Prevention of Future Deaths reports · 2021

Khairul Rahman

Regulation 28 report to prevent future deaths, reference 2021-0226, written 2 Jul 2021. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report2 Jul 2021
Reference2021-0226
DeceasedKhairul Rahman
CoronerR Brittain
Coroner areaInner North London
CategoryState Custody related deaths
Sourcejudiciary.uk record · original PDF
Responses published1

The report

Text extracted from the PDF text layer. Reproduced verbatim, including the scan's own layout.

REGULATION 28:  REPORT TO PREVENT FUTURE DEATHS 

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS 

THIS REPORT IS BEING SENT TO: 

 (Head of Healthcare) and Dr 

 (Regional Medical 

Lead) Practice Plus Group  HMP Pentonville  
(via  

) 

1 

CORONER 

I am R Brittain, Assistant Coroner for Inner London North. 

2 

CORONER’S LEGAL POWERS 

I make this report under paragraph 7, Schedule 5, of the Coroners and Justice Act 2009 
and regulations 28 and 29 of the Coroners (Investigations) Regulations 2013. 

3 

INVESTIGATIONS and INQUESTS 

Mr Khairul Rahman, an inmate at HMP Pentonville, died on 22 January 2021 at University 
College  Hospital  from  COVID-19.  I  concluded,  at  an  inquest  into  his  death  on  21  May 
2021, that he died from natural causes. In box 3, I set out as follows: 

Mr  Rahman  died  from  COVID-19  after  treatment  in  hospital.  There  were  intervals  to 
reviewing  his  clinical  condition,  whilst  he  was  detained  in  prison.  However,  it  is  not 
possible to state that this caused or contributed to his death. 

4 

CIRCUMSTANCES OF THE DEATH 

In January of 2021 there was an outbreak of COVID-19 in the prison. Mr Rahman had 
been previously coded as a ‘moderate risk’ in May 2020, owing to his asthma diagnosis.  

I heard evidence that he became unwell on the 4th of January 2021. However, he did not 
report this to prison staff, who first recognised that he was unwell at 10am on the 7th of 
January.  Attendance  of  nursing  staff  was  requested  at  approximately  10.30am.  It  is 
unclear  when  the  nurse  subsequently  attended  to  Mr  Rahman,  owing  to  non-
contemporaneous recording of the consultation, documented at approximately 5pm. The 
entry states: 

Pulse rate 129 bpm 
O/E – tympanic temperature 38.8 C 
Pulse oximetry 97% 
148  94 mmHg 

Examination: Had a covid19 swab taken 

I  heard  evidence  that  once-daily  observations  were  planned  to  be  undertaken.  In  oral 
,  Regional  Medical  Lead  of  Practice  Plus  Group  in 
evidence,  Dr 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 London, stated that a NEWS2 early warning score system was used by prison healthcare 
staff, in order to establish what next steps should be taken, based on clinical observations 
(along  with  clinical  judgement).  It  was  established  that  the  above  observations  would 
score  ‘3’  on  the  NEWS2  system  which,  according  to  score  calculators  would  prompt 
consideration of repeat observations to be taken every 4-6 hours.  

When asked to account for the disparity between the planned daily observations and the 
NEWS3 prompted 4-6 hourly observations, Dr 

 stated in oral evidence: 

I think that the honest answer is that, at the time, that we were struggling across all prisons 
to be able to monitor people…on a regular basis, i.e. specifically between 4-6 hours but 
we  were  relying  on  the  prisoners  working  with  us  to  self-report  any  changes  in  their 
symptoms. I can’t explain why we didn’t do a further observation before that point actually.  

