Prevention of Future Deaths reports · 2021

Anthony Clacher

Regulation 28 report to prevent future deaths, reference 2021-0356, written 22 Oct 2021. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report22 Oct 2021
Reference2021-0356
DeceasedAnthony Clacher
CoronerRachael Griffin
Coroner areaDorset
CategoryState Custody related deaths · Mental Health related deaths · Alcohol, drug and medication related deaths · Other related deaths
Sourcejudiciary.uk record · original PDF
Responses published4

The report

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

REGULATION  28:  REPORT TO PREVENT FUTURE DEATHS (1) 

NOTE·  This form is to be used after an inquest. 

REGULATION  28 REPORT TO PREVENT FUTURE DEATHS 

THIS REPORT IS BEING SENT TO: 

1.  Rt  Hon  Sajid Javid  MP,  Secretary of State for Health and  Social  Care 
2.  Victoria  Atkins  MP,  Minister for Prisons and  Probation 
3. 

,  Chief Executive Officer of Her Majesty's  Prison  and  Probation 

Service 

4. 
5. 

1 

CORONER 

,  Chief Executive Officer of NHS  England 

,  Chief Executive Officer of NHS  Digital 

I  am  Rachael  Clare  Griffin,  Senior Coroner,  for the Coroner Area  of Dorset 

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 

INVESTIGATION and INQUEST 

On  the  26th  March  2018,  an  investigation  was  commenced  into  the  death  of 
Anthony John  Clacher,  born  on  the  19th  May  1981. 

The  investigation concluded  at the end  of the Inquest on the  19th  October 2021. 

The  Medical  Cause  of Death  was: 

The  conclusion  of the  Inquest  recorded  by  the  jury was  a  narrative  conclusion 
that Anthony 
,  but he  was  not capable  of forming 
an  intention  that  the  outcome  be  fatal  due  to  his  mental  health  state,  lack  of 
general  observations and  use  of illicit substances. 

4 

CIRCUMSTANCES OF THE DEATH 

On  the  21 st  March  2018  Anthony,  a  serving  prisoner  at  HMP  Guys  Marsh,  was 
found 

 in  his cell,  C43  on  the  Dorset Unit at the  prison. 

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 

 
 1.  During the inquest evidence  was  heard  that: 

i. 

ii. 

to  be,  across 

time  of  Anthony's  death, 

At  the 
the  use  of  psychoactive 
substances  was  a  problem  at  HMP  Guys  Marsh  as  it  was,  and 
continues 
Psychoactive 
substances  were  said  to  be  the  most  dangerous  drug  in  prison. 
They  can  have  both  physical  and  mental  impact  upon  the  user 
and  in  themselves  can  cause  death  as  well  as  an  increase  in 
suicidal  ideation. 

the  prison  estate. 

Approximately  2  hours  25  minutes  before  Anthony  was  found 
  in  his  cell,  he  was  found  under  the 
influence  of psychoactive  substances.  He  was  attended  upon  by 
healthcare  professionals  and  prison  staff  and  placed  in  his  cell. 
At the time  there was  no  policy in  place  regarding  welfare  checks 
to  be  undertaken  upon  somebody  found  under  the  influence  of 
psychoactive  substances  and  the  prison  staff  would  rely  upon 
guidance provided  by the  healthcare staff. 

iii.  Observations  afford  the  opportunity  of monitoring  the  prisoners 
for  physical  and  mental  health  deterioration  and  an  opportunity 
to observe  preparatory acts  for self-harm.  There  are  known  risks 
associated  with  a  person  being  found  under  the  influence  of 
psychoactive  substances  and  they  include  the  risk  of  vomiting 
and  choking,  seizures,  heart  attack  or  a  significant  deterioration 
in  their mental  health. 

iv. 

v. 

vi. 

There  is  no  national  guidance  of  how  to  monitor  a  person  in 
prison  once 
found  under  the  evidence  of 
psychoactive substances. 

they  have  been 

Following  this,  and  other  deaths  associated  with  psychoactive 
substance  use  at  HMP  Guys  Marsh,  they  have  developed  a  local 
policy  of  prison  officers  undertaking  welfare  checks  when  a 
person  is  found  under  the  influence  of Psychoactive  substances. 
In these  circumstances  a  welfare  checks  log  is  started,  and  that 
person  will  initially remain  under  15  minute observations.  If there 
is  no  concern  after  an  hour  the  observations  will  be  reduced  to 
hourly  for  a  24  hour  period.  Evidence  was  given  that  this  has 
undoubtedly save  lives at HMP  Guys  Marsh. 

