PFD report

Sarah Louise Sutherland · Prevention of Future Deaths report

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Issued 15 Mar 2024•Surrey

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
0

Raised in this report

Recipients
5

Named on the report

Responses found
3

Of 5 recipients

Stated actions
7

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

No concerns are currently included for this report.

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.7

  1. 1

    Collaborate with the Professional Standards Authority and NHS on suicide prevention strategies.

    Stated by UK Council for PsychotherapyStated in progressThe respondent said that this action was in progress when they made their response on 21 March 2024.
  2. 2

    Continue monitoring the trust and any new information under CQC’s internal processes and methodology.

    Stated by Care Quality CommissionStated completedThe respondent said that this action was complete when they made their response on 21 March 2024.
  3. 3

    Discuss all received Reports to Prevent Future Deaths through the Regulation 28 Working Group and share key learning across national and regional NHS services.

    Stated by NHS EnglandStated completedThe respondent said that this action was complete when they made their response on 21 March 2024.
  4. 4

    Report learning from private-sector Summary Care Record trials to the Expert Advisory Committee, including benefits and unintended consequences.

    Stated by NHS EnglandStated plannedThe respondent said that this action was planned when they made their response on 21 March 2024.
  5. 5

    Work with the Expert Advisory Committee to seek approval for full Summary Care Record rollout in the independent and private sector and consider its scope and constraints.

    Stated by NHS EnglandStated plannedThe respondent said that this action was planned when they made their response on 21 March 2024.
  6. 6

    Review the interface between NHS and non-NHS-funded independent health providers.

    Stated by NHS EnglandStated in progressThe respondent said that this action was in progress when they made their response on 21 March 2024.
  7. 7

    Continue trialling Summary Care Record access with private hospitals and privately funded healthcare services throughout 2024.

    Stated by NHS EnglandStated in progressThe respondent said that this action was in progress when they made their response on 21 March 2024.

Recipient positions A position is what a recipient says about a concern when they do not describe a specific action.7

  1. 1

    The existing complaints and conduct process is considered sufficient; no action is proposed without a formal complaint about the psychotherapist.

    Stated by UK Council for PsychotherapyExisting arrangements considered sufficientThe respondent said that existing arrangements were sufficient, so no further action was needed.
  2. 2

    Formal liaison between NHS and private mental-health providers is outside CQC’s regulatory powers.

    Stated by Care Quality CommissionOutside remitThe respondent said that this matter was outside its role or authority.
  3. 3

    NHS England is better placed to set requirements and expectations for coordination between NHS and private mental-health services.

    Stated by Care Quality CommissionRedirects responsibilityThe respondent said that another organisation was responsible for deciding or taking action.
  4. 4

    UKCP is better placed than CQC to regulate and manage private psychotherapists.

    Stated by Care Quality CommissionRedirects responsibilityThe respondent said that another organisation was responsible for deciding or taking action.
  5. 5

    CQC does not consider that regulatory action currently needs to be taken after reviewing the information under its regulatory process.

    Stated by Care Quality CommissionNo action considered necessaryThe respondent said that no further action was needed.
  6. 6

    CQC cannot regulate the private practice because there is no evidence that the psychotherapist provided a regulated activity requiring CQC registration.

    Stated by Care Quality CommissionOutside remitThe respondent said that this matter was outside its role or authority.
  7. 7

    CQC and the UK Council of Psychotherapy are better placed to address regulation and management guidelines for private psychotherapists.

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

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

Collaborate with the Professional Standards Authority and NHS on suicide prevention strategies.

Verbatim wording from the response

“We are working closely with the Professional Standards Authority and the NHS in discussing opportunities for collaboration in support of suicide prevention strategies.”

Source location

Response from UK Council for Psychotherapy
Page 2 · response
Published 21 March 2024

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 monitoring the trust and any new information under CQC’s internal processes and methodology.

Verbatim wording from the response

“We appreciate the Coroner raising these concerns with CQC, since receiving the Regulation 28 report we have reviewed the information relating to the death in line with our regulatory process and methodology. Whilst we don’t consider there is any regulatory action that currently needs to be taken we will continue to monitor the trust and any new information that we receive in line with our internal process and methodology”

Source location

Response from Care Quality Commission
Page 3 · response
Published 21 March 2024

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

Discuss all received Reports to Prevent Future Deaths through the Regulation 28 Working Group and share key learning across national and regional NHS services.

Verbatim wording from the response

“I would also like to provide further assurances on 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 that key learnings and insights around preventable deaths are shared across the NHS at both a national and regional level and helps us pay close attention to any emerging trends that may require further review and action.”

Source location

Response from NHS England
Page 2 · response
Published 21 March 2024

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

Report learning from private-sector Summary Care Record trials to the Expert Advisory Committee, including benefits and unintended consequences.

Verbatim wording from the response

“The SCR Team at NHS England have done significant work with a number of private sector organisations, including a range of private hospitals and privately funded healthcare services trialling the use of SCRs within settings where they have previously been unavailable. This work will continue throughout 2024. It is difficult to define precisely what is included within private hospitals and privately funded healthcare services. However, all private hospitals and independent healthcare services that have approached NHS England to date seeking access to SCR have either been onboarded into the existing proof of concepts or there have been discussions with the requestors regarding initial setup and their use for access to SCR. Learnings will be reported back to an Expert Advisory Committee to better understand any benefits realised but also any potential unintended consequences.”

