Governance, Safety and Accountability in Social Prescribing: Who Is Responsible for What Across the Pathway?

Governance, Safety and Accountability in Social Prescribing: Who Is Responsible for What Across the Pathway?

Social prescribing often crosses organizational boundaries. A need may first be recognized in a healthcare setting, explored with a link worker or another person performing the linking function, and then addressed through an activity or service provided by a community organization. Several organizations may therefore be involved in one person's journey without belonging to the same management structure, profession or regulatory system.

That flexibility is one of social prescribing's strengths. It is also where governance becomes important.

A referral does not make every organization responsible for everything that happens next. Equally, sending someone elsewhere should not allow responsibilities to become unclear. Clinical care remains clinical care. A linking role has its own defined scope. A community organization remains responsible for the activity it provides. Someone, or some agreed governance structure, also needs responsibility for coordinating how the pathway itself works.

Good governance is therefore not about creating a single chain of command across healthcare, social services and community life. It is about making sure that responsibility is clear at each stage, communication works when another service needs to become involved, and no one is left between organizations because everyone assumed someone else was responsible.

WHO's social prescribing implementation toolkit emphasizes the need to define program objectives, management structures, accountability and the roles of clinicians, link workers, community organizations and implementation teams. It also recommends assessing the quality and capacity of community resources and maintaining communication across the pathway before routine implementation begins.[1] International evidence published in 2026 points in the same direction. A global scoping review of 115 peer-reviewed empirical studies found that social prescribing was implemented more coherently where pathways were clear, practitioner roles were well defined, cross-sector communication was regular, supervision was available and community-sector capacity was sufficient.[2]

For Viet Nam, these questions are worth resolving before social prescribing develops into a large referral network.

Key Points

• Social prescribing can cross organizational boundaries, but responsibilities should remain identifiable throughout the pathway.

• A social prescribing referral does not, by itself, determine how existing clinical, professional, organizational or legal responsibilities are transferred or concluded.

• Referring services, people performing the linking function, community partners and the designated coordinating function or governance body have different responsibilities that should be defined in advance.

• Safety arrangements should be proportionate to the activity and population. A neighborhood reading group should not be governed like a mental health service, but risk should not be ignored simply because an activity is community-based.

• Community organizations should be able to decline inappropriate referrals, communicate capacity problems and escalate concerns without being expected to perform clinical assessment outside their competence.

• Urgent, complex or deteriorating needs require a clear route toward appropriate professional support.

• Information sharing should be based on necessity, purpose and applicable Vietnamese legal requirements, not on an assumption that all information held by healthcare should follow someone into the community.

• Complaints, significant incidents and unsuccessful referrals can provide important information for improving the pathway.

• Governance should protect community organizations from becoming under-resourced extensions of healthcare.

• Viet Nam would benefit from testing governance arrangements through carefully designed pilots before attempting broader standardization.

Governance starts before the first referral

Governance problems are much harder to solve after a pathway is already operating. By then, referral habits may have formed, organizations may have developed different expectations, information may already be moving between systems and participants may reasonably assume that the organizations involved understand how responsibilities are divided.

WHO's implementation toolkit therefore places these questions early in pathway design. Before routine delivery begins, implementers should define the purpose of the model, who is involved, how the pathway is managed, how referrals and follow-up work, and whether the community services expected to receive participants have appropriate quality and capacity.[1]

A pathway therefore needs more than a directory and a referral form. Organizations involved should understand who can initiate a connection, what types of needs the pathway is designed for, who conducts the person-centered conversation, who checks whether a community resource is suitable, what support is offered to help the person access it, what follow-up is expected, what happens when concerns arise and what information can appropriately be shared.

The level of governance should reflect the model. A small pilot involving one healthcare organization and a handful of community partners may need relatively simple arrangements. A multi-site pathway involving hospitals, commune health stations, social services, local authorities and many community organizations would require more formal coordination.

The arrangements do not need to look the same everywhere. They do need to be explicit rather than assumed.

Who is responsible for what?

The question “Who is responsible?” can be misleading because social prescribing rarely has one answer. The more useful question is “Who is responsible for what?”

For the referring healthcare professional or healthcare organization, responsibilities arising from the healthcare it continues to provide should remain clear. If someone remains under clinical assessment, treatment or monitoring, sending a social prescribing referral does not itself decide when those responsibilities end or move elsewhere. Under Viet Nam's Law on Medical Examination and Treatment, practitioners are required to comply with professional requirements and are responsible for the medical examination and treatment they provide.[5] Existing clinical responsibilities should therefore end or transfer through the usual clinical, professional and legal processes that apply, not merely because a social prescribing referral has been sent.