In  addition,  HMP  Guys  Marsh  have  developed  another  local 
the  Persistent  Psychoactive  Substances 
initiative 
called 
Intervention  Plan  (PPSIP). 
This  initiative  is  used  where  a 
is  using  psychoactive  substances  persistently  and 
prisoner 
therefore  requires  further  support  and  monitoring  due  to  an 
increased  risk of harm.  Evidence  was  given  that this  initiative has 
undoubtedly reduced  deaths at HMP  Guys  Marsh. 

2 

 vii. 

viii. 

ix. 

The  third  initiative  HMP  Guys  Marsh  has  adopted  under  local 
procedures  is  the  Custodial  Officer  Intermediate  Life  Support 
(COILS)  initiative.  This  is  a joint initiative between the  healthcare 
and  prison  staff  where  the  healthcare  teams  have  trained  the 
prison  staff  in  life  saving  and  supportive  care.  The  staff  are 
trained  on  certain  medical  processes  including  the  ability to  take 
vital  observations,  use  certain  medical  equipment,  for example  a 
suction  machine,  and  have  access  to  an  emergency  kit  bag  to 
provide more than  basic  life support to  prisoners.  The  benefits of 
this system  are that the  prison  staff themselves can  provide more 
advanced  care  in  the  absence  of  healthcare  professionals.  In 
addition,  when  healthcare  professionals  are  in  attendance,  the 
healthcare  professional  can  take  the  lead  in  advising  and  making 
decisions  regarding  care,  whilst the  support is  provided  by  prison 
officers.  It  was  described  as  similar  to  when  a lead  paramedic  is 
on  scene  supported  by  paramedics  and  emergency  care 
assistants.  Evidence  was  again  given  that this  has  undoubtedly 
saved  lives at HMP  Guys  Marsh. 

Evidence  was  given  that the  role  out of these  initiatives across  all 
prisons in  England  and  Wales  would  prevent future deaths.  Those 
at  HMP  Guys  Marsh  and  Practice  Plus  Group  are  happy  to  share 
their  procedures  and  documents  to  assist  in  the  rolling  out  of 
these  processes  at other establishments. 

further  given 

that  at  HMP  Guys  Marsh 

Evidence  was 
the 
healthcare  provision  is  not  available  24  hours  per  day,  7  days  a 
week.  At  the  time  of Anthony's  death,  the  healthcare  provision 
was  Monday  to  Friday,  7.30am  to  6.00pm.  Following  Anthony's 
death  healthcare  is  now  available  every  day  of the  week  but  is 
not available  between  6pm  and  7.30am.  If a medical  event were 
to  occur  at the  prison  during  these  hours,  the  prison  staff would 
be  dependant on  waiting for paramedic support. 

x.  Whilst  there  has  been  the  benefit  of  increased  awareness  and 
ability to  deal  with  an  emergency event due  to the  roll  out of the 
COILS  initiative,  evidence  was  given  by the Head  of Healthcare  at 
HMP  Guys  Marsh  that  medical  events  happen  more  frequently 
when  healthcare  is  not  on  site  during  the  evening  hours.  HMP 
Guys  Marsh  are  discussing  extending  the  healthcare  hours  until 
10.00pm  but this  would  still  leave  a  lack  of healthcare  provision 
at HMP Guys  Marsh  between  10.00pm and  7.30am. 

xi. 

Practice  Plus  Group  use  SystmOne  as  a  medical  records  system 
for those at HMP  Guys  Marsh  as  do  all  prison  in  the  prison  estate. 
Evidence  was  given  by  the  Head  of Healthcare  that this  system 
was  designed  for  use  in  GP  practice  and  not  for  use  in  prisons. 
Prisoners'  medical  records  are  often  quite  voluminous,  and 
evidence  was  given  that  it is  not  possible  to  read  the  entirety  of 
the  records  and  therefore  key  words  are  searched  to  draw  out 
the  relevant  information .  Evidence  was  given  that every  entry is 
very  important,  and  it  is  important  not  to  miss  vital  information 

3 

 xii. 

xiii. 

xiv. 

xv. 

xvi. 

xvii . 

especially  in  those  high-risk  individuals  with  complex  needs. 
Evidence  was  given  that  whilst  certain  information  can  be  very 
clear  with  SystmOne,  complex 
information  about  emotional 
difficulties  that  prisoners  may  suffer  for  example  is  not  the 
easiest to locate  and  can  be  missed. 

