Prevention of Future Deaths reports · 2025

Michael Barry

Regulation 28 report to prevent future deaths, reference 2025-0296, written 12 Jun 2025. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report12 Jun 2025
Reference2025-0296
DeceasedMichael Barry
CoronerSean Horstead
Coroner areaEssex
CategoryAlcohol, drug and medication related deaths
Sourcejudiciary.uk record · original PDF
Responses published3

The report

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

REGULATION 28:  REPORT TO PREVENT FUTURE DEATHS

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS

THIS REPORT IS BEING SENT TO:

Mid and South Essex Integrated Care Board

Department of Health and Social Care

NHS England & NHS Improvement

CORONER

I am Sean Horstead, Area Coroner, for the coroner area of Essex

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.

INVESTIGATION and INQUEST

On 8th September 2023 I commenced an investigation into the death of Michael
Paul Barry aged 46 years.  The investigation concluded at the end of the inquest
on  the  30th  May  2025.  Mr  Barry  died  at  Broomfield  Hospital,  Court  Road,
Chelmsford,  Essex  from a  confirmed  medical  cause of  death, following  Post
‘Ia  Pneumonia’ and,  under  Part  II  (as  having
Mortem  examination,  of
contributed to the death but not a direct cause): ‘Excessive use of Codeine’.

I provided a Narrative Conclusion confirming that the deceased died, despite
optimal medical care following admission to Hospital, from fatal complications
of  a  community  acquired  pneumonia  on  a  background  of  excessive  use  of
Codeine medication.

Notwithstanding evidence of the deceased’s history of mental health issues and
previous  suicidal  ideation,  and  an  attempt  to  take  his  own  life  by  way  of
overdose some three months prior to his death, the evidence did not disclose
to  the  requisite  standard  of  proof  the deceased’s  intent  at  the  time  of  taking
excessive codeine medication in the period prior to his last hospitalisation.

1

2

3

4

CIRCUMSTANCES OF THE DEATH

1

 The deceased had a long-standing history of mental health problems and illicit
drug and alcohol misuse.  By the time of his death Mr Barry’s use of illicit drugs
had significantly diminished (though he continued to  ‘binge drink’ to  excess).
However, he had developed a long-standing dependency on prescribed opiate
based pain-killing medication following significant surgery some years prior to
his death.

Whilst the evidence did not disclose the source of the codeine taken in excess
prior to his death, the evidence positively confirmed that, absent concomitantly
raised  paracetamol  levels, the  codeine  identified in  the  toxicological  analysis
was likely not from the medication prescribed by the deceased’s GP Practice.
Accordingly, no direct causative link could be found, to the requisite standard
of proof, between the prescribed medication itself and the death and, further,
no  finding  or  determination  was made  that  was critical  of  the  GP’s on-going
prescribing  of  the  pain-killing  medication.  However,  the  lack  of  specialist
support to which the GP could refer the patient was a significant concern.

5

CORONER’S CONCERNS

During the inquest the evidence revealed matters giving rise to concern and 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.  –

Notwithstanding the positive finding that the specific medication prescribed by
Mr Barry’s GP had not been the source of the excessive codeine taken prior to
admission to hospital, compelling evidence was received at the inquest from  a
Partner  at  the  GP  Practice  (with  a  particular  specialism  in  this  area  of
dependency-forming  medications) 
no  specialist
commissioned service available for GPs to which they might refer their patients
to  manage  reduction  of  their  intake  of  prescribed  dependency-forming
medications.  This is in contrast to the availability of commissioned services for
patients who are dependent on illicit drugs and/or alcohol.

remains

there 

that 

The  evidence  confirmed  that  reduction  or  cessation  of  dependency-forming
medications needs to be very carefully managed due to the risk of withdrawal
symptoms and, in the context of the unchallenged evidence received, requires
specialist input and training to maximise the prospects of success and to avoid
potentially fatal consequences.   The evidence, again unchallenged,  was that
the continuing absence of such a commissioned service gives rise to the risk of
avoidable future deaths.

