility ofcoroners to highlight matters of concern, where we believe there is a risk of future deaths. Concern about the use of agency staff is by no means new information. This report does not tell the hospital anything they do not already know. It is difficult even for the senior managers within the trust to identify the cause or v~
f. ~ INVESTORS \ 8 IN PEOPLE In partnership with the Ministry of Defence ~-~ Frimley Health incorporates Frimley Park Hospital, Heatherwood Hospital and Wexham Park Hospital

causes of these national shortages. Coroners are under a duty to flag up concerns where there is a risk of future deaths - even where the solution to that concern is not clear. I have heard in evidence on more than one occasion that recruiting more nurses is difficult - not because the trusts are not trying to recruit them, but simply because there are insufficient nurses out there to recruit. Given the fact that this issue is a national one, and the root cause of it is nursing staff shortages, I have considered it necessary to include the Secretary of State for Health and Social Care, to add my voice to this ever-increasing national concern. The MATTERS OF CONCERN are as follows. ­ (1) Is the trust able to carry out any steps to reduce their reliance on agency nursing staff- for instance, by using nurses from a smaller pool of their own bank staff who receive the same training as permanent staff, or any other similar measures? This question is for the hospital trust. (2) What plans are there nationally to reduce the shortage of nursing staffgoing forward? This question is for the Secretary of State.' I recognise the point you have made about the reliance on agency staffing being a national issue for the NHS and that you have also directed your concerns to the Secretary of State for Health. It would not be appropriate for me to seek to address or comment on the national issue in this response, but I hope to set out what Frimley Health NHS Foundation Trust is doing to address your first concern listed above. I will explain how we are aiming to reduce our reliance on agency nursing staff by: a) Working to increase the recruitment of nursing staff and, b) Encouraging our substantive staff to undertake bank shifts. I will also address how grateful the Trust is for the flexible resource which agency staff provide us with in assisting with patient care when we do have unavoidable gaps in our staffing and how we are improving the way in which we work with our agency staff to ensure the safety of our patients.
1. Our nursing recruitment The Trust is constantly undertaking a range of initiatives to recruit nurses and has been successful in reducing the nursing vacancy rate over the past two years from 13.7% in April 2019 to 8.9% in October 2021. The Trust advertises vacancies through a combination of targeted and specific advertising, alongside generic campaigns, open days, virtual events, and attraction campaigns using social and digital media and professional publications. We also look to increase our student placement capacity year on year to increase the number of nursing staff in training. It is the intended aim that these nurses will then continue in substantive roles within the Trust upon qualification. We offer various training routes into registered nursing through Trainee Nursing Associate (TNA) and Degree Apprenticeship routes. Over the last few years we have successfully supported 50 Care Assistants through their Nursing Associate (NA) training and currently have a further 57 staff on their TNA programme. These programmes have continued to grow each year and it is hoped that this will help stabilise our substantive nursing workforce over the next three years and reduce our reliance on temporary staffing. International recruitment forms a large part of our nursing recruitment activity, with 172 international nurses recruited in 2019120 and around 200 so far in 2020/21 . We have an ambition to increase our international nurse recruitment to around 400 nurses throughout 2022, with additional funding from NHSE/1 to support this.