Evidence  was  given  that it would  be  of benefit if SystmOne  could 
be  adapted  so  that  key  information  could  be  flagged,  marked  or 
easily  identifiable  in  order  that  vital  information  is  not  missed 
which  could  be  central  to  the  treatment  of  a  prisoner  and 
particularly their mental  health. 

Evidence  was  given  at the  Inquest that PSI  64/2011  or the  ACCT 
version  6  guidance  does  not give  direction  about the  attendance 
of  healthcare  at  ACCT  reviews  and  most  importantly  at  ACCT 
reviews where  it is  proposed  to close the ACCT. 

Evidence  was  given  throughout the  Inquest that the  input of the 
healthcare team  is  very important to the ACCT  process  and  it was 
suggested  that to  provide  direction  that  healthcare  professionals 
are  required  to attend  at all  ACCT  reviews  especially those  where 
it is  to  be  closed  is  vital  and  this  should  be  reflected  in  national 
guidance. 

Information was  provided  that the  PSI  64/2011  is  currently under 
review  and  that this  could  be  addressed  within  new  PSI  and  in  a 
safety  bulletin  or  update  following  the  release  of ACCT  version  6 
in  July 2021. 

Evidence  was  also  given  that  during  the  Covid-19  pandemic 
prisoner  movements  have  been  reduced  which  has  meant  that 
rather  than  prisoners  arriving  at  HMP  Guys  Marsh  on  a  several 
days a week there  has tended to be  the arrival  of large cohorts  of 
prisoners  once  a  week.  One  example  was  given  that  17 
prisoners  could  arrive  at the  prison  on  the  same  day.  Evidence 
was  given  that this  has  caused  significant  pressures  to  be  placed 
upon  the  prison  and  healthcare  staff  to  progress  the  prisoners 
through  the  reception  area. 

As  part of the  reception  process,  prisoners  undergo  a  healthcare 
screening.  Evidence  was  given  that  it  is  simply  not  possible  to 
review  all  the  medical  records  of the  prisoners  arriving  in  these 
circumstances  and  this  could  therefore  result  in  vital  information 
being  missed.  It is  unknown  at this  time  whether the  movement 
of  prisoners  in  this  way  will  continue  beyond  the  Covid-19 
pandemic. 
The  Head  of  Healthcare  at  HMP  Guys  Marsh 
confirmed  that  as  you  cannot  access  a  prisoner's  records  until 
they  arrive,  there  is  a  risk  of future  deaths  given  the  fact  that 
they simply do  not have  the  capacity to  review  the  all  healthcare 
records  at the point of reception. 

4 

 2. 

I  have concerns with regard  to the following: 

i. 

ii. 

iii. 

iv. 

v. 

There  could  be  future  deaths  across  the  prison  estate  nationally 
due  to  a  lack of observations  and  welfare  checks  upon  prisoners 
who  are  found  under  the  influence  of  Spice  and  I  request 
consideration  be  given  to  the  rolling  out  of  the  local  processes 
adopted  at  HMP  Guys  Marsh,  nationally.  This  includes  the  roll 
out  of  their  Welfare  Checks  Policy,  the  Persistent  Psychoactive 
Substances  Intervention  Plan  (PPSIP)  and  the  Custodial  Officer 
Intermediate Life  Support initiative (COILS). 

I  have  concerns  that future  deaths  could  occur due to the  lack of 
24  hour  healthcare  across  the  prison  estate. 
I  would  therefore 
request  consideration  be  given  to  the  provision  of  healthcare  to 
all  prisons  24  hours a day,  7 days a week. 

I  have  concerns  that future  deaths  could  occur due to the  lack of 
attendance  of healthcare  staff at ACCT  reviews,  especially where 
the  ACCT  is  closed.  I  request  that  consideration  is  given  to 
providing  guidance  nationally  by  way  of a  safety  bulletin  or  an 
update to the ACCT version  6 guidance  and  in  the  new  PSI  to  be 
released  in  the future  on  the  policy  on  management of prisoners 
at  risk  of harm  to  self,  to  others  and  from  others,  ensuring  the 
attendance of healthcare staff at all  ACCT  reviews. 

that  vital 

I  am  concerned 
information  contained  within  a 
prisoner's  medical  health  records  stored  on  SystmOne,  could  be 
missed  due  to  fact  the  software  is  more  adapted  to  GP  practice 
than  prison  healthcare.  This  could  result  in  a future  death  and  I 
request  consideration  is  given  to  adapting  SystmOne  for  better 
use  in  prisons  to  ensure  information,  especially  where  there  are 
complex  care  needs,  is  easily  assessable  and  highlighted  to avoid 
crucial  information  regarding  a  patient's  care  and  safety  being 
missed. 