2

 The long-standing and continuing lack of commissioned services in primary or
secondary care for assisting people to safely reduce and withdraw from such
prescribed  medication  was  confirmed  in  her  evidence  by  the  Director  of
Pharmacy  and  Medicines  Optimisation  within  the  Mid  and  South  Essex
Integrated Care Board (the ICB).  This witness helpfully set out important steps
currently proposed and/or being taken to educate clinicians and service users
alike of the dangers of opiate based prescription medications (alongside their
relatively limited benefits in most, though not all, cases) with a view to reducing
the size of the cohort of patients at risk of becoming dependent/addicted in the
medium and  longer  term.    However,  this  does not  -  absent  a  commissioned
service to which GPs and patients may turn for specialist advice and assistance
- address the immediate and on-going risk of future deaths to those currently
dependant on/addicted to these medications, with the numbers of such patients
having significantly increased in the post-COVID 19 period as a consequence
of lengthy delays to, for example, chronic pain-relieving surgery.

Precisely  this  issue  was  highlighted  in  a  previous  PFD  Report  from  14th
November 2019 issued by the former Senior Coroner in this jurisdiction.  The
response  from  the  (then)  Clinical  Commissioning  Group  had  indicated  an
intention to roll-out a Prescribed Opioid Dependence Local Enhanced Service
in early 2020, but this was not implemented due to the COVID 19 pandemic.

Since then,  including at the date of  Mr Barry’s death in November 2023 and
through  to  today,  there  remains  no  such,  or  similar,  commissioned  service
across Essex or, it appears, consistently across England and Wales with only
rare pockets around the country where such a service is commissioned.

ACTION SHOULD BE TAKEN

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

YOUR RESPONSE

You are under a duty to respond to this report within 56 days of the date of
this report, namely by Thursday August 7th 2025. 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.

6

7

8

COPIES and PUBLICATION

3

 I have sent a copy of my report to the Chief Coroner and to the following
Interested Persons and others:

The Family of the Deceased

Essex Partnership NHS Foundation Trust

Fern House Surgery

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 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

HM Area Coroner for Essex Sean Horstead

12.06.2025

4

Responses

3 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 Department of Health and Social Care (PDF)
Minister of State for Health (Secondary Care) 

39 Victoria Street 
London 
SW1H 0EU 

HM Coroner Mr Sean Horstead 
Essex and Thurrock Coroner’s Service,  
Essex County Council,  
Seax House,  
Victoria Road South,  
Chelmsford,  
CM1 1QH 

18th August 2025 

Dear Mr Horstead, 

Thank you for the Regulation 28 report of 12th June 2025 sent to the Department of Health 
and Social Care about the death of Michael Paul Barry. I am replying as the Minister with 
responsibility for prescribing.  

I would like to take this opportunity to say how saddened I was to read of the circumstances 
of Mr Barry’s death, and I offer my sincere condolences to their family and loved ones. The 
circumstances your report describes are concerning and I am grateful to you for bringing 
these matters to my attention.  

Your report raises concerns over the lack of specialist commissioned services available to 
GPs for onward referral of patients requiring assistance with management of dependency-
forming medicines. Specifically, a lack of services focused on reducing intake of prescribed 
dependency-forming medications and those offering specialist advice.  

Your report also highlights that the reduction or cessation of prescriptions for dependency-
forming  medications  needs  to  be  very  carefully  managed,  due  to  the  risk  of  withdrawal 
symptoms.  Reduction  and  cessation  of  such  medications  requires  specialist  input  and 
training to maximise the prospects of success and to avoid potentially fatal consequences.  

In  preparing  this  response,  my  officials  have  made  enquiries  with  NHS  England  and  the 
Medicines  and  Healthcare  products  Regulatory  Agency  (MHRA)  to  ensure  that  your 
concerns have been adequately addressed.  

