- CQC requires that there are systems, processes and practices in place to ensure that all care and treatment is carried out safely.
- Dental practices should learn from incidents and ensure that improvements are made when things go wrong.
- There should be systems, processes and practices in place to keep people safe and safeguard them from abuse.
- Risks to individual people who use services should be assessed and their safety monitored and maintained.
Are you working safely?
To answer this question, CQC’s definition of ‘safe’ needs to be understood. In How CQC Regulates Primary Care Dental Services: Provider Handbook, March 2015, the CQC states “By safe, we mean that people are protected from abuse* and avoidable harm. *Abuse can be physical, sexual, mental or psychological, financial, neglect, institutional or discriminatory abuse”.
However, what does that mean to dental practices? CQC inspectors now have an inspection handbook that contains inspection prompts in the form of ‘KLOE’ (Key Lines of Enquiry). These are the questions that are likely to be asked during an inspection and for which you will need to provide evidence. So, let us drill down into those inspection prompts and explore what that means to dental practices.
The safe inspection prompts
S1 – What systems, processes and practices are in place to ensure that all care and treatment is carried out safely?
Dental teams should have a clear understanding of how to report RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013). The expectation is that any safety incident should be recorded, learned from and quality assurance measures implemented to prevent a similar event occurring in the future. The Control of Substances Hazardous to Health (COSHH) should be fully understood. Hazardous products should be identified, risk assessed individually and measures put in place to mitigate any risks during use. Providers are also expected to comply and respond to relevant patient safety alerts, recalls and rapid response reports published by the Central Alerting System (CAS) and Medicines and Healthcare products Regulatory Authority (MHRA). These agencies can be signed up to online and alerts will be delivered via e-mail.
S2 – How are lessons learned and improvements made when things go wrong?
When something goes wrong in practice, dental teams are now expected to implement Regulation 20 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, the Duty of Candour. Patients affected by the incident must be offered an apology and informed of any actions taken as a result of the incident. Dental providers are legally bound to identify and investigate safety incidents, clinical errors and near misses that affect patients and staff alike. Lessons should be learned and communicated to ensure that risks can be mitigated and similar events do not happen again.
S3 – What systems, processes and practices are in place to keep people safe and safeguard them from abuse?
All staff members should understand how to identify, report and respond to suspected or signs of definite abuse. Staff should receive training on safeguarding of children and vulnerable adults (Level 2), complaints handling and whistleblowing in order to meet their accountability to report concerns. Policies and procedures should be in place and team members should be educated on how legislation plays out in the reality of day-to-day practice. If legislation changes, staff should be alerted to the changes ideally in a monthly team meeting. Female genital mutilation and modern slavery are criminal activities in this country and staff should know how to escalate any issues that they maybe alerted to to the appropriate authorities.
S4 – How are risks to individual people who use services assessed and their safety monitored and maintained?
Dental teams are required to deliver person-centred care (Regulation 9) where patients have a voice and are central to all decision-making. Staff should be trained to identify any deterioration in a patient’s health and to deal with medical emergencies effectively and efficiently. All team members should be ‘fit and proper’ for their role in the first instance so selection and recruitments processes are a crucial element of the safe KLOE. Evidence for safe recruitment processes and optimum staffing levels are a key focus for CQC in 2019 so practices must have evidence for this. Staff personnel folders should be comprehensive and complete prior to an employee commencing work. A list of folder contents is included in the Toolkit as a checklist.
S5 How well are potential risks to the service anticipated and planned for in advance?
Any disruptions to service provision must be planned for, be it service developments, a flood or a power cut. A business impact analysis needs to be performed to assess the impact on service delivery and the time it may take to get the service back to normal. Disaster planning and emergency policies and procedure arrangements need to be formalised and documented. All staff should have easy access to emergency contact numbers and know what to do in the event that there is an emergency or if service delivery is interrupted in any way.
S6 What systems, processes and practices are in place to protect people from unsafe use of equipment, materials and medicines?
Providers must ensure that the practice premises are fit for purpose, secure and maintained in accordance with The Health and Social Care Act 2008 Code of Practice on the prevention and control of infections and related guidance. Infection prevention and control is still high on the CQC’s priority list and practices must show good clinical governance that demonstrates that ‘essential standards’ are being met as a baseline. ‘Best practice’ action plans should be in place with justification for not meeting this standard documented if appropriate. There must be sufficient instruments and equipment to service a clinical session and allow for the decontamination process to take place.
Practices must also comply with the legislation and regulations relating to the Control of Legionella Bacteria in Water Systems – HTM 04-01. It is recommended that an external provider performs an initial risk assessment, formulates a written scheme and trains the team on Legionella management. Thereafter, providing that there have been no changes to the practice’s water systems, an internal risk assessment performed by a trained staff member is adequate. Water testing maybe necessary and water logs should be maintained to demonstrate that the system is safe.
Providers must also adhere to legislation to ensure that X-ray equipment is safe to use and is tested and serviced in line with IRMER guidance; that there are appropriate arrangements for handling, prescribing and managing medicines; that where possible safer sharps are being used (the use of traditional sharps needs to be risk assessed); and that clinical waste is handled within the realms of HTM 07-01.
Safety is vital
Demonstrating that your practice is safe and creating evidence to show this has many benefits. Patients expect that you have the skills and knowledge to deliver care but they want to see the tangible evidence that you are keeping them safe. This builds patient trust and increases their commitment to your practice. From a CQC perspective, if your practice can demonstrate safe ways of working, the inspectors are less likely to dig deeper in an inspection.
In Nicki’s next article, she explores the effective KLOE and how to demonstrate that your practice is driving constant improvement.
Use the following item in the Toolkit to put the ideas in the article into practice:
- Checklist - Staff personnel file contents
- Checklist - Obligatory audits in the dental practice
- Form – Key lines of enquiry evidence prompts audit: safety of the service (already online)
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