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Judith Timmins
April 2015
‘Compliance Coach: Winning Strategies to Achieve Compliance’
 SEN/RGN: 1978 to 1995.
 Clinical history: ophthalmology, general surgery /medicine, T and O
and day surgery, plastics .
 Nurse manager: 1995 to 2000
 CCG manager: 2000 to 2010
 Private sector acute site, (care home and housing regional
management: 2010 to September 2014 (BUPA, BMI, Anchor Trust &
Shaw Healthcare)
 Survival Solutions: October 2014
 CQC background & history, current and past political issues
 New ways of inspecting
 How to Prepare
 What to Expect when you are Inspected , how to respond, common pitfalls, samples of reports
 Potential future for regulation
 Session plan: 2 – 3 hours with comfort breaks
 A regulatory body & part of the DOH
 Established in 2009 via the Health and Social Care Act 2008 to establish a
single regulator for health and social care, after a decade of poor practice
 Replaced CSCI and the Healthcare Commission & mental health commission
 New set of regulations after healthcare scandals ( Winterbourne ) in 2013 and
Stafford
 From 2014 includes dentists, GPs and homecare suppliers
 Exists to monitor safe delivery of healthcare & to promote improvement
 Chair: David Prior ( Formerly Tory politician) and CEO: David Behan
 Chief Inspectors: Mike Richards (hospitals ) Andrea Sutcliffe ( social
care & Steve Field ( GP) John Milne (Dental-Jan 2015)
 Not without is chequered past! ( Winterbourne, Morecambe Bay,
Stafford )
 Specialist practitioners now in place
 Times of visits and duration can vary: days nights & weekends. 1 to 2 days are
the norm but can be weeks at an acute trust. Can work with MBC,SW’s and
CCG to triangulate information and vary their visits with these staff over months
of time. Recent inspection at UHB /QE in Edgbaston: 3 weeks .
 May return unannounced during the 2 weeks after the visit to follow up
 Themed inspections e.g. dementia
 Response to a concern or complaint.. Can be maliciously based
 Should give notice ( this varies ) but not usually in a care home
 They have to be allowed access ( unless a dire emergency that affects client
care) E.g. Recent events at The Hawthorns
Looking to establish ‘CREWS’ where the service must be :
Effective.
Caring.
Responsive.
Well led.
Safe. (abuse, safeguarding, consent, meds issues)
NB: CQC have defined the characteristics of all these definitions and have prompts to
lead their discussions and questioning to enable them to make a decision on the
outcomes.
 Outstanding
 Good
 Requires Improvement
 Inadequate
 NB There is no ‘average,’ ‘satisfactory’ or ‘acceptable’ and no
‘very good’!
 Ongoing local information about the provider: Staff, carers &
complaints.
 Intelligent Monitoring: user & staff surveys
 Pre inspection: CQC records & other stakeholders: CCG, MBC
 On site direct and indirect observations & inspections:
records, policies, environment, what carers tell them
The fundamental standards are:
• Care and treatment must be appropriate and reflect service users' needs and
preferences.
• Service users must be treated with dignity and respect.
• Care and treatment must only be provided with consent.
• Care and treatment must be provided in a safe way.
• Service users must be protected from abuse and improper treatment.
• Service users' nutritional and hydration needs must be met.
• All premises and equipment used must be clean, secure, suitable and used properly.
• Complaints must be appropriately investigated and appropriate action taken
in response.
• Systems and processes must be established to ensure compliance with the
fundamental standards.
• Sufficient numbers of suitably qualified, competent, skilled and experienced
staff must be deployed.
• Persons employed must be of good character, have the necessary
qualifications, skills and experience, and be able to perform the work for
which they are employed (fit and proper persons requirement).
• Registered persons must be open and transparent with service users about
their care and treatment (the duty of candour).
10 minutes
 Introduction where CQC will explain their day’s plan to manager on site.
 Will be an ‘expert by experience’
 Mix of observation, chatting to staff, clients, carers and managers.
 Triangulate information with NHS managers, MBC, SW s, AHP teams, GP ‘s.
 Will look at documentation, (consent, care plans and care records, commercial
records, training records, feedback sign off and presentations, policies and
procedures, safeguarding documentation, client, carer and staff feedback forms )
 PIR report requested /jungle drums !
 Will follow up on areas in PIR at visit
 Show around and offer coffee ( beware here!)
 Leave alone but be cooperative
 They may give a rough timeline & agree a loose day s plan
 Feedback at days end
 Preparation is key:
 Hold a team meeting after PIR completed and discuss areas on PIR, and ensure they
are aware of what the inspector will look at
 Discuss what you may have problems with and put in an action plan on this NOW
 Fully brief staff on how to behave, what to say but be aware that comments can be
misconstrued very much.
