CQC to resume inspections: have you reviewed your Covid-19 practices?
Following the suspension of routine inspections as a result of the pandemic, CQC are due to resume these in September (presumably assuming there is no second virus surge of significant proportions).
Clearly an obvious area for attention will be infection prevention and control steps that have been taken by providers to address the pandemic over recent months. CQC have recently issued guidance on the information gathering tool that their inspectors will be using for this. Although targeted at care homes it will be adapted for other services.
The full guidance is available here on the CQC website and covers the following questions:
- Are all types of visitors prevented from catching and spreading infection?
- Are shielding and social distancing complied with?
- Are people admitted into the service safely?
- Does the service use PPE effectively to safeguard staff and people using services?
- Is there adequate access and take up of testing for staff and people using services?
- Does the layout of premises, use of space and hygiene practice promote safety?
- Do staff training, practices and deployment show the service can prevent and/or manage outbreaks?
- Is IPC policy up-to-date and implemented effectively to prevent and control infection?
In addition there are a series of eight mandatory questions:
- Does the service have sufficient and adequate supply of PPE that meets current demand and foreseen outbreaks?
- Are staff using PPE correctly and in accordance with current guidance?
- Has the service received external PPE training during the pandemic sourced from a Mutual Aid trainer or of similar equivalence?
- Does the service know where to go for advice should there be an outbreak – which authorities and what their role and responsibilities are?
- Is the service participating in the testing program that is currently provided for residents and staff members?
- Do staff in the service understand the principles of isolation, cohorting and zoning appropriately?
- Has the service implemented isolation, cohorting and zoning appropriately?
- Has the service adequately taken measures to protect clinically vulnerable groups and those at higher risk because of their protected characteristics (BAME, physical and learning disabilities)?
Providers could usefully be taking the time now to collate their answers to these questions in readiness for inspections. Even if your service is not inspected in the near future, taking steps to consider these issues now shows both good governance and risk management. It should also of course put you in the best place to address any second surge.
This briefing is for guidance purposes only. RadcliffesLeBrasseur LLP accepts no responsibility or liability whatsoever for any action taken or not taken in relation to this note and recommends that appropriate legal advice be taken having regard to a client's own particular circumstances.