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Inspections: Be Prepared
The routines of the day start and it is another busy day; the staff are arriving for the handover of duty from night to day, the people in your care are starting to rise, drinks are offered, assistance where needed is given. It all works like a military operation, except this is not an army camp. Everyone knows what needs to be achieved and it all runs like a Swiss watch
It’s another normal day at the office however, this is not any normal nine to five job. You have chosen to build your career by taking on the role of the Registered Manager of a care service. You and your dedicated team of staff cater for, and look after, some of the most vulnerable and elderly people in society. Your office is called “home”.
The bustle of the day starts; you welcome staff, check on your service users and say good morning, check to ensure no adverse incidents have taken place and that everyone is fit and well. You check the appointments for the day and the list of things that will need to be attended to, you take this all in your stride you do it every day. Whilst most days you love your job there are other days when you wonder why you decided to do this. You’re undertaking the routine tasks that have to be looked at every day, you are the manager you have a responsibility not only to your employer, but to your staff, other professionals and the people that choose to live at the service.
The doorbell rings and you hear the words “Hello I am the regulatory inspector and I am here to undertake an unannounced inspection on your service”.
Don’t panic! How many times in our lives have we heard this phrase?
All providers of care have seen massive changes in the last few years. Not just from the change in names of the Regulators, but the introduction of the new Health and Social Care Act.
From National Minimum Standards to OUTCOMES and the Essential Standards of Quality and Safety. We get the hang of one thing then everything changes again!
I am digressing, let’s go back. The Regulatory Inspector has arrived. Gone are the days when one size fits all inspections were undertaken. This is a new era and a new focus and it’s not on policies, procedures and practices undertaken by the service, but the quality and safety that your service needs to provide to people to meet the new standards.
This new era is about you, your staff, and the most important aspect, the people who use your service and what they should experience when they use a registered health and adult social care service.
The Regulatory Inspector is not your enemy. They are not there to catch you or your staff out. They come in peace, to monitor and check that you are meeting the Essential Standards of Quality and Safety (England) or the National Minimum Standards (Scotland & Wales & Northern Ireland).
Their focus is on having evidence that demonstrates that people who use services have good outcomes and experiences, meaning that their care is effective and that they are safe at all times. That service users are involved in their care, and that their views are listened to, and acted upon, at all times.
It all sounds so easy
The essential standards of quality and safety consist of 28 regulation set out in the Health and Social Care Act 2008 (updated 2012) (Regulated Activities) for England. For each regulation there is an associated outcome this is the experience that the Regulatory Inspector expects people within services to have as a result of the care they receive, these outcomes directly relate to the quality and safety of care.
The Regulatory Inspector is there to assess the service to ensure compliance with the regulations and standards, that health and social care being provided is person centred, consistent, and takes into consideration the effects that care and interventions have on a person.
The Evidence – is this something we have to give in court? Remember the Regulatory Inspector is not a judge however, judgement comes later!
The Regulatory Inspector is there to measure and evaluate the service to ensure the health, welfare and safety of the service users within your care.
All of the regulatory bodies including the Care Quality Commission (CQC), Care & Social Services Inspectorate Wales (CSSIW), Social Care & Social Work Improvement Scotland (SCCWIS) and Regulatory Quality Improvement Authority (RQIA) have up to date guidance on their websites to guide you through the evidence requirements in order to reach a satisfactory outcome for the service users in your care.
It is essential that you as a registered manager and your staff read the regulatory guidance and where necessary receive training. This is needed so there is a clear understand of the importance of your roles and responsibilities with regards to meeting these essential standards.
The following evidence will help assist the Regulatory Inspector when he/she is evaluating your service:
- A comprehensive and up to date Statement of Purpose;
- A comprehensive and up to date Service User Guide;
- That all documentation from care plans to risk assessments relates to the people who use the service and takes into account diversity.
It’s all sounding so far so good. You may say “we have all this”, and you might do, but the Regulatory Inspector will want more.
