Prevention of Future Deaths reports · 2023

Jacqueline Campbell

Regulation 28 report to prevent future deaths, reference 2023-0070, written 22 Feb 2023. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report22 Feb 2023
Reference2023-0070
DeceasedJacqueline Campbell
CoronerSean Cummings
Coroner areaMilton Keynes
CategoryAlcohol, drug and medication related deaths
Sourcejudiciary.uk record · original PDF
Responses published2

The report

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

Regulation 28: REPORT TO PREVENT FUTURE DEATHS 

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

REGULATION 28 REPORT TO PREVENT DEATHS 

THIS REPORT IS BEING SENT TO: 

1  Hilltops Medical Centre, Kensington Drive, Great Holm, Milton Keynes 

2 

3 

Community Services 

 - NHS England National Director for Primary Care and 

Keynes Integrated Care Board 

 - Chief Medical Director, Bedfordshire, Luton and Milton 

1  CORONER 

I am Sean CUMMINGS, Assistant Coroner for the coroner area of Milton Keynes 

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 04 July 2022 I commenced an investigation into the death of Jacqueline Sharman 
CAMPBELL aged 56.  The investigation concluded at the end of the inquest on 08 February 
2023.  The conclusion of the inquest was that: 

Ms Jacqueline Sharman Campbell died on the 30th June 2022 at her home address. She 
had battled chronic backpain for more than 20 years. It was difficult to manage. She was 
prescribed large doses of gabapentin, tramadol and amitriptyline. She was also prescribed 
fentanyl patches and oral diazepam. She likely inadvertently overdosed on tramadol and 
that, in combination with the other medicines, all possessing the ability to depress the 
central nervous system, had the synergistic effect of causing respiratory depression and 
death. 

4  CIRCUMSTANCES OF THE DEATH 

Ms. Campbell was medically retired. She worked for Transport for London and had an 
accident over 20 years ago where she injured her back. This resulted in continuing chronic 
back pain for which she took prescribed medication. Family report that she was not very 
good at managing this medication. 

During the late evening of Wednesday the 29th  of June 2022 Jace Campbell, the son of 
Jacqueline came home and found his mother collapsed in her ensuite bathroom. Other 
family members have been contacted and came to Jace’s assistance. Paramedics were 
called but they were unable to save Jacqueline and they confirmed her death on the 30th  of 
June 2022. 

5  CORONER’S CONCERNS 

During the course of the investigation my inquiries revealed matters giving rise to concern. 
In my opinion there is a risk that future deaths could occur unless action is taken.  In the 

Regulation 28 – After Inquest 
Document Template Updated 30/07/2021 

 circumstances it is my statutory duty to report to you. 

The MATTERS OF CONCERN are as follows: 
(brief summary of matters of concern) 

, 

, gabapentin 

 and fentanyl 

, amitriptyline 

to be applied every 72 hours. 

Ms Campbell had experienced a work-place related accident approximately 20 years prior to 
her death when she had fallen off a broken chair at work. She suffered with back pain, 
which became chronic, thereafter. She had a number of interventions including referral and 
attendance at pain clinics, manual therapy, CBT and pharmaceuticals. 
During her time with pain no clear cause was identified on MRI and other imaging. She was 
treated for chronic low back pain of indeterminate cause. 
Over the years she was treated with multiple, and escalating doses of, medications. These 
included at the time of her death, diazepam 
tramadol 
patches 
She was found collapsed at home in her bathroom and there was a possibility of a 
positional component to the respiratory depression consequent on the long-lie. The medical 
cause of death was given by the pathologist 
 as 1a Central Respiratory 
Depression 1b Tramadol excess with fentanyl II Long lie following a fall, chronic post 
traumatic back injury. 
The police and paramedics attending the scene describe the finding of “hundreds”  of 
packets of medications, some opened, some unopened. 
This polypharmacy was identified by the pathologist who conducted the post mortem 
(taking from the toxicology report) as “In summary, excess Tramadol (
metabolite (
death. Although lower than levels typically seen in fatalities, the moderate excess in 
conjunction with other prescribed drugs, most notably fentanyl are sufficient to have 
produced central respiratory depression. No other significant post mortem findings were 
noted, and the prolonged lie following a fall may well have contributed a postural 
component to the respiratory depression” 
Her GP, 
management of patients who describe intractable debilitating pain is challenging and 
difficult and that requests for other or increasing doses of medication can be difficult to 
resist. 
to be dangerous. He told me that after a certain point the benefits of increasing or adding 
doses or medications in terms of pain relief were minimal. This scenario seems to be an 
invidious one for GP’s and patients alike. 

