This page is from APP, the official source of professional practice for policing.
This module continues to be under review in line with the wider review of the accompanying modules of APP on managing sexual offenders and violent offenders.
There are three key stages in considering risk for the purposes of public protection – risk identification, risk assessment and risk management. Dealing with the risks posed by multi-agency public protection arrangements (MAPPA) offenders requires identifying risk factors and the context in which they occur. This provides a solid foundation on which risk assessment and management can take place.
A police officer or member of police staff may come across a sexual or violent offender or a potentially dangerous person in their routine duties. It is important that effective action is taken to deal with apparent risk of harm. When an individual has been identified as a sexual offender, violent offender or potentially dangerous persons (PDP), that person should be assigned a named management of sexual or violent offenders (MOSOVO) officer for risk assessment and offender management purposes.
It is important for the MOSOVO officer to be aware of all relevant information relating to the offender. Intelligence reports concerning individuals with Violent and Sex Offender Register (ViSOR) markers or other intelligence indicators should always be created by officers and staff and brought to the MOSOVO officer’s attention. What may not seem particularly important or relevant to frontline officers and staff may require immediate action by the MOSOVO officer in relation to the individual’s risk management plan.
The module provides advice on identifying risk factors (static or dynamic), setting a risk management plan, assessing risk and using appropriate risk assessment tools. By gathering information, staff can develop appropriate methods for managing the risk an offender poses based on full and accurate information.
The first step in identifying people who pose a serious harm is to establish the specific risk factors which apply to those individuals. Thorough information gathering should be followed by analysis to identify harm and risk factors. This is a dynamic and continual process.
Risk identification requires information from a range of sources and is the responsibility of all staff.
Offenders subject to registration
The intelligence briefing is the mechanism by which front line staff will become aware of the new MOSOVO offenders in their area.
Systems and processes should be in place so that when police officers and staff encounter a registered offender, they create an intelligence record and route it to the right people. The responsibility for ensuring these processes are in place will vary from force to force. This process allows risk assessment and management to be based on full and accurate information. It also helps to inform identification of new risk. This is particularly important where a recall to prison may be needed.
Communication between departments
Where a police officer or member of police staff comes across information that suggests that a person poses a risk of serious harm or that a victim is at risk of suffering serious harm they must take immediate effective steps to remove or reduce the risk.
Officers and staff in any role may come across offenders, victims or information that gives rise to concerns but those investigating child abuse, vulnerable adult abuse, domestic abuse, hate crime and sexual offences, are more likely to encounter such situations.
Whenever information indicates a possible risk of serious harm, it should be made known to the appropriate department within the force via briefings, ViSOR, local intelligence systems and regional tools (for example, NICHE, SLEUTH, REDSIGMA), Police National Database (PND) and daily management meeting (this list is not exhaustive).
Risk assessment is the process of establishing the following:
- likelihood of a behaviour or event occurring
- frequency with which it may occur
- whom it will or may affect
- extent to which that behaviour will cause harm
Risk assessment sometimes involves categorising each offender at a particular time as presenting a distinct level of risk (namely, low, medium, high or very high). Operational experience has found that risk assessment can also identify the specific nature of the risk posed. It relies on a combination of actuarial tools (Offender Assessment System (OASys) Sexual reoffending Predictor (OSP)), dynamic tools (Active Risk Management System (ARMS)) and professional judgement.
No risk assessment tool can accurately predict the risk posed by a particular individual. These tools can, however, demonstrate that individuals who share specific characteristics tend to cause harm, reoffend or be reconvicted at particular rates. The value of any risk assessment tool depends on the skill of those using it and the efficiency of the IT system it runs on.
The professional judgement of police officers and others involved in risk assessment is central to public protection. Risk assessment tools support officers to use their professional judgement. On occasion, the assessor may override the outcome of an assessment tool. This may be based on the assessor’s objective professional judgement (including their training, experience and knowledge of the individual being assessed).
Any risk assessment outcome that is overridden by the assessor’s professional judgement should be recorded. It should include the rationale and justification for the decision, according to the principles of auditable decision making.
Accuracy depends on the quality of information known or believed to be correct. Information must be recorded accurately to ensure auditable and appropriate decision making.
Risk assessment tools provide a structured approach to assessing the risk an individual may pose to the public, and contribute to the overall quality and accuracy of assessments. Risk assessment tools are not, however, without limitations.