I  have  concerns  with  the  movement  of  prisoners  around  the 
prison  estate  in  large  cohorts  as  it  could  result  in  information 
regarding  a  prisoner's  health  not  being  identified  which  could 
result  in  a  lack  of  healthcare  provision  to  the  prisoner  which 
could  result 
therefore  request  that 
consideration  be  given  to the  review of the  processes  when  large 
cohorts  are  received  at  prisons  and  the  resources  available  to 
prison  and  healthcare staff prior to the arrival  of the  prisoner and 
during  the  progression  of  the  prisoners  through  the  reception 
process. 

in  a  future  death. 

I 

6 

ACTION  SHOULD  BE  TAKEN 

In  my  opinion  urgent  action  should  be  taken  to  prevent  future  deaths  and  I 
believe you and/or vour oroanisation  have the  power to take such  action. 

5 

 7 

YOUR RESPONSE 

You  are  under a duty to respond  to this report within  56  days of the date of this 
report,  17th  December 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  and  to  the  following 
Interested Persons: 

(1) Irwin Mitchell  Solicitors on  behalf of Anthony's family 
(2)  Hill  Dickinson  LLP,  of  behalf  of  Practice  Plus  Group,  EDP,  Midlands 

Partnership NHS  Foundation Trust. 

(3) Government  Legal  Department,  One  Kemble  Street,  London,  WC2B  4TS 

on  behalf of the Ministry of Justice 

(4)  Radcliffes  Le  Brasseur  LLP  on  behalf of Central  and  North  West  London 

NHS  Foundation Trust 

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 

22nd  October 2021 

Signed 

ti3i  ~ 
5 
~ .., 
Rachael C Griffin  '  • 

6

Responses

4 responses 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 Department of Health Social Care (PDF)
• 

Department 
of Health & 
Social Care 

Ms  Rachael Clare Griffin 
HM  Senior Coroner,  Dorset 
HM Coroner's Office 
Bournemouth Town  Hall 
Bournemouth  BH2 6DY 

Dear Ms Griffin, 

From  Gillian Keegan MP 
Minister of State for Care and Mental Health 

39 Victoria  Street
London 
SW1HOEU

21  January 2022 

Thank you  for your letter of 22 October 2021  to Sajid Javid about the death of Anthony 
Clacher.  I am  replying  as Minister with  portfolio responsibility for prison  healthcare and  I 
would  like to express my deep condolences to  Mr Clacher's family and  loved  ones at what 
must be a difficult time. 

NHS  England  and  NHS  Improvement (NHSEI) is  responsible for the commissioning of 
healthcare for the prison estate.  I am  aware that NHSEI  has provided  a response to  you 
on  the matters of concern  in  your report relating to  healthcare.  I will  not repeat the detail of 
that response.  However,  I offer the following  comments. 

Firstly,  I am  clear that all  individuals detained  in  custody are entitled to the same quantity 
and quality of health and social care services as individuals living  in  the community. 

As a signatory to the National Partnership Agreement (NPA) for Prison  Healthcare1,  the 
Department of Health and Social Care is committed to working with  the  Ministry of Justice, 
Her Majesty's Prison  and  Probation  Service (HMPPS),  NHS  England  and  NHS 
Improvement (NHSEI),  the  UK Health Security Agency (UKHSA) and the Office for Health 
Improvement and  Disparities (OHIO),  to ensure safe,  legal,  decent and effective care that 
improves health outcomes and  reduces health  inequalities for prisoners,  and  are working 
with  our partners on  the next version of the  NPA,  which will be ready for April 2022. 

All people in  prisons should receive a health assessment within the first 24  hours of entry. 
The initial assessment should be fully comprehensive to ensure that all the physical and 
health  needs of an  individual are identified and addressed at an  early stage. 

During  custody,  healthcare providers in  prison  should  have robust processes in  place to 
identify,  assess and  treat offenders with  mental health  or substance misuse needs. 

1  National Partnership Agreement for Prison Healthcare in  England 2018-2021  (publishing.service.gov.uk) 

 
 
 Decisions about whether to  provide treatment are made on  the basis of an  identified 
clinical  need. 