First, regarding the lack of specialist commissioned services available to GPs, NHS England 
has advised that the Prescribed Opioid Dependence Local Enhanced Service referenced in 
your  report  has  been  a  locally  proposed  initiative  that  was  not  commissioned  nationally. 
Therefore, whilst I do understand your concerns on this matter, NHS England is not able to 
comment on this specific service.  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
   
 NHS  England has  said  that  the Essex Partnership  University  NHS  Foundation  Trust  (the 
Trust)  recognises  the  growing  concern  around  dependence  on  prescribed  medication, 
particularly following the COVID-19 pandemic, during which access to elective procedures 
and chronic pain management services was disrupted.  

The Trust agrees that the safe reduction or cessation of these medications requires clinical 
expertise and coordinated care planning to reduce the risk of harm, including the potential 
for serious withdrawal effects and, in some cases, avoidable deaths.  

At  present,  however,  the  Trust  is  not  commissioned  to  provide  a  specialist  service  for  a 
stand-alone prescription medication dependency service that would allow direct referral from 
GPs solely for tapering and withdrawal management of these medicines. 

I would like to take this opportunity to detail what initiatives are in place by key organisations 
to address the wider areas of concern raised by your report. I have detailed these below.  

NHS England   

The Government commissioned a review into the use of medication and overprescribing. 
The outcome of this work, titled the National overprescribing review report, was published 
in  September  2021.  The  report  evaluated  the  extent,  causes  and  consequences  of 
overprescribing  and  made  20  recommendations  to  address  it.  NHS  England  and  partner 
organisations have been implementing the review’s recommendations over the past 3 years, 
aiming  to  achieve  long  term  sustainable  reductions  to  overprescribing  via  delivery  of 
systemic and cultural improvements within the NHS.   

A  number  of  interventions  are  being  delivered  by  NHS  England  to  address  and  reduce 
overprescribing including:  

•  Publication  of  the  National  medicines  optimisation  opportunities  for  the  NHS  in 
2024/25,  which  includes  an  opportunity  on  chronic  non-cancer  pain  management 
without opioids. ICBs have been encouraged to select opportunities for delivery.  

•  Support for delivering Structured Medication Reviews (SMR).   

•  A  national  programme  to  offer  non-pharmacological  alternatives  such  as  social 
prescribing,  as  well  as  funding  for  social  prescribers  through  the  ARRS.  Social 
prescribing is demonstrated to support patients address wider determinants of health 
which  may  be  an  underlying  or  contributory  factor  to  the  inappropriate  use  of 
medication.  

The NHS Medicines Safety Improvement Programme (which forms a key part of the NHS 
Patient  Safety  Strategy)  is  also  delivering  a  focussed  programme  of  work  relating  to  the 
improved care of people with chronic pain and a reduction in the use of prescribed opioids. 
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.  

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’. This 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, including opioids, by:   

•  Optimising  personalised  care  for  adults  prescribed  medicines  associated  with 

dependence or withdrawal symptoms.  

• 

Informing  ICB  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.    

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

Across 2022 and 2023, 18 Integrated Care Systems received intensive support to develop 
and  implement  improvements  in  care  and  a  further  15  participated  in  shared  learning 
events.  

Commissioning of services to support people with chronic pain (including services to support 
people  to  safely  withdraw  from  prescribed  medicines  that  may  cause  dependence  and 
withdrawal)  now  lies  with  Integrated  Care  Boards  (ICBs).  NHS  England  expects  ICBs  to 
commission  appropriate  services  to  meet  the  needs  of  the  population  that  the  ICB 
geographically  covers.  This  includes  taking  due  regard  to  any  of  the  above  national 
commissioning or clinical guidance.  

Controlled  Drugs  Accountable  Officers  and  Controlled  Drugs  Local  Intelligence 
Networks 

In light of the information provided by NHS England, I hope you will find it helpful if I explain 
the safeguards currently in place to ensure that healthcare organisations adopt safe practice 
in this area. NHS England has a clear responsibility in providing systems oversight for the 
management and use of controlled drugs, including opioids such as codeine. I am aware 
that  NHS  England’s  Controlled  Drugs  Accountable  Officers  (CDAOs)  undertake  this  role 
within each geographical region across England. They provide assurance that all healthcare 
organisations, including GP practices and pharmacies, adopt a safe practice for appropriate 
clinical use, prescribing, storage, destruction and monitoring of controlled drugs.   