In a statement provided after the conclusion of the inquest, provided in order to address 
concerns I had raised regarding this point, Dr 

 set out: 

When  Mr  Rahmun  was  initially  seen  on  7/1/21  he  had  observations  taken  which  were 
abnormal  and  were  somewhat  suggestive  of  Covid-19,  and  a  swab  was  taken.  The 
positive result was entered into Mr Rahmun’s records on 11/1/21. It is expected that when 
the result was known to be positive the protocol would be activated, which means covid 
age would be worked out which would then guide us on our future observations. It is these 
subsequent  observations  which  would  include  the  NEWS2  and  not    necessarily  the 
original observations taken on 7/1/21… Covid age is what Practice Plus Group were using 
to  guide  us  on  the  frequency  of  observations  and  had  to  be  calculated  after  a  positive 
result… Mr Rahmun was due to undergo once daily observations, which was appropriate 
given the known risk at that time… 

Despite NEWS2 being a hospital based scoring system and it not being ideal for the prison 
estate  it  was  the  best  we  had  at  the  time…  Throughout  the  pandemic  healthcare  staff 
have been reminded regularly at daily handover meetings to use NEWS2 when carrying 
out observations and this is a message that has continued.  

No further treatment or care was provided to Mr Rahman prior to concerns being raised 
to  prison  staff  at  approximately  1pm  on  8  January,  regarding  a  deterioration  in  his 
condition. Emergency services were called, with the details of the request given as ‘sats 
46’. The ambulance service attended and, despite 15 litres per minute of oxygen being 
administered, were not able to get Mr Rahman’s oxygen saturations above 78%. He was 
transported  to  University  College  London  Hospital  where,  despite  intensive  care 
treatment, he died on 22 January from the consequences of COVID-19.  

5 

CORONER’S CONCERNS 

During the course of the inquest the evidence revealed matters giving rise to concern. In 
my opinion there is a risk that future deaths will occur unless action is taken. In the 
circumstances it is my statutory duty to report to you. 

The MATTERS OF CONCERN are as follows: 

1.  There does not seem to be a robust system in place in the prison healthcare 
setting for contemporaneous or accurate retrospective documentation of the 
timing of clinical interactions. I heard evidence and received a further statement, 
following the conclusion of the inquest, which set out the difficulties that the 
prison environment causes, in terms of being able to document accurately. 
However, I remain concerned that the lack of accurate documentation means 
that subsequent review of the appropriateness of clinical care, in particular, 
response times is hampered; 

2 

 
 
 
 
 
 
 
 
 
 
 
 2.  The interval to further observations being undertaken were not inline with the 

NEWS2 scoring system and, in oral evidence, it was set out that prisoners were 
expected to self-report deterioration. This differs from latter information, 
provided after the conclusion of the inquest. However, it remains a concern.  

The use of the NEWS2 scoring system remains unclear; the post-inquest 
information seemingly sets out both that this system was only to used after a 
positive COVID-19 result but also at daily handover.   

Whilst recognising that the prison environment differs from a hospital setting, I 
remain concerned that the care provided was not as guided by the NEWS2 
scoring system and that no alternative system appears to be in place that can 
be used effectively in the prison healthcare setting.  

 6  ACTION COULD BE TAKEN 

In  my  opinion  action  could  be  taken  to  prevent  future  deaths  and  I  believe  that  the 
addressees have the power to take such action.  

7 

YOUR RESPONSE 

You are under a duty to respond to this report within 56 days of the date of this report, 
namely by 27 August 2021. I, the coroner, may extend the period. 

Your response must contain details of action taken or proposed to be taken, setting out 
the timetable for action. Otherwise you must explain why no action is proposed. 

8 

COPIES and PUBLICATION 

I have sent a copy of my report to the Chief Coroner, Mr Rahman’s family, the Prison and 
Probation Ombudsman, HMP Pentonville and the CQC.  

I am also under a duty to send the Chief Coroner a copy of your response.  

The Chief Coroner may publish either or both in a complete or redacted or summary form. 
He may send a copy of this report to any person who he believes may find it useful or of 
interest. You may make representations to me, the coroner, at the time of your response, 
about the release or the publication of your response by the Chief Coroner. 

9 

Dated: 2 July 2021 

Assistant Coroner R Brittain 

3

Responses

1 response published against this report on judiciary.uk. A response is a body's written reply to the coroner's concerns; publication is at the discretion of the Chief Coroner's office, so an absent response does not mean nobody replied.