There will always be a degree of unreliability in predicting the risk any individual poses. Ensuring the most appropriate and accurate risk assessments, taking account of all available information and intelligence, and communicating with other agencies all help to reduce false predictions. Chief officers should ensure that any decisions contributing to risk identification, assessment and management are auditable.
The tool for assessing risk of registered offenders commonly used by the police is the Active Risk Management System (ARMS).
Static risk factors
Also known as historical factors, these include a suspect’s previous offending history and the number of offences committed. These are factors that cannot be changed by any form of treatment or intervention. Static factors are the basis for actuarial assessment and are fundamental in considering an individual’s potential to reoffend in the long term.
Static factors do not, however, provide a full and accurate picture of the likelihood to cause harm. They are also not effective in measuring changes in risk levels or in determining how and when to intervene at particular points in the risk management process.
Examples of static risk factors include:
- previous criminality
- previous convictions
- previous physical assault by the offender
- previous sexual assault by the offender
- previous child abuse by the offender
- previous domestic abuse by the offender
- evidence of escalating severity or frequency of assault by the offender
- whether the offender has lived in a stable, intimate relationship
Active risk management system (ARMS)
Operational opinion suggests that the value of the OSP as a statistical prediction model for the evaluation of the long-term risk associated with sexual offenders has long been recognised. Such a singular approach to risk assessment, however, takes no account of the so-called acute risk factors that (as evidenced through completed investigations) have been found to have a relationship to imminent offending.
Dynamic factors are known to be changeable and potentially responsive to engagement by professionals and are, therefore, considered to be key to the success of the risk management plan. ARMS intends to support and standardise professional judgement in measuring these dynamic factors. By taking account of both risk and protective factors, it is believed that a more balanced assessment of risk will be arrived at. ARMS includes opportunities for the assessor to draw together their findings into a narrative of what needs to be done to address risk or to increase strengths in the situation and is intended to lay the groundwork for arriving at an effective risk management plan.
Dynamic risk factors
These are changeable factors which relate to the offender’s personal circumstances and behaviour. They include:
- sexual interests (for example, sexual preoccupation, sexual preference for children, preference for sexualised violence, other offences related to sexual interest)
- distorted attitudes (for example, adversarial sexual beliefs, or beliefs that support child abuse, sexual entitlement, rape, rationalisations for offending, viewing women as deceitful)
- management of relationships (for example, feelings of personal inadequacy, distorted intimacy balance, grievance-oriented thinking towards others, lack of emotional intimacy with adults)
- management of self (for example, lifestyle impulsiveness, poor problem solving, poor management of emotions)
- employment status and type of employment
- high levels of hostility and aggression
- lack of self-control
- substance misuse
- mental ill health
- use and availability of weapons
- grooming behaviour patterns
- access and proximity to victims
Dynamic risk factors are significant in designing and delivering risk management plans, and in predicting the imminence of reoffending. As far as is reasonably practicable, the police should identify risk factors at an early stage (and as part of a continual process).
The outcome of the OSP or any other risk assessment tool should be recorded on the ViSOR system in accordance with current Home Office ViSOR Standards. It should also be shared with all relevant agencies. Staff should review all assessments regularly as well as when there is a change in the offender’s circumstances.
Offenders who are a risk to children
The term ‘Schedule 1 offender’ was used in the past to describe anyone convicted of an offence against a child under Schedule 1 of the Children and Young Persons Act 1933. Now the term ‘risk-to-children’ is generally used for those identified as posing an ongoing risk to children.
The conclusion that an individual poses a risk to children should be based on all available information. This includes information provided by relevant agencies such as risk assessments by the probation service, prison service and health professionals, whether individually or via MAPPA.
When an offender who is a risk to children is identified as a MAPPA offender or PDP, the force MOSOVO unit is responsible for the police role in managing them. The force child abuse investigation unit (CAIU) should be involved as appropriate.
For further information see:
Risk management involves the police, other agencies and the offender or PDP themselves using various strategies to reduce the risk posed by the offender. There are three levels of risk management described in current MAPPA guidance.
- Level 1: ordinary agency management.
- Level 2: active multi-agency management.
- Level 3: active multi-agency management at senior management level (referred to as level 3 multi-agency public protection (MAPP) meetings).