CDAOs facilitate the routes to share concerns, report incidents, and take remedial action as 
well  as  highlighting  good  practice.  This  is  shared  with  wider  partners  such  as  Integrated 
Care Boards and the police through the Controlled Drugs Local Intelligence Networks (CD 
LINs). Details of all CDAOs in England are held on a national register, which is owned and 
published  by  the  Care  Quality  Commission:  www.cqc.org.uk/content/controlled-drugs-
accountable-officers.  

National Institute for Health and Care Excellence 

As you may already be aware, the National Institute for Health and Care Excellence (NICE) 
is the independent body responsible for developing evidence-based guidance for the NHS 

 
 
 
 
 
 
 
 
 and is responsible for developing guidance in line with established methods and processes. 
NICE  guidelines  are  based  on a  thorough  assessment  of  the  available  evidence  and  are 
developed  through  a  rigorous  process,  that  includes  extensive  engagement  with 
stakeholders  and  expert  input  throughout  the  guideline  development  process.  NICE  has 
published guidelines on the assessment and management of chronic primary pain and the 
safe prescribing and withdrawal management of medicines associated with dependence of 
withdrawal symptoms. These guidelines can be found here: 

•  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.   

NICE guidelines describe best practice and the government expects NHS commissioners to 
take them into account in designing services that meet the needs of their local populations. 
It is however important to note that NICE guidelines are not mandatory and do not override 
a  clinician’s  responsibility  to  make  decisions  appropriate  to  the  individual  needs  of  their 
patients.  

Commission for Human Medicines 

As  with  any  patient  dependent  on  an  opioid  medicine,  cessation  of  treatment  should  be 
undertaken slowly under the supervision of a healthcare professional to prevent the potential 
from  withdrawal  reactions.  In  2020,  following  a  review  of  addiction  and  dependence  to 
opioids  by  the  Opioid  Expert  Working  Group  of  the  Commission  for  Human  Medicines, 
consistent warnings were added to product information to include this guidance. In addition, 
MHRA  published  a  Drug  Safety  Update  article  for  healthcare  professionals  and  a  leaflet 
which healthcare professionals are encouraged to give to patients. 

The MHRA continues to review the safety and access to codeine and will take regulatory 
action if considered appropriate. 

Managing co-occurring substance use and mental health 

As  you  mentioned  in  your  report,  Mr  Barry  had  a  long-standing  history  of  mental  health 
problems  and  illicit  drug  and  alcohol  misuse.  Therefore,  I  hope  you  will  find  it  helpful  if  I 
explain the actions being taken more broadly for those with substance use and mental health 
needs.  Following a recommendation from Dame Carol Black’s independent review of drugs 
in 2020, the Department has been developing a comprehensive action plan to set out a path 
to improving service provision for those with co-occurring substance use and mental health 
needs.  

NHS  England  and  the  Department  have  worked  with  subject  matter  experts,  including 
people with lived experience, academics, clinicians, and service providers in creating this 
plan.  The  plan  is  aimed  to  be  as  inclusive  as  possible  and  is  built  on  the  principles  of 
‘Everyone’s  job’  and  ‘No  wrong  door’.  The  first  principle,  ‘Everyone’s  job’,  states  that 
commissioners and providers of mental health and alcohol and drug treatment services have 

 
 
 
 
 
 
 
 
 
 a joint responsibility to meet the needs of people with co-occurring conditions by working 
together to treat those with mental health conditions as well as substance use conditions. 
The second principle, ‘No wrong door’, states that providers in alcohol and drug treatment, 
mental health and other services have an open-door policy for individuals with co-occurring 
conditions and make every contact count. Treatment for co-occurring conditions is available 
through every contact point and services should be working together seamlessly to meet 
needs.  

