Standard 7 — Governance & Management
Criteria in this standard
7.2 — Incident Reporting and Root-Cause Investigation
7.3 — Internal Audit, On a Fixed Schedule
7.4 — Complaints Logged, Investigated, Closed
7.5 — Management Review, With Minutes and Actions
Named Accountable Clinical Lead
Non-Negotiable
In plain terms: One real, current person is clearly on the hook for the organization’s clinical quality and safety — not a title left over from someone who’s since moved on.
| Transport category | Standalone MTO | Hospital-operated | Ambulance service |
|---|---|---|---|
| Applicability | Full | Full | Full |
Why this matters
A clinical lead title left unassigned after someone departs creates exactly the accountability gap that becomes visible only when something goes wrong and the honest answer to “who owns this” is uncertain. Authority to halt an unsafe transport needs to be genuinely exercisable, not merely written into a job description that’s never actually been tested in practice.
What good looks like
- A current, verifiable individual holds the role, matching employment records.
- Documented authority to halt an unsafe transport exists and has been exercised.
- Crew can correctly name this person without hesitation.
Common failure modes
- A named lead has left the organization and the title was never reassigned.
- Halt authority exists on paper but has never actually been exercised.
- Crew give inconsistent answers about who holds this accountability.
Worked example
If you are starting from zero — do this first
- Check who is actually named as clinical lead and confirm current employment.
- Issue or update a formal appointment letter with explicit halt authority.
- Brief crew directly, not relying on an organizational chart update alone.
Self-assessment questions
Evidence: Current employment record, appointment letter
Evidence: Signed delegation of authority
Evidence: Crew interview
Evidence: Governance role documentation
Evidence: Mission/values statement
Common reasons for a PARTIAL answer
- An acting lead functions informally without a formal appointment letter.
- Halt authority is assumed rather than explicitly documented.
Implementation plan
| When | What |
|---|---|
| Week 1 | Verify who is actually, currently accountable. |
| Week 2 | Issue or update the formal appointment letter with explicit authority. |
| Week 3 | Brief all crew directly and update the organizational chart. |
| Ongoing | Review this appointment whenever the role changes hands. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| ASK | Crew interview | Asks crew members separately who holds clinical accountability, without prompting. |
Evidence base
Incident Reporting and Root-Cause Investigation
Non-Negotiable
In plain terms: Every incident is logged in one place and genuinely investigated for the real reason it happened — not just “crew error” — with fixes actually tracked through to done.
| Transport category | Standalone MTO | Hospital-operated | Ambulance service |
|---|---|---|---|
| Applicability | Full | Full | Full |
Why this matters
“Crew error” as a complete investigation finding is almost always incomplete — what allowed the error to occur is the genuine root cause, and stopping short of identifying it leaves the underlying condition fully intact to produce the same failure again. Fragmented, informal incident tracking across different staff members makes any real trend analysis or systematic investigation effectively impossible.
What good looks like
- A single incident log captures every reported event.
- Investigation identifies root cause beyond “crew error.”
- Corrective action is tracked to actual completion with a named owner.
Common failure modes
- Incidents are tracked informally across different staff, nothing centralized.
- Investigation stops at “crew error” with no deeper analysis.
- Corrective actions are agreed but never tracked through to completion.
Worked example
If you are starting from zero — do this first
- Build a single, centralized incident log if none exists.
- Review recent incidents for root-cause depth beyond “crew error.”
- Add a corrective action tracker with named owners and completion dates.
Self-assessment questions
Evidence: Incident log
Evidence: Investigation record
Evidence: Corrective action tracker
Common reasons for a PARTIAL answer
- Investigations stop at the first obvious explanation.
- Corrective actions are agreed verbally but not formally tracked.
Implementation plan
| When | What |
|---|---|
| Week 1 | Build or consolidate a single incident log. |
| Week 2 | Train investigators on basic root-cause technique. |
| Week 3 | Build a corrective action tracker with owners and dates. |
| Ongoing | Review incident trends for recurring patterns. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| DOCUMENT | Incident and corrective action review | Selects a recent incident and assesses root-cause depth and corrective action completion. |
Evidence base
Internal Audit, On a Fixed Schedule
Core
In plain terms: Every base location gets genuinely audited on a real schedule — not just the main office, with a satellite base conveniently skipped.
| Transport category | Standalone MTO | Hospital-operated | Ambulance service |
|---|---|---|---|
| Applicability | Full | Full | Full |
Why this matters
A satellite or remote base location excluded from audit scope, often simply because it’s less convenient to reach, creates exactly the kind of blind spot where gaps accumulate unnoticed. Audit findings need enough genuine detail for someone outside the audit to understand what was actually checked, rather than a checklist of ticks with no real substance behind it.
What good looks like
- The audit schedule explicitly covers every base location.
- The most recent audit actually happened on or near its scheduled date.
- Audit findings are detailed enough for someone outside the audit to understand.