In  relation  to  healthcare participation in  the Assessment, Care in  Custody and Teamwork 
(ACCT)  process,  and  in  particular,  the consideration of closing  an  ACCT,  I am  advised that 
NHSEI  has worked with  HMPPS to review the ACCT process and  healthcare attendance 
and findings are anticipated  in  early 2022.  Responsibility for the ACCT process lies with 
HMPPs and  I am  informed that it will  respond to you more fully on this matter. 

In  relation to the electronic patient record platform used in the prison estate (SystmOne),  I 
understand that it has been adapted for use in  this setting with  specific templates for 
example,  to  support the  reception  of prisoners.  The  integrated summary care record that 
provides key patient information to clinicians is also accessible.  I am  advised that further 
improvements are planned,  including  linking the SystmOne platform to the  National 
Offender Management Information System  (NOMIS) . 

During the COVID-19 pandemic,  NHSEI  and  Public Health England , have worked  closely 
with  HMPPS to ensure appropriate arrangements are in  place for people in  prison to 
continue to access the physical and mental health care services they need.  In  addition, 
you  may wish to  note that since November 2020,  the  Digital  Person Escort Record 
(dPER),  which  is  accessible to  healthcare staff prior to a prisoner transfer and highlights 
risks and  key information,  has been  available across the prison estate,  to support the 
reception  process. 

More generally,  I would  like to assure you that we recognise that substance misuse in the 
prison estate presents real  challenges for both  healthcare and  prison  staff.  Restricting 
supply and  reducing  demand for drugs and  building  recovery from  substance misuse is 
vital to ensure safe and productive prisons and to  reduce reoffending . 

NHSEI  commission services which are designed to enable local delivery,  tailored to the 
specific challenges experienced  by  individual establishments. 

NHSEI  published a revised  service specification for Integrated Substance Misuse Services 
in  Prison 2  which describes a recovery orientated,  integrated prison substance misuse 
treatment service.  The specification covers traditional drugs of abuse,  psychoactive 
substances,  illicit abuse of prescribed and over the  counter drugs, and alcohol. 

The  use of a range of psychoactive substances has presented considerable additional 
challenges to all  staff working  in  prisons due to the wide ranging  and  unpredictable effects 
of these drugs,  particularly synthetic cannabinoids.  Psychoactive substance use can  be 
effectively treated through psychosocial interventions .  However,  preventing initial or 
ongoing  use is key,  through treatment which aids desistance,  and working with  individuals 
to manage triggers and prevent relapse are all  important.  Otherwise,  the primary 
treatment returns to symptom  control and  crisis management. 

2  NHS England» Service specification: Integrated Substance Misuse Treatment Service in  Prisons in 
England 

 I can  confirm that NHSEI  is working  closely with  HMPPS to ensure establishment-level 
resilience to psychoactive substances,  through a co-ordinated approach to both  supply 
and demand reduction.·. 

I hope this response is  helpful.  Thank you for bringing these concerns to my attention . 

GILLIAN KEEGAN
Response from Hmpps (PDF)
Director General Prisons 
HM Prison and Probation Service 
8th Floor Ministry of Justice 
102 Petty France 
London SW1H 9AJ 

2 February 2022 

Mrs Rachel C Griffin 
Senior Coroner for Dorset 
Bournemouth Town Hall  
Bournemouth 
BH2 6DY 

Dear Ms Griffin 

Thank you for your Regulation 28 report of 22 October 2021 following the inquest into the 
death of Anthony Clacher at HMP Guys Marsh on 21 March 2018. I am responding on 
behalf of Her Majesty’s Prison and Probation Service (HMPPS) as the Director General of 
Prisons. I apologise for the late return of this response. 

I know that you will share a copy of this response with the family of Mr Clacher and I would 
like to express my condolences for their loss. Every death in custody is a tragedy and the 
safety of those in our care is my absolute priority. 

Following evidence heard at the inquest, you have raised several concerns and I will 
address those which relate to the prison service. I understand that NHS England and NHS 
Improvement (NHSE/I) are responding separately on healthcare related matters for which 
they have responsibility. I thank you for bringing your concerns to my attention. 

The first concern you raise is that there could be future deaths across the prison estate due 
to a lack of observations and welfare checks on prisoners who are found under the 
influence of illicit psychoactive substances, and you have requested that consideration be 
given to a national roll out of some of the local initiatives which have been implemented at 
HMP Guys Marsh. The national Drug Strategy Team have been in touch with regional 
prison safety groups to gather information on the local initiatives which have been 
implemented around the country, including those in place at HMP Guys Marsh, and are in 
talks with NHSE/I national team about rolling out some of these initiatives on a national 
scale. We are committed to learning from local practices and to use these to inform the 
development of national policies to drive improvement and work to save lives and keep 
people safe.  