Source location

Response from NHS England
Page 1 · response
Published 21 March 2024

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 the Expert Advisory Committee to seek approval for full Summary Care Record rollout in the independent and private sector and consider its scope and constraints.

Verbatim wording from the response

“The SCR Team will work with the Expert Advisory Committee to seek full rollout approval within the independent/private sector and consider the scope of this approval and any specific exclusions, constraints, or caveats. We already have full rollout approval for Mental Health Services within the NHS, which would include psychotherapists working within these services. However, we have not yet been approached by organisations representing private psychotherapists.”

Source location

Response from NHS England
Page 2 · response
Published 21 March 2024

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

Review the interface between NHS and non-NHS-funded independent health providers.

Verbatim wording from the response

“Work is also in progress to review the interface between the NHS and non-NHS funded independent health providers. This work is in its infancy, but NHS England can provide an update to the coroner in due course. We understand that the CQC are also undertaking work regarding standards for online care and exploring opportunities for better sharing of information both into private sector providers and receiving information back to the patient’s registered GP practice from private providers.”

Source location

Response from NHS England
Page 2 · response
Published 21 March 2024

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 trialling Summary Care Record access with private hospitals and privately funded healthcare services throughout 2024.

Verbatim wording from the response

“Your second concern raised the need for coordination of NHS mental health services and private psychotherapy. The Summary Care Record (SCR) was originally designed and communicated to support patients when they receive emergency care. Over time, the significant value of access to SCR to wider healthcare services has been recognised and, as a result, the SCR Team have worked with the Expert Advisory Committee to extend its use into multiple other care settings through a governance framework into which patients and professionals contribute.”

Source location

Response from NHS England
Page 1 · response
Published 21 March 2024

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 existing complaints and conduct process is considered sufficient; no action is proposed without a formal complaint about the psychotherapist.

Verbatim wording from the response

“We have a Complaints and Conduct Process (CCP) which provides a centralised and transparent process for considering complaints or concerns by members of the public and clients about therapists in relation to their clinical practice. We will investigate cases where there is evidence that calls into question a therapist’s suitability to be on our Register and indicate a breach of UKCP’s code of ethics and professional practice. UKCP regularly receives complaints about UKCP registrants from the NHS and third parties (non-clients) and these are processed under the CCP. We have not received a formal complaint about Sarah’s private psychotherapist. Complaints must normally be made within 3 years of the conduct complained of. The time frame for considering a complaint under the CCP varies depending on the nature of the complaint, the documentary evidence and number of witnesses.”

Source location

Response from UK Council for Psychotherapy
Page 1 · response
Published 21 March 2024

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

Formal liaison between NHS and private mental-health providers is outside CQC’s regulatory powers.

Verbatim wording from the response

“While CQC share the Coroner’s concerns in relation to the lack of a formalised mechanism for liaison and communication between NHS and private providers this is outside the scope of our regulatory powers. NHS England are better placed to act in setting requirements and expectations for improving this coordination of services.”

Source location

Response from Care Quality Commission
Page 3 · response
Published 21 March 2024

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 better placed to set requirements and expectations for coordination between NHS and private mental-health services.

Verbatim wording from the response

“While CQC share the Coroner’s concerns in relation to the lack of a formalised mechanism for liaison and communication between NHS and private providers this is outside the scope of our regulatory powers. NHS England are better placed to act in setting requirements and expectations for improving this coordination of services.”

Source location

Response from Care Quality Commission
Page 3 · response
Published 21 March 2024

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

UKCP is better placed than CQC to regulate and manage private psychotherapists.

Verbatim wording from the response

“We understand that ████████ is registered with UK Council of Psychotherapy. UKCP are better placed than CQC to act in the regulation and management of private psychotherapists.”

Source location

Response from Care Quality Commission
Page 3 · response
Published 21 March 2024

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

CQC does not consider that regulatory action currently needs to be taken after reviewing the information under its regulatory process.

Verbatim wording from the response

“We appreciate the Coroner raising these concerns with CQC, since receiving the Regulation 28 report we have reviewed the information relating to the death in line with our regulatory process and methodology. Whilst we don’t consider there is any regulatory action that currently needs to be taken we will continue to monitor the trust and any new information that we receive in line with our internal process and methodology”

Source location

Response from Care Quality Commission
Page 3 · response
Published 21 March 2024

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

CQC cannot regulate the private practice because there is no evidence that the psychotherapist provided a regulated activity requiring CQC registration.

Verbatim wording from the response

“Unfortunately, the CQC is unable to provide reassurance required regarding this concern or to comment upon it. The private practice where Sarah Louise Sutherland received psychotherapy is not registered with CQC and therefore not regulated by the CQC. The psychotherapist would not be required to register with CQC unless she was providing a regulated activity as defined in section 8 of the Health and Social”

Source location

Response from Care Quality Commission
Page 1 · response
Published 21 March 2024

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

CQC and the UK Council of Psychotherapy are better placed to address regulation and management guidelines for private psychotherapists.

Verbatim wording from the response

“This response focuses on the areas of concern raised in your Report that are relevant to NHS England national policy and programmes. We note that you have addressed your Report to other organisations, such as the Care Quality Commission (CQC) and the UK Council of Psychotherapy who will be better placed to answer to your first concern around the guidelines for regulation and management of private psychotherapists.”

Source location

Response from NHS England
Page 1 · response
Published 21 March 2024

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
3/5

Data last updated 7 September 2026