Prevention of Future Deaths reports · 2023

Amirah Khalifa

Regulation 28 report to prevent future deaths, reference 2023-0481, written 27 Nov 2023. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report27 Nov 2023
Reference2023-0481
DeceasedAmirah Khalifa
CoronerAnita Bhardwaj
Coroner areaLiverpool and Wirral
CategoryAlcohol, drug and medication related deaths · Hospital Death (Clinical Procedures and medical management) related deaths
Organisation namedLiverpool University Hospitals NHS Foundation Trust
Sourcejudiciary.uk record · original PDF
Responses published1

The report

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

Regulation 28: REPORT TO PREVENT FUTURE DEATHS 

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

REGULATION 28 REPORT TO PREVENT DEATHS 

THIS REPORT IS BEING SENT TO: 

1  NHS England & NHS Improvement  (PFDs) 

1  CORONER 

I am Anita BHARDWAJ, Area Coroner for the coroner area of Liverpool and Wirral 

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 06 February 2023 I commenced an investigation into the death of Amirah KHALIFA aged 
42.  The investigation concluded at the end of the inquest on 24 November 2023.  The 
conclusion of the inquest was that: 

Narrative Conclusion: Inappropriate and prolonged administration of steroids contributed to 
by neglect. 

4  CIRCUMSTANCES OF THE DEATH 

 once a day. She 

 twice daily and then 

Amirah Khalifa was a 41 year old lady who had a complex medical history, including a 
presumed hepatocellular carcinoma for which she underwent a TACE (trans arterial 
chemoembolization) in 2016. On 31 August 2018 Amirah was admitted to the Royal 
Liverpool Hospital presenting with vomiting and right upper quadrant pain, a known 
complication after a TACE procedure. Various medications were prescribed but the pain was 
ongoing. On 11 September 2018, whilst still in hospital, Amirah was prescribed 
dexamethasone (a steroid), initially 
was then discharged from hospital. A discharge summary was sent to her General Practice 
(GP) requesting the steroid medication to be reviewed. When the steroids were prescribed 
there was no indication noted as to the length of the intended treatment course in the 
clinical notes or in the discharge letter issued by the hospital team. In April 2019 the 
steroids were noted as a repeat prescription in the GP records rather than an acute 
prescription. It is unclear upon what basis this was done. On 12 June 2019 Amirah was 
admitted to the Royal Liverpool University Hospital with dizzy spells. It was noted that her 
high blood pressure was poorly controlled. Her dexamethasone was continued in hospital 
and on discharge. A discharge summary was sent to her GP practice with the steroids to be 
continued. On 12 September 2019 Amirah was admitted to the Royal Liverpool hospital 
with similar symptoms. Her dexamethasone was continued again in hospital and on 
discharge. Throughout 2019-2022 Amirah had numerous consultations with various 
specialists in the Royal Liverpool University Hospital. On 29 December 2022 Amirah was 
admitted to the Royal Liverpool University Hospital feeling generally unwell and with leg 
pain. Treating medical professionals deemed that Amirah's case was complex and multiple 
organ systems were investigated and treated. Despite active treatment Amirah deteriorated 
and died on 31 January 2023. The post mortem examination found it was more likely than 
not Amirah died as a result of multiple organ failure caused by sepsis and intestinal 
haemorrhage as a result of long term steroid therapy. Throughout, on each discharge from 
hospital, a discharge letter was sent to Amirah’s GP and was generally to continue the 

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

 dexamethasone. There were a number of failures relating to the care and treatment 
afforded to Amirah; through numerous appointments an incomplete medication history was 
taken and documented which did not include dexamethasone. Amirah had multiple complex 
conditions and was under the care of numerous specialists, many of whom clearly did not 
appreciate she was on steroids, and had been, for a lengthy period of time. Amirah was 
seen by numerous clinicians both in the hospital and in the community and at no stage was 
it questioned as to why she was still on the steroids, and why at the high dose she was on. 
Evidence has been heard that it was rare for a patient to be on these steroids at this dose 
for a lengthy period of time. Amirah presented with symptoms clearly suggestive of the 
possibility of complications of steroid use, namely uncontrollable blood pressure, diabetes, 
swelling and cognitive impairment. There was a failure to recognise these obvious 
presentations and the link between them and the long term steroid use. There was a failure 
to document in the clinical notes and / or in the discharge letter, the indication or length of 
the dexamethasone tablets. This failure prevented adequate instructions being provided to 
Amirah’s GP as to the intended length of the dexamethasone treatment and monitoring of 
the same. There was a failure for the GP to clarify the discharge with the hospital and to 
review the medication, this failure was exacerbated by the fact the prescription was 
changed to repeat from acute with no apparent reason. Overall, there was a catalogue of 
missed opportunities both in hospital as well as in the community to identify that Amirah 
remained unnecessarily on dexamethasone tablets despite multiple reviews as an inpatient 
and outpatient. Even when the ongoing prescription was identified, and Amirah was 
symptomatic of Cushing’s disease and steroid induced diabetes the correct action to wean 
treatment completely was not undertaken. It is a basic and fundamental expectation for a 
clinician in charge of a patient’s care to monitor and review prescribed medication, 
particularly acute medication such as steroids. There was a failure to do this for Amirah 
despite the fact that there were numerous opportunities to do so over a lengthy period of 
time. The accumulation of failures through the primary and secondary care services has led 
to a gross failure to provide basic medical attention to Amirah who was in a dependent 
position and had every reason to rely upon those who had management of her care and 
treatment to prescribe, monitor and review her medication. It is more likely than not the 
inappropriate and prolonged administration of steroids caused Amirah’s death. 