 Feedback: Take copious notes and agree these when feedback session in progress
 Be professional but don't show overly concern at the visit.
 CEO/manager must be present – alert if out on visits
 Storage & Administration of drugs especially CD s
 Using other clients drugs
 Not being aware of drug side effects
 No drug review e.g. antibiotics, BP tablets, statins
 Record keeping... Where do I start ?!!
 Covert administration e.g. in cereal. NB Check policy!
 Consent to administer
 Gaps on MAR sheets
 No valid/expired prescription
 Administering without signing for drugs etc
 Giving in a job lot on a tray with unmarked medicine pots
or without taking the prescription sheet with you to the
client
‘Successful management of quality requires
truthfulness about the problems and then effective
action to improve. We are supplying the former; it
is up to the service to respond by acting on it.’
Last updated:19 January 2015
 Be very careful ..what you don’t say is as important as what you do say!
 Be honest .. but circumspect
 Don't give a plethora of information not relevant or requested
 Be professional: maintain eye contact, have a quiet environment, set
aside time to talk to the inspector, turn OFF your phone: DO NOT
maintain a relationship with it during the chat with CQC
 Give 1:1 commitment to the interview but ensure client safety.... You
cannot refuse a visit unless safety or dignity is compromised or carer
agreement withheld
 Highlight positive improvements or thing you feel proud of or
issues that you are working on
 Be enthusiastic & positive.
 What do SU’s like best.
 What has worked well/poorly. What are we trying to improve
on and what progress have we made
 Be aware of latest developments, improvements/critical
issues/complaints in the service.
 If training is a problem explain why and what the team are doing
about it ..ALWAYS put a positive spin on it
 ‘Oh yes we never see our manager..
OR ...’However we have a team meeting shortly to sort this out and I m
confident that it will be sorted due to XYZ actions being taken’
 ‘Oh no we never give covert meds’ .. Whilst doing this !
 ‘I hate working here.’
 ‘I’m leaving soon anyway ‘
 More regulation... not less
 Media and CQC exposure of poor care
 Increased powers of CQC re enforcement and MBC (Councils)
 Larger organisations & the reduction of smaller care provider’s
 More CQC errors, challenges from GP s and NHS trusts.
Recent Southend GP challenges and NHS Hinchinbrook.
Thank you
..Questions?

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CQC full version

  • 1. Judith Timmins April 2015 ‘Compliance Coach: Winning Strategies to Achieve Compliance’
  • 2.  SEN/RGN: 1978 to 1995.  Clinical history: ophthalmology, general surgery /medicine, T and O and day surgery, plastics .  Nurse manager: 1995 to 2000  CCG manager: 2000 to 2010  Private sector acute site, (care home and housing regional management: 2010 to September 2014 (BUPA, BMI, Anchor Trust & Shaw Healthcare)  Survival Solutions: October 2014
  • 3.  CQC background & history, current and past political issues  New ways of inspecting  How to Prepare  What to Expect when you are Inspected , how to respond, common pitfalls, samples of reports  Potential future for regulation  Session plan: 2 – 3 hours with comfort breaks
  • 4.  A regulatory body & part of the DOH  Established in 2009 via the Health and Social Care Act 2008 to establish a single regulator for health and social care, after a decade of poor practice  Replaced CSCI and the Healthcare Commission & mental health commission  New set of regulations after healthcare scandals ( Winterbourne ) in 2013 and Stafford  From 2014 includes dentists, GPs and homecare suppliers  Exists to monitor safe delivery of healthcare & to promote improvement
  • 5.  Chair: David Prior ( Formerly Tory politician) and CEO: David Behan  Chief Inspectors: Mike Richards (hospitals ) Andrea Sutcliffe ( social care & Steve Field ( GP) John Milne (Dental-Jan 2015)  Not without is chequered past! ( Winterbourne, Morecambe Bay, Stafford )
  • 6.  Specialist practitioners now in place  Times of visits and duration can vary: days nights & weekends. 1 to 2 days are the norm but can be weeks at an acute trust. Can work with MBC,SW’s and CCG to triangulate information and vary their visits with these staff over months of time. Recent inspection at UHB /QE in Edgbaston: 3 weeks .  May return unannounced during the 2 weeks after the visit to follow up  Themed inspections e.g. dementia  Response to a concern or complaint.. Can be maliciously based  Should give notice ( this varies ) but not usually in a care home  They have to be allowed access ( unless a dire emergency that affects client care) E.g. Recent events at The Hawthorns
  • 7. Looking to establish ‘CREWS’ where the service must be : Effective. Caring. Responsive. Well led. Safe. (abuse, safeguarding, consent, meds issues) NB: CQC have defined the characteristics of all these definitions and have prompts to lead their discussions and questioning to enable them to make a decision on the outcomes.