 agreed that the prescribing of the various drugs identified had potential 

) are indicative of recent moderately excessive ingestion prior to 

, gave clear and candid evidence. I accept the 

) and a 

 told me that subsequent to Ms Campbell’s death the practice had convened 
and discussed the circumstances and agreed on regular reviews for patients taking these 
sorts of medication. There were no plans identified to actively look for these patients and to 
work to rationalize and / or reduce their medications. 
I am of the view that polypharmacy including gabapentinoids and opiates represents a 
severe safety risk in patients with a iatrogenic drug dependency. I consider that the risk in 
individuals like Ms Campbell of an inadvertent overdose of medications which have a 
cumulative and synergistic effect to depress the central nervous system can easily become 
extreme and lead to death. There have been a number of deaths in the Milton Keynes, 
Bedfordshire and Luton areas related to concomitant use of high dose and combination 
gabapentinoids and opioids. 

6  ACTION SHOULD BE TAKEN 

In my opinion action should be taken to prevent future deaths and I believe you (and/or 
your organisation) have the power to take such action. 

7  YOUR RESPONSE 

You are under a duty to respond to this report within 56 days of the date of this report, 
namely by April 19, 2023.  I, the coroner, may extend the period. 

Your response must contain details of action taken or proposed to be taken, setting out the 

Regulation 28 – After Inquest 
Document Template Updated 30/07/2021 

 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 

I have also sent it to 

who may find it useful or of interest. 

I am also under a duty to send a copy of your response to the Chief Coroner and all 
interested persons who in my opinion should receive it. 

I may also send a copy of your response to any person who I believe may find it useful or 
of interest. 

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: 22/02/2023 

Sean CUMMINGS 
Assistant Coroner for 
Milton Keynes 

Regulation 28 – After Inquest 
Document Template Updated 30/07/2021

Responses

2 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 Hilltops Surgery (PDF)
kkkk

Partners:  

Associates: 

Coroners Office 

Via email 

19th April 2023 

Re: Ms. Jacqueline Campbell 

Thank you for the Section 28 Report dated 22.02.2023. You have requested a response to 
this report from Hilltops Medical Centre outlining the actions we have taken and proposed 
actions with the timeline.  

We have reviewed this case in depth and have taken the following actions.  

1)  Following the unexpected death on 30/06/2022- We discussed this in our weekly Multi-

Disciplinary Meeting on 1/7/2022 to review the care provided.  

2)  In March 2022 we carried out an audit of patients on high dose opioids ( > 120mg oral 

morphine equivalent) and arranged a review of these patients. We repeated this Audit in 
November- December 2022 and are currently in the process of redoing this audit and 
consideration given to dose reduction where appropriate.   

3)  Practice pharmacist and prescribing lead attended the Opiate Prescribing session during 
Protected Learning time and shared in our Multi-Disciplinary Meeting on 25/03/2022. 

4)  We have identified other patients on combination of 

Opiates+Gabapentinoids+Benzodiazepines/Z-drugs who have now been reviewed. 

5)  We are ensuring that these patients are reviewed 3 monthly, with robust recall systems in 
place, preferably face to face and with named clinician to review and rationalise the 
medication.  

6)  We have also identified patients on a combination of opioids and benzodiazepines and are 

arranging reviews for these patients currently.  

