Enterprise-wide Risk Management
Summary This Policy Directive describes the requirements for NSW Health organisations to
establish, maintain and monitor risk management practices in accord with the
Australian/New Zealand Standard ISO 31000:2018, consistent with whole of
Government policies.
Document type Policy Directive
Document number PD2022_023
Publication date 01 July 2022
Author branch Corporate Governance & Risk Management Unit
Branch contact (02) 9391 9654
Replaces PD2015_043
Review date 01 July 2027
Policy manual Not applicable
File number H22/33301
Status Active
Functional group Corporate Administration – Governance
Applies to Ministry of Health, Public Health Units, Local Health Districts, Board Governed
Statutory Health Corporations, Chief Executive Governed Statutory Health
Corporations, Specialty Network Governed Statutory Health Corporations, Affiliated
Health Organisations, NSW Health Pathology, Public Health System Support Division,
Cancer Institute, NSW Ambulance Service, Dental Schools and Clinics, Public
Hospitals
Distributed to Ministry of Health, Public Health System, NSW Ambulance Service
Audience Boards;All Chief Executives;Directors;Health Service Managers;Audit and Risk
Committees
Policy Directive
Secretary, NSW Health
This Policy Directive may be varied, withdrawn or replaced at any time. Compliance with this directive is
mandatory for NSW Health and is a condition of subsidy for public health organisations.
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POLICY STATEMENT
All NSW Health organisations must establish and maintain a risk management framework
that is appropriate, fit for purpose, and tailored to the needs of the organisation.
SUMMARY OF POLICY REQUIREMENTS
All staff (permanent, temporary or contract) are accountable for managing risk in their day-today roles, including carrying out their roles in accordance with policies and procedures,
identifying risks and inefficient or ineffective controls and reporting these to the appropriate
level of management.
Managers and decision makers at all levels in NSW Health organisations are accountable for
managing risk within their sphere of authority and in relation to the decisions they take.
In addition to the responsibilities above, senior executives are responsible for managing
specific strategic risks as the risk owner and are responsible for ensuring necessary controls
and treatment plans are in place to effectively manage that risk, including providing adequate
resources.
The Chief Executive officer has ultimate responsibility and accountability for risk
management in their organisation.
All staff are to contribute to a positive risk culture that encourages desirable risk management
behaviours such as open and regular discussion of risk, with concerns about business
practices raised and acted upon promptly.
NSW Health organisations are to nominate or appoint an appropriately skilled Chief Risk
Officer who is responsible for the oversight and promotion of risk management; for designing
the risk management framework; and for the oversight of activities associated with
coordinating, maintaining and embedding the framework.
All NSW Health organisations must have an enterprise-wide risk management procedure in
place that outlines how the organisation will identify, assess, manage and monitor risks. It
must include processes for escalating risks and for providing risk reports to the senior
executive team, the Chief Executive, the Audit and Risk Committee and Board.
The organisation’s risk appetite and risk tolerance are to be documented, communicated and
regularly reviewed.
Risk owners must reduce a risk to an acceptable level through implementing additional
controls or improving existing controls. Where the current level of a risk is outside the
organisation’s risk tolerance, it is to be escalated to more senior levels of management.
Where a NSW Health organisation is unable to manage a risk to be within its tolerance
levels, the risk is to be escalated to the Ministry of Health for further advice or support. The
Enterprise-wide Risk Management
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ownership and management of a risk that has been escalated remains the responsibility of
the health organisation.
All NSW Health organisations are to maintain a risk register which provides an accurate and
complete record of risk assessment and management activities. The risk register is to be
subject to regular review and update as risks are addressed and new risks identified.
The NSW Health risk matrix must be used by all NSW Health organisations when assessing
risk.
Where a new or emerging risk that has the potential to be system-wide is identified, the
organisation is to complete a Potential System-wide Risk Notification Form, have it approved
by the Chief Executive, and forward it to the Ministry of Health’s Corporate Governance and
Risk Management Unit.
Risk management and reporting is to be a standing agenda item for senior executive team
meetings, for Audit and Risk Committee meetings, and for Board meetings.
Reporting is to be appropriate for the size and complexity of the organisation and must
periodically include the number of risks that are operating outside the organisation’s risk
tolerance and the number of risks that are overdue for review.