Current MAPPA guidance requires offenders to be managed at the lowest level consistent with providing an auditable risk management plan. This provides clarity of role for all agencies involved in managing the offender.
Presently, no legislation recognises PDPs as a class of person. In many instances, a PDP is a person without any convictions for a criminal offence. The prison and probation services do not, therefore, have an automatic role in managing the risk posed by PDPs. In exceptional circumstances, however, it may be appropriate for either agency to be involved in a multi-agency process for assessing risk.
Given the statutory role of the probation and prison services to work with convicted offenders, involving these agencies in managing non-convicted people should be exceptional and decided on a case-by-case basis with the authority of the relevant manager.
Risk management plans and interventions
A lead agency risk management plan should be created for all registered offenders. Where the lead agency is the police, this should be created by the MOSOVO officer, in response to their assessment of the offender. These plans should state how restrictive and constructive interventions can reduce or manage the risk of harm and the likelihood of reoffending.
Risk management plan objectives should focus on achieving outcomes. Staff should complete and record actions from risk management plans. Supervisors should check that all actions are completed within a specific timescale.
Supervising officers should also ensure that police actions resulting from each risk management plan are implemented and reviewed as dictated by MAPPA, depending on the level of risk identified. For further information, see the risk management plan section of MAPPA Guidance.
An individual being managed at level 2 or 3 has a MAPPA risk management plan in addition to the police risk management plan. MAPPA guidance specifies what should be covered in a MAPPA risk management plan and emphasises the need to review the plan on a regular basis or when significant new information is obtained or events occur.
National intelligence model (NIM) target profile
It is good practice for police forces to make very high-risk offenders the subject of a NIM target profile. Staff should monitor this profile through the operating practices of tasking and coordinating meetings.
Offenders who do not cooperate with risk management plans, for example, by refusing to allow the police or probation service entry to their home, or by refusing to answer questions, may be indicating an increased risk.
Risk management interventions can be either restrictive, for example, to minimise the risk of harm by monitoring or restricting activities, or constructive, for example, a sex offender treatment programme. Some interventions are both restrictive and constructive, for example, home visits by the police and probation service.
Staff should record all interventions with a systematic analysis of what they are intended to achieve, how they will be enforced, and why they are a suitable way of managing the risk posed by that offender. Effectiveness and enforceability should be given as much attention as issues of lawfulness and proportionality, bearing in mind the European Convention of Human Rights, Articles 2, 3 and 8.
For example, if a curfew is in place, the means of enforcing it should be clear and include the arrangements, in particular approved premises, for enforcing the curfew, such as unannounced curfew checks or electronic monitoring.
This may require police examination of an address to check that security and enforcement arrangements are suitable. If an intervention is breached, all agencies should have a process in place to respond.
The main types of intervention, some of which can be supported by licence conditions, court orders and other measures can be described as either restrictive or constructive.
- residing at approved premises
- office-based supervision (for example, by a probation officer)
- home visits and other regular visits to the offender’s premises
- prosecutions for any offences
- court orders – see Court orders and notices
- restrictions on associations
- restrictions on residence
- restrictions on movement – particular areas that the offender is excluded from (for example, areas where they may encounter the victim, schools, football matches, playgrounds) and restrictions containing an offender in a specified area
- restrictions on activities (for example, employment, hobbies) and certain possessions (for example, computers)
- bail or curfew checks (for example, by electronic monitoring, or by phone calls or visits)
- notification requirements
- recall to prison for breach of licence conditions
- target hardening in relation to past or potential victims
- overt police activity
- electronic monitoring (for example, as a means of enforcing a curfew)
- satellite tracking (for example, for monitoring exclusion restrictions)
- covert surveillance
- covert human intelligence sources (CHIS) tasked against the offender
- use of Automatic Number Plate Recognition (ANPR)
- relapse prevention programmes
- various types of computer-monitoring software or triage software have been trialled by a number of police forces and may be considered to monitor computer/internet use by registered sex offenders (RSOs)
- attending accredited programmes (for example, a sex offender treatment programme)
- sharing information (for example, with neighbourhood policing teams, other agencies, members of the public or the media)
- provision of suitable diversion activities (for example, employment or other constructive activities)
- psychological or psychiatric input
- support and accountability groups in the local community who provide regular support to an offender to prevent reoffending and assist reintegration into the community
For further information see approved premises.