I hope this response is helpful. Thank you for bringing these concerns to my attention.   

Yours sincerely,  

MINISTER OF STATE FOR HEALTH (SECONDARY CARE)
Response from Mid and South Essex Integrated Care Board (PDF)
10 July 2025

Mr Sean Horstead
HM Area Coroner
HM Coroner's Office
County Hall
Seax House
Victoria Road South
Chelmsford
CM1 1QH

Dear Mr Horstead,

Re: Regulation 28 Report to Prevent Future Deaths

Thank you for your Regulation 28 Report dated 12 June 2025 concerning the tragic death of
Mr Michael Paul Barry. We would like to express our sincere condolences to Mr Barry’s family
and assure you that we have taken your concerns extremely seriously.

Summary of Concerns

We note your findings regarding the absence of a commissioned specialist service to support
patients  in  primary  care  with  the  safe  reduction  and  withdrawal  from  dependence-forming
prescribed medications. We also acknowledge the contrast with the availability of services for
those  dependent  on  illicit  substances  and  alcohol,  and  the  associated  risks  of  unmanaged
withdrawal.

Our Response

The  Mid  and  South  Essex  Integrated  Care  Board  (ICB)  is  committed  to  improving  patient
safety and outcomes  across  all  areas of  care.  However,  as  with  all healthcare  systems,  we
must continually balance a wide range of competing priorities, including urgent and emergency
care,  mental  health,  cancer  services  and  cardiovascular  disease.  While  the  issue  of
dependence-forming medications remains a significant concern, and we are taking meaningful
steps to address it, the pace and scale of service development are inevitably influenced by the
need to allocate limited resources across multiple areas of critical need. Nonetheless, we fully
recognise  the  risks  highlighted  in  your  report  and  remain  committed  to  reducing  harm  and
improving support for patients affected by medication dependency.

The ICB has adopted a multi-faceted strategy to address the risks associated with prescribed
dependence-forming medications, particularly opioids. Our approach includes:

 1. Prevention and Education

The  ICB  continues  to  prioritise  prevention  as  a  key  strategy  in  reducing  harm  from
dependence-forming medications. This includes  reducing the number of patients  initiated on
opioids and supporting clinicians with education and tools to manage prescribing safely.

In 2024, the ICB led the East of England-wide communications campaign “Pain Killers Don’t
Exist”,1 aimed at educating the public on the risks of long-term high-dose pain medication and
empowering individuals to make  informed decisions. Thus, seeking to  reduce the number of
patients seeking to be prescribed dependence forming medications.

Concurrent to this, regionally funded accredited Dependence Forming Medications (DFM) e-
learning  on  ‘Reducing  opioids  in  chronic  pain’  and  ‘Cognitive  Behavioural  Therapy  for
persistent pain’ training was offered to all practices through a locally commissioned Medicines
Optimisation Local Enhanced Scheme in 2023-24.

As  further  support  for  clinicians  treating  patients  who  are  prescribed  dependence  forming
medications,  the  ICB  has  developed  and  disseminated  comprehensive  guidelines  for  the
management of acute and chronic non-malignant pain, including specific guidance on Opioid
Tapering for Chronic Non-Cancer Pain. These  resources provide a structured framework for
identifying at-risk patients and supporting safe withdrawal.

In addition, links to community services—many of which are self-referral—are made available
to patients through primary care.

The  ICB  will  continue  with  its  successful  prevention  of  harm  strategy  to  reduce  the  overall
number of patients taking dependence-forming medications. Public information to support this
strategy can be found on our website.2

2. Service Development

A    new    Opioid    Reduction/Discontinuation    Pathway    is    planned    within    the    Community
Musculoskeletal  (MSK)  Service,  currently  in  procurement  and  due  for  implementation  in
February 2026.

This    pathway    will    provide    structured,    face-to-face    support    to    patients,    including    the
development of personalised deprescribing plans, regular reviews, and coordination with GPs
to  avoid  duplication  of  prescriptions.  Patients  on  high-dose  opioids  (≥120mg/day  morphine
equivalent) will remain under the service until safely stabilised. Where appropriate, referrals will
be made to mental health or addiction services.

