QCS have realised a new Clinical Governance Policy to its members this week. Clinical Governance is an umbrella term which usually focusses on 7 areas to drive continuous improvement, quality and safety for patients. For staff working in Health settings, ‘Clinical Governance’ is a phrase that is frequently used. For staff working in Social Care however, although everyone is familiar with ‘quality frameworks’- ‘good governance’ is less familiar language. Abi Spence, our Registration and Inspection Specialist explores what good governance looks like and how you can ensure a robust governance framework.
What does CQC expect good governance to look like and what should you?
About 10 years ago, I went to a Health and Social Care regulatory national workshop. I caught the speaker’s eye by giving some profound insight into a situation. In real life, I was unaware of what I had actually said, but it seemed to go down well!
The phone call
Later that week I received a phone call in which I was made aware of a managerial position which must, at the time, have been a few rungs up from where I was. I was encouraged to think about applying… and so I did.
The day of reckoning
The day of the interview came, and I had bought a new suit. That alone was bound to get me in I thought. It was obvious that they fancied me for the role, and I practiced hard remembering the company’s motto – I even had a little mime worked out for under the table if I forgot it.
The question floored me. ‘So what do you think strategic leadership is?’ Oh my goodness! Now someone was asking me, I had no idea of what that would look like or how to express it… not even with mime this time! I must have just stared blankly for what seemed like minutes, I can still see the interviewer now raising an eyebrow. Needless to say, the job was not offered and I learnt a lesson.
Blank faces
I have seen the blank face I displayed in others when I have asked about Governance. It is not comfortable from the other side of the table either when someone cannot find the words or does not have a structure in place to discuss.
Governance, what does CQC expect?
Unlike Clinical Governance, I was surprised by the wide definition of governance within Social Care. The internet is full of part-definitions and fractured insights. Whatever our personal ideas, it is important to look at what the regulations say to help focus the mind, and from that point springboard past it.
Health and Social Care Act 2008 (Regulated Activities) Regulations 2014: Regulation 17
The preamble on the CQC website states ‘The intention of this regulation is to make sure that providers have systems and processes that ensure that they are able to meet other requirements in this part of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (Regulations 4 to 20A).’
In a nutshell, the provider needs to run a service, and understand and act on what happens in the service in regards to quality and safety for the people it supports, and the people it employs. This is done by having a firm structure of accountability and responsibility in place, with processes and systems to support and improve it from the leadership.
The CQC Key Lines of Enquiry under the Domain ‘Well Led’ explains some of the elements it is looking for in this respect. The example hyperlinked is for residential care.
What does the service specifically need?
Well, that depends. Just like your service, your governance will be unique but some elements remain a staple. It will be based on the needs of the people you support, what you need to know to make decisions on direction, and to maintain compliance/ensure the service is good/outstanding. What is important is CQC can ask to see a report within 28 days of how you are assessing, monitoring and improving the quality and safety of the service as well as the risks identified.
Keeping it together
My daughter has an old-fashioned leather pouch. The circular kind that lays flat with two strings woven to the ends. All her precious things are kept inside …you know pieces of tarmac, sticks and bottle tops! When she forgets to pull the strings those precious things are not gathered up into that bag. It does not mean they don’t exist, but it makes it hard to find them if they are scattered around.
Likewise, your governance arrangements should be kept together in a document, easy to find and easy to show. This should be of a high level – with detail found in your policies, and evidence in your assessment, monitoring and evaluation tools and reports.
Who is who: Ever been asked who is responsible for something and you don’t quite know? Being clear about the positions held in the organisation and who is responsible for what from a leadership point of view is vital. If there is just you – still spell it out. If it isn’t down, does it happen? That is what I would be asking.
What takes place? This is really answered by more questions. Ask yourself what you assess, what you monitor and how you evaluate within your service and how often. The regulations tell you what is expected. Remember this is in relation to;
- Those employed (Regulation 19).
- Service users (see all other regulations).
- Directors or equivalent (Regulation 5).
- The requirements for the organisation and Manager (Reg 4,6,7).
- The building and equipment (Regulation 15).
- The fine detail will be elsewhere but you should link it together by reference.
How often does it take place?
I clearly remember asking a manager how often they monitored a particular area of the service? The response was, I have done it once. On another occasion, there was no clear pattern or routine as to when monitoring took place, with large unexplainable gaps. We sat together and trawled the paperwork as nothing was clear and I am not sure who was more confused by the end of it.
Top tip – be systematic and clear on how often you assess, monitor and evaluate. Who receives what and in what form?
What are the reporting requirements?
We all have bits of paper, but where do they end up. Evaluating, monitoring and weighing up the risk is one thing, but who in a position to make decisions gets to see it and what do they get to see? Information is not exempt from being evaluated. Systems should be in place for monitoring the effectiveness of what is collected, how it is collected and how it is presented.
How do you come to decisions and what is in place for improvement?
So we know what you do, how often you do things and who is accountable. But at a board or equivalent level, who makes the final decisions and how? Is there a regular meeting and who attends?
Inclusion
Within all of this remember that people need a voice. That is all people. Include how information is disseminated and people’s voices are heard. It should be clear through governance, the ethos and culture of your organisation to listen, learn and improve.
You may well have all of these precious gems in place. But are they in an explainable format? Are they together and show your good governance – because that in itself shows that it is.
Finally, QCS has just released a new Clinical Governance Policy and Procedure. If you are a QCS client, you will find this policy in the Quality Assurance section of your online system.