Potential negative consequences
When an intervention is being considered, staff should consider any potentially negative consequences, that is, unintended outcomes given the context and characteristics of the offender. Restrictions on residence in a certain area can, for example, result in offenders living some distance from support systems of family and friends. This can lead to increased isolation, financial and emotional stress and decreased stability, all of which can increase risk.
An understanding is therefore required as to the impact of actions on the suspects in line with the ECHR Article 8 (right to respect for private and family life), balanced with the requirements to protect rights of victims under Articles 2 (right to life) and 3 (prohibition of torture). Staff should therefore assess the potential negative consequences with the potential public protection benefits.
Police offender managers must ensure that such changes trigger an appropriate reassessment of the risk level at which an offender is managed, and that the management plan in place to deal with that risk is fit for purpose. HM Inspectorate of Probation (2009) Risk of Harm Inspection Report: A Stalled Journey provides important information to support this rationale.
Sources of information
Information gathering is a key police role in managing risk to protect the public and enables defensible decision making. There is a wide range of sources of information available to assist in monitoring, assessing and managing risk. These include:
- police intelligence
- national databases such as Police National Computer (PNC), PND and ViSOR
- previous police interviews
- information from victims (for example, victim statements)
- information and observations from home visits
- information from other agencies both statutory and voluntary, for example, housing, local authority, mental health
- pre-sentence reports from the probation service
- prison intelligence (for example, behaviour and contacts of offenders in prison)
- post-programme reports (from prison or probation services) on offenders who have completed programmes to address offending behaviour
Factors to be monitored to identify, assess and manage risk
Staff should monitor several factors to identify, assess and manage risk. This list has been compiled using the acute dynamic predictors developed by the authors, RK Hanson and AJH Harris, of The Dynamic Supervision Project: A Collaborative Initiative on the Community Supervision of Sexual Offenders.
The relevant factors are:
- access to actual or potential victims (for example, work schedules, hobbies, general routines, evidence of intentional contact including grooming, stalking behaviour, hiding or lying about victim access opportunities, sexual offenders seeking or developing contact with children)
- emotional collapse of the suspect or offender (for example, existence or extent of support, work problems, health issues, substance misuse, mental ill health, excessive sleeping, paranoia, suicidal fantasies or gestures, agitation, anxiety, self-pity, hopelessness)
- collapse of the suspect or offender’s social supports (for example, perceived or actual loss of social support including significant friends, partners, family members or social organisations, vigilante activity or attack, unhealthy contacts such as those who collaborate with the offender to minimise or deny the offence, community rejection)
- hostility by the suspect or offender (for example, verbal or physical disputes, angry ruminating, irrational or reckless defiance, expressions of hostility to women, direct or veiled threats, planning retribution)
- substance misuse by the suspect or offender (for example, evidence of deception, out-of-control drinking or drug use, drinking for courage in preparation for an offence, taking prescription medications that have the potential for misuse, no attempt at self-control)
- sexual preoccupations by the suspect or offender (for example, deviant sexual fantasies, increased or excessive masturbation, rumination on sexual issues, inappropriate comments, use of pornography, prostitutes or telephone sex lines)
- rejection of supervision by the suspect or offender (for example, disengagement, missed appointments, manipulation, deception, indirect or active hostility, open confrontation)
- any factors unique to the offender (for example, a specific date or event such as an anniversary that causes an emotional response, homelessness, contact with a particular person in the family, particular health problems
Staff should consider the relevance of each factor on a case-by-case basis. All staff involved in assessing risk should be familiar with these factors and review them periodically and at specific points in the monitoring and risk management processes (for example, prior to each home visit).
For further information see:
- static risk factors
- dynamic risk factors
Registered sexual offender risk factors and identity issues
The following factors which are areas for concern include:
- Overseas travel where an RSO:
- is likely to leave the UK because of previous travel abroad to commit offences
- has an occupation which entails regular overseas travel
- has previously travelled to a hub airport and only declared travel to the country of that airport
- travels overseas regularly
- A vocation or profession where an RSO has regular contact with vulnerable persons, for example, teaching or working in a hospital. In such cases the RSO will be aware that it is much harder to continue to work in that area if Disclosure and Barring Service (DBS) checks are required.
- Previous convictions for fraud where an RSO has used a change of identity as a tool for committing fraud. They may be more likely to consider doing this again to avoid DBS and law enforcement checks.
