Terence Grainger

Mr Christopher Morris 
HM Area Coroner for Greater Manchester (South) 

By email only: 

Dear Mr Morris 

1st Floor 
30 Cannon Street 
London 
EC4M 6XH 

020 3283 6600 
circlehealthgroup.co.uk 

21st March 2025 

Response to Regulation 28 Report to Prevent Future Deaths  

I  write  following  the  conclusion  of  the  inquest  into  the  death  of  Mr  Terence  Grainger  and  in 
response to your Regulation 28 report dated 5th February 2025. 

At the outset, may I extend my deepest sympathies and condolences to Mr Grainger’s family for 
their loss. I recognise that this remains an extremely challenging time for them, and I reiterate 
the  commitment  conveyed  previously  by  my  Circle  Health  Group  (CHG)  colleagues  to 
addressing, as far as possible, all areas for improvement identified through internal and coronial 
review of this case. I am therefore grateful to you bringing to my attention your concerns about 
the absence of an electronic patient observation system featuring in CHG’s plan to introduce an 
electronic patient record (EPR).  

In the hope that it may assist with explaining CHG’s position on this matter, I have detailed below 
the current regulatory requirements and the progress CHG has made to date with regards to 
introducing its EPR. I must however start by confirming, as a matter of important clarification, 
that  CHG  has  every  intention  of  introducing  a  full  EPR,  including  expansion  of  an  electronic 
patient observation system, such as those currently available in CHG’s critical care facilities, 
into ward-based  settings.  There  are  however  a  number  of  foundation steps  that  are  planned 
ahead of this for reasons that I consider to be important, and which I have explained later in this 
letter.  

Regulatory requirements 

Use of electronic observation systems in healthcare is not currently a regulatory requirement 
for  Care  Quality  Commission  (CQC)  registered  providers  such  as  CHG.  The  accurate 
completion of contemporaneous records and the access to those by the treating team remains 
a key requirement of Regulation 17 (Good Governance) of the Health and Social Care Act 2008 
(Regulated Activities) Regulations 2014, regulated by the CQC. 

Circle Health Group Limited | Registered number: 2164270 
Registered office: 1st Floor, 30 Cannon Street, London EC4M 6XH | Registered in England & Wales 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 CHG ensures and monitors compliance with this,  and other regulatory requirements at  CHG 
hospitals,  through  various  mechanisms,  all  of  which  are  quality  assured  through  CHG’s 
governance and assurance framework. These mechanisms include: 

1.  Production and publication of clear and accessible policies  for sta(cid:431),  agency workers  and 
consultants, detailing the expectations and processes for record keeping at CHG hospitals. 
Those policies include CHG’s ‘Management of Records and Clinical Documentation’ policy 
and  the  ‘Practising  Privileges’  policy.  These  policies  supplement  the  national  external 
guidance  for  nursing,  medical  and  allied  health  professionals  regarding  record  keeping 
standards,  issued  by  the  various  regulatory  bodies,  namely  the  General  Medical  Council, 
Nursing and Midwifery Council and Health and Care Professions Council; 

2.  Development and implementation of clinical pathway documentation, including supportive 
tools such as checklists and observation charts. This is periodically reviewed and revised as 
necessary to assist the e(cid:431)ective, e(cid:431)icient and accurate capturing of clinical information by 
clinical teams; 

3.  Access to record-keeping training modules via CHG’s dedicated internal learning platform, 
in addition to the inclusion of scenario-focussed record keeping training as part of clinical 
modules  that  form  part  of  the  CHG  mandatory  training  programme.  Further,  many  CHG 
hospitals  employ  practice-based  educators  who  deliver  and/or  provide  further  support  to 
hospitals  in  arranging  bespoke  record  keeping  workshops  and  training  sessions  for  their 
clinical teams where these would be beneficial;  

4.  Groupwide Quality and Safety Improvement Programmes, developed through trend-analysis 
of  incidents,  complaints,  patient  feedback  and  inquests,  many  of  which  include  further 
training on, and profile-raising of, record-keeping standards as part of wider clinical practice; 

5.  Contemporaneous medical record audits, completed by CHG hospitals every four months, 
to monitor hospital teams’ compliance with record keeping requirements, including, but not 
limited to, completeness and legibility of records. Any areas of concern identified by the audit 
processes are addressed through comprehensive action plans developed by the hospital;  

6.  Audit  results  and  completion  of  action  plans  are  reported  via  CHG’s  central  reporting 
platform and reviewed by CHG hospitals at their clinical governance committee meetings. 
CHG’s national clinical governance committee oversees this assurance process through its 
review  of  audit  results  across  the  group,  identifying  and  addressing  areas  requiring 
improvement, including through escalation to board level where appropriate.  

