Prevention of Future Deaths reports · 2023

Paige Allen

Regulation 28 report to prevent future deaths, reference 2026-0249, written 26 May 2023. A coroner writes one of these when an inquest reveals a risk that could cause further deaths unless something changes.

Date of report26 May 2023
Reference2026-0249
DeceasedPaige Allen
CoronerGraeme Hughes
Coroner areaSouth Wales Central
Sourcejudiciary.uk record
Responses published1

The report

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

GRAEME HUGHES

HIS MAJESTY’S
SENIOR CORONER

SOUTH WALES CENTRAL 
CORONER AREA 

CORONER’S OFFICE

THE OLD COURTHOUSE

COURTHOUSE STREET

PONTYPRIDD

CF37 1JW

Telephone: 01443 281100
Facsimile: 01443 485862
Email: Coroneradmin@rctcbc.gov.uk

ANNEX A

REGULATION 28:  REPORT TO PREVENT FUTURE DEATHS (1)

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

REGULATION 28 REPORT TO PREVENT FUTURE DEATHS

THIS REPORT IS BEING SENT TO:

– Chief Executive Cwm Taf Health Board

CORONER

I am Graeme D Hughes Senior Coroner, Area of South Wales Central.

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 4 May 2021 I commenced an investigation into the death of Paige Jeanette ALLEN . The 
investigation concluded at the end of the inquest 25/05/2023. The conclusion of the inquest 
was Misadventure.

The medical Cause of Death determined to be:-

1a   Multiple Blunt Force Injuries

1

2

3

1b   

1c   

 II    

Coroner’s Office, The Old Courthouse, Courthouse Street, Pontypridd, CF37 1JW

Phone/Ffôn  (01443) 281100       Fax/Ffacs  (01443) 485862

 
 
 CIRCUMSTANCES OF THE DEATH

4

Paige Allen had a diagnosis of Emotionally Unstable Personality Disorder. Symptoms of 
this disorder included impulsive risk-taking behaviour at times of high anxiety. On the late 
evening of 20.4.21 into the early hours of 21.4.21 she has travelled to Southerndown Cliffs, 

. She has contacted 
the emergency services who have attended and attempted a rescue. It is more likely than 
not, that during the same she has lost her footing, her ability to remain in position and 
fallen to her death. Her death was confirmed at 3.07am on 21.4.21. At the time that she left 
the cliff edge it was not found that she deliberately did so.

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. 

Whilst I did not find that the matter of concern outlined below was directly causative of, nor 
contributory to, Miss Allen’s death, my concern broadly is that those patients who contact 
mental health services in Cwm Taf Morgannwg University Health Board (CTMUHB), 
especially at the time of crisis may be assessed without the assessing practitioner having 
immediate & comprehensive access to relevant and proximate medical records, notes & 
plans (such as WARRN assessments, & Care & Treatment Plans).

5

More particularly, the evidence indicated that should a patient present to mental health 
services in the Bridgend locality, but have their secondary mental health care managed in 
either the Merthyr/Cynon locality or the Rhondda/Taff/Ely locality or vice versa, the 
assessing practitioner will not immediately i.e. at the time of assessment, have access to 
that patient’s FACE records.

My concern is that this has the potential to deprive the assessing practitioner of pertinent 
and proximate material which may increase the risk of an incomplete or insufficient 
assessment.

That being potentially significant in informing the assessing practitioner of his/her 
action/planning for that individual in crisis.

Whilst I received evidence that CTMUHB has pledged to adopt a system, which it is 
believed will ameliorate the current situation, I am concerned that until such time as the 
same is available and immediately accessible across the three localities, the risk identified 
persists.

Interim measures may wish to be considered to mitigate the risk identified.

Coroner’s Office, The Old Courthouse, Courthouse Street, Pontypridd, CF37 1JW

Phone/Ffôn  (01443) 281100       Fax/Ffacs  (01443) 485862

 
 
 
 
 
 
 6

7

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 21st July 2023 only 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.

COPIES and PUBLICATION

I have sent a copy of my report to family who may find it useful or of interest.

Also to HeaIth inspectorate Wales and the Health Minister

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.

