Prevention of Future Deaths reports · 2021
Regulation 28 report to prevent future deaths, reference 2021-0433, written 17 Dec 2021. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.
| Date of report | 17 Dec 2021 |
|---|---|
| Reference | 2021-0433 |
| Deceased | Nichola Lomax |
| Coroner | Joanne Kearsley |
| Coroner area | Manchester North |
| Category | Hospital Death (Clinical Procedures and medical management) related deaths · Mental Health related deaths · Other related deaths |
| Source | judiciary.uk record · original PDF |
| Responses published | 1 |
Text extracted from the PDF text layer. Reproduced verbatim, including the scan's own layout.
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REGULATION 28: REPORT TO PREVENTFUTURE DEATHS (1)
REGULATION 28 REPORT TO PREVENT FUTURE DEATHS
THIS REPORT IS BEING SENT TO:
1. The Right Honourable Sajid Javid Secretary of State for Health and Social Care
2. Dr
. Chair of the Faculty of Eating Disorders Royal College of Psychiatrists
Chief Executive Officer of NHS England
Chief Executive of the Academy of Medical Royal Colleges
Dr
Chief Executive Northern Care Alliance
Chief Executive Greater Manchester Mental Health Trust
Chief Executive of The Priory Group
Chief Executive of Health Education England
, Bury Clinical Commissioning
, Greater Manchester Health and Social Care Partnership/ Integrated Care
Board Greater Manchester
CORONER
I am Joanne Kearsley, Senior Coroner for the Coroner area of Manchester North
2
CORONER'S LEGAL POWERS
I make this report under paragraph 7, Schedule 5, of the Coroner's and Justice Act 2009 and
Regulations 28 and 29 of the Coroners (Investigations) Regulations 2013
3
INVESTIGATION and INQUEST
On the 12th August 2020, I commenced an investigation into the death of Nichola Jane Lomax. The
investigation concluded on the 10th December 2021. The medical cause of death was confirmed as
1a) Liver Failure 1b) Anorexia Nervosa 2. Refeeding syndrome and cholecystitis.
I recorded a
narrative conclusion that Nichola died. as a result of the physical complications of the mental disorder
anorexia nervosa, contributed to by neglect.
I found on the balance of probabilities if appropriate care and refeeding had been provided to Nichola
it is more likely than not she would have survived.
A significant number of failings were identified.
4
CIRCUMSTANCES OF DEATH
Nichola had an eighteen year history of an eating disorder. She had been an inpatient in 2011 and
2016. Since 2017 she had disengaged with services, with the exception of her GP. Until June 2018
there was regular weighing of Nichola by her GP but this then ceased (it is not known why as she
continued. to engage with them for other matters).
At the beginning of 2020 Nichola felt unwell and on three occasions attended via ambulance at A&E
atFairfield GeneralHospital "FGH". She attended on the 13th January, 23rd March and the 28th April
2020. On each of these occasions she is treated for low otassium.
In Janua her wei ht was
noted to be 31.6kg (BMI 11.6) although it is not known if she was actually weighed and therefore if
this was accurate. There was no recorded weight in March or April.
The Northern Care Alliance ("NCA") accepted that on each of these three occasions Nichola should
have been admitted to hospital as she was a high risk for refeeding syndrome. In addition, it was
accepted by the NCA that it had not disseminated or trained staff in respect of MARSIPAN
(Management of Really Sick patients with Anorexia Nervosa) guidance.
In addition during these admissions no discharge follow up was suggested for her GP and there was
no referral of Nichola to any specialist services. No consideration was given to the involvement of
Psychiatry with Nichola.
On the 1st June Nichola attended her GP practice having been found by a family member unable to
walk and "like she could die at any minute". From this stage onwards the Advanced Clinical
Practitioner at the GP practice did everything she could do to help Nichola. She immediately
recognised the life-threatening condition. She weighed Nichola, her weight was 26.7kg and her BMI
10. In all likelihood this was the first accurately recorded weight since 2018.
She immediately sent Nlchola to A&E at FGH and referred her to the Community Eating Disorder
service ("CEDS") which for Bury is under Greater Manchester Mental Health Trust ("GMMH").
CEDS made a referral for inpatient admission to the Specialist Eating Disorder Unit at The Priory as
they recognised her need for inpatient admission. However CEDS did not accept Nichola as their
patient as they do not accept anyone with a BMI less than 14.
At FGH Nichola was admitted until the 3rd June to treat her electrolyte imbalance. She was not
admitted to address her risk of refeeding. There was no recognition that this was Nichola's fourth
attendance at A&E since January. During this admission there was poor nursing input and poor
recording in the nursing notes. There was no nutrition or fluid charts and no monitoring of her daily
intake or any purging behaviours. There was poor dietetic input and no attempt to obtain any advice
from a specialist eating disorder dietitian. There was a failure to follow the basic dietetic input which
was given and no prescribing of supplemental drinks. There was a lack of clarity as to the treatment
plan for Nichola other than to stabilise her electrolyte imbalance.
There was a confused picture and understanding as to whether NG feeding was actively going to be
considered. This led to an incoherent referral to psychiatry for them to assess her capacity for
discharge.
At this stage the court found Nichola was willing to stay in hospital, in fact she was asking to stay in,
she was engaging with treatment in that she was eating orally, there was no evidence any medic
was wanting to treat Nichola by way of NG feeding and there was no evidence anyone had discussed
in an appropriate way, NG feeding with Nichola and no evidence she had refused the same.
No attempts were made to discuss her case with the Priory and she was discharged on the 3rd June.
The CEDS and GP were concerned about her discharge, CEDS wrote a letter for Nichola to take
with her to the hospital. She was once again asked to attend A&E went back to FGH on the 5th June
2020. On this occasion she was admitted until the 11 th June 2020. During this admission the court
found there a number of failings:-
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-
-
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-
a lack of close monitoring of her nutritional intake and purging behaviours,
there was no prescribing of supplemental drinks,
there was no adherence to the Trusts refeeding policy,
there was a lack of specialist dietetic advice which should have been escalated to management
if there were difficulties obtaining the same,
There was an unclear treatment plan in terms of whether Nichola required NG feeding
Inappropriate and unclear requests were made of psychiatry
On the 11 th June there was a discussion between the medical doctor and the Priory. This
conversation was totally unacceptable. At the conclusion of the call both Consultants had an
The Priory
irreconcilable understanding as to the result and advice each were providing.
understood from this conversation that Nichola no longer required inpatient admission to their
service. This was not correct. The Trust were indicating Nichola was medically stable and no longer
required admission in FGH.
In addition the Priory believed Nichola was being discharged under
the care of the community mental health team with a 7 day follow up. This was not the case. In the
meantime the medical doctor believed Nichola was under the CEDS service due to the letter which
had been provided by them in support of her admission on this occasion. As a result of this poor
communication Nichola was discharged from FGH and the Priory cancelled her inpatient referral.
There was then a delay in making a re-referral to the Priory. This should have occurred on or around
the 16th June when CEDS become aware that Nichola had been removed from the waiting list. A
second referral was not sent by them until the 3rd July.
This led to a delay in a bed for Nichola. Despite all the specialists indicating Nichola's case was one
of the two most extreme cases they had seen in over 15 years of practice, at no stage was her case
escalated to NHS England to try and obtain a bed out of area
Between the 11 th June and the 22nd July Nichola was monitored by the advanced clinical practitioner
within the GP practice. She attended regularly for weighing and bloods. Despite this her condition
deteriorated and she was admitted to hospital on the 27th July (as it was hoped an inpatient bed was
going to be available on the 29th July). She deteriorated further and died on the 3rd August 2020.
5
CORONER'S CONCERNS
During the course of the inquest the evidence revealed matters giving rise to concern. In my opinion
In the circumstances it is my
there is a risk that future deaths will occur unless action is taken.
statutory duty to report to you.
The MATTERS OF CONCERN are as follows:-
1) Inadequate Training of doctors and other medical professionals re eating disorders
For National / NCA / Royal College of Psychiatrists
Over 30 members of the medical profession saw Nichola during her three admissions to FGH in
2020. Of those, only one had knowledge of MARSIPAN and his understanding of MARSIPAN was
extremely limited. This is not a question of lack of familiarity by professionals, it reflects a complete
absence of any understanding that MARSPAN exists and indeed how to implement it in respect of
the emergency treatment of an anorexic patient.
Previous Regulation 28 reports suggests this remains an ongoing concern nationally and MARSIPAN
is not being disseminated to practitioners on the ground.
Whilst MARS I PAN can be accessed via a link in the NICE guidance on Eating Disorders. My concern
is that Acute Trusts may not have sufficient regard to Guidance issued by Royal College of Psychiatry
which is relevant to the medical care which they provide.