The organisation’s risk management framework must be the subject of an internal audit at
least once every five years.
An Internal Audit and Risk Management Attestation Statement is to be submitted to the
Ministry of Health by 17 July each year, stating whether the NSW Health organisation has
complied with this Policy Directive and the NSW Health Policy Directive Internal Audit
(PD2022_022).
REVISION HISTORY
Version | Approved By | Amendment Notes |
PD2022_023 July – 2022 |
Secretary, NSW Health | Updated to support development and implementation of organisation-appropriate risk management frameworks. |
PD2015_043 (October 2015) |
Deputy Secretary, Governance, Workforce and Corporate |
Updated policy directive |
PD2009_003 (June 2009) |
Director General | New policy directive |
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CONTENTS
1 BACKGROUND …………………………………………………………………………………………………………….. 3
1.1 About this document…………………………………………………………………………………………………. 3
1.2 Key definitions …………………………………………………………………………………………………………. 4
1.3 Legal and legislative framework…………………………………………………………………………………. 4
2 RISK MANAGEMENT RESPONSIBILITIES …………………………………………………………………….. 5
2.1 Responsibilities of staff……………………………………………………………………………………………… 5
2.2 Managers and decision makers …………………………………………………………………………………. 5
2.3 Senior executives …………………………………………………………………………………………………….. 5
2.4 The Chief Risk Officer ………………………………………………………………………………………………. 5
2.5 Internal Audit……………………………………………………………………………………………………………. 6
2.6 The Chief Executive………………………………………………………………………………………………….. 6
2.7 Audit and Risk Committee…………………………………………………………………………………………. 6
2.8 The Board ……………………………………………………………………………………………………………….. 6
3 ENTERPRISE-WIDE RISK MANAGEMENT FRAMEWORK………………………………………………. 6
3.1 Risk culture ……………………………………………………………………………………………………………… 7
3.2 Risk appetite and risk tolerance …………………………………………………………………………………. 7
4 RISK MANAGEMENT METHODOLOGY …………………………………………………………………………. 8
4.1 Risk identification……………………………………………………………………………………………………… 8
4.1.1 Risk categories………………………………………………………………………………………………….. 9
4.1.2 Risk register………………………………………………………………………………………………………. 9
4.1.3 Identification of potential system-wide risks ………………………………………………………….. 9
4.1.4 Notification of risks to other NSW Health organisations………………………………………… 10
4.2 Risk assessment…………………………………………………………………………………………………….. 10
4.2.1 NSW Health risk matrix …………………………………………………………………………………….. 11
4.3 Risk treatment and escalation ………………………………………………………………………………….. 12
4.3.1 Escalation of organisation-level risks to the Ministry of Health ………………………………. 12
4.4 Monitor and review …………………………………………………………………………………………………. 12
4.4.1 Monitoring and reviewing individual risks ……………………………………………………………. 12
4.4.2 Executive monitoring and reporting ……………………………………………………………………. 13
5 ATTESTATION STATEMENT……………………………………………………………………………………….. 13
5.1 Annual attestation of compliance ……………………………………………………………………………… 13
5.2 Requesting an exception to policy requirements ………………………………………………………… 13
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6 GLOSSARY OF TERMS ………………………………………………………………………………………………. 14
7 APPENDICES ……………………………………………………………………………………………………………… 15
7.1 Recommended risk categories and areas of risk to consider within the categories ………… 15
7.1.1 Clinical care and patient safety ………………………………………………………………………….. 15
7.1.2 Financial management……………………………………………………………………………………… 15
7.1.3 Governance and performance …………………………………………………………………………… 15
7.1.4 Health of the population ……………………………………………………………………………………. 16
7.1.5 Infrastructure …………………………………………………………………………………………………… 16
7.1.6 Legal………………………………………………………………………………………………………………. 16
7.1.7 People and culture …………………………………………………………………………………………… 16
7.1.8 Reputation ………………………………………………………………………………………………………. 17
7.1.9 Service delivery ……………………………………………………………………………………………….. 17
7.1.10 Work health & safety ………………………………………………………………………………………… 17
7.2 Recommended risk register data fields……………………………………………………………………… 18
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1 BACKGROUND
Risk is the effect of uncertainty on objectives. Risk management involves identifying the
types of risk exposure within an organisation, measuring those potential risks and proposing
means to mitigate or exploit them.
