Prevention of Future Deaths reports · 2024

Teresa Bennett

Regulation 28 report to prevent future deaths, reference 2024-0081, written 14 Feb 2024. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report14 Feb 2024
Reference2024-0081
DeceasedTeresa Bennett
CoronerSarah Riley
Coroner areaNorth West Wales
CategoryAlcohol, drug and medication related deaths · Wales prevention of future deaths reports (2019 onwards)
Sourcejudiciary.uk record · original PDF
Responses published1

The report

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

Assistant Coroner  
 for North West Wales 

Sarah Olga Riley, Assistant Coroner for North West Wales 

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS 

THIS REPORT IS BEING SENT TO:   

Chief Executive of Betsi Cadwaladr University Health Board, 

1 

CORONER 

I am Sarah Riley, Assistant Coroner for North West Wales                                   

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. 
http://www.legislation.gov.uk/ukpga/2009/25/schedule/5/paragraph/7 
http://www.legislation.gov.uk/uksi/2013/1629/part/7/made 

3 

INVESTIGATION and INQUEST 

On the 8th December 2021, I commenced an investigation into the death of Ms Teresa Ann 
Bennett. The investigation concluded at the end of the inquest on the 9th February 2024.  
CIRCUMSTANCES OF THE DEATH 

4 

Teresa Ann Bennett was a female, aged 57 at the time of her death. She had 
a number of significant comorbidities, and her case was unusual and 
complex. Mrs Bennett was prescribed and taking 13 separate medications at the time of 
her death, seven of which, including Fentanyl, had side effects linked to the central 
nervous system.  

On the evening of the 30th November 2021, Ms Bennett’s son had seen her taking her 
medication as usual. Ms Bennett retired to bed around 30 minutes or so later.  
Around 3am on the 1st December 2021, Ms Bennett’s son found her asleep on the 
bedroom floor, appearing to have fallen from the bed. He helped her back to bed, 
ensuring she was comfortable, and left the room. At around 12pm on the 1st December 
2021, Ms Bennett’s son noticed that she was still in bed and it became apparent that she 
had passed away. Ms Bennett’s son called the Emergency Services who attended and 
declared life extinct at 13.12pm.  

A post mortem examination was ordered and the cause of death recorded at inquest was:  
1a Multi organ failure  
1b Fatty liver and combined drug toxicity 

 micrograms of Fentanyl over 72 hours. This was 

Mrs Bennett was prescribed 
 patch and one 
provided as one 
identifiable as being different in size.  
At post mortem, 
 Matrifen (a form of fentanyl) patches were found on Ms 
Bennett’s legs, two on the left and one on the right. This would amount to a dose of 

 patch, both to be used at same time and 

Coroner's Office, Shirehall Street, CAERNARFON, Gwynedd, LL55 1SH 

 
 
 
 
 
 
         
 
 
 
 
  
 
      
 
 
 
 
 
 
 
 
 
 . This dose differs from what was prescribed and issued by the GP and correlates 

to a significant dose increase of 
of morphine daily. The toxicological analysis showed multiple drugs with Fentanyl 
being within the toxic and fatal range.  

 over 72 hours, which is the equivalent of 

/ hr over 72 hours since 2008. The instructions recorded in 

It was recognised that Ms Bennett was prescribed a high dose of Fentanyl. Ms Bennett 
had been on a dose of 
the GP notes simply stated ‘remove old patch and apply new patch every 72 hours’ 
There was no evidence to suggest that Ms Bennett was not compliant with her 
medications. There was no evidence of ordering discrepancies, no stockpiling or using 
the medication incorrectly and there was nothing to indicate that Ms Bennett raised any 
concerns or mentioned any difficulties with the medication she was taking. 

The prescription dose of Fentanyl had not changed since 2008 and the directions for use 
had not changed.  There was no evidence that the application of Fentanyl patches 
resulting in a dose of  micrograms was intentional. I found that Ms Bennett had 
inadvertently overdosed on Fentanyl, and that, in combination with other medicines, a 
number of which possessed the ability to depress the nervous system, led to her death.  

Ms Benett’s GP practice was managed directly by the Health Board. It is Standard 
Health Board practice for medication reviews to be completed at 12-15 month intervals 
but, in Ms Bennett’s case, that target had not been met on a single occasion since 2015. 
There is a lack of monitoring and no standardised process for medication reviews in the 
Health Board managed practices.  

There is a risk of harm if medication reviews are not undertaken at regular intervals, 
including a risk of death in complex cases, like Ms Bennett’s. There is also a risk of 
harm or death if all pertinent matters are not considered during the reviews. At inquest, 
the Health Board produced an improvement plan that, inter alia, included actions to 
address the lack of compliance with the 12-15 monthly medication reviews. The target 
completion date for addressing the lack of compliance with the 12-15 monthly 
medication reviews is the 31st May 2025, a further 15 months from now. This, in my 
view, is not quick enough and I am concerned that future deaths may occur.  

5 

CORONER’S CONCERNS 

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

The MATTERS OF CONCERN are as follows.  – 

(1)  Lack of compliance with the target of 12-15 monthly medication reviews in Health Board 

managed GP practices.  

(2)  No standard practice for medication reviews leading to a lack assurance that all pertinent 
matters will be covered and the approach varying between clinicians and practices.  

(3)  The risk of inadvertent overdose in individuals like Ms Bennett, where medication that 

can cause e.g drowsiness and fatigue, is prescribed alongside strong opiates and other 
drugs that have the ability to depress the central nervous system when such medicines 
are prescribed without regular reviews nor specific advice in respect of the associated  
risks issued to patients e.g in Ms Bennett’s case, she was instructed to simply “remove 
old patch and apply new patch every 72 hours” 

Coroner's Office, Shirehall Street, CAERNARFON, Gwynedd, LL55 1SH 

         
 
 
 
  
 
 
 
 
 
 
 
 
 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 
10th April 2024. 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 Ms Bennett’s son, as an Interested 
Person  

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. 