2) Accessing Specialist Advice
For National, NCA/GMMH/PRIORY
None of the practitioners in Nichola's case knew how to access specialist eating disorder advice
including medical or dietetic advice. There are no pathways to assist acute clinicians in how to
access this specialist advice. To this day the clinicians told the Court they would not know where to
go other than to try and contact the Priory. The Court heard from the Priory they are not
commissioned to provide advice.
3) Referral Criteria for the Priory and Community Eating Disorder Service
For GMMH, PRIORY, BURY CLINICAL COMMISSIONING, ICB
In Greater Manchester the Community Eating Disorder Service (CEDS) do not accept patients who
have a BMI of less than 14. The court heard this is in part due to the structure and commissioning
of the service. Adherence to this criteria had the following implications for Nichola's care:
• As the only service who can refer to the Priory, CEDS become aware of Nichola. CEDS
involvement created the impression that they were providing care to her. This created a
confused picture as to who was co-ordinating her care.
• This meant that monitoring of Nichola was undertaken by the GP practice who were not
specialists and had limited knowledge of eating disorders. It would have been more clinically
appropriate for CEDS to have taken on this role and the court heard that in many other areas
of the country the CEDS accept patients with BMls lower than 14 and have responsibility for
the monitoring and co-ordination of the patients care.
The Court heard evidence from a number of practitioners as to their understanding of the referral
criteria for Nichola to be admitted to The Priory. The clear impression given by The Priory was that
Nichola would not be accepted until 1) a bed became available but also 2) her BMI increased to
somewhere around 12/13. The Court was told that the rationale for this is that a patient with a BMI
below 13 is at high risk of refeeding according to MARSIPAN and more likely to require an acute
hospital admission.
This impression meant that hospital clinicians and the GP understood that Nichola would not be
accepted by the Priory until her weight had increased. However the court heard that the Priory can
take someone with a BMI of less than 13 if medically stable and the benefits of specialist care
outweigh the risks of refeeding. Given the impression created by the Priory no attempt was made to
obtain an emergency bed for Nichola who was medically stable for some time after the 11 th June.
4) Lack of Critical Services
For BURY CCG / ICB /GMHSCP
The Court heard evidence that despite FGH having a 24/7 Emergency Department, adherence had
not been paid to NICE guidance which recommends the establishment of an Acute Liaison Psychiatry
service. In this case the court heard that such a service would have provided continuity of care and
psychiatric input. The only available psychiatry input at Fairfield hospital for the acute staff is either
within the A&E department where there are psychiatric nurses or using the on-call psychiatrist, this
post being on call for all psychiatry matters within the whole of Bury. There is no specific liaison
psychiatric service for the Acute Hospital. .
The evidence was that there is no Consultant Psychiatrist allocated to the CEDS in Bury or the 6
other boroughs of Manchester. However even though the CEDS is provided by the same mental
health trust, it is only the city of Manchester that does have an allocated Consultant Psychiatrist.
5) Community Monitoring of patients with an Eating Disorder
For BURY CCG /NATIONAL/ ICB/ GMHSCP
There is a lack of clarity as to whether there is any formally commissioned provision for the monitoring
of moderate to high risk Eating Disorder patients within the community. The Court heard from
GMHSCP that this was the responsibility of primary care however it was unclear whether this was
known by those working in primary care and whether this service had ever been commissioned.
6) Nursing Input and Recording
For NCA
Notwithstanding that the NCA made admissions in relation to the clinical care provided to Nichola,
the Serious Incident Review did not consider the nursing input. Evidence during the course of the
Inquest showed the nursing input to be poor and lacking in basic care. There were no nutrition/ fluid
charts on her first admission in June. There was a lack of close monitoring of her food and purging
behaviours which would have been essential information to provide to the Doctors involved in setting
her treatment plan. There was a poor documentation and incorrect completion of documentation
which highlighted her malnutrition but then recorded conflicting information.
7) Delay in Re-Referral
For GMMH/PRIORY
Due to a misunderstanding following the telephone discussion between the Priory and FGH on 11 th
June Nichola was clearly removed from the Priory waiting list. This led to confusion for the GP
practice who did not know why she had been removed. There was then a delay by the CEDS in re
referring Nichola which on balance likely led to a delay in a bed being available. This should not
have occurred and more worryingly had not been noted as there had been no incident review of this
case by either the Priory or the CEDS.
7) Lack of Recognition of the need to Investigate
For National Medical Examiner
It was of concern to the court that the only reason Nichola's death was referred to HM Coroner was
her initial medical cause of death had incorrectly included paracetamol toxicity. It was not until the
court investigated this case, that there was any recognition by any of the agencies that there had
been failings in the care of Nichola. If this death had not been reported to the Coroner, none of the
above failings or the need for learning would have been identified. The court is extremely concerned
that there is the real potential for the under reporting of such cases and a lack of appropriate
investigation to ensure learning is captured so as to prevent future deaths. This is important given
the court heard eating disorders have the highest mortalit rate of an mental disorder.
6
ACTION SHOULD BE TAKEN
In my opinion action should be taken to prevent future deaths and I believe each of you
respectively 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 14th
February 2022. 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 namely:
Farleys Solicitors - representatives for the family of NICHOLA LOMAX
Pennine Care NHS Trust - Interested Person
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 from. 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.
Date:
9
Signed:
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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.
Bundle Index
SECTION A – Evidence
Document
Date
Author
Pages
Signed Regulation 28
20/12/2021
A1 – A6
Reg 28 response from
Gillian Keegan
29/07/2022
A7 – A10
Reg 28 response - RCPsych 04/02/2022
A11 – A17
Reg 28 response - NHSEI
18/02/2022
A18 – A22
Reg 28 response - AOMRC
11/02/2022
A23 – A24
Reg 28 response - NCA
14/02/2022
A25 – A28
Reg 28 update - NCA
12/08/2022
A29 – A29
Reg 28 Response -GMMH
13/04/2022
A30 – A33
Reg 28 response - Priory
25/02/2022
A34 – A36
Reg 28 response - NHS HE
15/02/2022
A37 – A39
Reg 28 response - Bury
CCG
03/02/2022
A40 – A43
Reg 28 response - GMCA
11/02/2022
A44 – A49
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From Gillian Keegan MP
Minister of State for Care and Mental Health
39 Victoria Street
London
SW1H 0EU
020 7210 4850
25 July 2022
Joanne Kearsley
Senior Coroner
HM Coroners Court
Newgate House
Newgate
Rochdale
OL16 1AT
Dear Ms Kearsley,
Thank you for your correspondence of 17 December 2021 to the Secretary of State
for Health and Social Care, Sajid Javid, regarding the tragic death of Nichola Lomax.
I extend my deepest condolences to Ms Lomax’s family and friends. I, the Department,
and health bodies, at both a national and local level, take the Report’s concerns very
seriously. Improving eating disorders services is a key priority for the Government
and a vital part of our work to improve mental health services.
Your report raises important concerns regarding adult eating disorder treatment and
shared learning across the health system. Following the Parliamentary and Health
Service Ombudsman (PHSO) report “Ignoring the alarms: how NHS eating disorder
services are failing patients”1, regarding the tragic death of Averil Hart, the Department
of Health and Social Care has been working with NHS England and NHS Improvement
(NHSEI), Health Education England (HEE), the General Medical Council, the National
Institute for Health and Care Excellence and the Royal College of Psychiatrists through
a delivery group to continue to address the recommendations. We understand the
importance of working with such partners and remain committed to continue working
to push forward improvements for this vulnerable group.
Regarding the matter of concern that you raise related to inadequate training of
medical professionals regarding eating disorders - doctors should have the necessary
knowledge and experience of mental health to assess patients holistically, considering
the individuals’ physical, social and psychological needs. Through the PHSO delivery
group, NHSEI is working with HEE and other partners to procure training courses that
will increase the capacity of the existing workforce to allow them to provide evidence-
based treatment to more people, as they have set out in detail in their responses. The
Department will continue to support and assure this work to progress against key
actions, including ensuring better awareness of eating disorder training and continuing
professional development. We recognise the work of external partners, such as Beat,
to push forward better training in medical courses, and the necessary focus of Eating
1 https://www.ombudsman.org.uk/sites/default/files/page/ACCESSIBILE%20PDF%20-
%20Anorexia%20Report.pdf
1
A7
Disorder awareness week this year on this issue, which we will continue to support as
a Department.
Eating disorders have some of the highest mortality rates of any mental health disorder
and appropriate monitoring of anorexia nervosa patients by primary or secondary care
providers is vital. Under the NHS Long Term Plan, the Department is committed to
ensuring a more integrated service across primary and secondary care for people with
severe mental illnesses, including eating disorders, and to giving 370,000 adults with
severe mental illness greater choice and control over their care and support them to
live well in their communities by 2023/24. To support improvements in mental health
care more generally, including eating disorder care, we remain committed to
expanding and transforming mental health services in England and to investing an
additional £2.3 billion a year in mental health services by 2023/24.
