HID COIN quality assurance procedure

SPC/Admin/74

OG status:

Fully open

Author unit / section:

HID HQ

Target audience:

All HID COIN users

Version:

6

Introduction

1. This instruction describes HID's arrangements for data quality (DQ) checks on COIN records. Operational band 1s, operational band 2 managers and other staff with specific COIN data responsibilities should read and be familiar with the arrangements.

2. The objectives of the DQ checks are to improve the quality of data held on COIN, and to provide assurance to the HID Director and HID Management Board (HMB) that COIN data is completed in line with HID's core principles that we – 'Go to the right places, Do the right things, Finish what we start and Leave a clear record'

3. The aim is to instill a culture of 'getting the important things right first time', enabling HID to reduce the frequency and volume of DQ checks undertaken.

Roles and responsibilities

4. Unit Heads have overall responsibility for ensuring that operational and administrative DQ checks are carried out on all COIN records, and that appropriate action is taken to address any issues that are raised.

5. Operational Managers (normally B2s) - should carry out operational checks on data related to regulatory activity. The nature, extent and frequency of the checks will need to be varied, dependent upon the level of performance of their team and compliance with the monthly checks.

6. Data Quality Coordinators (DQCs) in each unit/division should carry out administrative checks, produce and distribute standard COIN reports for colleagues and managers. The DQC has overall responsibility for collating this information for periodic submission to HID HQ.

7. The Directorate Data Quality Coordinator (DDQC) is the person designated in HID HQ to liaise between BSD DIS and local DQCs, and forward data reports received from BSD to DQCs for action.

8.  HID HQ will send out a calling note to Operational Managers and DQCs specifying the relevant period, the information required and the deadline for returns. HID HQ will be responsible for collating Administrative and Operational returns for submission to HMB.  

Operational checks

9.  Operational checks should be recorded on a copy of the form at Annex 1 and filed in TRIM. The form should be copied to Unit Heads and the DDQC by the requested deadline..

10.  Operational managers should carry out 100% monthly checks on all of the following:

(a)  Notices and Schedules

• appropriate use of legislation supported by EMM
• appropriate use of a single or several notices
• wording of schedule is clear and accurate with no continuing requirements
• will it be possible to check compliance with the actions sought.   
• appropriate timescale(s) for compliance
• notices added to COIN within 10 days of service

(b)  Notices past their 'comply–by date'

Notices passed their Comply-by date without a result – COIN Report 5 (outstanding task list report)

(c) Outstanding issues

• Status of Issues (Report 17 - issues raised against both cases and service orders where the Required Date for Closure has passed)

11. Operational managers should carry out sample monthly checks on the following:

(a)  COIN Notes on Closed cases  

• These checks on a sample of COIN Notes should concentrate on:
  • clarity – do they make sense, include date and purpose of visit, who was seen 
  • are relevant attachments (eg EMM1 or Notice) named appropriately
  • that the case is linked as required
  • explanation if no notice was issued or
  • cases resulting in notices are properly closed-out.
    
    COIN Reports 26 and 29 are useful sources (26 – Notes and case search report and 29 – Topic Based Inspection Report)

(b)  Reports linked to COIN

• These checks on a sample of completed investigation and visit reports (and associated letters) should ensure they meet the required standards, and ensure that Investigation Reports are attached to COIN, or a TRIM reference is provided in the COIN Notes field, when appropriate.

(c)  Outstanding complaints

• Monthly checks should be carried out on all outstanding complaints over 6 months, using COIN report 3 (Case Management Report) and the operational line manager should take the appropriate action.

12. (a) Investigation Tracking

• Operational Line Managers should check and ensure that Investigation Tracking is up to date, for example that  the case status is changed to "open-investigation"; that reviews are timely: and entries contain information that sufficiently describes progress with an investigation and the outcome of the review, or provide links to other TRIM documents, if the information is restricted.
• Unit Heads should sample investigation tracking to a sufficient level to assure themselves of compliance with the guidance. They should also undertake a 10 month review on all open cases and record the outcome on the Investigation Tracking page.

HID HQ will provide a monthly report to Unit Heads and DQCs indicating whether the 3 week or 2 month reviews are recorded, to help identify each division's cases. The Quick Reference Guide on Investigation Tracking  is useful when carrying out these checks.

(b)  Invoice comments  

Invoice comments should help dutyholders to understand what work has been done and the costs incurred. Transparency helps HSE to explain publicly the costs of the various regimes, and to defend challenges to invoices brought by individual dutyholders.

• Comments should be as specific as possible about the work done on-site or back in the office such that an accountant or senior manager reading the invoice in isolation understands the nature of the work done. The following is a list of possible areas that it might be useful to comment on, depending upon the type of intervention or dutyholder.
  • describe what was actually looked at as part of an inspection or investigation, quoting the relevant Regulations, where appropriate
  • describe the topics discussed with a dutyholder or their representatives, either on site or by other forms of contact
  • state the purpose of discussions with specialists or other HSE colleagues (and usually name them), or external agencies
  • refer to investigation reports being prepared for enforcement decisions, rather than just say "preparing reports"
  • ensure work done to support written report is clear e.g reviewing statements in preparation for writing up an investigation report or inspection visit to be sent to the dutyholder
  • give details of time spent reviewing correspondence or responses from dutyholders
  • refer to updating HSE management information systems and records – but don't simply refer to COIN
  • give details of any follow-up actions or visits.
  • name the dutyholder's representatives met on site or contacted by other means, but there is no need to name everyone.

13. Specific guidance has been prepared for FFI, which covers many of the above areas. The guidance specifically covers the preparation of Notice of Contravention (NoC) letters and attaching the letters to COIN. Operational managers should follow this guidance. For other regimes they should sample check comments to a sufficient level to assure themselves that it's in line with the guidance.

Administrative checks

14.  The DQC should carry out data checks, produce and distribute standard reports for colleagues and managers. They should collate this information for periodic submission to HID HQ, using the form provided at Annex 2 which should be filed in TRIM, copied to the DDQC and their Unit Head.

15.  The DQC should carry out 100% monthly checks covering the following: 

(a)  Notices created

• All notice cases created within the period stated on the HID HQ calling note should be checked using COIN report 19. The record should have been created in line with COIN guidance and checks made to ensure there are the necessary links to the relevant cases or a service order.  Notices should be added to COIN within 10 days of service.

(b)  Fatal incidents

• All fatal incident cases created and closed within the period stated on the calling note should be checked against COIN guidance. For investigations involving several dutyholders, DQCs should check that the cases have been correctly linked to each other, including the allocation of the 'master' case and inclusion of this text in the summary.

(c) Prosecutions

• All prosecutions created and closed in the period stated on the HID HQ calling note should be checked against COIN guidance, and should include the correct links to relevant records, including the source of the prosecution eg RIDDOR, inspection.

Recording and reporting arrangements

16.  DQCs and Operational Managers should record the outcome of their checks against the above criteria in the format of Annex 1 for all operational checks, and Annex 2 for administrative checks. All proformas should be filed in TRIM, copied to the DDQC and their Unit Head.

17.  Results from all the DQ checks will be used by HID HQ to populate the HMB performance dashboard and provide other information to support the Business Assurance function.

Any queries about the procedures should be addressed to HIDHQ Building 5N.2, Redgrave Court, Bootle.