The second concern you raise is in relation to healthcare attendance at ACCT reviews. I 
understand that evidence was heard at the inquest about the new version of ACCT (ACCT 
v6) which was rolled out nationally in July 2021. The ACCT v6 guidance is clear that case 
reviews must be multi-disciplinary and that healthcare staff must be invited to attend the first 
ACCT case review, as well any subsequent reviews where healthcare involvement is 
relevant to supporting an individual. Attendance at case reviews must be driven by the 
individual’s specific needs and support required to ensure consistency and continuity of 
care as the case review team work together to drive meaningful outcomes and take 
ownership for their assigned Support Actions. Team members should try to attend case 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 reviews in person, however, where this is not possible they can still contribute through the 
written contribution form which is included in the ACCT documentation. ACCT user 
guidance was issued to all establishments in advance of the roll out of ACCT v6 to ensure 
that staff were familiar with the new version and confident with the key changes made to the 
document. All establishments were provided with bite size awareness training packages to 
deliver to staff and upskilling materials to equip staff with the necessary skills to complete 
ACCT V6, and revised training modules are being rolled out nationally for all staff involved 
in the delivery of ACCT.  

The third concern you have raised is that, as a result of the pandemic, prisoners have been 
arriving into prisons in large cohorts and this has put additional pressure on the reception 
procedures for prison and healthcare staff. While I recognise that this added to the 
pressures on staff assessing prisoners coming into prison, this has been necessary in order 
to keep prisoners safe, manage infection rates in line with public health advice, and to 
ensure that prisoners are receiving as full a regime as possible. This has only been possible 
through a cohort of prisoners arriving into prisons at the same time to begin a period of 
reverse cohorting together. As we begin to move away from the exceptional delivery 
measures, efforts are being made to transfer prisoners in smaller numbers and the aim is to 
return to standard delivery as was in place pre-pandemic. 

Thank you again for bringing your concerns to my attention.  I trust that this response 
provides assurance that action is being taken to address the matters that you have raised.  

Yours sincerely 

Director General of Prisons
Response from NHS Digital (PDF)
Rachael C Griffin 
HM Senior Coroner for Dorset 
The Coroner’s Office for the County of Dorset 
Bournemouth Town Hall 
Bournemouth 
BH2 6DY 

  7 & 8 Wellington Place 
Leeds 
LS1 4AP 

14 December 2021 

Dear Ms Griffin 

NHS  Digital  Response  to  Regulation 28  Report  –  inquest touching  the  death  of  Anthony 
John Clacher 

I am writing in response to the Regulation 28 Prevention of Future Deaths report received from 
HM Senior Coroner dated 22nd October 2021.  This follows the death of Anthony John Clacher 
who sadly passed away on 21st March 2018.  

This  was  followed  by  an  investigation  and  inquest  which  concluded  on  19th  October  2021. 
Unfortunately, NHS Digital was not informed that this inquest was occurring, and did not have the 
opportunity to provide information and address your concerns directly.   

I am 
Digital.  

 and am writing in my capacity as Director of Primary Care Technology at NHS 

I would like to express my sincerest condolences to Anthony’s family.  

The Regulation 28 Prevention of Future Deaths report outlines five matters of concern. 

We do not consider that matters of concern  i, ii, iii or v relate to NHS Digital and thus have no 
comment on these.  

We respond below to matter of concern iv outlined in the report: 

www.digital.nhs.uk 
enquiries@nhsdigital.nhs.uk

 
 
 
 I am concerned that vital information contained within a prisoner’s medical health records stored 
on SystmOne, could be missed due to the fact that the software is more adapted to GP practice 
than prison healthcare.  This could result in a future death and I request consideration is given to 
adapting  SystmOne  for  better use  in  prisons  to  ensure  information,  especially  where  there  are 
complex care needs, is easily assessable and highlighted to avoid crucial information regarding a 
patient’s care and safety being missed.    

1)  The IT system used in HM Prison and Probation Service (HMPPS) healthcare settings is known 
as  the  health  and  justice  information  service  (HJIS).   HJIS  is  provided  by  an  independent 
private sector IT supplier called TPP (tpp-uk.com) pursuant to a contract with NHS England 
and Improvement (NHSEI).  HJIS is a modified version of TPP’s SystmOne product.   