7)  We have discussed and agreed that patients on a combination of 

Opiates+gabapentinoids+Benzodiazepines/Z drugs are reviewed 3 monthly and patients on 
high dose Opioids are reviewed 6 monthly. We agreed to use the Arden’s ‘Opioid Initiation 
and Monitoring’ template during the reviews to ensure all areas of review are covered. 
8)  We had a meeting with the Integrated care Board on 9/3/2023 discussing about completing 
a Significant Event Analysis. Discussion about Medicine Management personnel from the 

Kensington Drive, Great Holm, Milton Keynes MK8 9HN 
01908 568446 
www.hilltopsmedicalcentre.org 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
              
 
 
 
 
 
 
              
 
 
 
 
  
 
 
 
 kkkk

Integrated care Board coming into the practice, who visited on the 17/4/2023 to support run 
searches/identify patients.  

9)  We are liaising with the Integrated Care Board to enquire about other services available and 

have been advised they are currently working on this aspect. 

10) The Primary Care Network prescribing lead has presented the case in the regional meeting 
to share with other clinicians and Integrated Care Board Medication safety group, other 
regions in Integrated Care Board and Commissioning Services.   

11) The practice has arranged a meeting for the clinicians to review the NICE guidelines on safe 
prescribing/managing drugs that can cause dependence and withdrawal (NG215), NICE 
guidelines on Assessment and Management of Chronic pain in over 16s ( NG193) and 
General Medical Council- Good Practice in Prescribing and Managing Medicines and Devices.  

Thanking you, 

Yours Sincerely, 

General Practitioner 

Kensington Drive, Great Holm, Milton Keynes MK8 9HN 
01908 568446 
www.hilltopsmedicalcentre.org
Response from NHS England (PDF)
Mr Sean Cummings 
The Coroner’s Office 
Civic Offices 
1 Saxon Gate East 
Central Milton Keynes  
MK9 3EJ 

Dear Mr Cummings, 

National Medical Director  
NHS England  
Wellington House 
133-155 Waterloo Road  
London 
SE1 8UG 

17 April 2023  

Re: Regulation 28 Report to Prevent Future Deaths – Ms Jacqueline Campbell 
who died on 30 June 2022 

Thank  you  for  your  Report  to  Prevent  Future  Deaths  (hereafter  “Report”)  dated  22 
February 2023 concerning the death of Ms Jacqueline Campbell on 30 June 2022. In 
advance of responding to the specific concerns raised in your Report, I would like to 
express my deep condolences to Jacqueline’s family and loved ones. NHS England 
are  keen  to  assure  the  family  and  the  coroner  that  the  concerns  raised  about 
Jacqueline’s care have been listened to and reflected upon. 

NHS  England  is  the  facilitator  of  system  partners  in  their  work  to  deliver  the  2019 
Public  Health  England  (PHE)’s  'Dependence  and  withdrawal  associated  with  some 
prescribed  medicines:  an  evidence  reviews'  (the  review)  recommendations.  These 
system  partners  include  the  Department  of  Health  and  Social  Care  (DHSC),  Arm's 
Length Bodies (ALBs) including the National Institute for Health and care Excellence, 
(NICE),  Care  Quality  Commission  (CQC),  Medicines  and  Healthcare  products 
Regulatory  Agency  (MHRA)  and  Health  Education  England  (HEE)  to  ensure  cross 
system  improvements  can  be  delivered.  NHS  England  is  not  responsible  for  the 
implementation of recommendations assigned to other organisations.  

The National overprescribing review report commissioned by DHSC in 2018 evaluated 
the  extent,  causes  and  consequences  of  overprescribing  and  made  20 
recommendations  to  address  it.  NHS  England  aims  to  make  long  term  sustainable 
reductions to overprescribing and is working on several outputs to help implement the 
review’s  recommendations.    Outputs  include  national  resources  to  help  practices 
improve  the  consistency  of  repeat  prescribing  processes,  supported  by  appropriate 
training;  and  resources  to  enhance  structured  medication  reviews  for  patients  who 
may experience harm from taking multiple medicines. 