Our International Educated Nurses (IEN) are supported from day 1 in the organisation with preparation for their UK exam to enter the Nursing Midwifery Council register. Following successful entry onto the register, all lEN's then enter a preceptorship period where they are supported and developed alongside our newly qualified nurses from the UK. Pastoral care for our international staff is a priority as we recognise the importance of ensuring that all of our workforce is valued, and that they feel integrated as part of our community. Our registered nursing workforce is also supported by healthcare support workers. The Trust regularly undertakes recruitment drives to meet the national target of zero healthcare support worker vacancies. This is again supported by offering additional training through apprenticeship routes and the Care Certificate, with additional funding currently being provided by NHSE/I to support this initiative. 209 care assistants have started in the Trust over the last 12 months with a further 93 having been recruited who are currently completing their pre-employment checks. The Trust recognises that there needs to be a continued focus on recruitment and is always looking at all options to improve our vacancy rate. We recognise that patient care is best provided by a consistent, and substantive nursing staff team and recruitment of nursing staff will continue to be a main priority for us as an organisation.
2. Encouraging our substantive staff to undertake bank shifts and increasing the number of 'bank nurses' we employ To supplement and support our substantive nursing teams the Trust runs its own Staff Bank, this provides a team of bank nurses who provide cover for planned and unplanned shortfalls in staffing, covering vacancies and absences. This flexible resource is invaluable across all NHS organisations. When employed on a permanent contract with the Trust, all our staff are automatically registered with a 'bank contract' and are encouraged to undertake any additional shifts they can work. Furthermore, the Trust recognise that staff who leave permanent roles within the Trust do so for a variety of reasons. Staff leaving permanent contracts with the Trust are actively encouraged to remain on the bank register, thus allowing them to return to work shifts at the hospital under a bank only contract.
3. Staff retention and wellbeing. The Trust recognises the importance of retaining staff as well as recruitment, this is vital to achieving a safe and sustainable workforce. We understand that retention of nursing staff is a recognised challenge nationally and we are working hard to improve staff wellbeing as a cornerstone of this issue. We have recently been allocated funding from NHSE/I for two posts which will be actively recruited to in early 2022 to support the 'NHS People Promise'. One post will be held within the Trust as a People Promise Manager and the second within our Integrated Care System (ICS) as a Retention Lead. These roles will support the Trust and the wider ICS to ensure our workforce:
• Are compassionate and inclusive,
• Feel recognised and rewarded, and feel that they have a voice that counts,
• Feel safe and healthy,
• Are always learning,
• Are able to work flexibly. This will enhance the work already in place as we have a range of initiatives to support the retention of staff including:
• Comprehensive educational and career development pathways
• Preceptorship programme for newly qualified nursing staff
• A dedicated 24hr Employee Assistance Programme (available via free call or free app with live chat or email options)

• Access to rapid mental health support via our NHS resilience hubs, provided by our local Mental Health Trusts, and offering 1: 1 support and rapid access to IAPT as well as bespoke workshops and support for teams
• Mental Health First Aid training with our in-house MHFA instructors
• Ongoing refurbishment programme of staff rest areas
• Executive listening events, where our executive team have dedicated time set aside to listen to any concerns raised by staff
• Staff benefits, including salary sacrifice schemes, a lease care scheme and a cycle to work scheme
• Flexible working and flexible retirement options
• Reward and recognition programmes such as ViP (Values into Practice) awards, extra annual leave day given to all staff in recognition for work during the pandemic.
4. Induction training for agency and bank staff Agency staff are utilised to provide an additional flexible workforce outside of our own bank workers. The Trust recognises that it is much better for patient care if we can use agency staff who are familiar with our hospitals and our policies. We work hard with our agency providers to ensure that, wherever possible, we are provided with agency staff who have worked in our organisation previously. Wherever possible Frimley Health NHS Foundation Trust appoints agency staff through suppliers who are party to the Framework Agreement with the NHS Workforce Alliance. This agreement sets out that agencies providing temporary workers to NHS Trusts under this agreement will ensure:
• 'that the Temporary Worker is fully trained, compliant with any professional registration required for the role' (para 8.12 of the Framework agreement) and.
• 'that Temporary Workers are fully trained in accordance with the UK Core Skills Training Framework Agreement.' (para 8.13 of the Framework agreement)

The Trust has also recently relaunched the induction training for all staff including agency and bank staff. There is now an induction programme which is delivered to all new bank nurses and Health Care Assistants before they can book on to a vacant shift and there is also a local induction provided to any new staff member working on a ward provided by the nurse in charge of the ward. Through this induction we will ensure that all agency staff are aware of how to find all policies and key training updates on our Trust intranet. I hope that the information provided within this response is helpful to set the context of the actions being taken by Frimley Health Foundation Trust in the face of the national challenge around nurse recruitment and staffing of clinical areas.

Chief Executive