This investment has already begun, with all Integrated Care Systems (ICSs) receiving
funding to transform adult community mental health services, including eating
disorders, with the expectation that all ICS will have transformed services in place by
2023/24. In 2021/22, 33 ICSs are transforming adult eating disorder services, with the
remainder due to begin transformation of services in 2022/23. In their response,
NHSEI have set out the importance of this funding and adherence to adult eating
disorder patient care guidance, to ensure the highest standards of care. NHSEI’s work
continues to highlight to systems the importance of early intervention services, as well
as ongoing medical monitoring and ensuring access to care in the right place, and at
the right time.
The Department recognises that NHS eating disorder services are facing increased
demand. For example, the number of children and young people entering urgent
treatment for an eating disorder increased by 73% in financial year 2020/21 compared
to 2019/20 according to NHS data. Recognising this increase in demand, on 27 March
2021 the Department published its Mental Health Recovery Action Plan, backed by an
additional £500 million of targeted investment, to ensure that right support is in place
for this financial year.
As part of this funding £79 million is being used to significantly expand children’s
mental health services, including allowing 2,000 more children and young people to
access eating disorder services. £58 million has been allocated to accelerate the adult
community support to bring forward the expansion of integrated primary and
secondary care for adults with severe mental illness, including eating disorders.
In addition, the Department is developing a new long term, cross-government Mental
Health Strategy in the coming year. The Government will launch a public discussion
paper this year to inform the development of this strategy. This will set us up for a
wide-ranging and ambitious conversation about potential solutions to improve mental
health and wellbeing.
This case is shocking and is a tragedy, and something taken very seriously in the
Greater Manchester healthcare system, hence the collaborative system response and
approach to improving services moving forward. This should and will be a “never
event” in the Greater Manchester ICS’s developing quality and safety model under the
new Integrated Care Board (ICB). Unfortunately, cases like this have been seen
2
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nationally as well, from which all regions must learn lessons and share good practice.
All three ICS regions in the North West are part of the eating disorder lead provider
collaborative and this will strengthen learning and development across the area too.
This case has accelerated the mobilisation of the dedicated Greater Manchester
Mental Health system quality and safety group, which will be a system wide panel,
including - social care, primary care, acute care, mental health, voluntary, community
and social enterprise, all blue light services and service users and carers, and will be
chaired by the executive medical lead for mental health. This panel will report to the
Greater Manchester system quality and safety board, chaired by the chief Medical
Director and supported by the Chief Nurse, and accountability for monitoring and
quality improvement will be under the ICB (Chief Medical Director and Chief Nurse)
supported by the Executive Medical lead for Mental Health and the wider clinical and
care professional leadership group.
There has been a year on year rise in eating disorders and a particular rise through
the pandemic across all ages, especially in young people and young adults.
Nationally, the launch of MEED2 in May this year will see the most significant quality
improvement in eating disorders in the last 5 years in addition to the transformation of
young people’s eating disorder services. This is the “Management of medical
emergencies in eating disorders” guidance developed by The Royal College of
Psychiatrists (2020) and now embedded in the NICE guidance for eating disorders
assessment, treatment and management. This is based on the previous MARSIPAN3
and Junior MARSIPAN guidelines for managing severe anorexia nervosa, but MEED
is all ages and all eating disorders with a shared language and risk assessment tool
that can be used by all clinical and care professionals across the system. This includes
social care colleagues to strengthen the safeguarding support for vulnerable adults.
This tool is akin to the NEWS 2 tool, developed by The Royal College of Physicians
for risk assessment and triage for those presenting with physical health illnesses and
now a shared language across the urgent and emergency care system.
The traffic light system in MEED has been endorsed by NHSE/I and is being rolled out
across the system in Greater Manchester and nationally now so that, like NEWS 2, we
can see significant improvement in risk assessment and triage. There will also be a
requirement for all ICSs to have a formally established whole-system MEED group,
which we have started for young people and are now starting for adults, with a link
across the two to ensure the transitions are also addressed. Greater Manchester have
also accelerated the review of the whole adult eating disorders pathway, including
revised protocols with our independent sector providers and greater collaboration with
the voluntary, community and social enterprise sector providing both prevention and
recovery support as well as carer support. The MEED groups will be responsible for
training rollout with resource support from the Mental Health programme and our
provider collaboratives which will be monitored through the system quality and safety
group at a Greater Manchester level.
2 https://www.rcpsych.ac.uk/improving-care/campaigning-for-better-mental-health-policy/college-
reports/2022-college-reports/cr233
3 The Management of Really Sick Patients with Anorexia Nervosa
3
A9
I hope this reply helps to reassure you that partners across the health system are
working to make improvements as a result of this report to prevent this happening in
future. The Department takes the matters raised in this report seriously and will
continue to engage on progress via the PHSO Delivery Group, and through the new
mental health strategy.
I hope this response is helpful.
GILLIAN KEEGAN
4
A10
Joanne Kearsley, Senior Coroner for Coroner area of
Manchester North
Dear Ms Kearsley
Royal College of Psychiatrists response to Coroner’s Report into
the death of Nichola Lomax
Purpose of response
To respond to those aspects of the Coroner’s Report into the tragic death
of Nichola Lomax that are relevant to the Royal College of Psychiatrists, in
particular to what is referred to as the “MARSIPAN” guidelines in the
Report. The updated guidance referred to in this document will have a
different title (Medical Emergencies in Eating Disorders) but given the
language in the Report, we are using “MARSIPAN” for ease of reference in
this response.
We would first of all though like to take the opportunity to extend our
sincere and deepest sympathies to Nichola’s family, friends and all who
cared for her.
Background
The Royal College of Psychiatrists is the professional medical body
responsible for supporting psychiatrists throughout their careers, from
training through to retirement, and in setting and raising standards of
psychiatry in the United Kingdom. The College aims to improve the
outcomes of people with mental illness, and the mental health of
individuals, their families and communities. In order to achieve this, the
College sets standards and promotes excellence in psychiatry; leads,
represents and supports psychiatrists; improves the scientific
understanding of mental illness; works with and advocates for patients,
carers, and their organisations. Nationally and internationally, the College
has a vital role in representing the expertise of the psychiatric profession
to governments and other agencies.
While these are extremely tragic circumstances on which to have to
communicate, we hope that the information we provide in this note
responds to the issues you raise that are relevant to the College, and that
this may contribute to minimising the risk of similar events occurring in
A11
the future. If you have any questions or would like to discuss any aspect
of our response, please do not hesitate to contact us at
This response has been developed with the support of the College’s Eating
Disorder Faculty, which is the part of the organisation that brings
together psychiatrists working in eating disorders across the age
range. It aims to secure the best outcome for people with eating
disorders by:
promoting excellent services,
supporting the prevention of eating disorders,
ensuring prompt treatment to achieve higher recovery rates and
prevent complications,
improving medical training in eating disorders,
promoting quality and research,
setting standards and
being the voice of eating disorder psychiatry.
“MARSIPAN" Guidelines
The College role is one to influence, support and advise, and we do
not have any statutory responsibility. For example, in light of the
reference to the “MARSIPAN” guidelines in the Report, we have no
formal levers by which we can assure ourselves of compliance with it,
including the provision of the necessary funding and associated
workforce resources to implement it.
That said, the College and its Eating Disorder Faculty have
undertaken significant activity that seeks to improve services through
mechanisms such as evidence-based guidance and training.
The impetus for publishing the “MARSIPAN” guidelines in 2010 was the
tragic death of a young woman in hospital in 2008 It was developed in
collaboration with the Royal College of Physicians and the Royal College of
Pathologists, with a focus on ensuring the safe management of
emergencies in anorexia nervosa. The document was published on the
RCPsych website, and a number of conferences and training events were
organised by the College to promote its dissemination.
As that original document only applied to adult care, Junior MARSIPAN
guidance was developed in 2012, and in 2014, the adult document
originally published in 2010 was revised. Owing to the insufficiency of
randomised controlled trials in the field, the MARSIPAN guidance was
initially based on expert consensus of best practice, rather than the
A12
methods required by the NICE guidelines. However, it was quoted in the
NICE Eating Disorder guidelines (NICE, 2017) in the context of the
management of refeeding in hospitals. It is also referred to in the NHSE
Commissioning guidance for specialist inpatient and community services.
(National Collaborating Centre for Mental Health, 2019; NHS England,
2013).
Although the guidance was widely accepted by specialist services
(particularly CAMHS eating disorder services and paediatrics), the College
identified and acknowledged that many acute trusts did not implement it
fully and consistently, which corresponds with your findings in this case.
