Oral Health Improvement and Dental Services in Scottish Prisons

5. Governance

Monitoring

5.1 The monitoring of prison dental services will be at a range of levels and each will have an identifiable lead officer:

Scottish Government	- Deputy Chief Dental Officer;
NHS Board	- Prison Health Lead;
Public Dental Service	- Clinical Dental Director;
	- Dental Team;
NHS National Services Scotland	- Practitioner Services Division;
	- Information Services Division;
Scottish Prison Service	- Prison Governor;
	- Prison staff.

5.2 Responsibility for dental services within each prison establishment is by the Health Board. However the Deputy Chief Dental Officer will maintain a strategic overview regarding the development and delivery of dental services to prisoners to ensure a consistent national approach.

5.3 NHS Board health centre manager will ensure that the usage of the dental facilities is maximised by helping the dental team manage the dental clinical activity by ensuring available appointments are filled whilst the dental team are not on the premises. The manager will also monitor and respond to all clinically related complaints where appropriate.

5.4 The Public Dental Service clinical dental director will ensure that the dental surgery and associated decontamination processes are compliant with all extant guidance including practice inspections, decontamination and quality improvement. The director will ensure that the dental team has training to enable them to work effectively within a custodial environment.

5.5 The dental team working in each prison shall engage with all relevant local and national clinical governance, quality improvement and training initiatives.

Information Sharing

5.6 An Information Sharing Protocol (ISP) has been developed by NHSScotland and the Scottish Prison Service; this is intended to identify the commitments required by each organisation to enable sharing of personal information. Sign up and ownership is at the highest level. It is a statement of the principles and assurances which govern the activity of information sharing. It ensures that the rights of all those who are involved in the process are protected.

5.7 Agreement has been reached to allow healthcare staff to have read/write access to the SPS Prisoner Record (PR2).

5.8 The prison identifiable information in the prison clinical system (establishment, hall, and cell) should not transfer to clinical systems outwith the prison. Healthcare staff are asked to ensure prison identifiable information contained within the electronic dental record is kept to an absolute minimum.

5.9 Appointment letters should be addressed where possible to the Health Centre and PO Box address for the appropriate prison establishment as opposed to an individual prisoner. By sending appointment letters direct to prisoners, security risks arise in the prison and will ultimately result, after further delay, in the appointment being changed by healthcare staff.

5.10 A patient's medical condition can have an impact on the dental care provided. Previously dentists had access to a prisoner's paper medical record, this should continue with an appropriate level of access within the new medical IT system.

Email

5.11 NHS staff should be set up with *.nhs.net email addresses as outlined in the Information Sharing Protocol (ISP) so that emails containing personal or sensitive information can securely be sent between SPS using *.pnn.gov.uk and NHS using *.nhs.net email addresses. Any emails of a sensitive nature should be appropriately marked e.g. restricted or NHS confidential.

Dental Registration

5.12 An R4 prison dental record form must be completed for every prisoner coming into prison. The record should be marked to make clear whether the prisoner is eligible for occasional or full registration status.

5.13 Prisoners who are on remand or have sentences of one year or less, or due to be released within six months, should be marked as occasional on the R4 record. All other prisoners who should be marked as fully registered on the R4 record.

5.14 Further guidance will be required regarding the prisoners existing registration status within the community upon admission.

Consent

5.15 There is no requirement to gain consent from the prisoner to provide healthcare and medication. The legislative changes allow for the Health Boards to provide prisoner healthcare instead of SPS from 1st November 2011. The R4 prison dental record form acts as a practice registration and consent to data sharing not consent to treatment.

5.16 Legislative changes, implied consent, privacy notices and the ISP are the combined basis for all healthcare provision, system access and data sharing between organisations.

5.17 PDS dentists can access a prisoner's Emergency Care Summary. Wherever possible access should only be made once and the prisoner's dental record updated accordingly. This is to avoid unnecessary repeat access to ECS for the same patient.

Community Health Index (CHI)

5.18 A PO Box address has been created for each prison and should be recorded in the R4 clinical system. The address field on CHI will be updated to include the PO Box for the prison (thus not identifying people as being in prison). This will remain on CHI until a prisoner registers with their community general medical practitioner post-liberation.

Dental Health Records

5.19 Historically, prison dental records have not been connected to national data collection systems in Scotland. Dental records were maintained by the contractor dentist and were the property of the dentist. As dental services are now managed by the local NHS board the sharing and transfer of dental notes can be progressed.

5.20 The movement of prisoners within the prison system is significant and can be challenging in terms of timely access to dental records to support delivery of care.

5.21 A high level review of the options available to allow key dental clinical information to be shared between sites across the Scottish Prison Service estate is currently being undertaken. This will ensure seamless transfer of care between establishments and result in more meaningful throughcare.

5.22 With a prisoner's agreement, Boards should seek to ensure that this continuity of care is maintained on release by communication with the prisoner's registered dentist, where available.

Clinical Activity Reporting

5.23 Dentists working in prisons should have a unique identifier and use a dedicated clinical management system to record activity. Practitioner Services Division (PSD) has a key role in information management for dentistry. Activity in prisons should be submitted electronically to PSD using the standard NHS systems and appropriate activity reporting tools for prisons dental services should be developed by Information Services Division (ISD).