  • 8.  Outstanding  Good  Requires Improvement  Inadequate  NB There is no ‘average,’ ‘satisfactory’ or ‘acceptable’ and no ‘very good’!
  • 9.  Ongoing local information about the provider: Staff, carers & complaints.  Intelligent Monitoring: user & staff surveys  Pre inspection: CQC records & other stakeholders: CCG, MBC  On site direct and indirect observations & inspections: records, policies, environment, what carers tell them
  • 10. The fundamental standards are: • Care and treatment must be appropriate and reflect service users' needs and preferences. • Service users must be treated with dignity and respect. • Care and treatment must only be provided with consent. • Care and treatment must be provided in a safe way. • Service users must be protected from abuse and improper treatment. • Service users' nutritional and hydration needs must be met. • All premises and equipment used must be clean, secure, suitable and used properly.
  • 11. • Complaints must be appropriately investigated and appropriate action taken in response. • Systems and processes must be established to ensure compliance with the fundamental standards. • Sufficient numbers of suitably qualified, competent, skilled and experienced staff must be deployed. • Persons employed must be of good character, have the necessary qualifications, skills and experience, and be able to perform the work for which they are employed (fit and proper persons requirement). • Registered persons must be open and transparent with service users about their care and treatment (the duty of candour).
  • 13.  Introduction where CQC will explain their day’s plan to manager on site.  Will be an ‘expert by experience’  Mix of observation, chatting to staff, clients, carers and managers.  Triangulate information with NHS managers, MBC, SW s, AHP teams, GP ‘s.  Will look at documentation, (consent, care plans and care records, commercial records, training records, feedback sign off and presentations, policies and procedures, safeguarding documentation, client, carer and staff feedback forms )
  • 14.  PIR report requested /jungle drums !  Will follow up on areas in PIR at visit  Show around and offer coffee ( beware here!)  Leave alone but be cooperative  They may give a rough timeline & agree a loose day s plan  Feedback at days end
  • 15.  Preparation is key:  Hold a team meeting after PIR completed and discuss areas on PIR, and ensure they are aware of what the inspector will look at  Discuss what you may have problems with and put in an action plan on this NOW  Fully brief staff on how to behave, what to say but be aware that comments can be misconstrued very much.  Feedback: Take copious notes and agree these when feedback session in progress  Be professional but don't show overly concern at the visit.  CEO/manager must be present – alert if out on visits
  • 16.  Storage & Administration of drugs especially CD s  Using other clients drugs  Not being aware of drug side effects  No drug review e.g. antibiotics, BP tablets, statins  Record keeping... Where do I start ?!!
  • 17.  Covert administration e.g. in cereal. NB Check policy!  Consent to administer  Gaps on MAR sheets  No valid/expired prescription  Administering without signing for drugs etc  Giving in a job lot on a tray with unmarked medicine pots or without taking the prescription sheet with you to the client
  • 18. ‘Successful management of quality requires truthfulness about the problems and then effective action to improve. We are supplying the former; it is up to the service to respond by acting on it.’ Last updated:19 January 2015
  • 19.  Be very careful ..what you don’t say is as important as what you do say!  Be honest .. but circumspect  Don't give a plethora of information not relevant or requested  Be professional: maintain eye contact, have a quiet environment, set aside time to talk to the inspector, turn OFF your phone: DO NOT maintain a relationship with it during the chat with CQC  Give 1:1 commitment to the interview but ensure client safety.... You cannot refuse a visit unless safety or dignity is compromised or carer agreement withheld
  • 20.  Highlight positive improvements or thing you feel proud of or issues that you are working on  Be enthusiastic & positive.  What do SU’s like best.  What has worked well/poorly. What are we trying to improve on and what progress have we made  Be aware of latest developments, improvements/critical issues/complaints in the service.
  • 21.  If training is a problem explain why and what the team are doing about it ..ALWAYS put a positive spin on it  ‘Oh yes we never see our manager.. OR ...’However we have a team meeting shortly to sort this out and I m confident that it will be sorted due to XYZ actions being taken’  ‘Oh no we never give covert meds’ .. Whilst doing this !  ‘I hate working here.’  ‘I’m leaving soon anyway ‘
  • 22.  More regulation... not less  Media and CQC exposure of poor care  Increased powers of CQC re enforcement and MBC (Councils)  Larger organisations & the reduction of smaller care provider’s  More CQC errors, challenges from GP s and NHS trusts. Recent Southend GP challenges and NHS Hinchinbrook.