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CQC corporate bodies to have such formal systems , but smaller services often have less formal ways of overseeing their work , which can be just as effective , but harder to evidence to the inspector .
Pleased with your CQC inspection or bruised by the experience ? David Finney gives you the key issues
The first phase of inspections of substance misuse services by the CQC Hospital Directorate is now complete and all reports published . The experience of providers under this new regime has been varied : some received accolades , while others with previously excellent ratings have been severely criticised . Some services have even closed as a result of the new approach .
Sometimes CQC have ‘ requested ’ that providers temporarily suspend admissions while changes are made . This has been serious where there is a quick turnover of residents ( in detox , for example ) and numbers in treatment quickly reduce . Problems have also arisen when commissioners have been informed of negative comments in an inspection report , which has led to admissions being suspended or reduced .
CQC have already published the ‘ key lines of enquiry ’, used by inspectors , but many inspection judgements seem to be have been made according to additional criteria , such as NICE guidelines , extra guidance issued by CQC or simply the interpretation of regulations by the inspector .
Therefore , providers often ask me : are inspectors looking for services that replicate the NHS , or do they appreciate the distinctiveness of residential rehabilitation services , or the informality and reach of community-based services ?
So , let us consider some of the issues attracting inspectors ’ attention :
1 . The Mental Capacity Act . CQC expect that all staff have some awareness of what this act means for their service . Staff training is important , but staff also need to know what to do if someone lacks capacity while in the service , and how to assess for capacity in the first place .
2 . Governance . CQC seem to increasingly expect an NHS-like system of accountability , where matters such as incident management , safeguarding , service user outcomes , key performance indicators etc are formally monitored ; improvements made and risk registers produced . It is reasonable to expect
3 . Ligature risks . A focus on this topic springs from the mental health background of the CQC directorate inspecting substance misuse services . To my knowledge , there have been very few incidents of suicide risk in residential services , but now services are being expected to thoroughly examine their environment for ligature risks . CQC provide separate guidance about this issue on their website .
4 . Clinical issues . These have been many and varied , but inspectors have often focused on assessment tools such as SADQ and CIWa for alcohol dependence and withdrawal , and other tests for drug dependence such as SDS . They often comment on the use of emergency medication such naloxone and rescue medication for seizures . NICE guidelines figure highly in CQC inspection reports , whereas they are only mentioned in passing in the ‘ key lines of enquiry ’. There is also an expectation that providers have a multi-disciplinary team ( MDT ) in place ; smaller services who are not equipped with an array of professionals on their staff team may have some difficulty explaining how they provide this .
5 . Care Issues . These have included a wide range of subjects , from a lack of thoroughness in initial comprehensive assessments and seemingly low involvement of clients in their care planning , to the lack of privacy in shared rooms and the new topic of a requirement for same-sex accommodation ( which seems to reflect concerns about mixed wards in the NHS ).
6 . Statutory notifications . There has been controversy over which deaths to report , especially in community services where service users may have infrequent contact with drug and alcohol workers . Exactly what qualifies as a death ‘ while receiving a service ’ is clearly up for debate with CQC . Other events , such as when police are involved or when a serious injury occurs , are also classed as ‘ notifiable incidents ’ by CQC , which providers can easily overlook . As it is a statutory requirement to make these notifications , CQC will deem any omission to do so as a ‘ breach of regulation ’, which has serious implications in terms of enforcement action .
These are just some of the issues causing concern and setbacks for substance misuse services – as if the funding crisis suffered by many services were not enough to dampen spirits . The CQC Hospital Directorate has certainly been making its presence felt during this round of inspections ; so what of the future ?
There is no public indication of when CQC will introduce ratings for the substance misuse sector , and the most recent consultation about CQC methodology amalgamated all the criteria into a generalised document that said very little about substance misuse services at all . Should providers just wait and hope for the best until we find out what CQC will do next – or is it better to actively prepare for the next round of inspections in the light of what we know already ?
David Finney is an independent social care consultant who has been involved in the inspection of substance misuse services for 21 years , most of the time working for government inspection bodies . He is planning a training event to address these issues on 10 July .
14 | drinkanddrugsnews | May 2017 www . drinkanddrugsnews . com