This does not mean that a doctor becomes responsible for everything that later occurs in a gardening group, exercise class or cultural activity. It means that responsibility for clinical care should not be informally shifted onto a non-clinical organization simply because someone has been connected with it.

For the linking function, the responsibilities are different. Depending on the model, this role may involve exploring what matters to the person, identifying possible community resources, discussing options, facilitating the first connection, helping overcome practical barriers and following up. The pathway should define how far that responsibility extends. Someone performing a linking function should not be expected to diagnose disease, modify treatment or make clinical decisions unless they are separately qualified and legally authorized to perform those activities.

This distinction becomes especially important when one person has more than one professional role. A nurse, social worker or another regulated professional may also perform a social prescribing linking function. Their professional qualification does not mean every social prescribing interaction becomes a clinical encounter, but the label “link worker” does not remove professional duties when they are actually performing regulated professional activities.

For the community partner, responsibility relates primarily to the activity or service it provides. Depending on the organization, this may include maintaining accurate information about the activity, communicating eligibility or participation requirements, managing staff or volunteers appropriately, operating the activity safely within its purpose, responding to incidents in its setting and communicating when it cannot reasonably support a referral.

Community organizations should not be expected to accept unlimited referrals or to take on responsibilities for which they do not have the competence, authority or resources.

Finally, the designated coordinating function or governance body needs to ensure that the different parts of the pathway fit together. Depending on the local model, this could sit within a healthcare organization, partnership, steering group, project team or another arrangement. Its functions may include referral criteria, role definitions, partnership arrangements, workforce preparation, escalation processes, information governance, complaints, monitoring and periodic review.

Without some coordinating function, the gaps between organizations can easily become gaps in accountability.

A simple conceptual map may help:

RoleCore responsibility within the pathwayReferring health or service providerResponsibilities arising from the professional or service activities it continues to provideLinking functionPerson-centered navigation, appropriate connection, agreed follow-up and escalation within its defined scopeCommunity partnerAppropriate delivery of its own activity, capacity boundaries and communication of relevant concernsCoordinating function or governance bodyPathway design, role clarity, partnership arrangements, escalation, information governance, monitoring and learning

This is a governance framework, not an allocation of legal liability. Actual legal responsibility depends on the activities undertaken, the organizations involved, professional scopes of practice, contractual arrangements and applicable Vietnamese law.

Safety, safeguarding and escalation need practical arrangements

Safety matters in social prescribing, but it should not be used as a reason to turn ordinary community life into a clinical environment. A reading group, walking club or community arts activity does not require the governance infrastructure of a hospital. Excessive clinical documentation or risk-management requirements could discourage small community organizations from participating and undermine the informal, welcoming character that makes many community resources valuable.

At the same time, calling something “non-clinical” does not make risk disappear.

A global umbrella review published in 2026 was the first review to categorize potential harms associated with social prescribing. It identified plausible psychological, group or social, equity and opportunity harms, with opportunity harms such as inappropriate or ineffective referrals and participation-related costs most frequently represented. The review searched the literature to June 2024 and found no reported evidence of direct physical harms, but the authors explicitly described this as a silence in the available evidence rather than evidence that physical harm cannot occur. The review also could not determine how frequently the identified harms occur.[3]

The practical implication is not that social prescribing is unsafe. It is that safety should be considered rather than assumed.

A poorly matched referral may leave someone feeling rejected or more isolated. An inaccessible activity can reinforce inequity. Repeated referrals to programs that are full can undermine trust. Sending someone to a resource that cannot manage the person's needs can place pressure on the organization as well as create disappointment or risk for the participant.

Safety arrangements should therefore be proportionate to the activity, population and reasonably foreseeable risks. A low-risk community social activity may need little more than clear leadership, basic emergency arrangements and a known route for raising a concern. An activity involving children, people with substantial cognitive impairment, people experiencing severe mental health difficulties or higher-risk physical activities may require more structured arrangements.

The term safeguarding is frequently used in UK social prescribing practice. NHS England's updated Workforce Development Framework Version 2 places safe practice, supervision and safeguarding within link-worker development. Within the NHS Primary Care Network model, networks are also expected to be satisfied that organizations and groups receiving referrals have basic safeguarding processes for vulnerable individuals.[4]

These principles are useful, but Viet Nam should not treat the UK safeguarding framework as though it were a Vietnamese legal regime. The practical question here is simpler: if a serious concern becomes apparent, does the person involved know what to do and where responsibility should move next?