When exploring the reasons for this, we understood that the barriers to
implementation included:
the lack of targeted funding and training of the workforce
the methodology and impact of RCPsych College Reports do not
carry the same weight as the NICE guidelines
an overlap with the NICE Nutrition Support for Adults guidelines
(NICE, 2006), which acute trusts follow (even though that excludes
eating disorders).
To address these issues, the College agreed on a major revision of
MARSIPAN in 2019.This work is now close to completion and is due to be
published in the first half of 2022. The main aims of the revision are to
tackle the barriers identified previously to its implementation (to achieve
wider acceptance and dissemination of these guidelines), and to widen
the scope to include all eating disorders across the age range.
The revision has been supported by the College’s National Collaborative
Centre for Mental Health, and it has been developed via a robust
methodology. Wide consultation on the draft has been taken forward with
internal and external stakeholders, including other Faculties within the
College, such as Child and Adolescent, General Adult and Liaison. We
have and are still actively engaging with other medical Royal Colleges, the
BDA, other charities such as BEAT, and experts by experience. We will be
seeking endorsement from external stakeholders, including the Academy
of Medical Royal Colleges (AOMRC). This process is important to ensure
that clinicians, not just psychiatrists understand that they have a role to
play in identifying and tackling eating disorders.
The College will also work with relevant stakeholders, such as HEE,
AOMRC, RCGPs, RCPCH, RCEM, RCP and our College Curriculum
committee to ensure that the guidelines are embedded in relevant
undergraduate and postgraduate training materials.
A13
However, implementation of the guidance will be dependent not just
on dissemination but also on the leverage and resources that can and
must emerge from those who are responsible for it. Therefore, we
are also in discussion with NHSE/I to seek their active support and
this engagement has been positive and we look forward to further
work with and by them to help embed these new guidelines across
the country.
Training
As reflected earlier in our response, to maximise the impact of these
guidelines we will need to see a ramping up of the training and expansion
of the workforce in mental health and beyond.
In terms of training, as Eating Disorder psychiatry is not a GMC
recognised subspecialty, we have made significant efforts to address this
gap. Following a national survey showing that most medical doctors
receive fewer than 2 hours of training about eating disorders (Ayton and
Ibrahim, 2018) and the PHSO report (Parliamentary and Health Service
Ombudsman, 2017), we have been working with the GMC, HEE, Beat,
NHSE PHSO implementation group, the RCPsych Curriculum committee,
and examination panels. A summary of progress so far is shown below:
1. We published a Position Statement ‘Improving Core Skills and
Competence in Risk Assessment and Management of People with
Eating Disorders: What all Doctors Need to Know’, which provides a
blueprint for training at all levels (Ayton et al., 2020) The key
messages included:
There is an imperative to improve training in eating disorders for
all undergraduate doctors in the interface between physical and
mental health, alongside a greater emphasis on mental health in
undergraduate training.
Postgraduate training in all specialties should include nutritional
and psychological aspects of eating disorders, including
recognition of severe malnutrition as a medical emergency,
regardless of aetiology.
Leadership competencies should emphasise the need for all
doctors to create and manage safe patient pathways across
complex systems.
2. In collaboration with HEE and BEAT we developed online training
materials about eating disorders for medical students and
foundation trainees, which are freely available.
A14
3. With funding and support from the GMC, we will be working with
AOMRC on developing shared curricula about eating disorders for
postgraduate training across relevant Royal Colleges. This work has
started in January 2022.
4. The College Curriculum, Education and Training Committees are
exploring how they can strengthen core and higher training in
eating disorders. This work is still ongoing.
5. The RCPsych received funding from HEE to develop eating disorders
credentialing, which will improve the standards of training for those
who wish to specialise in the field. This work will be starting in the
next few months.
Funding and Workforce
The implementation of best practice guidelines is dependent on
appropriate funding and the development of the workforce, which we look
to the Government to provide and support. There has been some
welcome progress in resources in the recent past, particularly in relation
to children and young people but to maximise the impact of the soon to
be published guidelines this needs to be accelerated and expanded, in
particular a larger focus on adults with eating disorders is crucial.
In terms of workforce developments, the data shows the scale of what
needs to be done. According to the 2021 RCPsych Census, there are only
97 substantive consultants working in the field in the UK, and half of them
are part time. Vacancy rates were recorded as 12%. Approximately half of
the consultants work in independent specialist units, such as the Priory,
which are not well integrated into local health care systems, and this may
in some part explain the confusion and poor communication highlighted in
your report.
These numbers are in stark contrast with the 23,954 patients needing
hospitalisation for a primary or secondary diagnosis of eating disorder in
2020/21(NHS Digital, 2021). Many NHS specialist eating disorder services
are running without or have minimal consultant psychiatrist input, a
problem that was highlighted in a recent Reg 28 Report (Horstead, 2021).
If there are insufficient specialists to help manage these patients and to
advise colleagues who are unfamiliar with the condition, there remains
the risk of similar tragedies in the future.
It is essential that all eating disorder services employ a consultant
psychiatrist as part of specialist multidisciplinary teams, as they are the
only professional group who have training both in the physical and mental
A15
health aspects of eating disorders and assessing and managing complex
cases. Consultants also have important roles in training, research and
advising non-specialist services. The requirement for employing
consultant psychiatrists is clearly specified in the NHSE Commissioning
guidance and in the RCPsych Quality Network for Eating Disorders (QED),
however, many NHS services have insufficient or no psychiatric input, and
addressing this shortfall is essential for the prevention of future deaths.
This will require an urgent expansion of training and consultant posts as
part of the forthcoming investment into eating disorder services.
I hope you find this helpful and please let me know if I can be of any
further help.
Yours sincerely,
RCPsych Registrar
RcPsych ED Faculty Chair
Ayton, A., & Ibrahim, A. (2018). Does UK medical education provide doctors with sufficient skills and
knowledge to manage patients with eating disorders safely? Postgrad Med J, 94(1113), 374-
380. doi:10.1136/postgradmedj-2018-135658
Ayton, A., Nicholls, D., & Robinson, P. (2020). Improving core skills and competence in risk
assessment and management of people with eating disorders: What all doctors need to
know. Retrieved from https://www.rcpsych.ac.uk/docs/default-source/improving-
care/better-mh-policy/position-statements/ps04_20.pdf?sfvrsn=6c927307_2
Horstead, S. (2021). Regulation 28: Report to Prevent Future Deaths. Retrieved from Cambridge:
https://www.judiciary.uk/wp-content/uploads/2021/03/Averil-Hart-2021-0058-
Redacted.pdf
House of Commons Public Administration and Constitutional Affairs Committee. (2019). Ignoring the
Alarms follow-up: Too many avoidable deaths from eating disorders. Retrieved from London:
https://publications.parliament.uk/pa/cm201719/cmselect/cmpubadm/855/855.pdf
National Collaborating Centre for Mental Health. (2019). Adult Eating Disorders: Community,
Inpatient and Intensive Day Patient Care Guidance for commissioners and providers.
Retrieved from London: https://www.england.nhs.uk/wp-content/uploads/2019/08/aed-
guidance.pdf
NHS Digital. (2021, 2021). Hospital admissions with a primary or secondary diagnosis of eating
disorders. Retrieved from https://digital.nhs.uk/data-and-information/supplementary-
information/2021/hospital-admissions-with-a-primary-or-secondary-diagnosis-of-eating-
disorders-2019-20-to-2020-21
A16
NHS England. (2013). NHS Standard Contract for Specialised Eating Disorders (adults). Retrieved
from https://www.england.nhs.uk/commissioning/wp-
content/uploads/sites/12/2014/12/c01-spec-eat-dis-1214.pdf
NICE. (2006). Nutrition support for adults: oral nutrition support, enteral tube feeding and
parenteral nutrition. In.
NICE. (2017). NICE Guidance 69. Eating Disorders: Recognition and treatment.
Parliamentary and Health Service Ombudsman. (2017). Ignoring the alarms: How NHS eating
disorder services are failing patients. Retrieved from London:
https://www.ombudsman.org.uk/sites/default/files/page/ACCESSIBILE%20PDF%20-
%20Anorexia%20Report.pdf
A17
Ms J Kearsley, HM Senior Coroner
H M Coroner’s Office – Manchester North
Floor 2&3 Newgate House
Newgate
Rochdale
OL16 1AT
National Medical Director and Interim
Chief Executive, NHS Improvement
Skipton House
80 London Road
London
SE1 6LH
18 February 2022
Dear Ms Kearsley,
Re: Regulation 28 Report to Prevent Future Deaths – Nichola Jane Lomax who
died on 3 August 2020
Thank you for your Report to Prevent Future Deaths (hereafter “Report”) dated 4
December 2021 concerning the death of Nichola Jane Lomax on 3 August 2020. I
would like to express my deep condolences to Nichola’s family.