Risk management is essential to good management practice and effective corporate
governance and ensures decisions are made with sufficient information about risks and
opportunities. While it is impossible to remove all risk, the overall goal is to identify,
understand, manage and reduce risk to an acceptable level, to ensure effective operation,
service provision and resource utilisation across an organisation.
Risk is different from an issue, which is an event that has already occurred, or is currently
occurring, and is impacting, or has had an impact, on objectives.
Effective policies and systems combined with a sound risk culture help to promote desirable
risk management behaviour. These behaviours are reflected in the open and regular
discussion of risk which incorporates genuine risk concerns about business practices and the
timeliness of responses. Collectively, these behaviours help organisations stay within an
organisation’s risk appetite and achieve performance aspirations in a sustainable way.1
NSW Health is committed to developing a positive risk management culture, where risk is
seen as integral to the achievement of our aims at all levels of the organisation and where all
staff are alert to risks, capable of an appropriate level of risk assessment and confident to
report risk or opportunities perceived to be important in relation to each Health organisation’s
priorities.
1.1 About this document
This Policy describes the minimum requirements for NSW Heath organisations in
implementing and maintaining an enterprise-wide risk management framework. It is
complementary to the NSW Health Internal Audit Policy Directive (PD2022_022) and
consistent with AS/NZS ISO 31000:2018 Risk Management – Guidelines.
While NSW Treasury’s Internal Audit and Risk Management Policy for the General
Government Sector (TPP20-08) is only applicable to the Ministry of Health, the Mental Health
Commission, Health Professional Councils and the Health Care Complaints Commission, this
Policy Directive has been developed to align with the Core Principles and Core Requirements
outlined in TPP20-08.
1 1 Arzadon, E., Du Preez, R. and Sheedy, E., 2021. Auditing Risk Culture: A practical guide. [ebook] Sydney: Institute of Internal
Auditors – Australia. Available at https://www.iia.org.au/technical-resources/publications/auditing-risk-culture—a-practical-guide.
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1.2 Key definitions
Risk | The effect of uncertainty on objectives, noting that effect is a deviation from the expected and may be positive and/or negative. |
Board | In this document, references to “the Board” includes the Board of any local health district, specialty health network, or Board governed statutory health corporation, the Cancer Institute of NSW Board, Ambulance Services Advisory Board, Health Infrastructure Board, HealthShare NSW Board, and NSW Health Pathology Board. |
Current risk | The current amount of risk, after all existing controls are accounted for. |
NSW Health organisation |
A local health district, specialty health network, statutory health corporation, units of the Health Administration Corporation (including the NSW Ambulance Service, HealthShare NSW, eHealth NSW, Health Infrastructure and NSW Health Pathology), and health bodies established under their own statute, including the Cancer Institute of NSW. |
Risk appetite | The amount and type of risk that an organisation is prepared to pursue, retain or take to achieve goals and objectives. |
Risk owner | The manager responsible for ensuring that an identified risk is monitored and reviewed within set timeframes, and that appropriate controls are implemented and maintained. |
Risk tolerance | The assessed and accepted threshold levels of risk exposure that, when exceeded, will trigger a risk response. |
Senior executive | A senior member of the organisation who has management accountability for a core component of the health organisation. Senior executives generally report directly to the chief executive or to another senior executive within the health organisation. |
1.3 Legal and legislative framework
Government Sector Finance Act 2018
Health Services Act 1997
Accounts and Audit Determination for Public Health Entities in NSW
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2 RISK MANAGEMENT RESPONSIBILITIES
2.1 Responsibilities of staff
All staff (permanent, temporary or contract) are accountable for managing risk in their day-today roles, including carrying out their roles in accordance with policies and procedures,
identifying risks and inefficient or ineffective controls and reporting these to the appropriate
level of management.
Risks that are beyond a staff member’s capacity or delegation of authority must be escalated
to a higher level of management for review, with subsequent mitigations communicated back
to the staff member who identified the risk.
2.2 Managers and decision makers
Managers and decision makers at all levels in each NSW Health organisation are
accountable for managing risk within their sphere of authority and in relation to the decisions
they take. Risks that are beyond a manager’s or a decision maker’s capacity or delegation of
authority must be escalated to a higher level of management for review.
Responsibilities also include supporting a positive risk culture, managing risks within the
levels the organisation is willing to accept or tolerate, and supporting the implementation of
the organisation’s risk management framework as appropriate for their role.
2.3 Senior executives
In addition to the responsibilities above, senior executives are responsible for managing
specific strategic risks as the risk owner and are responsible for ensuring necessary controls
and treatment plans are in place to effectively manage that risk, including providing adequate
resources.
Senior executives must attend Audit and Risk Committee meetings, when requested, to
discuss the current management of specific risks.
2.4 The Chief Risk Officer
All NSW Health organisations are to nominate or appoint an appropriately skilled Chief Risk
Officer. This role may be a dedicated role or incorporated as a function of an existing role.
The Chief Risk Officer supports the Chief Executive and is responsible for:
the oversight and promotion of risk management within the organisation
designing the organisation’s enterprise-wide risk management framework
the oversight of activities associated with coordinating, maintaining and embedding the
framework in the organisation.
The Chief Risk Officer role (or function) is to be considered a senior role within the
organisation and be either a member of the organisation’s senior executive, or directly report
to a member of the senior executive team.
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2.5 Internal Audit
Internal Audit is responsible for providing assurance to the Chief Executive and to the
organisation’s Audit and Risk Committee on the effectiveness of the risk management
framework, including the design and operational effectiveness of internal controls.
The organisation’s enterprise-wide risk management framework must be the subject of an
internal audit at least once every five years.
2.6 The Chief Executive
The Chief Executive has ultimate responsibility and accountability for risk management in
their organisation. Risk management-related responsibilities also include promoting a positive
risk culture, determining and articulating the level of risk the organisation is willing to accept
or tolerate, approving the organisation’s enterprise-wide risk management framework and
plans, and ensuring these are communicated, implemented and kept current.
2.7 Audit and Risk Committee
Audit and Risk Committees across NSW Health have no executive powers, delegated
financial responsibility or management functions, but provide independent advice to the Chief
Executive and Board by monitoring, reviewing and providing advice about the organisation’s
risk management framework.
2.8 The Board
The Board is responsible for approving the organisation’s enterprise-wide risk management
framework, including the levels of risk appetite and tolerance, and for seeking appropriate
assurance on the effectiveness of the framework.
3 ENTERPRISE-WIDE RISK MANAGEMENT FRAMEWORK
All NSW Health organisations must establish, implement and maintain an enterprise-wide risk
management framework that is tailored to achieving their strategic and operational plans,
support the delivery of performance objectives, meet business needs and be integrated with
its systems and processes. It must also recognise the organisation’s contribution to broader
state-wide health strategies and objectives, such as the NSW State Health Plan and NSW
Health Strategic Priorities.
The Framework is to be consistent with AS ISO 31000:2018 Risk Management Guidelines
and:
be structured and comprehensive
be customised – the framework and process are customised and proportionate to the
NSW Health organisation’s external and internal context related to its objectives
be inclusive – appropriate and timely involvement of stakeholders enables their
knowledge, views and perceptions to be considered, resulting in improved awareness
and informed risk management
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be dynamic – effective risk management anticipates, detects, acknowledges and
responds to internal and external changes in a timely manner
be based on the best available information – inputs to risk management are based on
historical and current information, future expectations and any associated limitations
and uncertainties
take human and cultural factors into account
involve continual improvement – through learning and experience.
NSW Health organisations must also ensure that the identification and assessment of the
impacts of climate change is integrated into its enterprise-wide risk management framework,
and that the projected impact on assets and services is actively managed and mitigated.
3.1 Risk culture
Risk culture is a crucial element within the framework. Together with effective policies and
systems, sound risk culture encourages desirable risk management behaviours such as open
and regular discussion of risk, with concerns about business practices raised and acted upon
promptly.
All management and staff must support a positive risk culture, where, as a minimum:
Staff are thoughtfully engaged, and risk management is seen as an enabler, rather
than a barrier, for achieving business objectives.
