2026/1929

1. Complaints relating to interpreting services

1. How many complaints has the Trust received in the last five years relating to:
   • British Sign Language interpreting
   • No interpreter being booked
   • Communication support failures involving Deaf patients
   • Use of family members or friends instead of qualified interpreters
   • Video Relay Services (VRS) or Video Remote Interpreting (VRI)
2. Please provide a summary of each complaint (redacted where necessary).
3. Please identify whether each complaint was upheld, partially upheld or not upheld.
4. Please provide copies of any investigation reports or lessons learned.

2. Incident Reporting (Datix)

1. How many Datix (or equivalent incident reports) have been recorded relating to:

• No interpreter attending
• Communication failures involving Deaf patients
• Delayed diagnosis caused by communication barriers
• Missed appointments because communication support was unavailable
• Use of VRS/VRI
• Use of family members to interpret

1. Please provide the grading of each incident.
2. Please provide any associated action plans.

3. Monitoring of the Contract

Please provide:

1. The current Contract Management Plan.
2. All Key Performance Indicators (KPIs).
3. All monthly or quarterly performance reports received from the contractor during the last three years.
4. Minutes from contract review meetings.
5. Copies of any improvement notices, breach notices or contract concerns issued.
6. Any risk registers relating to interpreting services.

4. Booking Process

Please explain:

1. How interpreters are selected.
2. Whether cost forms part of the allocation process.
3. Whether bookings are sent to the lowest-cost interpreter first.
4. Whether interpreters are ranked by fee.
5. Whether hospitals can request named interpreters.
6. Whether continuity of interpreter is monitored.
7. Whether patient preference is recorded and monitored.

5. Qualifications

Please provide:

1. Your policy regarding interpreter qualifications.
2. Whether trainee interpreters are permitted.
3. How qualification status is checked.
4. How NRCPD registration is verified.
5. How professional indemnity insurance is checked.
6. How DBS status is checked.
7. Whether these checks are audited.

6. Accessible Information Standard

Please provide:

1. Evidence of how compliance with the Accessible Information Standard is monitored.
2. Any audits undertaken.
3. Any compliance reports.
4. Any Equality Impact Assessments relating to interpreting services.
5. Any internal audits concerning Deaf patient communication.

7. Video Relay Services (VRS/VRI)

Please provide:

1. Any policy governing when VRS/VRI may be used.
2. Any clinical risk assessment.
3. Any Equality Impact Assessment.
4. Any patient safety assessment.
5. Any evidence comparing VRS outcomes with face-to-face interpreting.
6. Guidance given to staff on when VRS is inappropriate.
7. Whether patient preference is recorded before VRS is used.

8. Financial Information

Please provide:

1. The total annual expenditure on:
   • Face-to-face BSL interpreting
   • VRS
   • VRI
2. Any documented cost savings expected from increasing VRS/VRI.
3. Any business cases supporting increased remote interpreting.

9. Accessibility of Complaints

Please provide:

1. A copy of the Trust’s complaints policy in BSL.
2. If no BSL version exists, please confirm this.
3. How Deaf BSL users can submit complaints in BSL.
4. Whether complaint responses are available in BSL.
5. How many complaints have been submitted in BSL during the last five years.
6. Whether the Trust monitors accessibility of its complaints process for Deaf patients.

10. Equality Act Compliance

Please provide:

1. Any Equality Impact Assessment undertaken before awarding the current interpreting contract.
2. Any review of the impact on Deaf patients.
3. Evidence that the Public Sector Equality Duty was considered before changing provider or introducing VRS.

11. Booking Data

For the last three financial years please provide:

• Number of BSL interpreter requests.
• Number fulfilled.
• Number unfilled.
• Number cancelled.
• Number converted to VRS.
• Number converted to VRI.
• Number where family members interpreted.
• Number involving trainee interpreters.
• Average booking notice.
• Average time taken to allocate an interpreter.

12. Contract Compliance

Please provide:

1. Any audits undertaken of the contractor.
2. Evidence that the contractor complied with NHS guidance requiring qualified interpreters.
3. Copies of any service improvement plans.
4. Any reports identifying concerns with contractor performance.

13. Procurement

Please provide:

1. The service specification.
2. Tender evaluation criteria.
3. Weighting given to:
   • Cost
   • Quality
   • Patient safety
   • Equality
   • Interpreter qualifications
4. Any documentation showing how quality was assessed separately from price.

14. Workforce

Please provide:

1. The number of interpreters registered with the contractor.
2. How many are:
   • NRCPD Registered Qualified Interpreters
   • Registered Trainee Interpreters
   • Non-registered
   • Level 6 BSL only
   • Communication Support Workers
3. How these figures are verified by the Trust.
4. Number of jobs allocated to each qualification level

15. Evidence that cost is not driving allocation

Please provide any documentation demonstrating that:

• interpreter allocation decisions are not based primarily on cost;
• local qualified interpreters have not been bypassed solely because they requested higher fees;
• hospitals have not been informed that “no interpreter was available” where the actual reason was a fee dispute or inability to secure an interpreter at the contractor’s preferred rate;

the Trust audits whether unfilled bookings are due to workforce shortages or commercial decisions by the contractor.

Please see details within the attached workbook/spreadsheet and supporting documents to support a response to the questions within this FOI. It is important to note that NHS Greater Manchester Integrated Care Board is not a Trust, it is a commissioning organisation. The ICB only funds the commissioning of Interpretation and Translation services for Primary Care as this is delegated funding from NHS England for this purpose. As such, we hold limited information but have provided what we do hold.

NHS Trusts fund and provide access to Interpretation and Translation Services for patients who are using hospital-based services.

Bolton NHS Foundation Trust – Freedom of information – Bolton NHS FT (boltonft.nhs.uk)

Northern Care Alliance NHS Foundation Trust – Freedom of Information Requests :: Northern Care Alliance

Manchester University NHS Foundation Trust – Freedom of Information – Manchester University NHS Foundation Trust (mft.nhs.uk)

Stockport NHS Foundation Trust – Freedom of information – Stockport NHS Foundation Trust

Tameside and Glossop Integrated Care NHS Foundation Trust – Freedom of Information Requests :: Tameside and Glossop Integrated Care (tamesideandglossopicft.nhs.uk)

Wrightington, Wigan and Leigh Teaching Hospitals NHS Foundation Trust – WWL Teaching Hospitals NHS Foundation Trust | FOI Disclosure Log

The Christie NHS Foundation Trust – Freedom of information disclosure logs (christie.nhs.uk)

Pennine Care NHS Foundation Trust – Freedom of Information :: Pennine Care NHS Foundation Trust

Greater Manchester Mental Health NHS Foundation Trust – Freedom of Information | Greater Manchester Mental Health NHS FT (gmmh.nhs.uk)

The ICB has not been operational for five years and therefore can only respond based upon the information it holds since the formation of Integrated Care Boards which was July 2022.

The contractual arrangements currently are based upon historical arrangements held under the previous 10 Greater Manchester Clinical Commissioning Groups. Many of the existing providers hold the information themselves and there are differences / inconsistencies in how their data is provided and contract managed across the 10 localities.