2)  NHS  Digital  operates  the  Digital  Care  Services  (DCS)  catalogue,  which  includes  the  GPIT 
Futures catalogue.  GPIT Futures enables GP users to buy assured digital tools and systems 
through approved assurance frameworks, and the framework agreement establishes a national 
GPIT  framework  between  NHS  Digital  and  the  suppliers  which  provide  IT  services  to  GPs.  
TPP is one such supplier, and this is the route through which the standard SystmOne product 
is available to GPs. 

3)  The  specification  and  contract  for  HJIS  are  bespoke  for  HMPPS  and  it  was  not  procured 

through the GPIT Futures framework.  

4)  Policy for HJIS is set by NHSEI.  

5)  Therefore, NHS Digital is unable to comment further on the current design and functionality for 

HJIS. 

6)  NHS  Digital  are  however  supporting  the  HJIS  team  in  NHSEI  to  set  up  a  competitive  re-
procurement in 2022/23 for HJIS and it is possible that the re-procurement will be done through 
NHS Digital’s Digital Care Services catalogue.  If so this would make NHS Digital the contract 
authority in future. 

7)  As part of supporting the re-procurement NHS Digital will consider this matter of concern when 
developing  of  the  set  of  capabilities  for  the  HJIS  re-procurement,  and  additionally  would 
welcome the opportunity to speak to the witness that made the observations about SystmOne 
in order to gather more detailed input. 

8)  Additionally,  NHS  Digital  is  currently  supporting  HJIS  in  the  following  related  ways,  and 
considers that these activities will also support improved access to a patient’s medical records 
within the HMPPS estate and between this and wider primary care:  

a.  to adopt other GP IT related products such as GP2GP which is a cross-system standard 
used  to  enable  patient  records  to  be  transferred  electronically  between  GP  system 
suppliers as they move practices.  Patient records are not currently transferred into HJIS 
when  an  individual  moves  into  the  detained  estate,  but  they  will  do  so  once  this  is 
enabled during FY22/23;  

b.  to  adopt  the  GP  registrations  system  used  in  England  to  track  the  organisation 
responsible  for  a  patient’s  care.   Presently  HMPPS  do  not  use  the  existing  system, 

www.digital.nhs.uk 
enquiries@nhsdigital.nhs.uk 

 
 
 
 
 
 
 
 
 
 
 
 
 known as NHAIS (National Health Application and Infrastructure Service), but will adopt 
the new system, to be known as Primary Care Registration Management system, when 
it is delivered in FY22/23; and 

c.  support for the HJIS transformation programme which is currently being led by North of 
England  Commissioning  Support  Unit  (NECS)  and  is  responsible  for  rolling  out  new 
Spine functionality to all of the detained estate sites.  

If I can be of any further assistance, please let me know. 

Yours sincerely 

Director of Primary Care Technology 
NHS Digital  

www.digital.nhs.uk 
enquiries@nhsdigital.nhs.uk
Response from NHS England and NHS Improvement (PDF)
Ms R. C. Griffin 
Senior Coroner  
Coroner’s Office for the County of Dorset 
Bournemouth Town Hall,  
Bournemouth,  
BH2 6DY 

National Medical Director & Interim 
Chief Executive, NHSI 
NHS England & NHS Improvement 
Skipton House 
80 London Road 
London 
SE1 6LH 

30th November 2021 

Dear Ms Griffin, 

Re: Regulation 28 Report to Prevent Future Deaths – Mr Anthony John 
Clacher; date of death 21 March 2018, HMP Guy’s Marsh.  

Thank you for your Regulation 28 Report dated 22nd October 2021 concerning the 
death of Mr Anthony John Clacher on 21 March 2018. Firstly, I would like to express 
my sincere condolences to Mr Clacher’s family.  

I note that the recent investigation into Mr Clacher’s death concluded that his death 
was self-inflicted as a result of 
the inquest, you have raised concerns within your Regulation 28 Report to NHS 
England, about a number of areas. I have listed these below along with the NHS 
England and NHS Improvement response to each. 

 and following the conclusion of 

NHS England and NHS Improvement is the responsible organisation for the 
commissioning of healthcare into prisons, which is devolved to seven regional 
teams. Commissioning healthcare in prisons is done on a principle of equivalence, 
which has been defined by the Royal College of General Practitioners. This definition 
broadly states that the aim is to ensure people detained in prisons in England, are 
afforded provision of and access to appropriate services and treatment that is 
considered to be at least consistent in range and quality, with that available in the 
wider community.  