Common failure modes
- A remote or satellite base is quietly excluded from audit scope.
- Audits slip significantly behind schedule with no tracking of the slippage.
- Findings are a checklist of ticks with no real substantive detail.
Worked example
If you are starting from zero — do this first
- List every base location the organization operates.
- Check which of these your current or most recent audit actually covered.
- Build a multi-year cycle that explicitly includes every location.
Self-assessment questions
Evidence: Audit schedule
Evidence: Audit completion records
Evidence: Audit report
Common reasons for a PARTIAL answer
- A satellite location was never explicitly added to audit scope.
- Audits happen but findings are too brief to act on.
Implementation plan
| When | What |
|---|---|
| Week 1 | List every base location requiring audit coverage. |
| Week 2 | Build a multi-year cycle with explicit scheduled dates for each. |
| Week 3 | Share the schedule and assign an auditor to the first session. |
| Ongoing | Track schedule adherence and escalate any slippage. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| DOCUMENT | Schedule and report review | Checks the audit schedule’s completeness against all actual base locations. |
Evidence base
Complaints Logged, Investigated, Closed
Core
In plain terms: Every complaint, from anyone, gets written down in one place, actually investigated, and the person who complained finds out what happened.
| Transport category | Standalone MTO | Hospital-operated | Ambulance service |
|---|---|---|---|
| Applicability | Full | Full | Full |
Why this matters
A complaint resolved verbally in the moment, with nothing logged, is effectively invisible to the organization’s quality system — it cannot inform trend analysis or prevention, and leaves no record the concern was genuinely taken seriously. Complaints from receiving facilities about handover quality or communication are a particularly direct, valuable signal for this kind of organization, and are easy to lose if not formally captured.
What good looks like
- A single complaints register captures every complaint, regardless of source.
- Each entry has a documented investigation outcome.
- The complainant is informed of the outcome where contact exists.
Common failure modes
- Complaints handled verbally in the moment are never logged.
- Receiving facility complaints about handover quality go uncaptured.
- A complaint is received but the outcome is never communicated back.
Worked example
If you are starting from zero — do this first
- Build a single complaints register covering all sources, including receiving facilities.
- Brief crew that informal feedback still counts and needs logging.
- Build a step to close the loop with the complainant.
Self-assessment questions
Evidence: Complaints register
Evidence: Investigation outcome record
Evidence: Callback or communication record
Common reasons for a PARTIAL answer
- Informal feedback from receiving facilities isn’t consistently logged.
- Outcomes aren’t consistently communicated back to complainants.
Implementation plan
| When | What |
|---|---|
| Week 1 | Build or consolidate a single complaints register. |
| Week 2 | Brief crew that informal feedback requires formal logging. |
| Week 3 | Add a required closing-the-loop step. |
| Ongoing | Trend complaint types quarterly for recurring themes. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| DOCUMENT | Register review | Selects a logged complaint and verifies investigation outcome and complainant communication. |
Evidence base
Management Review, With Minutes and Actions
Standard
In plain terms: Leadership genuinely sits down once a year, looks at real incident and complaint data, writes down what they decided, and someone checks those decisions actually get done.
| Transport category | Standalone MTO | Hospital-operated | Ambulance service |
|---|---|---|---|
| Applicability | Full | Full | Full |
Why this matters
Management review is where quality data is meant to actually reach the people with authority to allocate resources and set direction. A review that covers operational and budget matters thoroughly while quality-specific inputs — incidents, complaints, audit findings — get only a passing mention isn’t functioning as a genuine quality review, regardless of how well-attended the meeting is.
What good looks like
- Documented minutes with named attendees exist for the most recent cycle.
- Minutes specifically cover incidents, complaints, and audit findings.
- Output actions from the previous review are traceable to completion.
Common failure modes
- Review happens but focuses on operations and budget, not quality inputs.
- No written minutes exist, just a verbal assurance it happened.
- Agreed actions from the previous review were never followed up.
Worked example
If you are starting from zero — do this first
- Set a fixed annual date for the formal management review.
- Build an agenda explicitly covering incidents, complaints, and audit findings.
- Take real minutes and assign owners to every output action.
Self-assessment questions
Evidence: Signed meeting minutes
Evidence: Meeting agenda and minutes
Evidence: Action tracker
Common reasons for a PARTIAL answer
- Minutes exist but omit specific coverage of quality inputs.
- Actions are agreed verbally but never tracked to closure.
Implementation plan
| When | What |
|---|---|
| Week 1 | Set the annual review date and build a structured agenda template. |
| Week 2 | Gather required inputs — incident, complaint, and audit data. |
| Week 3 | Hold the review, take formal minutes, assign action owners and dates. |
| Ongoing | Track output actions to completion before the next cycle. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| DOCUMENT | Minutes and action tracker review | Confirms minutes cover required quality inputs and checks prior action completion status. |