PFD report

Jack Peter Zarrop · Prevention of Future Deaths report

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Issued 2 Oct 2023•West London

Report record

Published report and response evidence

This page connects the concerns raised in this report with statements found in recipients’ published responses. A link shows a clear evidence connection; it does not assign responsibility.

View original report
Concerns
3

Raised in this report

Recipients
3

Named on the report

Responses found
3

Of 3 recipients

Stated actions
8

Described in responses

Source document

Full report text

This is the full text from the original published report.

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Concerns and recipient responses

Select any concern, action or position to view the source wording.

Report evidence summary

Concerns raised3

  1. Lack of adequate mental health training for Custodial Nurse Practitioners seeing high-risk and complex patients in police custody
    Part of recurring concern: Failure to ensure police custody staff are competent for safe custody-suite workPart of recurring concern: Inadequate staff training for managing complex care needs
  2. Failure to train agency healthcare staff in the ACCT process and the threshold for opening an ACCT
    Part of recurring concern: Inadequate competence assurance and induction for agency staffPart of recurring concern: Unsafe reliance on agency staff for clinical staffing
  3. Failure of the 2003 Home Office circular to recognise suicide and self-harm risk as a core competency
Responses linked to these concerns

Each statement is shown once, even when linked to more than one concern.

Actions described in response An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.5

  1. Action

    Take the report’s findings to the NHS England Health and Justice Delivery Oversight Group for oversight of the proposed training-access action.

    Stated by NHS EnglandStated plannedThe respondent said that this action was planned when they made their response on 6 October 2023.
  2. Action

    Require regional teams to provide assurance at the planned Health and Justice Delivery Oversight Group meeting that agency and bank staff have timely access to ACCT training.

    Stated by NHS EnglandStated plannedThe respondent said that this action was planned when they made their response on 6 October 2023.
  3. Action

    Write to Health and Justice regional teams sharing concerns and requesting action to ensure agency and bank staff access necessary joint training, including ACCT training.

    Stated by NHS EnglandStated completedThe respondent said that this action was complete when they made their response on 6 October 2023.

Respondent positions A position is what a recipient says about a concern when it does not describe a specific action.7

  1. Position

    HMPPS is responsible for overseeing effective ACCT training delivery at prison establishments, including ACCT case manager and assessor training.

    Stated by NHS EnglandRedirects responsibilityThe respondent said that another organisation was responsible for deciding or taking action.

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Lack of adequate mental health training for Custodial Nurse Practitioners seeing high-risk and complex patients in police custody

Wider context from the report

“1.    The use of Custodial Nurse Practitioners (CNPs) in Police custody instead of doctors. The 2003 Home Office circular appeared to envisage nurses working alongside doctors, when this is not how they are deployed. CNPs are also seeing high risk and complex patients without adequate training in mental health. The deployment in Police custody of CNPs places detained persons at risk of death in the future. The 2003 Home Office circular also does not recognise the risk of suicide and self-harm as being a core competency. ”

Is this part of a recurring concern?

Yes — Failure to ensure police custody staff are competent for safe custody-suite work; Inadequate staff training for managing complex care needs.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure to train agency healthcare staff in the ACCT process and the threshold for opening an ACCT

Wider context from the report

“2.    The training of agency staff in the ACCT process and recognising the appropriate threshold to open an ACCT. The training of agency staff in ACCT does not appear to be part of the commissioning process by NHS England and individual providers do not appear to provide training to agency staff in the ACCT process. This places residents in prison at risk of death, given the high level of usage of agency healthcare staff in prison. ”

Is this part of a recurring concern?

Yes — Inadequate competence assurance and induction for agency staff; Unsafe reliance on agency staff for clinical staffing.

Open source report

Source evidence

How this individual concern was interpreted

PFD Monitor created a concise, searchable interpretation from the report wording shown below. Response links show a clear evidence connection; they do not assign responsibility.

PFD Monitor interpretation

Failure of the 2003 Home Office circular to recognise suicide and self-harm risk as a core competency

Wider context from the report

“1.    The use of Custodial Nurse Practitioners (CNPs) in Police custody instead of doctors. The 2003 Home Office circular appeared to envisage nurses working alongside doctors, when this is not how they are deployed. CNPs are also seeing high risk and complex patients without adequate training in mental health. The deployment in Police custody of CNPs places detained persons at risk of death in the future. The 2003 Home Office circular also does not recognise the risk of suicide and self-harm as being a core competency. ”

Is this part of a recurring concern?

No recurring-concern membership is currently published.

Open source report

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Take the report’s findings to the NHS England Health and Justice Delivery Oversight Group for oversight of the proposed training-access action.

Verbatim wording from the response

“In addition, the findings in your report will be taken to the NHS England Health and Justice Delivery Oversight Group (HJDOG) in December 2023. The HJDOG is the senior leadership forum, which holds responsibility for the oversight of delivery and continuous improvement in Health and Justice commissioned services, through both the national and regional teams, with a focus on improving health outcomes and reducing variation across England. Regional teams will be asked to give assurance at the HJDOG meeting planned for June 2024, that the proposed action has been delivered and agency and bank staff have timely access to ACCT training.”