A community volunteer does not need to become an investigator because someone discloses possible abuse. A walking-group coordinator should not be expected to clinically assess new chest pain. A person performing a linking role should not attempt to manage an acute psychiatric crisis outside their competence. They do, however, need a response appropriate to their role, such as contacting emergency services, directing the person back to healthcare, alerting an appropriate social or protection service, contacting an agreed professional within the pathway or following another process required by applicable Vietnamese law.

Escalation also needs to work in both directions. Social prescribing is often illustrated as movement from healthcare into the community, but real life is not one-directional. Someone may become unwell after joining an activity, a previously stable participant may deteriorate, or a community organization may discover that a person's needs are more complex than originally understood.

The response should match the situation. A resource reporting that its class is full is an operational issue. Concern about deterioration without immediate danger may require timely professional review. An emergency requires an emergency response. These situations should not all be handled through the same route.

A safer pathway also allows community organizations to say “this is not appropriate for us” and treats that information as useful feedback rather than failure. International implementation and safety evidence shows why inappropriate referrals, poor continuity and limited community capacity matter to the success and safety of the pathway.[2,3]

Community partners need boundaries and sustainable capacity

Community organizations are sometimes described simply as destinations for referrals, which can make them sound passive. In reality, they understand their own activities, workforce, resources and limitations better than the referring organization and should have a meaningful role in deciding whom they can support and under what circumstances.

If a community partner is expected to receive people with more complex circumstances, additional training, coordination or funding may be required. If referral numbers grow, the pathway should consider whether the organization has the staff, volunteers, facilities and financial capacity to absorb the additional demand.

The 2026 global scoping review found that limited community-sector capacity, workforce pressures and unstable funding were recurring barriers to sustainable social prescribing. It also cautioned against commissioning referral or link-worker capacity without considering the organizations expected to receive participants.[2]

This makes capacity a governance issue, not merely an operational inconvenience. A program should not be described as successful simply because referrals increased while the organizations receiving them became overwhelmed. Nor should nonprofit status or volunteer involvement be interpreted as unlimited free capacity.

Partnership arrangements do not need to become unnecessarily legalistic, particularly for low-risk community resources. Where connections are routine, however, both sides should understand the purpose of the resource, eligibility or participation requirements, current capacity, main contact points, expected communication, relevant safety arrangements, information needs and circumstances in which a connection may be declined or returned.

Community participation should be based on partnership, not a silent transfer of workload from formal services.

Information sharing and documentation need their own governance

Cross-sector pathways can create an understandable temptation to share more information so the receiving organization “knows the whole story.” That is rarely the right starting point.

A community organization does not automatically need someone's diagnosis, medication list or medical history merely because the connection originated in healthcare. Depending on the activity, it may need only limited information. Even basic identifiers such as a person's name and contact details, however, remain personal data and should be shared only when the applicable purpose, legal basis and other requirements are satisfied.

Viet Nam's Law on Personal Data Protection No. 91/2025/QH15 took effect on 1 January 2026, with Decree No. 356/2025/ND-CP providing detailed implementation provisions from the same date.[7,8] Article 26 of the Law provides that the collection and processing of personal data relating to health require the data subject's consent except in the circumstances specified in Article 19(1), together with compliance with other applicable requirements. Health information also attracts specific protection within the broader Vietnamese data protection framework.[7,8]

Healthcare information is separately subject to confidentiality requirements under the Law on Medical Examination and Treatment. Among other duties, practitioners must keep confidential information about a patient's health condition, information provided by the patient and medical records, subject to the exceptions provided by law.[5]

A social prescribing referral form should therefore not become a convenient way of exporting a medical record into the community. Agreement to participate in social prescribing should also not automatically be interpreted as agreement to share every piece of available information.

The pathway should specify what information is being shared, with whom, for what purpose and whether the recipient genuinely needs it. Each organization also needs to understand its own responsibilities when collecting, storing, accessing or disclosing personal data.

The practical principle is straightforward: share what is necessary for a defined purpose, protect it appropriately and do not collect or circulate information merely because it might be useful later.

Documentation should follow the same principle. Not every detail of a person's community participation needs to be reproduced in the healthcare record. A structured pathway may reasonably need to record that an introduction was made, what the person agreed to, whether contact was successful and whether an important issue requires follow-up or escalation. More complex models may require additional documentation, but the purpose should be clear.

Feedback from community organizations should also be proportionate. Healthcare may need to know that contact failed, a program is full, the connection was inappropriate or a significant concern arose. It does not automatically need a detailed narrative of everything the participant said or did during the activity.

Closed-loop communication is most useful when it answers the questions needed for coordination: Did the person connect? Is the resource still appropriate and available? Is further action needed?

