In September 2020, the Care Quality Commission (CQC) commissioned a special report, which looked at Infection, Prevention and Control (IPC) best practice. The study, entitled ‘COVID-19 Insight: Issue 4’ also shared examples of outstanding IPC across the social care and health sectors.
Following 300 inspections in care homes, the CQC observed that “very few of these services turned out not to be managing well and requiring a fuller inspection”. In terms of percentages, The CQC reported “90 percent assurance” in IPC. Having worked on the social care sector’s front lines for more than 15 years, maintaining extremely high IPC standards does not surprise me one jot. After all, maintaining world-class standards of cleanliness is one of the things that the social care sector does best. The care sector may not have the funding, the resources and the personnel as the NHS has, but it has always had systemic and systematic processes in place which over time have been deeply ingrained into the culture of the sector. Care services have a dedicated IPC framework, which everybody from the Registered Manager to those making deliveries understands and implements on a daily basis.
The social care sector is good at IPC
Many services, however, go the extra mile and strengthen their already excellent IPC programmes by using a content management platform. Over 140,000 providers have chosen Quality Compliance Systems (QCS), the leading provider of content, guidance and standards for the social care sector, to strengthen their IPC capabilities. Not only does QCS provide its customers with the latest IPC policies and procedures, but also best practice content to help them to stay ahead of the curve. This has been particularly the case throughout the COVID-19 pandemic as QCS has helped providers to manage the constant and sometimes sudden changes in government IPC policy.
Despite social care’s dedication and commitment to continuously improving IPC standards, a year ago, the NHS published the National Standards of Healthcare Cleanliness 2021. The 55-page document contains a set of updated standards that all healthcare settings – including acute hospitals, mental health and community services, primary care, dental care, ambulance trusts, GP surgeries, clinics and care homes – must meet, regardless of the way cleaning services are provided. Together with the Health and Social Care Act 2008 and associated regulations, the National Standard of Healthcare Cleanliness provides an assurance framework to support compliance with the core cleanliness standards and code of practice.
QCS, the organisation that I contract for, has fielded a lot of enquiries from worried providers, who are struggling to understand their new responsibilities. Their concern is understandable. Although the National Standards of Cleanliness was published a year ago, it came in the middle of a pandemic. It is no surprise, therefore, that providers, who were busy caring for service users in the greatest health crisis in decades, were unable to give the document their full attention. Given that they were wrestling with the pandemic, they should have been given more time to implement the changes.
That said, it is still unclear when the new guidance will come into force. NHS documentation does not state a clear date, while the CQC guidance is equally vague. My advice to providers is not to panic. Ironically, with the large majority maintaining such a high IPC bar during the pandemic and many exceeding it, they have proved to the regulator – and themselves – that they have what it takes to meet the requirements set out in the National Standards of Healthcare Cleanliness document.
So, what are they? Firstly, the guidance calls on “staff groups – both clinical non-clinical…” to collaborate “to meet the cleanliness standards for the whole area”. With the document largely written by NHS staff for NHS staff, this first standard may be a challenge for hospitals, but as I stated earlier, working together as one single entity to strive for even higher IPC standards is something that comes naturally to social care services.
Most of the other bullet points relate to auditing. The new guidance calls for every care service to conduct regular internal audits. It also says that providers need to be audited annually by an external organisation. Again, a culture of IPC auditing has been firmly instilled in those who work in the social care sector for many years. Providers using content management systems, such as QCS, have the tools to carry out risk assessments, which immediately highlight weaknesses in an IPC framework. They also have access to high-level auditing systems, to ensure that they can demonstrate that they are meeting Regulation 15 of the Health and Social Care Act 2008. This requires healthcare premises to be clean, secure, suitable and used properly. The regulation also ensures that providers maintain standards of hygiene appropriate to the purposes for which they are being used.
However, that said, I do feel that there are a multitude of smaller social care providers that won’t be able to afford regular auditing, which can run into thousands of pounds. There perhaps needs to be a set of exemptions put in place, as many smaller services are already feeling the pain of a perennial lack of funding, the cost of living crisis and sky-high insurance premiums. Surely providing training and resources would allow smaller care providers to carry out peer-to-peer reviews? Not only is this a cost-effective solution, it is highly effective as those carrying out the reviews would be highly experienced registered care managers.
My other major bugbear is that after providers have carried out an internal audit, the new guidance requires them to create posters displaying cleanliness star-rating scores. While this works in hospitals, I’m not sure it translates well to residential care homes where people live. Care homes already have to display their CQC rating and so having to showcase two different posters on windows might cause confusion. Secondly, as I alluded to earlier, the standards must also take into account the fact that care homes are not clinical environments where patients go to get better. They are people’s homes. There is a danger that posters could somehow detract from the rich, person-centred culture that care homes have worked so hard to create.
What providers should do
So, what should providers do? My advice is for Registered Managers to firstly review their Infection, Prevention and Control annual statement. Secondly, they should compare the statement to the new guidance set out in the National Standards of Healthcare Cleanliness 2021 document. Thirdly, Managers should work their way through the document and tailor it to requirements of their organisation. This, I think, is the key point. The responsibilities of each sector and each individual setting within it, should have been clearly laid out in the National Standards of Healthcare Cleanliness documentation.
With there being no clear timeframe for implementation other than a plethora of possible dates in 2022, the hope is that the guidance will be updated to better reflect the needs and requirements of individual sectors and settings. It is also vitally important that it the guidance mirrors any additional recommendations provided by the Department of Health and Social Care and the CQC.
To access the National Standards of Cleanliness, please see below link: