Part II: Tools for an effective follow-up and implementation
In Estonia, the NPM uses circulars which are sent to all relevant institutions under inspection to draw
their attention to the main shortcomings identified. By widely distributing these circulars they can create
a greater awareness of good and bad practices in specific institutions. The Slovenian Ombudsman sends
out a weekly Newsletter that often also includes a short summary of important NPM findings.
1.3 Action Plans
Requesting the authorities to develop action plans detailing their plan for implementation can
be a particularly effective tool for follow-up. An action plan, if developed on the basis of NPM
recommendations and taken as a practical tool to advance their implementation, can be a very
useful way to strengthen a strategic follow-up process, by setting clear goals, responsibilities and
timeframes, providing a framework for support and advice by the NPM, as well as the monitoring
and evaluation of state action.
A specific and very interesting example of using the dialogue specifically to develop follow-up action with
the authorities is to request institutions to develop action plans setting out how they will implement
their recommendations. Action plans can be a practical tool to measure implementation, to strategically
work towards the implementation of recommendations, providing a set of agreed measures that need
to be taken in order to address a particular problem and to support and evaluate the steps taken by the
authorities.
Some bodies in the UK NPM have adopted the practice of requesting action plans. Typically these action
plans state which recommendations have been accepted, partially accepted or rejected, and, in the case
of accepted recommendations, how the inspected body plans to address these.154 The action plans appear
to vary in sophistication, with one body requiring the provider to send a ‘Quality Improvement Plan’ which
outlines the actions taken within the timeframe required. The extent to which action has been taken on
the Plan is then assessed at the next inspection visit or the inspecting body may ask for a report more
quickly if there are concerns about some issue that requires urgent action.155 HMIP as one of the bodies
in the UK NPM also requests an action plan from the establishment inspected detailing how the latter will
respond to the recommendations that have been made. The action plans of the HMIP set out in table form
the recommendations made; whether the recommendation is rejected or accepted; the response in the
form of any action taken or planned – if the recommendation is rejected stating why the recommendation
is rejected; who has responsibility for implementing the response; and the target date when the action
will have been taken. If the action requires on-going or long-term action this is also stated.156 The
measures taken to implement the action plans are then assessed and monitored in subsequent visits to
the institution concerned. HMIC, another body in the UK NPM, in addition to giving recommendations,
provides ‘improvement actions’, namely those that may be less important than recommendations but
which could perhaps be implemented quickly or with limited resources.157 The Criminal Justice Inspection
Northern Ireland (CJINI) publishes action plan reviews and inspection follow-up reviews. These are not
presented separately to Parliament but their findings can be included in the CJINI’s annual report.158 In
addition, also in the UK one NPM body asks the inspected institution to provide an annual review on selfassessment against the recommendations.159
UK, NAO, Inspection (2015) para 2.14.
UK, NPM Recommendations Survey, response from RQIA.
156
In the UK action plans for prisons are published by the HMIP, see for example HMP Brixton Action Plan (14 May 2015)
<http://www.justiceinspectorates.gov.uk/hmiprisons/wp-content/uploads/sites/4/2015/03/Brixton-Action-Plan-2014.
pdf > accessed 16 June 2015.
157
UK, NPM Recommendation Survey, Response from HMIC 1.158 See for more information CJINI´s website: <http://www.
cjini.org/TheInspections/Action-plan-reviews---inspection-follow-up-revie.aspx>.
159
UK, NPM Recommendations Project. Summary of Findings, para 14.
154
155
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