I note the inquest concluded Nichola‘s death was a result of the physical
complications of the mental disorder anorexia nervosa, contributed to by neglect.
Following the inquest, you raised concerns in your Report regarding:
•
Inadequate training of doctors and other medical professionals re eating
disorders;
• Accessing specialist advice;
• Community monitoring of patients with an eating disorder; and
• Lack of recognition of the need to investigate.
I understand that colleagues in other organisations will also be responding to this.
My response will therefore focus on what we are doing to improve adult eating
disorder services in the NHS, both nationally and within the North West region.
Within NHS England and Improvement (NHSEI), we recognise that more needs to
be done to support those with severe mental health problems, including eating
disorders. The NHS Long Term Plan sets out an ambition to give adults and older
adults with severe mental illness, including adult eating disorders, greater choice and
control over their care and support them to live well in their communities. This
programme also requires that, by 2023/24, all ICSs establish or expand dedicated
community-based adult eating disorder services in line with published NHSEI
guidance on improving community-based care for adults & older adults with eating
NHS England and NHS Improvement
A18
disorders.1 By 2023/24 just under £1 billion of additional funding per year will be
invested in community mental health services, including eating disorders.
Since April 2021 all ICSs have received funding to transform their adult community
mental health services, including eating disorders. In 2021/22, 33 ICSs are
transforming adult eating disorder services, with the remainder due to begin
transformation of services in 2022/23. We are supporting this work with a significant
training programme to upskill staff, as well as further activity to support key aspects
of transformation such as imbedding early intervention models and improving
connections with Primary Care.
Alongside community mental health transformation, there is also a cross-
Government programme of activity to address wider issues with eating disorders, in
response to recommendations for action made by the Parliamentary and Health
Service Ombudsman’s 2017 report “Ignoring the Alarms: How NHS eating disorder
services are failing patients” and follow up 2019 report. As part of this work, NHSEI
are currently developing the specification for a national all-ages clinical audit of
eating disorder services, which will review the quality of care against NICE standards
and seek to drive improvement of the identification and appropriate management of
Eating Disorders and the quality and consistency of services.
I will now respond to each of your concerns in turn:
1. Inadequate training of doctors and other medical professionals re eating
disorders
As part of community mental health transformation, NHSEI are working in
partnership with Health Education England (HEE) on a number of different training
courses for staff supporting individuals with eating disorders. These include “Whole
Team Training for Eating Disorders” and “Eating disorder training for medical
students, trainees and doctors” (commissioned with the VCS organisation Beat),
which both promote use of MARSIPAN guidelines. HEE are also commissioning
Beat to produce targeted eating disorder training for staff working in acute settings in
2022, which will include reference to MARSIPAN guidelines.
The Royal College of Psychiatrists is currently finalising “Guidance on Recognising
and Managing Medical Emergencies in Eating Disorders” (replacing MARSIPAN and
Junior MARSIPAN). We are in discussion with the College about how best to
promote and embed this new guidance across all relevant clinical settings (including
potential dissemination by liaison psychiatrists who work in general acute settings),
and will also ensure training and guidance is updated to promote it. This guidance
will be supported by all the Royal Colleges so it will be clear this product is relevant
to staff outside of psychiatry.
This concern also reflects a wider challenge with the levels of training that doctors
and other medical professionals receive on mental health. We believe this is
imperative to support parity of esteem and improve patient care, particularly for
1 Adult Eating Disorders: Community, Inpatient and Intensive Day Patient Care: Guidance for
commissioners and providers (england.nhs.uk)
A19
eating disorders. This is not within our gift to deliver but we stand ready to support
HEE, the General Medical Council and partners in their efforts to achieve this
objective. I would recommend that this report is extended to the Medical Schools
Council; who are able to influence the curriculums and training standards for doctors
and medical professionals, in order to support this work.
Additional North West actions underway
Through the development of a Lead Provider Collaborative model for specialist
Eating Disorder services, Cheshire & Wirral Partnership NHS Foundation Trust as
lead provider for Specialised Eating Disorder services in the North West, are
developing approaches to strengthen system leadership in the field of Eating
Disorders. As part of this work, they have a number of priorities including the
promulgation across the region of good practice in ED care; improving the clinical
pathway for patients with Eating Disorders; the development of consistent protocols
for the management of physical health risks of eating disorders in the community;
and identification of workforce gaps in community services. Both the promulgation
of best practice and the development of consistent protocols will have a positive
impact on education and practice around Eating Disorder clinical management.
2. Accessing Specialist Advice
In 2019 NHS England and Improvement issued “Adult Eating Disorders: Community,
Inpatient and Intensive Day Patient Care” national guidance for commissioners and
providers. This highlights that one of the key functions of care for a comprehensive
eating disorder service is to “offer advice, support and consultation to other services
involved in a person’s care”.2 Providers and commissioners are encouraged
to develop pathways and protocols in line with this advice.
The introduction of mental health practitioners in Primary Care Networks (PCNs)
should also enable easier access to specialist services. These staff are based in
primary care but employed by mental health trusts, to support an integrated care
pathway for people with severe mental illness, including eating disorders.
Additional North West actions underway
NHS bodies in Greater Manchester are committed to developing a model of
community Eating Disorder services which fits that described in NHS England’s 2019
guidance. This model, once in place, will be able to be perform the role of primary
source of information and advice for all healthcare services that come into contact
with patients with an Eating Disorder.
In addition, NHS England will work with the Specialised Eating Disorder services in
the North West (CWP and The Priory) to clarify the expectation outlined in section
2.5 of the national service specification for Specialised Eating Disorder services
around the scope of advice and guidance to acute medical and to psychiatric wards
that this should include.
2 Adult Eating Disorders: Community, Inpatient and Intensive Day Patient Care: Guidance for
commissioners and providers (england.nhs.uk) (p.8)
A20
3. Community Monitoring of patients with an Eating Disorder
NHSEI’s national guidance sets out a clear expectation that community eating
disorder services develop integrated pathways with primary care and where
responsibility for medical monitoring sits. The guidance is clear that that “Medical
monitoring needs to be based on local medical monitoring agreements clearly
established across the community eating disorder service and primary care network,
with one consistent protocol agreed on by local commissioners. The protocol should
be developed in collaboration with primary care services and clearly outline the
responsibilities for each service (Table 2). A shared care pathway for medical
monitoring should be produced.”
The guidance further sets out “When responsibility for medical monitoring is
assumed by primary care, the limitations of this need to be recognised and mitigated.
The CED service should be accessible to provide specialist consultation to primary
care to ensure results are interpreted correctly, regardless of whether a person is
currently engaging with the CED service. To ensure that the CED service has
capacity to reliably provide this, opportunities for upskilling other staff members
(such as nurses) should be explored. A CED service that is accessible for
consultation will facilitate GPs’ safe acceptance of discharges from the CED service
and reduce demand on the CED service’s resources”
We are committed to ensuring a more integrated service across primary and
secondary care for people with severe mental illnesses, including eating disorders.
In order to receive system development funds for the expansion of adult community
eating disorder services, when developing funding bids systems were required to
“be clear on the arrangements for medical monitoring in partnership with primary
care to manage the physical health needs of people with eating disorders” and 21/22
Mental Health Delivery Plan highlighted that systems should “ensure AED pathways
have medical monitoring protocols in place with primary care”.
Working with HEE, we have also commissioned eating disorder charity Beat to
develop training to support staff in Primary Care which will include specific training
on medical monitoring. NHSEI are currently exploring what additional resources
could be developed to better support and engage Primary Care.
I noted earlier in this response work to introduce Mental Health Practitioners in
Primary Care. Although these practitioners will not directly undertake the medical
monitoring themselves, they will be able to liaise with the staff who will undertake it
and help to ensure adequate oversight of the care of patients with severe mental
illnesses, including eating disorders, across primary and secondary care.
A21
Additional North West actions underway
NHS bodies in Greater Manchester are committed to developing a model of
community Eating Disorder services which fits that described in NHS England’s 2019
guidance. This model, once in place, will be in a position to undertake the medical
monitoring of high risk and non-adherent patients whilst also offering specialist
consultation to primary care for low-moderate risk patients and those discharged
from the community Eating Disorder services.
4. Lack of Recognition of the need to Investigate
The National Medical Examiner is also concerned about deaths of people with eating
disorders. In late 2021, the National Medical Examiner’s team proposed a round
table discussion with subject matter experts and stakeholders, including
representatives from the Chief Coroner’s office, with a view to publishing guidance
for medical examiners through the National Medical Examiner’s series of Good
Practice papers. The round table discussion to inform this paper is due to take place
in February 2022, with publication expected later in 2022.