Leaders and managers have a good understanding of the business environment, the
risks that are present, and how they may be changing.
Managers and leaders in the business are good role models of risk management
behaviour, e.g. reporting and resolving risk issues, complying with policies.
People who speak up about risk issues/concerns are valued by managers, their
concerns are taken seriously, and managers respond to their concerns appropriately.
Leaders and managers regularly communicate about risk management, in both formal
and informal ways.2
3.2 Risk appetite and risk tolerance
All NSW Health organisations are to ensure risk appetite and risk tolerances are
documented, communicated and regularly reviewed. The risk appetite statement must be
linked to the organisation’s strategic goals, performance agreement and operational plans,
and have consideration of the organisation’s contribution to broader state-wide health
strategies and objectives, such as the NSW State Health Plan and NSW Health Strategic
Priorities.
In developing or updating risk appetite, NSW Health organisations are to consider the level of
risk appetite, as outlined in Table 1.
2 Arzadon, E., Du Preez, R. and Sheedy, E., 2021. Auditing Risk Culture: A practical guide. [ebook] Sydney: Institute of Internal
Auditors – Australia. Available at https://www.iia.org.au/technical-resources/publications/auditing-risk-culture—a-practical-guide.
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Table 1: Levels of risk appetite
Level | This means there is… |
Zero | No willingness to take on any risk The organisation will not operate in this area. |
Low | A willingness to take on a limited level of risk necessary to achieve goals and objectives The organisation may operate in this area, or in this way, where the value is assessed as worthwhile, after risks have been effectively mitigated or uncertainty minimised. |
Moderate | A willingness to take on a moderate level of risk for benefits linked to goals and objectives The organisation may operate in this area, or in this way, after risks have been effectively mitigated to pursue benefits that enhance strategic outcomes or operational objectives. |
High | A willingness to take on higher levels of risk to maximise gains The organisation may operate in this area, or in this way, after all options are considered and the most appropriate option selected to maximise strategic or operational gains. |
In developing the risk appetite statement, organisations may articulate the level of appetite
for individual risk categories, so long as the approach establishes boundaries for sound
decision making and risk taking.
The organisation’s risk appetite is to be approved by the Chief Executive and by the Board,
on advice from the Audit and Risk Committee.
4 RISK MANAGEMENT METHODOLOGY
All NSW Health organisations must develop and maintain an enterprise-wide risk
management procedure that outlines how the organisation will identify, assess, manage and
monitor risks. It must include a process for escalating risks and for reporting risks to the Chief
Executive and Audit and Risk Committee, and to the Board.
Risk is to be considered and assessed at different levels, across many functions and
activities, as appropriate for the size and complexity of the organisation.
All risk assessments, including their identification, controls, likelihood, consequence, and risk
rating are to be documented consistently across the organisation. Controls embedded within
the organisation’s current business processes are to be identified as part of the risk
evaluation process.
In developing risk management procedures, NSW Health organisations are to ensure an
identified risk can be assessed and rated in the context of the environment in which the risk
was initially identified (i.e., project, ward, unit, service, or facility level), and managed
accordingly.
4.1 Risk identification
NSW Health organisations are to ensure risks are identified by examining sources of risk,
areas of impact, causes and potential consequences of events and scanning the
environment.
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Organisations must ensure there is formal consideration and documentation of risk and
opportunities during:
Strategic, business, service and workforce planning
Budget planning and monitoring
Planning, development and implementation of new service delivery methods,
programs, clinics or projects
Planning, development, implementation and maintenance of new and existing
information technology hardware and software systems
Development and implementation of new or revised policies, procedures and
guidelines
Changes to service delivery, projects or agreed levels of activity
Planning and implementing capital projects and programs
Scoping of, and reporting of findings from, internal audits
Procurement and acquisitions processes.
Risks may also be identified by the risks associated with not pursuing an opportunity.
4.1.1 Risk categories
As part of the risk identification process, all risks must be categorised. Categorising risks
supports identification of risks across the key aspects of a health organisation’s business.
NSW Health organisations may set their own risk categories, use risk categories documented
in earlier policy directives, adopt the recommended risk categories outlined in Appendix 7.1,
or use a mix of all these options.