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 
circumstances it is my statutory duty to report to you. 

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

The current SCR model does not appear to automatically flag drugs such as 

1. 
steroids, which are known to have potentially fatal side effects if used for the long term 
without appropriate monitoring.  It is understood that some drugs do have these flags, but 
that steroids do not. 

In addition, the SCR does not have a space recording for clinical indication for 

2. 
initiation of the drugs, to aid a future prescriber to consider whether the drug is still 
clinically indicated. 

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 January 22, 2024.  I, the coroner, may extend the period. 

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

 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 

Royal Liverpool University Hospital 
Sandringham Medical Centre 

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: 27/11/2023 

Anita BHARDWAJ 
Area Coroner for 
Liverpool and Wirral 

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

Responses

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

Response from NHS England (PDF)
Anita Bhardwaj 
Liverpool and Wirra Coroner’s Service 
Gerad Majella Courthouse 
Boundary Street 
Liverpool  
L5 2QD 

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

24 January 2024  

Dear Coroner, 

Re: Regulation 28 Report to Prevent Future Deaths – Amirah Khalifa who died 
on 31 January 2023.  

Thank  you  for  your  Report  to  Prevent  Future  Deaths  (hereafter  “Report”)  dated  27 
November  2023  concerning  the  death  of  Amirah  Khalifa  on  31  January  2023.  In 
advance of responding to the specific concerns raised in your Report, I would like to 
express my deep condolences to Amirah’s family and loved ones. NHS England are 
keen to  assure the  family and  the  coroner  that  the  concerns raised  about  Amirah’s 
care have been listened to and reflected upon.  

Your Report raises the concern that the current Summary Care Record (SCR) model 
does  not  appear  to  automatically  flag  drugs  such  as  steroids  which  may  have 
potentially fatal side effects when used long term. You also raised that the SCR does 
not have space for recording the clinical indication for initiation of certain drugs to aid 
future prescribers.  

The National Care Records Service is the improved successor to the Summary Care 
Record application (SCRa). The NCRS has been developed gradually over the last 4-
5 years, and as the NCRS product has matured, we have been migrating service users 
across from SCRa to NCRS throughout 2023.  

NCRS provide a quick, secure way to access national patient information to improve 
clinical  decision  making  and  healthcare  outcomes  and  it  is  free  to  use.  It  includes 
additional features and services beyond the legacy SCRa product. The service is a 
web-based  application  and  can  be  accessed  regardless  of  what  IT  system  an 
organisation is using. NCRS provides access to an ever-increasing number of centrally 
provisioned national digital services that support the direct care of patients, including:  

•  Summary Care Records (SCR) - core and Additional Information   
•  National Record Locator Service (NRL) – pointers to and retrieval of data 
held in local provider systems.  

Details  of  long-term  conditions,  significant  medical  history  and  the  reason  for  any 
prescribed medication, should now be included by default for patients with an SCR, 
unless they have previously told the NHS that they did not want this information to be 
shared. For more information, and to illustrate the type of content included in an SCR, 
an example SCR is available here: Additional Information in the SCR.  

                                                                                                                       
 
 
 
 
 
 
 
 
 
 
 
  
 
    
 
  
 It is also relevant to the circumstances of Amirah’s care to note that NHS England has 
commissioned  the  Royal  Pharmaceutical  Society  (RPS)  and  the  Royal  College  of 
General  Practitioners  (RCGP)  to  develop  tools  and  guidance  to  help  primary  care 
healthcare professionals to improve issues concerning repeat prescribing. This follows 
the  publication  in  September  2021  of  the  Good  for  you,  good  for  us,  good  for 
everybody plan to reduce overprescribing in England and to ensure that patients get 
the right treatment for their needs. The final toolkit is expected to be published in May 
2024.  

NHS England has also engaged with Cheshire and Merseyside Integrated Care Boad 
on the circumstances of Amirah’s care raised in your Report and has been sighted on 
the  Serious  Incident  Review  undertaken  by  Liverpool  University  Hospitals  NHS 
Foundation  Trust  (‘the  Trust’).  As  part  of  the  review,  the  Trust  has  identified  clear 
opportunities to prevent a similar incident occurring again and NHS England welcomes 
the actions outlined in the Trust’s Improvement Plan. These include:  

•  Making  the  completion  of  the  ‘changes  to  Medication’  part  of  Discharge 

Summary documentation compulsory. 

•  Ensuring that the indication for long-term steroid treatment is included in drug 
initiation,  clerking  documentation,  discharge  letters,  medicines  reconciliation 
and primary care records.  

•  Making the medicines section of clinical letters compulsory.  

NHS England would refer you to the Trust for any further information on their review 
and action plan.  

I would also like to provide further assurances on national NHS England 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, 

Medical Director for Professional Leadership and Clinical Effectiveness        

NHS England

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