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27th April 2020

Keeping compliant in the face of change

The article below was fist published in the CMM magazine, which you can read here.


From changes to regulation, to having to find new ways of working, COVID-19 is certainly making life different. Philippa Shirtcliffe, Head of Care Quality at QCS, explains where coronavirus is accelerating positive change and why compliance will always remain central to providers.

We are living in difficult times. For the last five months, we have been at war with an invisible, and insidious virus, which, to date, has claimed over 170,000 lives globally. With nearly 126,000 confirmed cases and over 16,500 deaths, the UK has been hit particularly hard by this new strain of coronavirus, yet the spirit, compassion and resolve of the UK’s 1.49 million frontline carers, who provide outstanding person-centred care for millions of people, remains undimmed. [i]

Regulators too are playing their part. While I cannot speak for the Care Quality Commission (CQC), as the Head of Care Quality for Quality Compliance Systems (QCS), I talk to registered managers from care homes and domiciliary care agencies every day and a significant portion of our customers have fed back the positive role that CQC is playing in supporting them to provide outstanding care in highly challenging circumstances.

Change of focus

Indeed, with all inspections cancelled, CQC has shifted its focus, carving out an important role for itself in helping providers to adapt and respond to the changing situation. Care providers – and we talk to services of all shapes and sizes – are telling us that CQC has adopted a much more flexible approach to regulation. Many say that in this unprecedented climate, it has recognised that providers may not be able to keep up to date in terms of auditing.

I also know that CQC has opened up digital communication channels recently. The message it is communicating to providers up and down the country is overwhelmingly positive and reassuring. In a time of national crisis, the regulator is saying, meet us halfway; follow regulation where you can and if you’re unable to do so, document the reasons why you have had to deviate away from normal processes.

In an age of social distancing, CQC inspectors are also participating in webinars, where they're providing key advice to providers. As they create a new collaborative relationship with care providers, barriers are being broken down, and the hope is that the sector is witnessing real and lasting change. But if it is to happen, the sector must come together as one and use its collective voice to work with regulators to ensure that national and regional protocols remain consistent.

Still much to do

The majority of our customers are telling us that the current local and national guidelines surrounding PPE are confusing. Regional guidelines state even if nobody in a home has symptoms of COVID-19, care workers need to wear gloves, an apron and a mask, while national advice states the exact opposite. Although this protocol has been put in place by Public Health England, care providers are looking towards CQC to provide them with clear guidance.

In the long-term, the advice from inspectors will probably be to ask providers to carry out risk assessments, which also take account of the local area too, and base their decision on those assessments. If providers are using digital communication platforms to establish regular contact with inspections team, this is something that can be nipped in the bud much sooner.

Compliance is key

However, it’s not just clarity that is needed, but a greater recognition of the challenges faced by the different entities that make up the care sector.

Take the UK’s domiciliary care services, who, between them, look after millions of people. Since the coronavirus epidemic began in February, most of the questions that we've received around PPE have come from them. For example, questions such as, ‘when and where does a domiciliary care worker, who uses public transport to travel between homes, put their PPE on?’ Or, ‘when a domiciliary care worker reaches a home, do they have to change PPE every time they venture into a new room as national guidelines dictate?’. With a national shortage of PPE this would be impossible, but these micro-examples serve to illustrate a wider point of the paucity of bespoke and structured messaging.

Thanks to 24-hour news stations, and a daily update from Government, there’s no shortage of information. But as far as the care sector is concerned, there are very few organisations, who are capable of taking a step back, disseminating and distilling that information and integrating it into easily digestible policies and procedures. At QCS, we have been gathering and sifting through coronavirus best practice guidance to produce easy-to-read policies and procedures. We’ve also created factsheets, bulleted information cards and produced a series of ‘How to’ blogs, which anyone can access on our coronavirus hub for free, even if they don’t use our software.

Many of our providers are feeding back that the policies, which are regularly updated, are helping them to stay compliant. But it is not just Pandemic Infection Prevention and Control policies that are valued in a time of crisis. Even now, providers must not lose sight of CQC’s key questions and the KLOEs that underpin them. When you’re stressed and busy, it’s easy to forget that person-centred care is holistic in nature. It’s not just about protecting residents from coronavirus, it's also about ensuring their happiness, their wellbeing and making sure that no one’s human rights are being breached.

Technology can be a great leveller

With the coronavirus pandemic intensifying recruitment and retention challenges, providing outstanding care is not easy. But technology is a great leveller. Providers who find themselves suddenly short of staff due to Government’s seven- to fourteen-day self-isolation policy can now use technology to form partner networks with local providers, and share staff when possible.

Technology can also help raise efficiency and productivity. If a registered manager, for example, is presenting with mild coronavirus symptoms, they could use Zoom or Skype to communicate with staff, even while they need to self-isolate at home, and can use digital systems to ensure that regulation is being adhered to. This means that a service can continue to be well-led, even in the middle of a pandemic.

Technology also ensures that training doesn’t have to stop. Zoom and Microsoft Teams enable providers to foster an eLearning approach. That said, while eLearning is extremely effective, the best providers realise that a ‘hybrid’ structure, which also encompasses face-to-face teaching, is required. This requires training providers to embed several steps into their programmes, which provide tangible evidence that staff have understood what they have been taught and how it fits into the wider regulatory context.

One-on-one meetings are not only an extremely effective way of checking understanding and identifying any gaps in knowledge, but they also help to flag wellbeing issues. Indeed, if anxieties and concerns are aired at an early stage, it can prevent more serious issues at a later date. Therefore, this hybrid approach, if used correctly, can alleviate pressure and help to build future resilience.

Greater collaboration

Most of all, this crisis has shown us the power of collaboration. Whether you’re one of the courageous few working on the front lines, or, like most of the population, applauding their efforts from our doorsteps and windows, it demonstrates what can be achieved when we pull in the same direction.

With recessionary clouds gathering on the horizon, even when we have beaten the virus, there will be major challenges to overcome. Budgets will inevitably be cut. But the heroic deeds of care workers will be remembered by the public. The hope is that the NHS and the social care sector will work together much more closely than they have done in the past.

Before the crisis, it would have been inconceivable to think that the care sector could ever shake off its ‘Cinderella service’ tag. Now, however, thanks to brave actions of a few, we may be on the cusp of positive and profound change. There are have been very few shafts of sunlight in this crisis, but this might be one of them.

[i] Figures taken from Johns Hopkins coronavirus data centre. Figures are accurate at the time of writing.



*All information is correct at the time of publishing. Use of this material is subject to your acceptance of our terms and conditions.

Philippa Shirtcliffe

QCS Clinical Policy Lead

Philippa Shirtcliffe is Head of quality at QCS. She is a registered nurse with over 30 years working in Health and Social Care. She has had varied career undertaking operational and strategic leadership roles within social care. Read more

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