The risk management categories must be described in the organisation’s enterprise-wide risk
management procedures and included as a field in the risk register.
4.1.2 Risk register
All NSW Health organisations are to maintain a risk register which provides an accurate and
complete record of risk assessment and management activities. The risk register is to be a
‘living document’, subject to regular review and update as risks are addressed and new risks
identified, and as strategies and controls for existing risks are updated. Recommended fields
for inclusion in an organisation’s risk register are included in Appendix 7.2.
4.1.3 Identification of potential system-wide risks
Where an organisation identifies a new or emerging risk that has the potential to be systemwide, the organisation is to complete a ‘Potential System-wide Risk Notification Form’, have it
approved by the Chief Executive, and forward it to the Ministry of Health’s Corporate
Governance and Risk Management Unit via email [email protected].
Forms are available from the NSW Health intranet page.
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In notifying the Ministry, the notification must include a:
Clear and concise description of the risk and its potential system-wide impacts
Clear description of why this has been identified as an emerging or potentially
significant risk for the NSW Health system
Description of the organisation’s main controls and their limitations
Summary of any outcomes from discussions with leads within the organisation, as well
as any advice from the organisation’s Audit and Risk Committee.
Summary of any outcomes from discussions with stakeholders internal to the NSW
Health system, including any feedback from the relevant units within the Ministry of
Health.
System-wide risks that are generally known, or that have controls that are largely effective,
do not need to be reported to the Ministry.
4.1.4 Notification of risks to other NSW Health organisations
Where there are significant risks arising from strategic and operational activities of the
organisation that affect, or are likely to affect, other NSW Health organisations, the Chief
Executive is to formally communicate the risk, and any risk treatment that has been
undertaken to manage the risk, to those affected organisations.
In communicating the risk and risk treatments, the Chief Executive must have regard for the
benefits of sharing information to enable affected health organisations to understand the risk
and mitigations, against increasing the level of risk by sharing certain information.
4.2 Risk assessment
NSW Health organisations must develop and implement a process for assessing identified
risks. The process must reference the use of Table 2 and 3, below, and include:
identifying the causes and sources of the risk
identifying and assessing the effectiveness of existing controls to mitigate the risk
determining the potential consequences and likelihood of the consequences being
experienced.
Through this process, the level of risk is to be determined and compared with the
organisation’s risk tolerance to determine if further controls are needed.
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Table 2: Consequences from a risk occurring
Consequence | Context |
Catastrophic | Unexpected, or potentially preventable, death of multiple persons from the same event or cause; or Substantial reprioritisation of resources to salvage key strategic, operational or performance objectives |
Major | Unexpected, or potentially preventable, death of a person; or Reprioritisation of resources to ensure delivery of key strategic, operational or performance objectives |
Moderate | Major harm to a person (or persons); or Modest reprioritisation of resources to support strategic, operational and/or performance objectives |
Minor | Minor harm to a person (or persons); or Reprioritisation of resources to support delivery of key objectives at a unit- or service-level |
Minimal | Minor harm, not requiring medical treatment, to a person (or persons); or Short-term diversion of resources to achieve business unit or service objectives |
Table 3: Likelihood of a consequence being experienced
4.2.1 NSW Health risk matrix
The NSW Health risk matrix, below, must be used by all NSW Health organisations when
assessing both strategic and operational risks.
Consequence Rating | ||||||
Catastrophic | Major | Moderate | Minor | Minimal | ||
Likelihood Rating | Almost certain | A | D | J | P | S |
Likely | B | E | K | Q | T | |
Possible | C | H | M | R | W | |
Unlikely | F | I | N | U | X | |
Rare | G | L | O | V | Y |
Risk matrix key: Extreme (A – E) High (F – K) Medium (L – T) Low (U – Y)
Likelihood Time scale OR Probability
Almost certain | Several times a month | Greater than 97% |
Likely | Monthly, or several times a year | At least 70% but less than 97% |
Possible | Yearly, or several times over a three-year period | At least 30% but less than 70% |
Unlikely | Once every three years | At least 3% but less than 30% |
Rare | Less frequent than once every three years | Less than 3% |
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4.3 Risk treatment and escalation
Risk owners must reduce a risk to an acceptable level through implementing additional
controls or improving existing controls. Options for treating risk include:
avoiding the risk by stopping the activity or choosing an alternative activity
reducing the risk by removing the source of the risk or implementing further mitigation
strategies to change the likelihood and consequences of the risk
sharing the risk with another party
accepting the risk to pursue an opportunity but may include implementing further
mitigation strategies or strengthening existing controls.