The CQC have developed a Provider Compliance Assessment document with guidance to help providers in England to demonstrate compliance with outcomes, the other regulators also have pre assessment documentation with guidance on their websites. At some point all service providers will be asked to complete the relevant documentation. This can be asked for before the inspector makes a visit to the service or sometimes following a visit.
Thinking back you should have known you were going to get a visit you completed the Pre Assessment Documentation sometime back.
Regulatory visits can take place at any time. They are usually unannounced. Completion of any pre- assessment documentation from any of the regulators is not a guarantee that you will be visited. All service has to be visited at some time to ensure that you are meeting the essential standards of quality and safety, and that you are compliant according the regulated activity you are registered for.
By the way Quality Compliance Systems also have a PCA tool kit that assists service providers in completing the PCA!
All service providers should measure their own performance at regular intervals to monitor ongoing compliance with regulatory legislation. All service providers of adult social care should be gathering and collating all of the information obtained from the core groups.
Your evidence must come from a variety of different sources this includes your:
- Relatives or those acting on a person’s behalf;
- Professionals that visit the service which can include the GP etc;
- Any other stakeholders.
This evidence has to demonstrate:
- How you have assessed the needs of the people in your care appropriately and adequately, and how these needs are being met;
- How you address and minimise risks to the health, welfare, and safety of people;
- How you listen and act on all information and feedback received.
You could also use other evidence that may demonstrate outcomes for people directly or indirectly, such as:
- Service User satisfaction;
- Quality monitoring including reviews of the service;
- Complaints and concerns;
All of this crucial information about your service should be put into a format or report that is easy to understand and be available to everyone that lives at or visits the service.
Evidence any changes that you have made, together with the results of any improvements following analysis of the quality assurance data you have collated. Show the Regulatory Inspector the changes that you have made to protocols or practices within the service, and what positive impact this has had on the service users.
The Judgement Framework – Now remember the Regulatory Inspector is not a Judge
The framework is used to by the inspector to make a decision considering all of the evidence that your service is compliant. These outcomes directly relate to the quality and safety of care.
This is split into 4 stages
Stage 1: Determining whether there is enough evidence;
Stage 2: Checking whether or not the evidence demonstrates compliance, or whether there are concerns;
Stage 3: If concerns are identified, making a judgement about the impact on the people using the service;
Stage 4: Validating the judgement.
Setting the Bar
The Regulatory Inspector has inspected all of the key standards that will lead to a Judgement on each of these, but not today, they will be taking all of this information away to evaluate and review.
They come to say goodbye, and maybe give you some feedback, but you will not know the outcome or result of the inspection until the report arrives.
The Report – It’s finally arrived and these days it is also delivered at the speed of light, via email. How we have advanced with modern technology.
The decision is made and the Judgement is in.
Compliant: This means people who use services are experiencing the outcomes relating to the essential standards.
A minor concern: This means that people who use service are safe but are not always experiencing the outcomes relating to this essential standard
A moderate concern: This means that people who use service are safe, but are not always experiencing the outcomes relating to the essential standards, and there is an impact on their health and wellbeing because of this.
A major concern: This means that people who use services are not experiencing the outcomes relating to this essential standard and are not protected from unsafe or inappropriate care treatment and support.
Where the Regulatory Inspector has identified compliance no further action is taken – you can sit back, relax, and pat yourself and your staff on the back; a job well done however, you now have to constantly monitor your service to remain compliant.
Where the regulatory inspector has concerns, the most appropriate action will be taken to ensure that the necessary improvements are made. Although you may not think this is great, you have come through the inspection and slight amendments and adjustment need to be made. You submit your SMART plan but at least you know that the next time the Inspector arrives, you will be ready.
Where the regulator judges that there are a number of concerns, they will be looked at together and the level of action decided – usually a Warning or Statutory Notice. Again as a service you will have to respond appropriately, and be aware that your service will now be closely monitored and evaluated.
REMEMBER you are in a service industry in which you can achieve the highest standards and the best possible OUTCOMES, and that there are lots of tools and guidance available in the QCS system to help you achieve compliance.
But of greatest importance is that you and your staff CARE.
This is the most important OUTCOME that a person could wish for.