The medical examiner system has been implemented at acute trusts on a non-
statutory basis. Most trusts established medical examiner offices during 2020, after
DHSC confirmed funding details in late December 2019. In the year to September
2021 (the most recent figures available) NHS trusts reported that medical examiners
provided independent scrutiny of more than 185,000 deaths in England. The
National Medical Examiner asked the regional medical examiner for the North West
to confirm what involvement, if any, medical examiners had after the death of
Nichola Jane Lomax. The lead medical examiner at Northern Care Alliance
Foundation Trust confirmed that the medical examiner office was established after
August 2020, and therefore, medical examiners were not involved in reviewing the
circumstances of Ms Lomax’s death.
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
A22
Academy of Medical
Royal Colleges
10 Dallington Street
London, EC1V 0DB
Academy of Medical Royal Colleges
Regulation 28
A23
•
•
Academy of Medical Royal Colleges
Regulation 28
A24
A25 A26 A27 A28 Ms J Kearsley
Senior Coroner
Newgate House
Newgate
Rochdale
Friday 12th August 2022
Dear Ms Kearsley
Popham Centre
Fairfield District General Hospital
Bury
I write on behalf of the Northern Care Alliance NHS Foundation Trust to update you on developments in
respect of action taken to improve services following the tragic death of Nichola Lomax and the inquest into
her death heard in November 2021.
During the inquest into Ms Lomax’s death, lesson learning evidence was provided to the Court by
, detailing the steps taken since the incident and lessons learned by the Trust to effect change and
improve services offered to patients presenting with an eating disorder. A full action plan was put in place in
response to the Trust’s investigation. It was identified during the Trust’s investigation that prior to Ms Lomax’s
death, dissemination, and awareness of the Management of Really Sick Patients with Anorexia (“MARSIPAN”)
guidelines in place at the time was sporadic across the NCA’s care organisations. The Trust undertook
immediate steps whilst the investigation was ongoing to raise awareness of the guidelines.
A further update on the Trust’s continued action to improve services and addressing your specific areas of
concern raised in the Regulation 28 report issued following in the inquest was provided on 11 February 2022.
Since this time, updated guidance around the recognition and management for Medical Emergencies in Eating
Disorders (“MEED”) was released by the Royal College of Psychiatrists in May 2022. This replaces the
previous MARSIPAN guidance that was in place at the time of Ms Lomax’s death.
The Trust is now taking steps to update all applicable guidance documents and policies to reflect the current
MEED guidance. An NCA-wide steering group is in development to agree a NCA level MEED Quick Reference
Guide. This will be monitored and progressed through system partners who will discuss and confirm
governance arrangements under the Integrated Care System.
It was described in the Trust’s regulation 28 response that engagement was being sought for a training video
and formulating a plan for its development. I would like to advise you that this action has been superseded as
a result of the updated MEED guidance. In response to MEED, a national app has been developed which
includes a full suite of guidance and information with videos and support. The Trust is now working to roll the
app out and raise awareness of this across all Care Organisations alongside updating associated policies and
guidance. The first Steering Group is scheduled for early September. We will of course keep you appraised
of organisational developments in due course.
Please do not hesitate to contact me if you have any questions or require any further information.
Yours sincerely,
Associate Director of Patient Safety
A29
A30 A31 A32 A34 A35 A36 Joanne Kearsley
Senior Coroner for the Coroner area
of Manchester North
Directorate of Education & Quality
2nd Floor, Stewart House
32 Russell Square
London WC1B 5DN
Business Coordinator:
Email:
14th February 2022
Dear Joanne Kearsley,
RE: Nichola Jane Lomax – Regulation 28 Report
I write in response to your report of 17 December 2021 made under the Coroners
(Investigations) Regulations 2013. Please may I start by offering my sincere
condolences to Nichola Lomax’s family following her death.
Your report raises concerns regarding the care that Nichola Lomax received, together
with the training of doctors and other medical professionals in relation to mental health
conditions and eating disorders. Your report also highlighted concerns around the
knowledge and awareness of health professionals; specifically highlighting what
appeared to be a lack of knowledge of the Management of Really Sick Patients with
Anorexia Nervosa guidance (MARSIPAN). We note that Health Education England
(HEE) has been identified as having a duty to respond and the report has also been
sent to a number of bodies including: The Secretary of State for Health and Social
Care; the Chair of the Faculty of Eating Disorders Royal College of Psychiatrists; the
Chief Executive Officer of NHS England; The Chief Executive of the Academy of
Medical Royal Colleges; together with local health agencies and providers who were
involved in the care of Nichola Lomax prior to her death.
To respond to your concerns, I will first clarify HEE’s role and in the education and
training of the medical, nursing and health workforce. HEE is a non-departmental
public body accountable to the Secretary of State and Parliament. We are part of the
NHS and work with partners to plan, recruit, educate and train the health workforce.
Though HEE serves the people of England by educating, training and developing
healthcare professionals, we do not have responsibility for the design and delivery of
undergraduate medical education. Each individual medical school sets its own
undergraduate medical curriculum. Additionally in relation to postgraduate medical
A37
education, the various curricula for postgraduate specialty training are set by individual
Medical Royal Colleges against standards set by the General Medical Council.
Whilst the curriculum for medical education does not mandate how Foundation doctors
learn about specific conditions, as different learners and educators will have preferred
styles within their own setting. The 2021 Foundation Programme curriculum includes
an explicit statement around parity between physical and mental health. Foundation
doctors are now expected to learn about mental health issues much more than in the
past. In addition, the MARSIPAN guidelines have been presented to Foundation
School Directors and there has been other discussion on learning and eating disorders
within the Foundation Programme.
As part of reviewing this case, we have shared your report with colleagues here within
HEE, including our Dean with lead responsibility for Mental Health. Together with our
Mental Health Programme, the UK Foundation Programme Office and our Deputy
Chief Nurse. We believe that your report provides important learning and both the
circumstances and concerns in your report are vitally important in demonstrating the
need to increase awareness and understanding of the training and clinical guidance
already available to practitioners.
I should also highlight some of the work that HEE has been involved in, either to
support better awareness or strengthen professional practice through continuing
professional development. This includes a new teaching package on eating disorders
for foundation programmes that has been developed by the charity Beat Eating
Disorder, in collaboration with Health Education England and the Royal College of
Psychiatrists, and with the support of the General Medical Council. This training was
created in response to the Parliamentary Health Service Ombudsman investigation
into avoidable deaths from eating disorders and has been written by experienced
clinical trainers and developed with input from senior clinicians, medical students,
people with lived experience, and advisors from the General Medical Council and
Health Education England. Further information on this training can be found here:
https://www.e-lfh.org.uk/programmes/eating-disorders-training-for-medical-students-
and-foundation-doctors/
Beating Eating Disorder has previously endorsed MARSIPAN and though HEE is not a
member of the MARSIPAN working group, we have circulated information on their
work and guidance. We understand that they are working towards issuing revised
guidance in 2022 and we will then seek to ensure this is disseminated to relevant
teams and colleagues here at HEE.
HEE is also working with NHSE/I and a range of stakeholders to continually enhance
and develop the education and development offer in respect of eating disorders. We
have a suite of training available for specialist eating disorders teams including
Maudsley Model of Anorexia Nervosa Treatment for Adults (MANTRA), Cognitive
Behavioural Therapy for eating disorders (CBT-ed), and Whole Team Training for
eating disorders. We are currently launching on-line training for nursing staff and HEE
has recently commissioned training for GPs and primary care staff. HEE’s plans for
2022/23 also involve enhancing and expanding this suite of training across the breadth
of the NHS workforce.
A38
HEE is commissioning training to develop the skills and knowledge of professionals
who have contact with young people with an eating disorder; this is in direct response
to feedback from services around their identified training needs. This includes
additional training in Avoidant Restrictive Food Intake Disorder, training to support
parents, carers and families, and awareness training for staff who require the skills to
identify early signs and symptoms of an eating disorder. Work is underway to develop
an online resources hub, covering both the physical and mental health implications of
an eating disorder.
I hope this response provides assurance that steps are being taken to make sure that
there is shared learning from the death of Nichola Lomax. We recognise the
importance of improving the awareness of learning and resources available to clinical
practitioners involved in caring for people with mental health conditions. We also know
that recovery may for many people be a life-long journey and so we recognise the
importance of making sure our staff have the right learning and skills to give the right
support at all stages of the patient journey.
Finally, on behalf of HEE, I thank you for bringing these matters to our attention.
Yours faithfully,
Executive Director of Education and Quality & National Medical Director
A39
Headquarters:
Townside Primary Care Centre
1 Knowsley Place
Knowsley Street
Bury
BL9 0SN
3 February 2022
HM Senior Coroner
Rochdale Coroner’s Court
Newgate House
Newgate
Rochdale
OL16 1AT
Dear Ms Kearsley
I write on behalf of Bury CCG in response to your Regulation 28 report received on 23 December
2021, issued following the inquest into the death of Nichola Lomax.