 26 May 2023 

SIGNED:  

9

  for South Wales Central Coroner Area 

Coroner’s Office, The Old Courthouse, Courthouse Street, Pontypridd, CF37 1JW

Phone/Ffôn  (01443) 281100       Fax/Ffacs  (01443) 485862

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 Cwm Taf Morgannwg University Health Board
Cyfeiriad Dychwelyd/ Return Address: 
Bwrdd Iechyd Prifysgol 
Cwm Taf Morgannwg 
Pencadlys  
Parc Navigation, 
Abercynon  
CF45 4SN 

Cwm Taf Morgannwg 
University Health Board  
Headquarters 
Navigation Park 
Abercynon 
CF45 4SN 

Eich cyf/Your Ref: 

Dyddiad/Date: 

21 July 2023 

Mr G Hughes  
Senior Coroner  
South Wales Central  
Coroner’s Office  
The Old Courthouse  
Courthouse Street  
Pontypridd  
CF37 1JW  

Dear Mr Hughes  

Regulation 28 Report to Prevent Future Deaths  

I  am  writing  in  response  to  the  Regulation  28  Report  issued  to  Cwm  Taf 
Morgannwg  University  Health  Board  (CTMUHB)  on  26  May  2023      following 
conclusion of the inquest into the death of Ms Paige Allen, whilst under the care 
of Merthyr and Cynon Community Mental Health Services.  

the  assessing  practitioner  having 

The Regulation 28 report outlines the Coronial  concern  that patients who contact 
mental  health  services  in  CTMUHB,  especially  at  the  time  of  crisis,  may  be 
immediate  and  
assessed  without 
comprehensive  access  to  relevant  and  proximate  medical  records,  notes  and 
plans. More particularly, that should a patient present to mental health services 
in the Bridgend locality, but have their secondary mental health care managed in 
either the Merthyr and Cynon (M&C) locality or the Rhondda, and Taff Ely (RTE) 
locality or vice versa, the assessing practitioner will not immediately have access 
to that patient’s records.  

Cadeirydd/Chair: Jonathan Morgan Prif Weithredwr/Chief Executive: Paul Mears 

Croeso i chi gyfathrebu â’r bwrdd iechyd yn y Gymraeg neu'r Saesneg. Byddwn yn ymateb yn yr un iaith a ni fydd hyn yn arwain at oedi. 
You are welcome to correspond with the Health Board in Welsh or English. We will respond accordingly and this will not delay the response. 

https://ctmuhb.nhs.wales  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 At the time of Paige’s death the multiplicity of patient records across the localities 
was a known risk, and mitigation as it was at the time, was managed under the 
scrutiny  of  the  locality  Quality  Risk  Safety  and  Patient  Experience  (QSRE) 
meetings that were in place to provide assurance around clinical and patient risk 
matters. Patient records were variously recorded and stored in a mix of paper and 
electronic  systems  that  were  not  necessarily  known  to  all  staff,  and  service 
specific information systems were not able to support contemporaneous entries 
in  health  records  that  would  be  accessible  to  all  multi-disciplinary  team  staff 
across the mental health service. 

Subsequent to the tragic death of Paige, the Health Board has commenced on a 
programme  of  significant  structural  reorganisation  which  has  resulted  in  the 
reformation  of  a  pan  organisational  Mental  Health  Care  Group.  This  has  given 
clinicians  and  operational  managers  the  opportunity  to  begin  to  address  the 
conditions  that  lead  to  inconsistency  of  approaches  of  record  keeping  and 
information  sharing.  A  key  development  of  the  Care  group  has  been  the 
establishment  of  a  Quality  Improvement  Programme  with  a  number  of 
workstreams, most pertinently a High Quality Clinical Record (HQCR) group which 
has core goals of putting in place the actions to ameliorate the risks that come 
from  multiple  health  records  and  systems  and,  in  time,  eliminating  those  risks 
through the instigation of a Single Clinical Record.  

Chaired by the Clinical Service Group manager for Merthyr and Cynon Locality, 
with a multidisciplinary group from across CTM, the HQCR has aligned this work 
with  the  recommendations    and  learning  from  recent  external  reviews  most 
particularly  the  May  2022  Health  Inspectorate  of  Wales  (HIW)  Review  of 
Discharge Arrangements for Adults from Inpatient Mental Health Services within 
CTMUHB. A programme of work is underway to: 

  Standardise  approaches  to  the  management  of  paper  records  if  these  are 

required 

  Maximise risk mitigations for existing processes 
  Undertake a scoping exercise to phase out paper notes ensuring that the Care 
Group  maximises  the  use  of  existing  digital  systems  prior  to  the 
implementation of the Single Electronic Record.   

  Learn from the clinical record improvement at Ty Llidiard, regional Child and 
Adolescent Mental Health (CAMHS) in-patient service, whilst recognising that 
the wider care group has additional challenge in terms of scale and complexity. 