The NHS Medicines Safety Improvement Programme (which forms a key part of the 
NHS Patient Safety Strategy) has launched a focussed programme of work to improve 
the care of people with chronic pain and a reduction in the use of prescribed opioids 
by aiming to reduce harm from opioid medicines by reducing high dose prescribing 

                                                                                                                       
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
   
 (>120mg oral Morphine equivalent), for non-cancer pain by 50%, by March 2024. The 
programme  has  been  in  place  since  January  2021.  The  national  programme  is 
supporting Integrated Care Systems to learn from, adapt and adopt effective practice 
using a whole-system improvement approach. 

As of 31 March 2023, 17 Integrated Care Systems will be receiving intensive support 
to develop and implement improvements in care and a further 17 will be participating 
in shared learning events.   

In  March  2023,  NHS  England  published  ‘Optimising  personalised  care  for  adults 
prescribed  medicines  associated  with  dependence  or  withdrawal  symptoms  : 
Framework for action for ICBs and primary care’. The framework includes five actions, 
resources, and case studies to help systems develop plans that can support people 
who are taking medicines associated with dependence and withdrawal symptoms by:  
a.  Optimising personalised care for adults prescribed medicines associated with 

dependence or withdrawal symptoms. 

b.  Informing  ICB  (Integrated  Care  Boards)  improvement  and  delivery  plans, 
when  commissioning  services  and  developing  local  policies  that  offer 
alternatives  to  medicines  in  the  first  place  and/or  support  patients 
experiencing prescribed drugs dependence or withdrawal.   

c.  Ensuring  a  whole  system  approach  and  pathways  involving  multiple 
interventions,  to  improve  care  for  people  prescribed  medicines  associated 
with dependence and withdrawal symptoms. 

Additionally,  the  National  Institute  for  Health  and  Care  Excellence  (NICE)  has 
published guidelines on: 

• 

• 

Chronic pain (primary and secondary) in over 16s: assessment of all chronic 
pain and management of chronic primary pain 
Medicines  associated  with  dependence  or  withdrawal  symptoms:  safe 
prescribing and withdrawal management for adults.  

Commissioning of services to support people with chronic pain (including services to 
support people to safely withdraw from opioid use) now lies with ICBs. NHS England 
expects ICBs to commission appropriate services to meet the needs of the population 
that the ICB geographically covers.  

We have been sighted on the response from Bedfordshire, Luton and Milton Keynes 
Integrated  Care  Board  (BLMK  ICB)  who  advise  that  Hilltops  Surgery  regularly 
undertake  an  opiate  prescribing  audit.  This  is  to  identify  patients  on  high  doses  of 
opioids and flags that a conversation with the patient is needed to look at reducing 
their medication. The Surgery advises that discussions took place with Ms Campbell 
on multiple occasions to look at reducing her medication and that other patients have 
also been identified through this audit. We note that a conversation has taken place 
with  the  ICB  on  how  this  cohort  of  patients  require  their  medication  reviews  to  be 
undertaken more frequently and that the ICB will continue to work to review medicines 
management  for  patients  with  multiple  prescriptions  where  there  may  be  safety 
implications.  

 
 
 
 
 
 Hilltop  Surgery  also  advised  that  they  have  implemented  improvements  to  their 
prescribing  processes  to  include  ensuring  face  to  face  medication  reviews  with 
patients and operating a call and recall system that ensures the number of prescription 
reauthorisations are limited to three before a next review takes place.  

I would also like to provide further assurances on national NHSE work taking place 
around the Reports to Prevent Future Deaths. All reports received are discussed by 
the Regulation 28 Working Group, comprising Regional Medical Directors, and other 
clinical and quality colleagues from across the regions. This ensures that key learnings 
and insights around preventable deaths are shared across the NHS at both a national 
and regional level and helps us pay close attention to any emerging trends that may 
require further review and action. 

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

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