I will address the CCG’s
response to each of your concerns individually below.
1.
Referral Criteria for the Priory and Community Eating Disorder Service
It is acknowledged that at the time of Nichola’s involvement with the service, the community eating
disorder service (CEDS) commissioned by the CCG and provided by Greater Manchester Mental
Health NHS FT (GMMH) had an acceptance criteria of a BMI of 14 or more, and that this meant that
she was unable to access the service. The service for Bury patients was significantly under
commissioned in relation to the level of presenting demand and was not commissioned to provide
medical input to support monitoring of patients with more complex needs.
A business case to expand the service in line with national standards and Greater Manchester and
local priorities has been agreed between the CCG and GMMH, and was formally approved by the
CCG board on 22 December 2021. I understand that the court was provided with a copy of this
business case by GMMH during the course of the inquest; a further copy can be provided if needed.
The new model as agreed includes the addition of psychiatry/ medical input to the service (a
Consultant Psychiatrist and a Physical Health Practitioner) which will allow patients with a BMI of
less than 14 to be accepted by the service and monitored medically by a clinician who has experience
and knowledge of eating disorders. In addition it will include:
Increase in provision to meet the demand of 53 referrals per annum for Assessment.
Increased psychological therapist and dietitian capacity to meet the demand for the service.
This will enable the service to be responsive and achieve the same waiting times for
treatment as for Children and Young People. It will also allow the service to continue to offer
high quality NICE compliant/evidence-based interventions.
NHS Bury Clinical Commissioning Group
Our vision is to continually improve Bury’s Health and Wellbeing by listening to you and working together across boundaries
A40
The increased capacity of psychological therapist and dietitian time will allow for the service
to have capacity to meet the treatment length of interventions for anorexia nervosa.
A range of NICE compliant/evidence-based interventions delivered in both group and
individual formats. This will enable service user choice.
Psychiatry/medical input to enable robust medical monitoring and management and support
for staff in other setting managing individuals with the physical risks of an eating disorder. As
part of the new psychiatry/medical pathway, the service will also be able to offer phlebotomy
and ECGs within the service to enable ease of access and more rapid results and therefore
a safer pathway.
Psychiatry time to enhance the service offered to referrals accepted by the service with
increased physical/mental health complexity.
A FREED pathway to enable a responsive service and treatments tailored to the needs to
emerging adults with eating disorder to be delivered.
A SEED pathway to enable a pathway for those individuals who meet criteria for a severe
and enduring eating disorder.
The service will continue to attend Care Programme Approach (CPA) of individuals referred
to the intensive parts of the EDS pathway to contribute to care planning and discharge
planning and a smooth transition back to GMMH EDS.
The service will continue to offer regular coproduced and cofacilitated eating disorder training
accessibility to staff, services users and carers in all boroughs via GMMH Recovery Academy
and other bespoke training as required.
The service will continue to offer carer psychoeducation, skills training, support, and a regular
carers support group cofacilitated by staff and carers with expertise by experience.
The inclusion of Psychiatry time will also enhance the service offer to manage referrals of increased
complexity including those with other physical health comorbidities e.g. Type 1 diabetes and mental
health comorbidities e.g. individuals with significant depression and those with significant personality
disorder traits/diagnoses, both of which have increased in referrals received by the service. The
inclusion of psychiatry time would allow the service to support staff in other health settings including
acute physical and mental health hospitals and the service is planning to develop MARSIPAN
(Management of Really Sick Patients with Anorexia Nervosa, 2014) groups across the footprint of
the services, alongside the psychiatry colleagues providing inpatient eating disorder care at The
Priory, Cheadle.
GMMH have been notified of the CCG commitment to invest and are working locally with recruitment
across Greater Manchester to the roles requires to support the expansion of the service. GMMH
are best placed to advise as to timescales for implementation of the business plan but the information
we have currently is that the post for a consultant psychiatrist has been out to advert twice last year
and there have been no applicants due to a national and local shortage. Various methods are being
tried to identify a suitable applicant, including considering GPSI. I understand that work is underway
nationally to look at training and a pathway for non-psychiatry staff in these roles, led by Health
Education England and the Royal College of Psychiatry.
The referral criteria for the Priory is best addressed by other organisations but we understand from
recent GM meetings that BMI should not be used as a threshold for determining admission as a
matter of policy and it is not now relevant in referrals to the CEDS or from there to the Priory.
2.
Lack of Critical Services
The mental health provision at Fairfield General Hospital in 2020 at the time of Nichola’s attendances
did not meet the current CORE 24 standard. At the board meeting on 22 December 2021 the CCG
approved the funding to commission a CORE 24 light service as a step towards meeting the
standards of a full CORE 24 model. This is a jointly commissioned service between Bury and
Heywood, Middleton and Rochdale CCG (HMR CCG).
A business case for a full CORE 24 service was developed in conjunction with Pennine Care NHS
Foundation Trust by a Task and Finish Group which had been set up to review the performance of
the current service. The CORE 24 service will:
A41
Provide an all age 24/7 service to the A&E and all acute wards in Bury and HMR;
Access to a medical staff for diagnostic assessment and treatment;
Provide a self-harm follow up clinic within 72 hours.
In December 2020 the Bury Strategic Commissioning Board agreed to commissioned a pilot of an
Urgent Emergency Care by Appointment service (UEC) which provides urgent appointments for
people with mental health needs who would have otherwise accessed urgent care services at the
ED, contacted NHS 111 or been directed to an ED by their GP. The service aims to provide an
urgent mental health assessment within 24-72 hours to determine the person’s mental health needs
thereafter. The UEC service continues to achieve excellent outcomes in diverting activity away from
front end A&E and provides bookable appointments for people presenting with urgent mental health
needs.
Given the commitments made by Bury and HMR for the UEC by appointment service PCFT have
produced a subsequent proposal for the commissioning and provision of a Core 24 “light” service
across Fairfield General Site and Bury and Rochdale UCC. This request to the CCG is for a scaled
down version of a Core 24 model encompassing the all-age element of a Mental Health Liaison
service however recognises the ambition to achieve Core 24 standards as per NICE guidelines over
time and taking a phased approach to investment. Greater Manchester Health & Social Care
Partnership (GMHSCP) soon to become the GM Integrated Commissioning System (ICS) are
supportive of the development of the Core 24 Light service offer and have already committed FGH’s
share of the GM transformation monies to allow PCFT to begin mobilising the service.
The key outcomes of a Mental Health Liaison CORE 24 light service include:
Increased medical time
Provision of an all-age service
Provision of all-age assessment to the acute wards
Provides the street triage service
Reduces the waiting times for patients on medical wards
Continuity of care for patients attending A&E or admitted to an acute ward.
The new service will provide:
1 WTE liaison consultant psychiatrist
1 WTE medical secretary
1 WTE admin staff
2 band 6 mental health practitioners
Upskilling and re-banding of 3 band 5 nurses to band 6 roles
3 Band 2 support workers
Recruitment for these posts has started, although limitations of workforce availability are a concern.
There will still be some gaps remaining until the service moves to a fully compliant Mental Health
Liaison Core 24 model in that there is no clinical lead within this model and the service would not
meet many of the Psychiatric Liaison Accreditation Network (PLAN) standards which are best
practice standards for liaison psychiatry services.
Additional services are also in place to support the mental health crisis offer and mitigate the potential
risks of the gaps remaining, including the UEC appointment service described above. On 3rd April
2020, Claire Murdoch (National Mental Health Director - NHS England and NHS Improvement) wrote
to Mental Health Trust CEOs confirming that all mental health Trusts across the country, working
alongside CCGs and ICS, to urgently take the following actions:
Establish 24/7 open access telephone lines for urgent NHS mental health support, advice
and triage, and through which people of all ages can access the NHS urgent mental health
pathway/further support if needed.
Ensure that the 24/7 open access crisis line telephone number(s) and contact details
are available to the public, clearly on the website.
A42
To meet these requirements, both the GM Mental Health Trusts have developed 24/7 open access
for known and unknown service users. This meets key criteria in the GM responding to Mental Health
crisis model.
Bury Peer Led Crisis service is also in place for people experiencing a mental health crisis and are
at risk of suicide, it was launched in April 2021 as a 12-month pilot and approval is currently being
sought to extend the term of the service based on the outcomes achieved. It is provided by a local
organisation BIG in Mental Health and provides peer led support in a non-clinical environment to
adults experiencing a mental health crisis including those who are at risk of suicide. The service has
developed robust pathways with the PCFT Mental Health Liaison service and is an integral part of
the Bury Mental Health Crisis Pathway.