1. Consideration be given to the rolling out of the local processes adopted at
HMP Guys Marsh, nationally. This includes the roll out of Welfare Checks
Policy, the Persistent Psychoactive Substances Intervention Plan (PPSIP),
and the Custodial Officer Intermediate Life Support initiatives (COILS).

I understand that Her Majesty’s Prison and Probation Service (HMPPS) will provide 
a full response to this as the responsible organisation.  

NHS England and NHS Improvement 

 
 2.  Consideration be given to the provision of healthcare to all prisons 24 hours a 

day, 7 days a week  

All prisons have a health needs assessment (HNA) carried out prior to services 
being commissioned. This ensures the correct level of healthcare is delivered for the 
population need. 

All prisons have some healthcare services on-site and reception prisons (those sites 
which provide a service to the courts and effectively manage remand prisoners and 
those with a very short time to serve) have 24 hours a day, 7 days a week (24/7) 
healthcare. Other sites would only have this 24/7 service commissioned on-site 
where there was a significant call for it, which would be on the basis of an HNA 
(prisons with an aged demographic for instance). All women’s sites have 24/7 
healthcare as all receive from court.  

Access to healthcare services is however available 24/7 using external services with 
all sites having access to out of hours (OOH) and emergency, GP and first 
responder services should they be required.  

3.  Consideration is given to providing guidance nationally by way of a safety 
bulletin or an update to the ACCT V6 guidance and in the new PSI to be 
released in the future on the policy on management of prisoners at risk of 
harm to self, to others and from others, ensuring the attendance of healthcare 
at all ACCT reviews.  

NHS England and NHS Improvement worked collaboratively with HMPPS to review 
the Assessment, Care in Custody and Teamwork (ACCT) process around healthcare 
attendance. It has been rolled out by HMPPS across the prison estate and 
evaluation is underway with findings due early 2022. Responsibility for this lies with 
HMPPS, and we have collaborated with HMPPs to agree that they will be responding 
in full to this point.  

4.  Consideration is given to adapting SystmOne for better use in prisons to 

ensure information, especially where there are complex care needs, is easily 
assessable (sic) and highlighted to avoid crucial information regarding a 
patient’s care and safety being missed.  

The current SystmOne (S1) module that is used in prison is a bespoke system, 
already adapted for the secure estate.  Although this is based on primary care, there 
have been a number of adaptions to make improvements to the suitability of the 
system for the secure environment. This includes specially designed templates at 
reception based on NICE guidance to gather key, pertinent information when 
someone arrives into prison for the first time, as well as 
bespoke prescribing modules.  

 All sites have access to the integrated summary care record which houses the latest 
information regarding a patient’s significant health such as Diabetes, Mental health, 
for instance, along with regular medication and allergies.  This is the same 
functionality available to other clinicians outside which can be accessed to verify the 
patient’s condition at that time. 

 
 
 
 
 
 
 
 
 If the patients GP is also using TPP S1 and has the functionality set to share out the 
medical record, this can be seen in the tabbed journal when the patient is registered 
on the TPP S1 unit on arriving at the prison. 

Further improvements are planned over the next year to include the ability to link 
with PNOMIS and the capacity to access community records through GP2GP 
electronic transfer and, from 2022 should a patient wish to register with the detained 
estate as their GP practice the full medical record will be sent to the prison via 
GP2GP.  

5.  Consideration be given to the review of processes when large cohorts are 

received at prisons and the resources available to prison and healthcare staff 
prior to arrival of the prisoner and during the progression of the prisoners 
through the reception process. 

Progress in this area has already been made. Digital Person escort record (DPER) 
has been live across the prison estate since November 2020.  All reception 
healthcare staff should have access to the DPER prior to arrival of persons at the 
site. This platform highlights risks pertaining to patients arriving and can be used to 
ensure the correct processes are followed at reception for healthcare teams.   

Healthcare teams also have the ability to access the integrated summary care record 
(SCR) at reception to validate high level health issues and medication requirements.  

Further I can confirm that a review and update of the reception and secondary 
screening templates for healthcare is ongoing, and this is primarily within the female 
estate at present. This programme of work package will conclude by April 2022 and 
then, using lessons learned, the same system will be applied to the male estate 
during 2022.   

Thank you for bringing these important patient safety issues to my attention and 
please do not hesitate to contact me should you need any further information. 

Yours sincerely, 

National Medical Director & Interim Chief Executive, NHSI

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