The Health and Social Care Act 2008 Regulated Activities Regulations 2014 introduced a new emphasis for health and social care providers. The emphasis is centred on 11 fundamental Regulations that are inspected under 5 Key Lines of Enquiry (KLOE). The 5 KLOE ask is the service:
Inspection will focus on records, documents, interviews and other evidence that prove the company is operating effectively in each of the KLOE domains. Remember – inspection is evidence based and this is used to either confirm that the company is operating compliantly OR that the company is non-frame compliant.
Each KLOE will be marked either Outstanding, Good, Improvement Required or Inadequate. The overall rating will rest with what grade has been given in each of the 5 areas with Safe and Well Led taking a prime role in this.
Check the CQC website and have a look at companies who provide a similar service to your own and read their overall ratings. Where they have been rated – you will see from the reports as to where they have succeeded and where they have failed. Apply this to your own service.
1 – First Impressions – The Building
Think of how your service gives an impression to an Inspector.
- As they approach the building or enter your offices – what impression does it give?
- Is there a mal odour?
- Are there overflowing bins? Is there rubbish in the garden? Is there an impression of neglect?
TIP 2 – First Impressions – The Staff On Duty
- When the Inspector makes an unannounced inspection – are the Staff prepared to greet them politely?
- Do the Staff understand they have a part to play in being able to show the Inspector to a room and sign the Visitors Book?
- Know who is Shift Leader and how to contact the Registered Manager.
- Be able to show the Inspector records without being unduly nervous?
- Be able to answer questions like ‘What is Whistle-blowing or What would you do if you suspect a safeguarding issue?’
- Know where the Safeguarding Policies and other Policies are. Answer the questions -when did you last receive supervision or when did you last have a full fire drill?
These are just samples but other questions can be about things like their interview, induction and training.
TIP 3 – Availability And Quality Of Records And Documents
Records must be readily available. An audit of the type of records that will be required should be made. These must be well presented – digital records should be easy to access with Staff able to show the Inspector the records required.
Records must be up to date – documents must be signed and dated. NO LOOSE ENDS!
TIP 4 – Staff
Staff should present as smart in appearance, knowledgeable, using protective clothing, using hygienic procedures and wearing their uniform and ID badge (if appropriate). Staff will be observed in the way they interact with the Tenants/Service Users – how they speak to them and treat them in general. Members of Staff will be interviewed – see Step 3.
Senior Staff will be tested on their knowledge in order to judge if the service is well led. The number of Staff on the duty roster will be checked against the Care Plans.
Tip 5 – Service Users/Tenants
Service Users/Tenants will be observed and interviewed.
- Questions will focus on the choices they have and how much they are involved with their care provision?
- Other questions will surround the information they are provided with i.e. – do they know what has been agreed in their Care Plan?
- Do they know how to complain and who to complain to?
- How do the Staff treat them?
The relatives or representatives of the Service Users/Tenants may also be contacted or interviewed if they are visiting at the time of the inspection.
TIP 6 – Is The Service Safe? KLOE
This decision will be based on the examination of the Safeguarding Policies, Accident and Incident records, Risk Assessments (are they relevant and do they set out the steps taken to control the risk or eliminate them). Staff records :
- Are there at least 2 references and at least one from the last employer?
- Does the work history have any gaps and are they accounted for?
- If a person has a criminal record and you decide to employ them – is there a judgement framework to show that it has been risk assessed?
- Medication – are the MAR examined for gaps, errors and alterations and are they properly signed?
- Are the drugs locked in a suitable cupboard or trolley?
- Are drugs kept at a suitable temperature?
- Do the drugs tally with what has been taken and what remains?
- Are Controlled Drugs kept in a separate locked cabinet and what are the arrangements to administer them?
- Are there satisfactory arrangements for storing and returning unwanted drugs?
- Care Plans – are they personalised?
- Are they updated at suitable intervals?
- Do they contain sufficient information?
Assessments including Initial Assessments will be examined.
TIP 7 – Is The Service Effective? KLOE
A training matrix or chart will be required.
- Details of induction will be checked to see if it is sufficient for the role being carried out (is induction carried out according to the Care Certificate 2014?). If the company uses E learning – is there a method to check knowledge?
- Supervision of Staff – is this carried out every 4 to 6 weeks?
- Are samples of the current Staff Roster available?
- Are there policies that include Mental Capacity Act 2005 and Deprivation of Liberty?
- Are Staff knowledgeable on this subject?
- Menu planning. Are menus put together with the preferences, dietary, religious and cultural needs?
- Is there proof of this?
- Does the person preparing the food have information regarding this and how is it conveyed to them?
- What is the recording process for logging what each person has eaten and (if important for health) how much they have eaten each day?
- Is there input from healthcare professionals – is this included in the notes and care plans?
TIP 8 – Is The Service Caring? KLOE
- Minutes of meetings held for the people including their relatives and representatives?
- Do the minutes include their input?
- Are there quality surveys carried out with people, their representatives, Staff and professionals?
- Are the outcomes analysed and included in an annual audit with information as to how the service has improved as a result of the people’s input?
TIP 9 – Is The Service Responsive? KLOE
- Are pre-admission assessments comprehensive?
- Are there Specialist assessments e/g forensic support/mental health input?
- Complaints – are they kept in a file with a front log for east of analysis?
- Is each complaint properly investigated against the Complaints Policy and within the set time-frame and do the records show how it was resolved or the action taken and by whom?
- Records must be signed and dated. What emergency or out of hours support is there?
TIP 10 – Is The Service Well Led? KLOE
- Is there a quality assurance programme that includes an annual overview of the information taken from the various areas in order to produce an outcome on the performance of the service as a whole?
- Is there an external body carrying out checks/audits on the service and are their reports available?
- Is there a Development Plan for the service for the next 12 months stating what developments or improvements are planned?