In summary, it is acknowledged that the proposed new CORE 24 light service is still a little short of
the full CORE 24 light, but it is a significant step towards providing a full service. It is a pragmatic
and deliverable step forward in response to the lack of staffing and available investment to deliver a
full core 24 service now in one cycle of investment. A full CORE 24 service will require further
investment and workforce development and we understand that a GM business case has been
submitted to NHS England to secure the necessary funding to convert the light service into the full
service. In conjunction with the other initiatives described above, the mental health service offering
is vastly improved.
3.
Community Monitoring of patients with an Eating Disorder
Future plans for this are addressed in detail above; the medical monitoring of patients with an eating
disorder will be included within the service offered by the community eating disorder service.
It is hoped that this response provides assurance to the court that the CCG is taking the gaps in
commissioning of mental health services identified very seriously and that action has already been
taken for improvement. Unfortunately, wide scale changes to the service provision cannot be
achieved immediately but it is a priority for the CCG and we are working closely with our partners to
ensure that the actions which we have committed to are progressed as quickly as possible.
Yours sincerely
Accountable Officer for Bury CCG
A43
Greater Manchester Health and Social Care Partnership
4th Floor
3 Piccadilly Place
London Road
Manchester M1 3BN
Date: 11 February 2022
Ms J Kearsley
HM Senior Coroner
HM Coroners Court,
Floors 2 and 3,
Newgate House,
Newgate,
Rochdale,
OL16 1AT
Dear Ms Kearsley
Re: Regulation 28 Report to Prevent Future Deaths – Nichola Jane Lomax
03/08/20
Thank you for your Regulation 28 Report dated 17/12/21 concerning the sad death
of Nichola Jane Lomax on 03/08/20. On behalf of Greater Manchester Health &
Social Care Partnership or GMHSCP (which pending legislation will develop into the
GM Integrated Care Board (ICB) from the current shadow structures in July 2022), I
would like to begin by offering our sincere condolences to Ms Lomax’s family for their
loss.
Thank you for highlighting your concerns during Ms Lomax’s Inquest which
concluded on 10th December 2021. On behalf of the Partnership, I apologise that
you have had to bring these matters of concern to our attention but it is also very
important to ensure we make the necessary improvements to the quality and safety
of future services.
The inquest concluded that Nichola’s death was a result of 1a) Liver Failure 1b)
Anorexia Nervosa 2. Refeeding syndrome and cholecystitis.
A44
Following the inquest, you raised concerns in your Regulation 28 Report to Greater
Manchester Health and Social Care Partnership (GMHSCP) that there is a risk future
deaths will occur unless action is taken.
I hope the response below demonstrates to you and Ms Lomax’s family that
GMHSCP have taken the concerns you have raised seriously and will learn from this
as a whole system.
It is important to note that as part of the GMHSCP role of facilitating GM-wide mental
health transformation programmes (and associated investment) and providing
strategic support to locality commissioners and providers on development of
specialist and community mental health services - we convened all the key
stakeholders referenced in your report to discuss lessons to be learned in a
collaborative way and as a system wide quality panel. This was chaired by the
GMHSCP Executive Medical Lead for Mental Health and a review panel will be
convened in 3 months. This will help ensure going forward a coordinated set of
actions in response to this Regulation 28 Notice Report. We hope that the
subsequent agency responses that you receive positively address all the key areas
of concern at an individual and wider collective system level.
Please now see the Partnership’s response in relation to the specific concerns you
have raised for us, the actions agreed to be taken and how we can share the
learning from this case.
Referral criteria for The Priory and Community Eating Disorder Service (No. 3).
At a meeting convened by the GMHSCP on 28 January 2022, it was set out that
Greater Manchester Mental Health NHS FT (GMMH) is working with the Northern
Care Alliance (NCA) and the Priory to look at changing the previous eating disorder
pathways and resolve any practical inconsistencies in criteria for admission. GMMH
confirmed that BMI is no longer being used as a criterion for admission to their
service at the Priory. Access will be based on specialist clinical assessment of the
person’s level of need, and so will give full attention to physical and mental health
red flag signs and aligned to the national MARSIPAN framework.
While currently each locality CCG holds an individual contract with GMMH for the
Adult Eating Disorder (AED) service they currently commission, in July 2022, these
contracts will novate to the GM ICB and over the remainder of the 2022/23 financial
year, will be brought into a single contract with each provider delivering specialist
eating disorder services. This will enable a positive opportunity to resolve any further
unwarranted variation in referral criteria and commissioned care pathways across
GM.
In advance of this, GMHSCP MH Programme Team are working with partners to
ensure the Children and Young Person’s Eating Disorders working group that is
already in place is broadened to become an all-age group. This will address wider
transition issues between Children’s and Adult Eating Disorder services - an area of
particular concern for this patient group. Actions to ensure connectivity of evidence-
based pathways that apply consistent referral criteria will be a key part of the work of
this group. It will involve clinicians, commissioners, service providers and service
users. This is something that has already been encouraged over the past year in the
A45
development and expansion of the GMMH Adult Eating Disorders service, as further
locality and GMHSCP investments have been agreed.
All this work will ensure dedicated space and attention in Greater Manchester to
work through the issues highlighted in the Regulation 28 Report and share learning
between all stakeholders. This will also include formal oversight and assurance
through to the refreshed Quality Board function within GMHSCP and the GM ICB
from July 2022.
Lack of critical services (No. 4).
GMHSCP acknowledges that the mental health provision at Fairfield General
Hospital (FGH) in 2020 at the time Nichola was attending did not meet the national
Acute Hospital Liaison Mental Health Core 24 standard. However, since this time the
investment is now in place as agreed with both Bury and Heywood, Middleton, and
Rochdale CCGs and GMHSCP. This will provide a Liaison Mental Health Core 24-
Lite service at Fairfield Hospital. This is a firm step towards core 24 compliance and
will enable an all-age offer, with increased joint working between alcohol, adult
mental health and older people’s services. As a result, Pennine Care Foundation
Trust (PCFT) working with the Northern Care Alliance have now initiated the work to
recruit to and mobilise this service. However, the ambition is to move to a fully
compliant Liaison Mental Health core 24 service offer at FGH.
GMHSCP have submitted a formal proposal to NHS England to release just over £1
million (as the fair share allocation of national service transformation funding) to
support strengthening the GM MH Crisis and Liaison services. This will provide
additional investment to enable a Core 24 service offer at FGH and
Tameside/Wrightington, Wigan and Leigh Hospitals. This will mean that further
medical cover, clinical leadership will be in place, with further capacity to reach the
PLAN accreditation standards. This work will support 100% GM-wide Core 24 cover
across all the Acute Hospitals in the coming 2 year. This will exceed the national
ambition through the NHS Long Term Plan for 70% cover across GM.
GMHSCP also acknowledges that the commissioned adult eating disorders service
in Bury (like many areas of the country) was insufficient to meet local need. Since
then, funding has now also been confirmed between Bury CCG and GMHSCP to
implement the GMMH Adult Eating Disorders Business Case.
This will ensure across Greater Manchester commissioners and providers meet the
NHS Long Term Plan goals for comprehensive community adult eating disorder
services delivering enhanced service offers in line with current best practice clinical
guidelines, including:
• The service accepting individuals with differing severities of eating disorders and
offering a stepped care model in line with National Collaborative Centre for MH
Guidelines (2019).
• Timely, effective, evidence-based treatments, care and support that meet the
needs of individuals with the full range and severity of eating disorders
• NICE compliant/evidence-based psychological therapy will be offered in
individual and group formats
• Early intervention pathway (First Episode & Rapid Early Intervention for Eating
Disorders or FREED) as an evidence-based, specialist service model for 16- to
A46
25-year-olds with an eating disorder of less than 3 years’ duration – with a central
focus on reducing the duration of an untreated eating disorder through rapid
access to assessment and treatment optimising clinical outcomes
• Specific pathway for severe and enduring presentations with a focus on
improving quality of life and reducing hospital admissions for individuals who
meet a severe and enduring eating disorder (SEED) diagnosis
• Medical monitoring and management and support to staff working in medical
settings.
• Specialist dietetic assessment and intervention
• Family therapy to ensure transitions from CYP Eating Disorder Services are
optimal.
• Support and empower families, partners, carers and the person’s support
network
• Offer advice, support and consultation to other services involved in a person’s
care
• Coordinated care and work with other services to reduce and prevent gaps in
care during service transitions
• Clear processes around managing risk and safety as well as unattended
appointments.
• Appropriate clinical supervision to ensure professionals remain competent to
•
deliver evidence-based treatment
Improved awareness of the service in the community, the importance of early
identification and reduce the stigma to increase help-seeking in the local
population
• Collaboratively use routine outcome measurement to support a person to identify
and meet their goals for recovery
• Actively seek out feedback from the people and their families who are
experiencing the service
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