Source location

Response from NHSE
Page 2 · response
Published 6 October 2023

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Require regional teams to provide assurance at the planned Health and Justice Delivery Oversight Group meeting that agency and bank staff have timely access to ACCT training.

Verbatim wording from the response

“In addition, the findings in your report will be taken to the NHS England Health and Justice Delivery Oversight Group (HJDOG) in December 2023. The HJDOG is the senior leadership forum, which holds responsibility for the oversight of delivery and continuous improvement in Health and Justice commissioned services, through both the national and regional teams, with a focus on improving health outcomes and reducing variation across England. Regional teams will be asked to give assurance at the HJDOG meeting planned for June 2024, that the proposed action has been delivered and agency and bank staff have timely access to ACCT training.”

Source location

Response from NHSE
Page 2 · response
Published 6 October 2023

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Write to Health and Justice regional teams sharing concerns and requesting action to ensure agency and bank staff access necessary joint training, including ACCT training.

Verbatim wording from the response

“In response to the concerns noted, NHS England's National Director of Health & Justice, Armed Forces and Sexual Assault Services Commissioning, has written to Health & Justice regional teams sharing these concerns, asking commissioners to work with prison healthcare provider organisations and HMPPS locally, to ensure all staff, including agency and bank staff, have timely access to all joint training, including ACCT, that is necessary for them to undertake their role effectively within the prison environment. .”

Source location

Response from NHSE
Page 2 · response
Published 6 October 2023

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Provide the latest draft National Healthcare Specification, including requirements for governance, qualifications, competency assessment and clinical supervision.

Verbatim wording from the response

“Chief Officers are able to use the National Healthcare Specification to determine the type of medical care they require. The Specification can be tailored by forces should they not require all elements, and they can tender for the services they need; but the document is clear with regard training and qualifications. I attach the latest version of the service specification (draft until ratified by NHSE Clinical Reference Group – Nov 2023), which may be useful, and would like to highlight the following sections which I hope will provide you with reassurance:”

Source location

Response from National Police Chief's Council
Page 2 · response
Published 6 October 2023

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Work with NHS England and other stakeholders to deliver a fit-for-purpose police custody healthcare service specification.

Verbatim wording from the response

“I have reviewed the 2003 circular and would like to highlight that custodial healthcare has changed considerably since that point. The 2003 circular refers to the practice of using Police Surgeons in custody, this role is no longer in existence. Police Custody is a very regulated and scrutinised area of policing, it plays a pivotal role in the criminal justice process and cares for some of the most challenging and vulnerable people in society at what is often a very testing time. Our aim is to be effective, safe and to ensure that people are treated fairly, with as much dignity as possible. Having professional officers and staff who are well trained is essential. The NPCC Custody Portfolio works closely with NHS England, partners, and other stakeholders to deliver a service specification that is fit for purpose.”

Source location

Response from National Police Chief's Council
Page 1 · response
Published 6 October 2023

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

HMPPS is responsible for overseeing effective ACCT training delivery at prison establishments, including ACCT case manager and assessor training.

Verbatim wording from the response

“ACCT is the care planning process for prisoners identified as being at risk of suicide or self-harm, and training is provided by His Majesty’s Prisons and Probation Service (HMPPS). The ACCT process requires that certain actions are taken to ensure the risk of suicide and self-harm is reduced. The ACCT process is multi-disciplinary, involving”

Source location

Response from NHSE
Page 1 · response
Published 6 October 2023

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Responsibility for custodial nurse practitioners in police custody settings lies with the Police Chiefs’ Council, not NHS England.

Verbatim wording from the response

“Regarding the matter of concern around the use of Custodial Nurse Practitioners, this is for the Police Chief Council to respond to. NHS England does not hold responsibility for commissioning healthcare in police custody settings, therefore cannot comment.”

Source location

Response from NHSE
Page 2 · response
Published 6 October 2023

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

The Home Office cannot amend the archived and no longer extant 2003 circular, so it formally proposes no action.

Verbatim wording from the response

“I believe that the element of the matters of concern identified which was directed to the Home Office was the exclusion from the list of core competencies for Custodial Nurse Practitioners within Home Office Circular 020/2003 (Healthcare Professionals in Custody Suites: Guidance to Supplement Revisions to the Codes of Practice Under the Police and Criminal Evidence Act 1984) of the ability to identify the risk of suicide and self-harm in detainees. Home Office Circular 020/2003 is no longer extant: it was archived in 2013 and does not appear on the Gov.UK website. It is therefore not possible for the Home Office to make amendments to it, which is why, formally, we propose to take no action in response to your report.”

Source location

Response from the Home Office
Page 1 · response
Published 6 October 2023

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

NHS England is responding to concerns about prison healthcare staff training in the ACCT process.

Verbatim wording from the response

“I understand too that NHS England is responding to your second matter of concern, relating to the training of prison healthcare staff in the ACCT process.”

Source location

Response from the Home Office
Page 2 · response
Published 6 October 2023

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

The NPCC response addresses the remaining content of the first matter of concern.