Incidents, complaints and supervision are part of governance

A pathway that measures only successful referrals will miss some of its most useful information. Unsuccessful connections can reveal inaccessible services, incorrect eligibility assumptions, transport barriers, cultural mismatch or poor communication. Community organizations declining referrals may reveal unclear criteria or capacity pressure. Complaints may expose problems that routine outcome measures do not capture.

Significant safety incidents should be reviewed at the appropriate organizational level and reported or escalated where required by applicable law, policy or partnership arrangements. The fact that something happened in the community rather than inside a healthcare facility should not make it invisible to the pathway where it is relevant to pathway safety.

This is especially important because current social prescribing research provides very little information about the incidence or prevalence of harms. The 2026 umbrella review specifically calls for stronger identification and reporting of harms rather than assuming they are rare because they have not been documented.[3]

An early Vietnamese pilot could therefore learn from inappropriate referrals, failed connections, escalation events, complaints, privacy incidents, capacity problems and other unintended effects alongside positive outcomes. The objective should be improvement, not the creation of a punitive incident culture.

Participants should also know where they can raise a concern. They should not have to understand the organizational structure well enough to decide whether a complaint belongs to a hospital, link worker, community group or project office. A well-designed pathway can provide a clear entry point and then route the matter to the organization responsible for responding.

Supervision is another important part of governance. Linking work can expose workers to financial hardship, bereavement, domestic conflict, housing problems, mental distress and other complex circumstances even when the role itself is non-clinical. Without support, there is a risk of role drift, inconsistent decisions and emotional burden.

NHS England's updated 2026 workforce framework treats supervision as necessary for social prescribing link workers to practise safely and effectively and emphasizes managerial, professional and clinical support according to need.[4] NHS England Viet Nam does not need to reproduce the NHS supervision model, but the underlying principle is relevant: people performing linking roles need somewhere to take questions that exceed their competence and a defined person or structure to support difficult decisions.

Depending on the model, supervision might be managerial, professional, multidisciplinary or a combination. What matters is that a worker is not left to improvise alone whenever boundaries become unclear.

What does this mean in Viet Nam?

Viet Nam already has relevant legal and regulatory frameworks for healthcare, social work, social assistance and personal data protection. The instruments discussed here, however, do not establish a separate legal status or liability regime specifically for social prescribing.

That does not create a legal blank space. Existing legal and professional requirements continue to apply according to the activities actually being performed.

Medical examination and treatment remain governed by the Law on Medical Examination and Treatment No. 15/2023/QH15 and its implementing framework, including Decree No. 96/2023/ND-CP.[5,6] Personal data processing is governed by the Law on Personal Data Protection No. 91/2025/QH15 and Decree No. 356/2025/ND-CP.[7,8]

The current framework for commune health stations also creates an important point of connection. Circular No. 43/2025/TT-BYT, effective from 1 January 2026 and subsequently amended in part by Circular No. 53/2025/TT-BYT, gives commune health stations responsibilities extending beyond medical examination and treatment into community health and social assistance. Its social-work functions include receiving and screening people, assessing needs, providing psychological support, connecting or transferring people to relevant organizations, case management and coordination with community social-work collaborators.[9,10]

These functions are highly relevant to the development of social prescribing, but they should not simply be renamed as social prescribing. Instead, they illustrate why governance needs to be thought through carefully.

A future pathway involving commune health stations would need to clarify which functions already fall within existing social-work or healthcare responsibilities, what additional linking function social prescribing is intended to add, which community organizations participate, what information moves between organizations and what happens when someone's needs change.

The same principle applies to hospitals, private clinics, social-service organizations and community-led models.

Viet Nam should therefore avoid creating a vague new layer between existing systems. Social prescribing is likely to be most useful when it creates better connections among responsibilities that already exist, not when it makes those responsibilities harder to identify.

What could good governance look like in an early Vietnamese pilot?

Before the first participant enters an early pilot, the organizations involved should be able to explain the pathway's governance clearly and concisely.

They should be able to describe the purpose and limits of the model, who can enter the pathway, who coordinates it, the roles of referrers, the linking function and community partners, and the circumstances in which healthcare or another professional service retains or reassumes responsibility.

The pilot should define how community resources are identified and reviewed, how capacity is checked, how an organization can decline an inappropriate connection, how routine feedback works and what happens when a resource changes or closes.

It should also have proportionate arrangements for urgent or complex concerns, clear professional contact routes where needed, supervision for people performing linking functions and processes for significant incident review.