As part of their risk management framework, all NSW Health organisations must have
documented processes in place that enable staff to escalate risk to more senior levels of
management when the current level of risk is outside the organisation’s risk tolerance.
4.3.1 Escalation of organisation-level risks to the Ministry of Health
Where a NSW Health organisation is unable to manage a risk to be within its tolerance levels
and is not prepared to accept the level of risk, the organisation is to escalate the risk to the
Ministry of Health for additional guidance and support. The organisation is to complete an
‘Escalation of Organisation-level Risk’ form, have it approved by the Chief Executive, and
forward it to the Ministry of Health’s Corporate Governance and Risk Management Unit via
email [email protected].
In escalating to the Ministry, the notification must include:
A clear and concise description of the risk and its potential impacts on the organisation
The reason/s for the escalation
Details of the support needed, or an outline of the requested actions, and a rationale
for the support or actions.
The ownership and management of a risk that has been escalated remains the responsibility
of the health organisation. Forms are available from the NSW Health intranet.
4.4 Monitor and review
4.4.1 Monitoring and reviewing individual risks
Organisations must include the period for review of individual risks as part of their risk
management framework and ensure risk owners review individual risks within the required
time. Risks are to be reviewed at least every:
Risk Rating | Extreme (A – E) | High (F – K) | Medium (L – T) | Low (U – Y) |
Review period | 28 days | 91 days | 182 days | 364 days |
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4.4.2 Executive monitoring and reporting
All NSW Health organisations must ensure that risk management and reporting is a standing
agenda item for senior executive team meetings, for audit and risk committee meetings, and
for Board meetings.
Reporting to the senior executive team, and to the Audit and Risk Committee, is to be
appropriate for the size and complexity of the organisation. As an indicator of risk culture,
reporting is to periodically include the number of risks that are operating outside the
organisation’s risk appetite and the number of risks that are overdue for review.
5 ATTESTATION STATEMENT
5.1 Annual attestation of compliance
The Internal Audit and Risk Management Attestation Statement is an annual statement to the
Secretary, NSW Health about the NSW Health organisation’s conformance or otherwise to
this Policy Directive, and to the NSW Health Policy Directive Internal Audit (PD2022_022).
Advice, opinion or feedback may be sought from the Audit and Risk Committee in relation to
the organisation’s compliance.
The Chief Executive is to submit the Attestation Statement, along with the Internal Audit and
Risk Management compliance self-assessment for the financial year (available from the NSW
Health intranet), to the Ministry of Health (via email [email protected]) by 17
July each year, stating whether the NSW Health organisation complied with these Policy
Directives during the financial year immediately prior.
A copy of the final completed Internal Audit and Risk Management Attestation Statement
must be communicated to the Audit and Risk Committee and to the Board.
5.2 Requesting an exception to policy requirements
Where a NSW Health organisation is not able to comply with any of the requirements of this
Policy Directive, or with the NSW Health Policy Directive Internal Audit (PD2022_022), the
Chief Executive may apply in writing to the Secretary, NSW Health for an exception from the
relevant policy requirement(s) prior to 31 March of the financial year for which the exemption
is sought. The request must include an outline of why the organisation has not been able to
comply with the policy requirement/s.
A determination with respect to an exception will be for the reporting period only and, even if
circumstances for the initial exception are ongoing, further exceptions must be renewed
annually. Where an exception is granted, the exception must be indicated on the Attestation
Statement.
The organisation’s Audit and Risk Committee and Board must be notified of the request for
exception.
