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Lessons learned? – CQC raises the compliance bar for prospective learning disability service providers.
It appears that a change is coming for prospective providers of learning disability services, as CQC release plans that see a requirement for considerably more detail to support the application process. Under plans due to be rolled out over the remainder of this year, it will be necessary for providers seeking to register new services (or make changes to existing ones) to be much more explicit about their intentions.
CQC are looking to establish much more clarity about the background of people who want to own and run services with a range of additional questions for the application process. These concern the experience and history of applicants, the names, date of birth and information about board and governing body members of organisations, together with any additional responsibilities these people may hold. There are also questions around any disciplinary actions or proceedings that organisation members may be subject to, as well as financial history such as bankruptcy. Links and contracts with other organisations will also need to be divulged.
More depth and clarity is to be required around the way the prospective service will be run, any restrictions or consents needed for building and premises use and more information around staffing skill mix, numbers, roles and job titles. Unlike the current application form, there will be a requirement to provide narrative on issues such as safeguarding clients, environmental safety and medicines management, staff recruitment, retention, training and performance. Organisations will be required to give detail about quality assurance, continuous improvement and how they intend to manage comments and complaints. Moreover, the requirement will not only be to describe intent, but also to state how this will be evidenced.
Prospective owners as individuals will need to provide more detailed information about background and employment history including any previous registrations. Where applicants are in partnership with others, there will be a requirement to state the nature of the partnership.
Changes are also proposed to the statement of purpose, with a much more structured template that asks for details about philosophy of care, culture, best practice, continuous improvement and sustainability. Together with the Department of Health, CQC are revising the regulations to support this new approach from April 2014 and are asking new learning disability or autism service providers to voluntarily adopt the new model. Improving the statement of purpose with a very explicit template may seem daunting for small providers, but to provide this level of detail at the outset can be really helpful for future service development.
More emphasis will be placed on evidencing supervision of staff and professional development, with new supporting guidance to help providers to complete applications to the level of detail required. CQC also outline the planned approach to visit prospective services and evaluate the management systems in place to support the proposed business. Where new organisations are not yet trading, there will be a need to demonstrate how plans might be operated, with an increased scrutiny around operator knowledge, understanding and experience.
Many of the changes to applications are already being adopted in fit person interviews, where applicants are asked to offer significant detail around the statement of purpose, ethos and nature of the provision. They will be expected to demonstrate a real understanding of the responsibilities they have under the Health and Social Care Act 2008 in terms of legal obligations, notifications and managing the outcomes of inspections.
Safeguarding features large in the Fit Person interview, with applicants required to show an understanding of DOLS applications, awareness of potential abuse and the need to encourage staff to be vigilant, as well as a clear policy on whistleblowing. It will be necessary for interviewees to provide details of the operational plans for health and safety of workforce and site, including producing risk assessments that enable, rather than restrict, service users.
With regard to care planning , detail will be sought on the style and type of systems, how they are recorded, agreed, monitored and stored. There will be a need to demonstrate service user involvement in person centred care. Approaches to complaints and feedback are also scrutinised, as well as a consideration of quality improvement and governance systems.
Another change is the level of detail being requested concerning how service users will be supported to access the community around a planned new service. This will consider physical accessibility, transport links, location in relation to work, social and family contact, all of which will seek to avoid institutional isolation for service users.
All of these planned changes should be encouraging news for providers of responsive and high quality services. Many providers can already evidence all of these aspects of a good service and it could be argued that anyone seeking to operate a facility which cannot do so should never have been considered for registration. However, recent history proves that this has not been the case and lessons learned from large scale service failings have prompted these much needed reforms.
CQC have identified more specialist assessors with a background in learning disability services and are providing further training to ensure ongoing knowledge and understanding of this specific area of work. By engaging with organisations undertaking this new level of assessment and considering feedback over the coming year, it is planned that the more detailed application process will be incrementally rolled out to other service groups. They are planning to achieve legislation that will mean a significantly more robust test of provider suitability from April 2014.
Of course, a higher standard of application is hoped to lead to a higher quality of provision, but it remains to be seen whether organisations that show diligence around their planning and intentions are well monitored in practice afterwards. There is still significant work to do to ensure such attention to detail at the application stage translates into reality once a service is launched. It is undoubtedly better to lose poor providers at the first hurdle, but assuring provider quality and compliance over the longer term will need considerable investment and tenacity from regulators.
Virginia Tyler, RNLD DipNHM MSc – QCS Expert Contributor on Learning Disabilities