Verbatim wording from the response

“However, this in no way represents a lack of interest in the issues which you have identified. As the response to your report from the Chair of the NPCC sets out, the 2003 Circular has effectively been superseded by the publication of the National Healthcare Specification for police custody, which is written by NHS England on behalf of the NPCC, College of Policing and Home Office, and which Chief Constables may use when tendering for healthcare provision. That document is far more comprehensive than the 2003 Circular. The Home Office has a close interest in the content of the Specification, and in ensuring that highly qualified and capable medical personnel work in police custody. I understand that the NPCC response also represents the response to the remaining content of your first matter of concern.”

Source location

Response from the Home Office
Page 2 · response
Published 6 October 2023

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

The national healthcare specification adequately addresses custody healthcare qualifications, competency, supervision and training for doctors, nurses and paramedics.

Verbatim wording from the response

“Chief Officers are able to use the National Healthcare Specification to determine the type of medical care they require. The Specification can be tailored by forces should they not require all elements, and they can tender for the services they need; but the document is clear with regard training and qualifications. I attach the latest version of the service specification (draft until ratified by NHSE Clinical Reference Group – Nov 2023), which may be useful, and would like to highlight the following sections which I hope will provide you with reassurance:”

Source location

Response from National Police Chief's Council
Page 2 · response
Published 6 October 2023

Open published response

Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

The 2003 circular is outdated because the police surgeon role no longer exists and custodial healthcare has substantially changed.

Verbatim wording from the response

“I have reviewed the 2003 circular and would like to highlight that custodial healthcare has changed considerably since that point. The 2003 circular refers to the practice of using Police Surgeons in custody, this role is no longer in existence. Police Custody is a very regulated and scrutinised area of policing, it plays a pivotal role in the criminal justice process and cares for some of the most challenging and vulnerable people in society at what is often a very testing time. Our aim is to be effective, safe and to ensure that people are treated fairly, with as much dignity as possible. Having professional officers and staff who are well trained is essential. The NPCC Custody Portfolio works closely with NHS England, partners, and other stakeholders to deliver a service specification that is fit for purpose.”

Source location

Response from National Police Chief's Council
Page 1 · response
Published 6 October 2023

Open published response

Other statements in published responses

These actions and other statements could not be clearly connected to one concern in this report.

Recipient-stated actions An action is something a recipient says it has done, is doing, or plans to do in response to a concern raised.3

  1. 1

    Discuss Reports to Prevent Future Deaths through the Regulation 28 Working Group and share their key learning and insights across national and regional NHS teams.

    Stated by NHS EnglandStated completedThe respondent said that this action was complete when they made their response on 6 October 2023.
  2. 2

    Continue collaborating with partners to improve policing’s response to vulnerable people, including those with mental ill health.

    Stated by Home OfficeStated in progressThe respondent said that this action was in progress when they made their response on 6 October 2023.
  3. 3

    Support Liaison and Diversion schemes in police custody suites, fully rolled out across England.

    Stated by Home OfficeStated completedThe respondent said that this action was complete when they made their response on 6 October 2023.

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Discuss Reports to Prevent Future Deaths through the Regulation 28 Working Group and share their key learning and insights across national and regional NHS teams.

Verbatim wording from the response

“I would also like to provide further assurances on the national NHS England work taking place around the Reports to Prevent Future Deaths. All reports received are discussed by the Regulation 28 Working Group, comprising Regional Medical Directors and other clinical and quality colleagues from across the regions. This ensures key learnings and insights around events raised in Reports to Prevent Future Deaths are shared across the NHS at both a national and regional level and helps us to pay close attention to any emerging trends that may require further review and action.”

Source location

Response from NHSE
Page 2 · response
Published 6 October 2023

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Continue collaborating with partners to improve policing’s response to vulnerable people, including those with mental ill health.

Verbatim wording from the response

“I can assure you that the Home Office continues to work collaboratively with our partners to further improve policing’s response to people who are vulnerable, including those with mental ill health. This includes support for Liaison and Diversion schemes in police custody suites, which had been fully rolled out across England by March 2020. The Home Office is also committed to ensuring that custody is a safe and dignified environment for all detainees, visitors and staff which operates professionally, respectfully, and lawfully.”

Source location

Response from the Home Office
Page 2 · response
Published 6 October 2023

Open published response

Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation

Support Liaison and Diversion schemes in police custody suites, fully rolled out across England.

Verbatim wording from the response

“I can assure you that the Home Office continues to work collaboratively with our partners to further improve policing’s response to people who are vulnerable, including those with mental ill health. This includes support for Liaison and Diversion schemes in police custody suites, which had been fully rolled out across England by March 2020. The Home Office is also committed to ensuring that custody is a safe and dignified environment for all detainees, visitors and staff which operates professionally, respectfully, and lawfully.”

Source location

Response from the Home Office
Page 2 · response
Published 6 October 2023

Open published response
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Information checked against the published report and official responses · Data reviewed 7 Sep 2026 · About data quality and limitations

Official responses located
3/3

Data last updated 7 September 2026