Response from Practice Plus Group (PDF)
Practice Plus Group 
Hawker House 
5-6 Napier Court
Napier Road
Reading
Berkshire
RG1 8BW

practiceplusgroup.com 

Dr Richard Ian Brittain 
HM Assistant Coroner for London Inner North 

27th August 2021 

Dear Sir 

Re: Regulation 28: Prevention of Future Deaths report, Mr Khairul Mahmun RAHMAN 

I write in response to your Regulation 28 Prevention of Future Deaths Report issued to Practice 

Plus Group on 2nd July 2021 following the inquest touching upon the death of Mr Khairul Rahman 

at HMP Pentonville. Practice Plus Group would like to express its sincere condolences to Mr 

Rahmun’s family and friends. 

Practice Plus Group notes that this report was received this report 6 weeks after the inquest 

concluded on 21st May 2021. The Chief Coroner’s Guidance No. 5 ‘Reports to Prevent Future 

Deaths’ sets out a timeline for the making of reports. It is disappointing to have received the 

report sometime after the 10 working days specified in the guidance had passed, given the effort 

taken to provide a written response to the concerns raised at the inquest.  

This response addresses the matters of concern in so far as they relate to Practice Plus Group, 

the lead provider of healthcare services at HMP Pentonville since 1st May 2014. 

Matter of Concern 1: There does not seem to be a robust system in place in the prison 

healthcare setting for contemporaneous or accurate retrospective documentation of the 

timing  of  clinical  interactions.  I  heard  evidence  and  received  a  further  statement, 

following  the  conclusion  of  the  inquest,  which  set  out  the  difficulties  that  the  prison 

environment causes, in terms of being able to document accurately. However, I remain 

concerned that the lack of accurate documentation means that subsequent review of the 

appropriateness of clinical care, in particular, response times is hampered.  

Practice Plus Group Health and Rehabilitation Services Ltd. Registered in England No 10498997 
Registered Office: Hawker House, 5-6 Napier Court, Napier Road, Reading, Berkshire RG1 8BW 

 
  
 
 Response:  

Unfortunately, as a result of the prison environment the contemporaneous recording of clinical 

interactions on the electronic patient record (SystmOne) is often not possible. The limitations of 

the prison estate, notably the lack of Wi-Fi within HMP Pentonville makes the use of portable 

devices linking directly to SystmOne very challenging. 

Although it is currently beyond Practice Plus Group’s control to ensure all clinical interactions 

are contemporaneously recorded on SystmOne, we are committed to continuing to work closely 

with NHSE/I and HMPPS, via the NHSE/I Digital Assurance Board, to resolve the challenges 

with mobile connectivity in order to support the use of SystmOne when working on the wings or 

responding to emergencies. 

Practice  Plus  Group  regularly  remind  all  staff  of  the  importance  of  contemporaneous  record 

keeping  in  accordance  with  Documentation  and  Record  Keeping  Guidelines,  Nursing  and 

Midwifery Council (2018). This is shared through full staff meetings, management supervision 

and  clinical  supervision.  In  addition  a  documentation  audit  for  both  prescribing  and  non-

prescribing clinicians is undertaken regularly as part of the HIJ Audit Schedule for Practice Plus 

Group. The quality of record keeping in this case was commented on within the external clinical 

review: 

The quality of records management at HMP Pentonville was good and in line with the Nursing 

and  Midwifery  Council  (NMC)  Code  of  Conduct,  General  Medical  Council  (GMC)  Practice 

Guidelines and Health care Professional Council (HCPC) Standards of conduct, performance 

and ethics. 

In  addition  to  the  above,  Practice  Plus  Group  has  also  recently  updated  a  record  keeping 

training package to be shared with all staff which includes the importance of correctly recording 

the time of any interaction within the SystmOne record when making retrospective entries. This 

will be made available to staff HMP Pentonville by 30th September 2021.  

Practice Plus Group does not agree that response times to clinical care are hampered by the 

lack  of  contemporaneous  documentation  on  SystmOne  because  treatment,  escalation 

measures and/or referrals can be made prior to retrospective entry onto SystmOne. Indeed if a 

Page 2 of 5 

 
 
  
 
 
 
 
 
 staff member returned from the point of care to a central base in order to document notes in 

SystmOne between providing care to individual patients, response times may be significantly 

hampered by the travelling time.  

Matter  of  Concern  2:  The  interval  to  further  observations  being  undertaken  were  not 

inline with the NEWS2 scoring system and, in oral evidence, it was set out that prisoners 

were expected to self-report deterioration. This differs from latter information, provided 

after the conclusion of the inquest. However, it remains a concern. 

