CQC Hotspots – June 2017

Reviewing a further sample of 67 CQC dental inspection reports published over recent weeks, highlighted a number of compliance breaches which can easily be avoided, but which are still catching out some practices.

Of the 67 practices sampled, 9 practices were issued with breach notifications. Clearly the majority of practices are still getting things right, which is great news. All notices reviewed this month were again issued for breaches within the “Well Led” standard, with just one other issued in respect of “Safe”.

It is very clear from this, and several previous samples, that the “Well Led” standards are still causing problems for many practices, despite most being fully compliant in the many other aspects of good practice management.

The “Well Led” standard is inspected under the following broad areas:

• Governance Arrangements (management structure and responsibilities/delegation)
• Leadership, Openness and Transparency
• Learning & Development/Continuous Improvement
• Seek and Act on Feedback from staff and the public/patients

In the spirit of continuous improvement and to try and help 100% of practices achieve a clean pass, here are some of the key-findings and recommendations from these very recent inspections, which might just keep another practice out of trouble.

Interesting to note that several of the issues picked up by inspectors have been flagged up in previous bulletins and are all easily resolved once identified.

• Team members will usually be asked about the “Duty of Candour” which relates to a culture of open and honest communication amongst the team and with patients. This includes apologising to patients when things go wrong and staff feeling comfortable with raising issues and concerns. There should be a “no-blame” culture clearly evident.
• Inspectors are still picking up evidence of audits being undertaken and filed with no subsequent action planning or attempt to resolve identified issues. Remember that once you have identified a risk, the practice is responsible for pro-actively resolving and/or reducing the risk to an acceptable level. Always document timescales, responsibility and follow-up plans.
• Policies and procedures not signed, reviewed, circulated or updated. Your policies and procedures are essential working documents, which your team must be familiar with.
• Infection Control Audits, apparently completed, but not reflecting what is actually happening. Simple box-ticking is ineffective, a waste of everyone’s time and a real risk to the practice and patients. Remember that audits are intended to drive continuous improvement and change.
• Staff indicating that certain actions have taken place or resolved, but with no documentary evidence. Always make sure your efforts and hard work are recognised by keeping notes and records of what you are doing to improve the practice.
• Dental records (electronic or written) must be clear, concise and complete, with regular audits for each clinician. Feedback and monitor for improvements if necessary.
• Practices are still being picked up for inadequate recruitment and staff induction procedures. Follow simple, readily available checklists and procedures to demonstrate that you are doing things correctly and keep records in staff files.
• Ensure you are receiving, checking and taking action on relevant MHRA/CAS patient safety alerts. Dental practices don’t receive many but there must be a robust system in place to show that you identify and respond to any that are published.
• Ensure that all sterilisation and clinical equipment is fully maintained in accordance with manufacturer guidelines, externally validated by professionals/suppliers and that recommended routine/daily/weekly checks are undertaken diligently. Even more important is to have evidence and documents to support your checks and maintenance!
  
• Prescription and controlled medicines/drugs must be locked away and closely monitored.
• Management of sharp injuries are regularly checked. Ensure procedures are in place and communicated to all the team. Incident/Accident Reporting records must be updated for each event.
• COSHH records not held or maintained/reviewed. Practices work with a lot of high-risk substances. Essential that you have information sheets and risk summaries for all, including routine cleaning materials. Immediate access to this information will be vital in the event of an accident.
• Make sure that your clinical team have up to date Hep B immunity records confirmed and available for checking, before working in risk areas.
• When appointing Fire Marshalls, First Aiders and other “appointed” roles, make sure that they are adequately trained and know that they have been appointed to the role! Inspectors have talked with staff who are unaware of their responsibilities.
• Information Governance is becoming increasingly important, and high-profile as evidenced by recent events within the NHS. Make sure your team have been trained, with evidence, and are following your reviewed and updated IT security policies.
• The practice Health & Safety risk assessment must be kept up to date and where new or changed risks are identified, actions put in place to resolve quickly. Don’t delay as once identified, you have a responsibility to correct.
• Inspectors continue to come across missing or partially-completed, mandatory risk assessments including Sharps, Fire, Clinical Waste, COSHH and Manual Handling.
• Remember to date and review all of your practice policies and procedures at least annually. If nothing has changed simply re-date to show that you have been there.
• Don’t forget that associate dentists, therapists and hygienists should also have annual appraisals to review performance and identify training requirements.
• Appraisals are generally expected to show evidence of performance, learning needs, “general well-being” and future training/development plans. Something is better than nothing, so don’t delay or wait for “perfection”.  So often, inspectors are told that appraisals “are in hand” but not yet done.
• Collecting and responding to patient feedback and comments is essential. Even more important is to evidence what action has been taken in response to feedback. Inspectors will always ask for specific examples, so be prepared.
• Take care with “Off the Shelf” or “In a Box” Policy and Procedure packs. They are an essential and valuable source of material for many practices, but each policy/procedure must be reviewed and personalised to the practice and the way you work.
• Missing or out of date Accessibility Audits, which are required under the Equality Act 2010 along with action plans and explanations for not implementing best practice. One practice was picked up for not having a hearing loop on reception – something which can be reasonably implemented as required under equality legislation.
• The practice is responsible for overseeing CPD training – make sure you keep records of where everyone is within their CPD training cycle.
• For multi-site practices, make sure that their is a responsible person at each site – don’t just rely on a “roving” practice or compliance manager.
• Don’t forget to book regular team meetings into the diary – ideally monthly – and keep records of agendas, minutes and action points from each. It is not enough for staff to say that everything is discussed and resolved informally during the working day. Also remember to keep absent staff (holidays, part-time or sickness) fully up to date with evidence.

As always, remember that if something is not recorded or evidenced, in the eyes of the CQC and other external bodies such as the NHS, it didn’t happen, even though you may know full well that it did! This continues to catch practices out, leading to frustration and avoidable stress for all!

Findings from previous inspection reviews can be found here:  CQC Hotspots

There is plenty of help out there to plug any management gaps including Your Dental Manager, so please do get in touch if you have any concerns or want to further improve the overall management/efficiency of your practice: info@yourdentalmanager.co.uk or check our on-line calendar to book a complimentary chat.