Information governance should be agreed before referral information begins to move between organizations. The pilot should define what data are genuinely needed at each stage, the applicable legal basis and consent requirements, who may access the information, how long relevant records are retained and how privacy incidents will be managed.

Participants should know that participation is voluntary, understand the basic role of the organizations involved, know what information may be shared and have a clear way to raise questions or concerns.

Community partners should help design these arrangements rather than receiving a completed governance model from healthcare. A system that is easy for a hospital to administer but impossible for a small community organization to operate is not good governance.

Finally, governance itself should be evaluated. Inappropriate referrals, repeated escalation, long waiting lists, uncertainty among staff, complaints, information-sharing problems and community-provider feedback can all reveal where the pathway still needs clarification.

Governance should therefore be treated as a living part of implementation, not a policy document written once and filed away.

Key Takeaway

Social prescribing depends on relationships across healthcare, social services and community life. Those relationships are safer and more sustainable when each organization understands both what it is responsible for and what it is not responsible for.

A referral should not become a transfer of undefined risk. Clinical responsibilities should remain with appropriately qualified and authorized services for as long as those responsibilities apply. Linking roles should work within clear boundaries. Community organizations should be supported to provide the activity they are actually equipped to provide and should be able to decline inappropriate referrals. A coordinating function should help ensure that these responsibilities fit together.

Governance should also remain proportionate. The solution is not to turn every community group into a regulated healthcare service or surround ordinary community activities with unnecessary bureaucracy. It is to establish enough structure that people understand what happens when the pathway works as expected and what happens when it does not.

For Viet Nam, there is an additional reason to address these questions early. Social prescribing would operate alongside existing healthcare, social-work, social-assistance, community and legal systems rather than replacing them.

The most useful question is therefore not simply “Who is responsible for the referral?” It is:

“At each stage of the pathway, who is responsible for what, where does that responsibility end, and how is the appropriate next service brought in when the person's needs change?”

If those questions cannot be answered clearly, the pathway is not ready to scale.

References

1. World Health Organization Regional Office for the Western Pacific. A toolkit on how to implement social prescribing. Manila: World Health Organization Regional Office for the Western Pacific; 2022. ISBN 978-92-9061-976-5.

2. Kisa A, Kisa S. Models, implementation, and reported outcomes of social prescribing interventions: a scoping review. Frontiers in Public Health. 2026;14:1871347. doi:10.3389/fpubh.2026.1871347.

3. Cooper M, Okeowo D, Bennett L, et al. Potential harms of social prescribing: a global umbrella review and dark logic model. BMJ Open. 2026;16(5):e108998. doi:10.1136/bmjopen-2025-108998.

4. NHS England. Workforce Development Framework for Social Prescribing Link Workers. Version 2. Updated July 2026. Published 13 August 2026.

5. National Assembly of the Socialist Republic of Viet Nam. Law on Medical Examination and Treatment No. 15/2023/QH15. 9 January 2023. Effective 1 January 2024.

6. Government of Viet Nam. Decree No. 96/2023/ND-CP detailing certain provisions of the Law on Medical Examination and Treatment. 30 December 2023. Effective 1 January 2024.

7. National Assembly of the Socialist Republic of Viet Nam. Law on Personal Data Protection No. 91/2025/QH15. 26 June 2025. Effective 1 January 2026.

8. Government of Viet Nam. Decree No. 356/2025/ND-CP detailing certain provisions and measures for implementation of the Law on Personal Data Protection. 31 December 2025. Effective 1 January 2026.

9. Ministry of Health of Viet Nam. Circular No. 43/2025/TT-BYT guiding the functions, tasks, powers and organizational structure of commune, ward and special-zone health stations. 15 November 2025. Effective 1 January 2026.

10. Ministry of Health of Viet Nam. Circular No. 53/2025/TT-BYT amending and supplementing Circular No. 43/2025/TT-BYT. 31 December 2025. Effective 1 January 2026.

Article Information

Published: 26 September 2026
Last reviewed: 26 September 2026
Publisher: Social Prescribing Vietnam

Disclaimer

This article is provided for educational and informational purposes. It does not constitute medical advice, clinical guidance, legal advice, risk-management advice or official policy. Governance and legal responsibilities depend on the organizations involved, the activities performed, professional scopes of practice, contractual arrangements, individual circumstances and applicable Vietnamese law. Social prescribing does not replace medical examination and treatment, emergency care, formal social work, social assistance or other regulated services when these are required. Organizations developing social prescribing pathways should obtain appropriate professional and legal advice and establish locally applicable governance, safety, escalation, information-sharing, complaints and personal data protection arrangements before implementation.