Suspect or offender leaving the UK and/or changing their identity
Where there is a risk of this occurring, pre-emptive actions include:
- requesting Her Majesty’s Passport Office (HMPO) and/or the Driver and Vehicle Licensing Agency (DVLA) to put a marker on the file to alert the officer in charge if an application should be made
- checking more than once with the RSO what their identity credentials are (for example, driving licence and UK passport)
- checking for change of name and/or identity-related web searches and activity when monitoring the RSO’s internet use
To avoid unnecessary or high volumes of requests to these agencies, enquiries should be limited to the above areas. Officers need to be aware that highlighted markers such as DVLA enforcement markers will show on the PNC, and His Majesty's Passport Office (HMPO) markers may show on Omnibase. Omnibase is the application used by the passport validation service (PVS) to allow authorised users in government agencies to view 40 million passport records held in the HMPO passport application support system (PASS). (p15. Home Office’s guidance ‘Identifying British citizens and others exempt from deportation’).
In addition, accessing any DVLA driver record on the PNC will link previous records held on the licence holder and show any name changes. An offender may, however, try to obtain a new driving licence or passport by submitting false identity documents to support an application for a licence/passport.
All forces can access driver records via the Driver Licence Validation service, but this does not have the facility to link to any existing name changes via the PNC. The PNC should, therefore, be the preferred option for research and direct liaison with the agency concerned.
Note: DVLA and HMPO have strict rules on accessing their records via the PNC and Omnibase. Alternatively, data can always be obtained from the agencies via normal liaison channels.
Victims and potential victims
Officers and staff should take victims into account when assessing risk of harm, and include them in risk management plans (for example, whether any particular safety measures are needed). All victim contact documentation should be separate from the offender case file or contained in a confidential section.
Decisions to involve victims and potential victims in managing offenders should be made after consultation with the relevant agencies, including the probation victim contact or liaison units. The primary concern should always be for the victim, supporting the focus of the Code of Practice for Victims of Crime. MOSOVO officers should however be mindful of Article 8 and the need to balance the rights of potential victims and the suspect.
Victims can be a useful source of information about offending behaviour and the risk of serious harm, particularly if they still have some connection with the offender (for example, a relative). Staff should take account of the victim’s wishes and current circumstances. For example, a victim who has terminated all contact with the offender may find it disturbing to be asked for information about them.
If an offender has access to past victims who may have useful information, the victim should be given a point of contact to pass on the information to the police. In some circumstances, it may be appropriate to visit or meet the victim.
Past victims may have registered with their local force that they wish to be contacted when an offender on indefinite notification requirements applies for a review. The victim’s details will have been recorded on ViSOR if this is the case.
An offender’s access to potential victims raises a number of issues. This includes sharing information and the possibility of the potential victim providing information to assist in assessing risk. See Managing information for further information.
Some offender management techniques (including covert techniques) reveal individuals who are subject to serious harm or facing a high risk of imminent harm. Examples include cases where an offender is grooming a child or sexually abusing them. In such cases, the primary considerations should be protecting the child, the positive obligation to protect the lives of individuals and to protect individuals from degrading and inhuman treatment.
Monitoring and reviewing risk
The relevant supervisor in the offender management unit should monitor and review risk on a case-by-case basis. The strategic management board should monitor and review risk at a strategic level. An appropriately trained supervisor should oversee and countersign all risk assessments and risk management plans. The completion of risk management actions and reviewing risk are the responsibility of the officer dealing with the case and their supervisor.
If the case is managed at MAPPA level 2 or 3, there is a formal review process. Risk management plans should be monitored, reviewed regularly and kept up to date so that progress reports can be amended or the risk level reclassified.
Current MAPPA guidance provides clear review guidelines for offenders in the community. The responsible authority in their area must have arrangements to ensure that:
- all level 3 cases are reviewed within a maximum period of eight weeks
- all level 2 cases are reviewed within a maximum period of 16 weeks
Level 1 cases should be reviewed and managed in accordance with directives from the National Police Chiefs' Council (NPCC). To support this, chief officers should ensure they have the appropriate systems in place to manage threat, risk and harm.
When considering reactive management – the following must apply.
- Nominal has been managed as low risk for the last three years in the community.
- Nominal has been offence- and concern-free during this period.
- Current ARMS is low risk.
- Nominal is not subject of a civil order.