The  use  of  the  NEWS2  scoring  system  remains  unclear;  the  post-inquest  information 

seemingly  sets  out  both  that  this  system  was  only  to  used  after  a  positive  COVID-19 

result but also at daily handover. 

Whilst recognising that the prison environment differs from a hospital setting, I remain 

concerned that the care provided was not as guided by the NEWS2 scoring system and 

that no alternative system appears to be in place that can be used effectively in the prison 

healthcare setting. 

Response: 

Practice  Plus  Group  currently  adopts  the  NEWS2  tool  to  support  identification  of  the 

deteriorating patient, in order to aid clinical decision making.  

Throughout  the  pandemic  healthcare  staff  have  been  reminded  regularly  at  daily  handover 

meetings to use NEWS2 when carrying out observations.  However NEWS2 has limitations and 

should be used in conjunction with clinical judgement taking into account examination and other 

clinical observations. As outlined to you in evidence by Dr 

, at the time of Mr Rahman’s 

death    low  Oxygen  (O2)  saturations  were  considered  a  more  important  clinical  indication  of 

deterioration  in  all  clinical  settings,  subsequently  resulting  in  the  roll  out  of  patient  held  O2 

monitors at home in both community and prison settings in 2021. 

It  is  important  to  note  that  at  the  time  of  Mr  Rahman’s  death  there  was  no  clinical  guidance 

produced by NHS England to guide staff around the Management of COVID positive patients in 

a prison setting. In November 2020, Practice Plus Group developed the ‘Monitoring of patients 

who test positive for COVID’ Policy and this was updated and communicated to all staff by email 

Page 3 of 5 

 
 
 
 
 
 
 
 
 on 24th December 2020. This policy supported clinical staff to identify those patients at highest 

risk  of  serious  illness  as  a  result  of  SARS-CoV-2  infection  in  order  to  provide  enhanced 

monitoring of those patients.  This policy exceeded the monitoring individuals were receiving in 

the community and provided bespoke guidance to manage the large populations in custodial 

settings,  making  the  best  use  of  the  existing  healthcare  staff  and  resources.    To  put  this  in 

context, HMP Pentonville went into outbreak on 30th December 2020 and remained in outbreak 

throughout January 2021. Between December 2020 and January 2021, there were 181 patients 

who tested positive for SARS-CoV-2 and 43 healthcare staff absences from work due to COVID 

reasons.  

Practice Plus Group recognises the importance of NEWS2 scoring to identify potential clinical 

deterioration and have begun a service improvement project to encourage the appropriate use 

of the tool and embedding this into practice. A ‘Back to Basics’ workshop has been designed to 

‘Identify the Deteriorating Patient’ and ensure escalation of clinical abnormalities. This will be 

delivered  for  the  healthcare  team  at  HMP  Pentonville  by  30th  November  2021.  Within  the 

delivery of the training, small laminated NEWS2 cards will be distributed as an immediate ‘go to 

guide’  to  help  support  implementing  the  use  of  the  NEWS2  within  clinical  assessment  and 

identifying  the  deteriorating  patient.    Clinical  teams  will  be  advised  to  use  NEWS2  when 

assessing patients who are acutely unwell to support clinical decision making and ensure that 

people  who  are  seriously  ill  (both  with  COVID  and  with  other  diseases)  are  appropriately 

managed and admitted to hospital in a timely way, when appropriate.  

I trust that the above response provides assurance that Practice Plus Group are committed to 

providing  a  high  quality  healthcare  service  at  HMP  Pentonville.  In  response  to  the  specific 

concerns raised in relation to the death of Mr Rahman, we will ensure that the lessons learnt 

are implemented at HMP Pentonville and are shared across all of our healthcare services in 

prisons throughout England. 

We  would  like  to  take  the  opportunity  of  inviting  you  to  visit  the  healthcare  team  at  HMP 

Pentonville should you wish to discuss further or review first-hand the improvements described 

above.   

Page 4 of 5 

 
 
 
 
 
 
 
 
 
 Yours sincerely, 

Dr 
National Medical Director, Health in Justice Practice Plus Group 

Page 5 of 5

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