The ICB Executive Committee has endorsed a proposal to work up a business case to scale
up the Aegros Primary Care Network (PCN)-based model across the ICB, aiming to deliver this
service  affordably  while  maintaining  a  primary  care  focus  and  upskilling  clinicians  to  both
deprescribe and prevent new cases of dependency.

Conclusion

We recognise the urgency of addressing the risks identified in your report and are committed
to   implementing    sustainable,   system-wide   solutions.   While    the   absence    of   a   fully
commissioned specialist service remains a  challenge,  we are  actively working  to bridge this
gap through innovative models, education, and integrated care pathways.

1 https://www.midandsouthessex.ics.nhs.uk/health/campaigns/painkillers-dont-exist/

2 https://www.midandsouthessex.ics.nhs.uk/health/personalised-care/medicines-management/drugs-of-dependence/

2

 We trust this response provides assurance of our commitment to improving care for patients
at risk of harm from dependence-forming medication and so preventing future deaths.

Yours sincerely

Executive Medical Director
Mid and South Essex Integrated Care Board
Clinical Leadership and Innovation Directorate

3
Response from NHS England (PDF)
Mr Sean Horstead 
HM Area Coroner  
Essex & Thurrock Coroner’s Service  
Essex County Council  
Seax Houe  
Victoria Road South  
Chelmsford 
CM1 1QH 

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

29 July 2025   

Dear Coroner, 

Re: Regulation 28 Report to Prevent Future Deaths – Michael Paul Barry who 
died on 2 September 2023.   

Thank  you  for  your  Report  to  Prevent  Future  Deaths  (hereafter  “Report”)  dated  12 
June  2025  concerning  the  death  of  Michael  Paul  Barry  on  2  September  2023.  In 
advance of responding to the specific concerns raised in your Report, I would like to 
express my deep condolences to Michael’s family and loved ones. NHS England is 
keen to assure the family and yourself that the concerns raised about Michael’s care 
have been listened to and reflected upon.   

Your  Report  raises  the  concern  that  there  is  ‘no  specialist  commissioned  service 
available for GPs to which they might refer their patients to manage reduction of their 
of  intake  of  prescribed  dependency-forming  medications’.  This  is  in  contrast  to  the 
available commissioned services for patients dependent on illicit drugs and/or alcohol.  

National role 

NHS England remains aware of this important issue and has worked at a national level 
to  provide  guidance  and  support  across  the  NHS.  In  particular,  NHS  England  is 
responsible for providing oversight of the management and use of controlled drugs, 
including  opioids  such  as  codeine.  NHS  England’s  Controlled  Drugs  Accountable 
Officers (CDAOs) undertake this role within each geographical region across England. 
They provide assurance that all healthcare organisations, including GP practices and 
pharmacies, adopt  a  safe  practice  for  appropriate  clinical  use, prescribing,  storage, 
destruction and monitoring of controlled drugs.   

CDAOs  facilitate  the  routes  to  share  concerns,  report  incidents  and  take  remedial 
action, as well as highlighting good practice. This is shared with wider partners such 
as Integrated Care Boards (ICBs) and the Police through the Controlled Drugs Local 
Intelligence  Networks  (CD  LINs).  Details  of  all  CDAOs  in  England  are  held  on  a 
national  register,  which  is  owned  and  published  by  the  Care  Quality  Commission 
(CQC): www.cqc.org.uk/content/controlled-drugs-accountable-officers.  

                                                                                                                       
 
 
 
 
 
 
  
 
 
 
 
 
  
 Framework for prescribed dependency-forming medications 

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’.  

This  Framework  was  developed  for  action  with  and  for  ICBs  and  primary  care  in 
response to a Public Health England (PHE) review and recommendations (2019) and 
NHS  England’s  subsequent  analysis  of  the  data  up  to  2020/21.  NHS  England’s 
Framework was prepared in collaboration with organisations including the Department 
of  Health  and  Social  Care  (DHSC),  CQC,  National  Institute  for  Health  and  Care 
Excellence  (NICE)  and  the  Medicines  and  Healthcare  products  Regulatory  Agency 
(MHRA).  