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6 GLOSSARY OF TERMS
Current (or residual) risk |
The amount of risk, now, after all existing controls are accounted for. |
Effect | The deviation from the expected outcome or norm. |
Inherent risk | The amount of risk in the absence of controls. |
Issue | An event that has already occurred, or is currently incurring, and is impacting, or has had an impact, on objectives. |
Risk owner | The manager responsible for ensuring actions to address a particular risk are designed, implemented and regularly reviewed. |
Target risk | The desired optimal level of risk. |
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7 APPENDICES
7.1 | Recommended risk categories and areas of risk to consider within the categories |
7.1.1 Clinical care and patient safety
Access appropriate to needs and prioritised according to clinical need
Care evaluation, clinical handover, clinical pathways and variance analysis
Clinical quality improvement and clinical practice improvement
Complaints and concerns about clinicians
Decision making at end of life and mortality management
Discharge and transfer of care
Hospital-acquired complications
Informed consent
Patient safety, including incident management and near miss or incident trends
Protection of people unable to care for themselves while accessing health services
7.1.2 Financial management
Administration, such as accommodation, payroll, transport and travel
Commercial income
Fraud prevention and control
Operational budgets and financial performance
Public liability
Procurement of goods and services, maintenance and contracts management
Treasury Managed Fund and other insurance arrangements
7.1.3 Governance and performance
Accreditation
Climate adaptation
Credentialing and delineation of clinical privileges
External and internal auditing
Governance structures and delegations
Legislative compliance
Resource accountability
Performance Agreement requirements
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Project and program management
Strategic and operational planning
Sustainability
7.1.4 Health of the population
Alignment of strategic clinical direction, planning, monitoring and performance of population
health services
Community health
Disease prevention and control
Human behaviour and demographics
Health protection and surveillance
7.1.5 Infrastructure
Air quality, heating, noise, lighting, and radiation
Access and controls
Asset management
(including buildings, equipment, land, plant, vehicles, supplies and utilities)
Climate resilience
Hazardous substances and dangerous goods management
ICT Hardware infrastructure
Information and data management systems
Internal and external communication platforms
Minor & capital works
Security management and security monitoring
Software
7.1.6 Legal
Commercial and legal management
Contract management
Intellectual property
Litigation
Regulatory compliance
7.1.7 People and culture
Continuing education, learning and professional development
Human resources performance management
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Organisational and workplace culture
Professional development and mentoring
Recruitment selection, credentialing, retention and appointment
Succession planning
Workplace relations, including grievances
Visiting medical officers, contracts and volunteers
7.1.8 Reputation
Access to, and quality of, services
Climate impact and environmental sustainability
Compliments and complaints management
Consumer engagement and empowerment, and stakeholders’ expectations
Patient experience
Privacy and confidentiality
Release of information
The right care and services, including the protection of children and vulnerable populations,
provided in the right setting within appropriate timeframes
7.1.9 Service delivery
Business continuity management and disaster recovery planning
Catering and food hygiene
Chemicals, radiation and hazardous material management
Cleaning services
Disaster response
Electronic information security management and cyber security
Environmental sustainability
Infection control
Procurement
Records management
Waste management
7.1.10 Work health & safety
Workplace health and safety
Workers’ compensation and injury management
Contractor non-compliance
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7.2 Recommended risk register data fields
Data item | Data field explanation |
Organisation name | Name of the NSW Health organisation |
Risk ID | Unique identifier which identifies the risk |
Date risk created | Date risk was created |
Risk category | Relevant to the risk, using the risk categories listed in the organisation’s enterprise-wide risk management procedures, each risk is to be categorised. |
Risk description | A description of the risk, possible causes and impacts. |
Risk owner | Risk owner by position, not name (only one risk owner for each risk) |
Inherent risk rating | The risk rating, as per risk matrix, at the time of risk identification. |
Current controls | Description of the controls that are in place |
Control type | Type of control is either proactive or reactive |
Control effectiveness | Level of effectiveness of current controls is either substantial, partial, or ineffective |
Current risk rating | Risk rating after controls |
Additional controls / action items to mitigate risks:
Additional control description |
Identify and capture any further actions that need to be carried out to further reduce risk from “residual risk rating” in order to manage the risk to an acceptable level. |
Due date | Stipulate when the actions are due to be completed. |
Responsible position | Position (not name) responsible for implementation |
Target risk rating | Proposed risk rating after the implementation of mitigating actions |
Trend | Trend for the risk (e.g., decreasing; increasing; no change) |
Risk status | Active; Inactive. |