7.  Clinical  incidents  and  learning  responses,  which  are  overseen  by  CHG’s  Patient  Safety 
Incident Review Group, provide further opportunity to identify and appropriately address any 
required  improvements  regarding  individual  or  team  record  keeping  practices.  This  will 
include  management  via  individual  performance  investigations  and  referrals  to  the 
professional regulators where appropriate.  

Through  these  routes,  I  am  assured  that  record  keeping  systems  at  CHG  comply  with  the 
regulatory standards that apply across the sector in England, and support the delivery of safe, 
high  quality  patient  care.  Supported  by  its  governance  and  assurance  framework,  CHG 
continues to ensure that compliance with the regulatory requirements is maintained.  

 
 
 
 
 
 
 
 
 
 
 Progress towards a full EPR 

I share your view that an EPR, including an electronic system for recording patient observations, 
has the potential to further assist CHG’s clinical teams with contemporaneous record keeping, 
early identification of deteriorations and reducing the risk of record keeping errors.  

As you will no doubt be aware, introduction of a fully digitised and integrated health record has 
been a sector-wide ambition for many years. For this reason, and as shared during the coronial 
proceedings,  CHG  has  already  carried  out  significant  work  towards  the  digitalisation  and 
harmonisation of patient administrative and clinical electronic records across CHG. This work 
is the fundamental aim of CHG’s Digital Transformation Programme, led by a dedicated team 
accountable to CHG’s board, which commenced prior to this recent case and is ongoing. 

Transition to an EPR is a complex and lengthy process, with the associated challenges being 
well-illustrated through reports such as those issued by the Health and Social Care Committee 
evaluating Government progress on its commitment to digitise the NHS and, earlier this year, by 
Public  Policy  Projects.  For  example,  to  safely  and  effectively  implement  a  fully  electronic 
system, we must ensure, that there is: 

  procurement  of  user-friendly  and  fit-for-purpose  patient  administrative  and  clinical 

electronic record keeping systems; 

 

testing and assurance on the interoperability of digitalised systems to enable unimpeded 
access to information by clinical teams; 

  procurement and roll-out of system-compatible equipment; and  

  extensive  engagement  with  staff  and  consultants,  accompanied  by  a  comprehensive 
training programme to ensure that clinical teams using the systems have the necessary 
digital competencies to use them.  

These requirements all inherently pose complexities to be overcome. It is also fundamental that 
implementation of new electronic systems is approached cautiously to ensure that the desired 
improvements from digitisation are not negated by creating new risks to patient safety or care 
quality, or increasing existing ones. 

Progress  across  the  sector  with  the  transition  to  an  EPR  is  varied  and  CHG,  like  many  other 
providers,  continues  to  face  and  work  through  the  challenges  outlined  above.  However,  and 
more  positively,  we  have  overcome  a  number  of  teething  problems  and  to  date  have 
successfully introduced, across CHG, digitised systems for consent and pathology and imaging 
requests.  We are also currently in the  pilot phase for introducing an electronic pre-operative 
assessment system and, through CHG’s procurement process, all new equipment is designed 
to fully integrate with electronic patient records. While I recognise that there is work still to be 
done, CHG remains committed to progressing its Digital Transformation Programme as rapidly 
and safely as possible. 

I hope that the information in this letter duly reassures you that, notwithstanding the operational 
challenges,  CHG  is  actively  working  towards  introduction  of  an  EPR,  including  an  electronic 

 
 
 
 
 
 
 
 
 
 
 
 
 
 record  system  for  patient  observations.  Further,  that  pending  that  transition,  CHG  remains 
compliant with current regulatory record keeping requirements and will continue to monitor and 
ensure such compliance through its robust governance and assurance framework. 

Yours sincerely 

Interim Chief Executive Officer