A  range  of  stakeholders  were  consulted  during  the  process,  including  patients  with 
lived  experience  and  groups  representing  them,  charities  and  voluntary  sector 
organisations  involved  in  the  provision  of  services  in  this  area,  clinical  experts  and 
Royal Colleges. 

The Framework includes five actions, resources and case studies to help healthcare 
systems develop plans that can support people who are taking medicines associated 
with dependence and withdrawal symptoms including opioids by:   

•  Optimising  personalised  care  for  adults  who  are  prescribed  medicines 

associated with dependence or withdrawal symptoms.  

• 

Informing ICB 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.    

•  Adopting  a  whole  system  approach  and  pathways 

involving  multiple 
interventions, to improve care for people prescribed medicines associated with 
dependence and withdrawal symptoms.  

Additionally, NICE has published guidelines on:  

•  Chronic pain (primary and secondary) in over 16s: assessment of all chronic 
pain  and  management  of  chronic  primary  pain (including  guidance  on 
pharmacological management and the use of opioids for chronic primary pain). 

•  Medicines  associated  with  dependence  or  withdrawal  symptoms:  safe 

prescribing and withdrawal management for adults.   

Overprescribing guidance 

The National overprescribing review report was published in September 2021 and it 
evaluated  the  extent,  causes  and  consequences  of  overprescribing  and  made  20 
recommendations to address it. NHS England and partner organisations have been 
implementing the review’s recommendations over the past 3 years, aiming to achieve 
long  term  sustainable  reductions  to  overprescribing  via  delivery  of  systemic  and 
cultural improvements within the NHS.   

 A number of interventions are being delivered by NHS England to address and reduce 
overprescribing including:  

•  Publication of the National medicines optimisation opportunities for the NHS in 
for  chronic  non-cancer  pain 
to  select 

ICBs  have  been  encouraged 

includes  an  opportunity 

2024/25,  which 
management  without  opioids. 
opportunities for delivery.  

•  Support for delivering Structured Medication Reviews (SMR).   

•  A national programme to offer non-pharmacological alternatives such as social 
prescribing,  as  well  as  funding  for  social  prescribers  through  the  Additional 
Roles Reimbursement Scheme (ARRS).  Social prescribing is demonstrated to 
support patients in addressing wider determinants of health which may be an 
underlying or contributory factor to the inappropriate use of medication.  

Other developments 

The  NHS  Medicines  Safety  Improvement  Programme (which  forms  a  key  part  of 
the NHS  Patient  Safety  Strategy)  is  also  delivering  a  focused  programme  of  work 
relating to the improved care of people with chronic pain and a reduction in the use of 
prescribed  opioids.  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.  

In  2022/23,  18  Integrated  Care  Systems  received  intensive  support  to  develop  and 
implement  improvements  in  care,  with  a  further  15  participating  in  shared  learning 
events.  

Specialist commissioned service 

The commissioning of services to support people with chronic pain (including services 
to  support  people  to  safely  withdraw  from  prescribed  medicines  that  may  cause 
dependence and withdrawal) now lies with ICBs as a delegated specialised service. 
NHS England expects ICBs to commission appropriate services to meet the needs of 
the population that each ICB geographically covers. This includes taking due regard 
of the above national commissioning and clinical guidance. A multi-disciplinary team 
(MDT) approach is needed with input from, for example, pain specialists, dependence 
services, mental health services and peer support groups. I note that your Report has 
also been addressed to Mid and South Essex ICB and trust that they will be able to 
respond further on this issue.  

I  would  also  like  to  provide  further  assurances  on  the  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  events,  such  as  the  sad  death  of 
Michael, are shared across the NHS at both a national and regional level and helps 
us to 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,  

Co-National Medical Director 
(Primary Care)

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