The immediate mitigating actions of the HQCR included the review of all paper 
and electronic archives and systems to ensure that there was a congruence of all 
care  planning  documentation  for  inpatients  and  outpatients.  This  ensures, 
through  the  use  of  only  approved  Inpatient  Management  Plan  and  Care  and 
Treatment  Plan  (CTP),  that  all  staff  are  clear  on  what  documents  should  be 
available  to  them  when  seeking  them  out.    In  addition,  governance  measures 
were introduced to limit   access to any patient information held on the W and T 
electronic drives, with   senior level authorisation required in order to gain access,   

 
 
 
 
 
 
 
 
 
  
 the purpose of this measure being to limit variation and potential for confusion 
when accessing information   

The  HQCR  group  has  undertaken  process  mapping  regarding  passing  patient 
information between Community Mental Health Team (CMHT) and Inpatient for 
admission and discharge developing flow diagrams that have been   shared across 
the Care Group. They have also developed a number of user guides on how to 
access and use FACE/w-drive when accessing RTE and M&C records. At present 
the Mental Health teams will continue to use email to share information between 
RGH and Bridgend but now a secure email inbox is used at all times to ensure 
confidentiality but also simplifying access and gathering of information. 

As a mitigation for  the multiple record system that are still in place across the 
CTM  Mental  Health  service  the  HQCR  Workstream  has  developed  a  Clinical 
Information Access and Recording  matrix (CIARM) for clinical team /staff access   
(“who accesses what system for what purpose”) for all systems across the mental 
health service. This informs all clinical staff of how  to access patient clinical risk 
and discharge planning information both in and out of hours  and is the primary 
tool by which the care Group will mitigate the potential risks inherent with our 
present multiple systems.  

The CIARM covers all clinical areas and teams and will be accessible through the 
Health Board SharePoint (CTMUHB intranet) system for ease of access from every 
CTM desktop. A simple Standard operational procedure accompanies the matrix.   
Local copies have been copied, laminated and distributed to all inpatient units and 
unscheduled mental health assessment teams and strict version control will be 
maintained by the HQCR group. 

The  ongoing  implementation,  audit  and  development  of  future  mitigating 
processes  will  be  reported/escalated  routinely  by  the  HQCR  group  through  the 
Care Group Governance Framework. 

In  relation  to  the  longer  term  work  to  develop  safe  systems  for  sharing 
information,   I would like to provide assurance that the Executive and Board are 
committed  to  the  implementation  of  a  unified  electronic  record  system  for  the 
Mental  Health  and  Learning  Disabilities  Care  Group,  which  includes  Child  and 
Adolescent Mental Health Services.  

A business case has been developed and endorsed by the Executive. There are 
however  challenges  with  the  preferred  national  system.    The  Health  Board  is 
working closely with Digital Health and Care Wales and other Health Boards as 
part of the review of the national strategic programme for the Welsh Community 
Care Information System.  The outcome of this  review will influence timescales 
for WCCIS implementation for the Health Board. 

In November 2021 the Health Board signed off a deployment order enabling the    
move of 460 existing users accessing Welsh Community Care Information System 
(WCCIS) within the Local Authority over to a health board platform.  However, in  

 
 
 
 
 
 
 
 
 
 
 
 March  2022,  the  project  was  paused  due  to  health  board  infrastructure  and 
resource issues.  

In April 2023, key stakeholders met to recommence the project with, an  initial 
Programme Board meeting in May 2023 with  the Deputy Chief Operating Officer 
for Primary Community and Mental Health and the Director for Digital undertaking 
the joint role of Senior Responsible Officers.  The next meeting is planned for 10 
July 2023, with initial Operational Group to be held on 26 July 2023, chaired by 
the  MHLD  Service  Director  and  co-chaired  by  the  Assistant  Director  of  Digital 
Systems.  

Currently,  planning  is  underway  for  a  pre  implementation  phase  to  bring  all 
existing users, mainly within the CMHT’s who currently use WCCIS via the local 
authorities,  over  to  a  Health  Board  WCCIS  system.  The  timescale  for  this  is 
approx. 6 months, however CTM will be meeting with Aneurin Bevan University 
Health Board on 27 July 2023 to capture lessons learnt from their implementation  

As soon as the above is completed, phase 1 will commence, whereby the rest of  
CMHT Adults and Older Persons and also Tier 4 inpatients for CAMHS are brought 
onboard  as  users.  Phase  2  will  then  see  our  inpatient  and  rehab  units  being 
brought on board; timescales are dependent on point 2.  

The business case is in the process of review, with the lessons from Aneurin Bevan 
seen as key to fully understanding the resources and approach required to best 
move  forward  with  minimal  delay.  In  addition  the  Health  Board  is  working  in 
partnership  with  Health  Education  Improvement  Wales  to  develop  digital 
champion roles to influence and lead digital workforce transformation. 

I  hope  that  this  response  provides  assurance  that  CTMUHB  are  committed  to 
investing in the development and implementation of an integrated single digital 
health record but also developing robust and sound mitigations that fully address 
the concerns in the Regulation 28 Report relating to Paige’s death.  

Please do not hesitate to contact 
Executive Medical Director, if you would like further assurances or if you require 
a meeting to discuss any arising areas of continuing concern. 

Yours sincerely 

Prif Weithredwr/Chief Executive

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