Reactive management examples
Has been low risk in the community for three years with no concerns
- The nominal must be police managed (that is, not on supervision or licence by NPS) and have been assessed as low risk for the previous three years (whilst police managed). They must have a current ARMS assessment although they do not need to have had ARMS assessments for three years.
Nominal has been offence-free during this period (last three years)
- The offender manager must be satisfied that they are offence-free and there have been no concerns raised during the three-year period.
- Offence-free does not include all offences – it relates to further sexual offending. However, it is expected that other offences would be considered within the ARMS assessment and if they raised concerns this would be reflected in the overall risk level.
No civil order (sexual harm prevention order (SHPO) or sexual offence prevention order (SOPO))
- A nominal should not be placed on reactive management if a civil order is in force. This is because the existence of such an order would imply that additional measures are necessary to effectively manage the individual and as such are at odds with the principle of reactive management. Police forces may wish to review existing orders to ensure that they remain necessary and proportionate with an option to proactively seek to discharge any orders longer appropriate.
- However, if on a case-by-case basis forces deem an RSO suitable for reactive management pending discharge of the civil order, they can consider reactive management.
Withdrawal of reactive management
- If the nominal is subsequently placed back on active management due to a ‘significant change’, this does not necessarily mean there must be a further three-year period before they can be considered for reactive management. This will be a decision for the offender manager and supervisor dependent on the individual circumstances. However, any further sexual offence (or relevant nonsexual offence) would mean they would have to wait a further three years before being considered for reactive management.
- Reactive management can be considered with female sex offenders providing they are offence free and there have been no concerns over the past three years. At this stage, the decision will be based on professional judgement after consideration of all available information. This may include assessments previously completed by other agencies (PSR, OSP, ASSET, psychological assessments).
Recording reactive management
- The offender manager records relevant details from the above on the risk management plan (RMP) and leaves the review date blank. ViSOR is updated on the front page to show that the nominal is on reactive management. The supervisor must review and approve this decision. There is no requirement to be informed of this.
- The nominal must continue to fulfil responsibilities under the Sexual Offences Act 2003 (notification requirements). Scheduled checks can be put in place on an annual basis. This is a decision for an individual force although good practice would suggest a review of the case every 12 months.
- No visit required.
- No ARMS required.
Scheduled checks and triggers to consider (not an exhaustive list)
- Warnings Index Control Unit (WICU).
- International Criminal Police Organization (INTERPOL) notices (green etc.)
- Local intelligence.
- Agency checks – for example, children’s social care.
Information or intelligence received while on reactive management
- Update ViSOR with information intelligence.
- Assess the information – does this new information constitute a 'significant change'? Various options may be considered at this stage dependent on the circumstances and may include:
- a phone call to RSO
- a home visit (announced or unannounced)
- enquiries with other agencies
- further investigation
- If on assessing the information, it is felt it constitutes a 'significant change', then review ARMS.
A 'significant change' and review of ARMS does not mean that the RSO cannot go back on reactive management if they remain assessed as low risk.
A significant change is defined as circumstances that are likely to result in a major change in the current overall assessment and risk management plan.
Ask yourself the following question – does the change in circumstances or new information impact on the risk management plan? If the answer is ‘yes’, then a review should be completed.
The following are offered as examples of where a review may be required, but it is not exhaustive. Managers are encouraged to consider each case individually and apply and record their professional judgement.
Deterioration or changes in behaviour
- Consider – does a behaviour change reflect actions displayed during previous offending? For example, return to previous associates, increased substance use, deterioration of personal hygiene. Are factors and behaviours presenting that indicate a decline in motivation or capacity to engage effectively as currently managed? Are any of the displayed changes identified as risk predictors within the ARMS assessment?
- While in some instances a change of accommodation can be a significant event, for others it is part of a wider pattern of activity that is not linked to a risk of sexual harm.
- Consider – is the move because of difficulties with others? Does the new location present increased opportunities to offend – through associations or access to victims (consider domestic abuse and child safeguarding)? Does the move expose the offender to increased risks? Does obtaining independent accommodation present a positive achievement and as such reduce the risk of harm?
- A decrease in compliance or engagement can often indicate a change in approach is required to identify the underlying issues preventing compliance.
- Consider – is additional support required or further restrictive measures? Does the plan need to be reviewed in light of this? Is this suggestive of an increase in risk?