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 14th February 2024 

Signature_________________________ 
Assistant Coroner for North West Wales 

Coroner's Office, Shirehall Street, CAERNARFON, Gwynedd, LL55 1SH

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 Betsi Cadwaladr University Health Board (PDF)
Bloc 5, Llys Carlton, Parc Busnes Llanelwy, 
Llanelwy, LL17 0JG 

---------------------------------- 

Block 5, Carlton Court, St Asaph Business 
Park, St Asaph, LL17 0JG 

Dyddiad / Date: 10 April 2024 

Sarah Riley 
HM Assistant Coroner 
North Wales (West) 
Coroner's Office 
Coroner's Office 
Shirehall Street 
CAERNARFON 
Gwynedd, LL55 1SH 

Dear Ms Riley,  

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS 
Teresa Ann Bennett 

I  write  in  response  to  the  Regulation  28  Report  to  Prevent  Future  Deaths  dated  14 
February 2024, issued by yourself to Betsi Cadwaladr University Health Board, following 
the inquest into the death of Teresa Ann Bennett.   

I would like to begin by offering my deepest condolences to the family and friends of Ms 
Bennett.  

In the notice, you highlighted your concerns regarding: 

  The  lack  of  compliance  with  the  target  of  12-15  monthly  medication  reviews  in 

Health Board managed GP practices; 

  The  absence  of  a  standard  practice  for  medication  reviews  leading  to  a  lack 
assurance  that  all  pertinent  matters  will  be  covered  and  the  approach  varying 
between clinicians and practices; 

  The risk of inadvertent overdose in individuals like Ms Bennett, where medication 
that can cause e.g. drowsiness and fatigue, is prescribed alongside strong opiates 
and other drugs that have the ability to depress the central nervous system when 
such  medicines  are  prescribed  without  regular  reviews  nor  specific  advice  in 
respect of the associated risks issued to patients. 

In  response  to  these  concerns,  I  asked  our  primary  care  teams  to  review  and  submit 
improvement actions which are detailed below.  

We  have  commenced  benchmarking  work  on  21  February  2024  for  all  Health  Board 
managed practices to identify all patients on regular repeat medication who have not got 
a medication review documented in the notes in the last 12-15 months. This work will be 
completed  by  31  May  2024.  These  patients  will  then  be  risk  stratified  for  medication 
review. This will occur parallel to implementing new procedures as outlined below. 

Cyfeiriad Gohebiaeth ar gyfer y Cadeirydd a'r Prif Weithredwr / Correspondence address for Chairman and Chief Executive: 
Swyddfa'r Gweithredwyr / Executives’ Office 
Ysbyty Gwynedd, Penrhosgarnedd 
Bangor, Gwynedd LL57 2PW 

Gwefan: www.pbc.cymru.nhs.uk / Web: www.bcu.wales.nhs.uk 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 A pan Health Board policy is now being developed to outline the standards for medication 
review within our managed practices. This will be completed by 30 June 2024.  

In order to ensure we review outstanding patients on repeat medication the policy will risk 
score patients on a priority level from 1 to 4 and outline exactly who will be included in 
each level. For example, Level 1 risk patients will be those >75 on polypharmacy, patients 
on  high  dose  opiates,  down  to  level  4  patients  who  are  under  50  and  on  less  than  4 
medications.  

Standard Operating Procedures will then be put in place at each practice to add the detail 
of responsibility and governance of the process; this will differ at each practice due to 
staffing skill mix.  

Practices  will  report  their  progress  against  medication  review  targets  at  assurance 
meetings that will be held regularly (every 2 months). These will be reported at a newly 
formed  managed  practice  Quality  and  Governance  Group  which  will  cover  all  North 
Wales services.  

Addressing  the  concerns  regards  patient  information  and  their  awareness  of  risks, 
additional warnings are included on pharmacy labels on the outside of medication boxes, 
which  reference  the  risks  of  drowsiness.  In  addition,  patient  information  leaflets  are 
included  in  every  box  which  outlines  what  to  do  in  various  scenarios  e.g.,  increased 
drowsiness, if patches no longer giving pain relief, and if a patch falls off. 

Health  Board  Managed  Practices  will,  from  01  May  2024,  add  the  Faculty  of  Pain 
Medicine opioid leaflet onto the clinical system. This will be printed and given to patients 
on opioids at their medication review, or when opioids are started or doses changed. A 
copy of this leaflet is attached as an appendix.  

Learning will be shared with independent contractor GP practices via the primary care 
governance processes.  

Our medicines management  Local  Enhanced  Service  (LES)  running  from  April  2024  - 
March 2025 will contain two sections on opioid prescribing.  This LES is applicable for all 
GP practices within the Health Board area and is mandatory. 

We  would  be  happy  to  meet  with  you  further  and  discuss  our  plans  in  more  detail,  or 
provide further information and assurance should that be helpful.  

Once again, I offer my deepest condolences to the family and friends of Ms Bennett for 
their  loss  and  I  reiterate  my  sincere  apologies  to  them  for  the  concerns  identified  at 
inquest. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Yours sincerely 

Cyfarwyddwr Meddygol Gweithredol / Dirprwy Prif Weithredwr Dros Dro 
Executive Medical Director / Acting Deputy Chief Executive  

cc  

, Deputy Executive Medical Director 

, Deputy Director of Quality

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