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Emergency support framework: discussion questions for independent services for people with a learning disability and/or autism

Categories:
  • Organisations we regulate

The conversation with your inspector will focus on four areas. The questions are for the inspector to answer, helped by the discussion prompts. This helps us to understand how you are managing currently and whether you need support with anything. Your inspector may not need to cover all the questions as things may already be clear, so you don’t need to spend time preparing for them.

1. Safe care and treatment

1.1 Are infection risks to people using the service being thoroughly assessed and managed?
  • How effective are infection prevention and control arrangements? How are routine processes and escalations working?
  • Have the arrangements been reviewed and amended in response to the pandemic?
  • What arrangements does the provider have in place to support it to keep up to date with current infection prevention and control (IPC) guidance?
  • How are changes in guidance and processes being communicated to staff, and any necessary training provided?
  • What contingency plans are in place if arrangements fail?
  • How is the provider safely handling specimens and disposal of waste?
  • How is IPC managed during restraint?
  • How is IPC managed in seclusion or segregation?
1.2 Does the service have the resources to obtain, and have reliable access to, all the supplies, personal protective equipment and COVID-19 testing it needs, for both staff and people who use the service?
  • Was appropriate equipment, by patient group, available for COVID-19 and non-COVID-19 areas?
  • What assurances does the provider have that staff were sufficiently skilled to use equipment in COVID-19 and non-COVID-19 areas?
  • What is the provider’s current level of risk in relation to access to equipment, including personal protective equipment (PPE)?
  • What arrangements does the provider have in place to access PPE and does it know who to contact if it requires additional support?
1.3 Does the location’s environment and layout support preventing and containing transmission of infection?
  • Has the provider identified any risks within its environment in relation to managing COVID-19?
  • How has the provider managed these risks?
  • What changes has the provider made to the layout/environment in response to COVID-19? (For example, becoming a hot site, alternative use of premises, additional signage, etc)
  • How are patients managed in the waiting, communal, and shared sleeping areas if there is a mixture of COVID-19 and non-COVID-19 patients?
  • How does the provider assure itself that COVID-19 and non-COVID-19 patients, staff and visitors were routed safely through the hospital/service to prevent cross-contamination?
1.4 Are working arrangements and procedures clear and accessible to staff, people who use the service, their supporters, and visitors to the service?
  • How is the provider managing access to the service to ensure that high-risk patients are being identified and prioritised?
  • How is the provider supporting identified ‘high risk’ patients?
  • Are patients tested to determine their COVID-19 status, and segregated and streamed through the hospital appropriately?
  • Where the provider has made changes to how it operates to manage COVID-19 and non-COVID-19 patients:
    • Is this clearly communicated to patients?
    • How does the provider ensure staff are aware of these changes?
    • How has the provider taken into consideration vulnerable people and those with communication requirements, for example accessible information?
  • What changes has the provider made to facilitate/improve access to its services in response to COVID-19, for example telephone assessments, video or online consultations? How is the provider meeting the needs of patients who:
    • do not speak English?
    • do not have access to a computer, smart phone, tablet or telephone?
  • How does the provider ensure that patients have access to leave, including S17 leave/therapeutic activities/visits from relatives/advocacy input?
  • How is the provider ensuring that people on waiting lists to access services are kept safe? How is the provider communicating with people on waiting lists so they are aware of current service delivery situations?
1.5 Are medicines being managed safely and effectively?
  • Has COVID-19 affected the provider’s ability to manage medicines?
  • What steps have been, and are being taken, to ensure adequate and ongoing supplies of medicines are maintained? If the provider usually has a clinical pharmacy service, has this been maintained?
  • Have medicine support care plans been updated to include the risks presented by COVID-19? Does this include monitoring of the appropriate use of medicine to control patients’ behaviour?
  • How is the provider monitoring and addressing patients’ physical health conditions without support from community or acute based services? (INR monitoring, diabetic insulin, respiratory and cardiac).
  • What steps have been taken to ensure infection prevention and control is maintained when handling, administering, and transferring medicines and associated paperwork?
  • What steps have been taken to track and action incidents related to medicines during COVID19 pandemic?

Also consider (where relevant to the service and previous answer):

  • For patients routinely prescribed treatment through hospital specialist appointments, either remotely or through repeat prescribing, how are these medicines now obtained to ensure continuity of treatment, for example Clozapine, antipsychotic depots, lithium, methylphenidate?
  • What system blocks has the provider experienced/is experiencing (including legislation and guidance blocks), which have affected managing medicines?
  • Does the provider have a system for collecting feedback from patients/advocates around medicines issues, and what actions has it completed as a result? Were alternative forms of administrating medicines considered to reduce risk? Did this include patients’ own views?
1.6 Are risks to the health and wellbeing of people using the service being properly assessed, monitored and managed?
  • Are there systems in place to manage and review existing risks?
  • Has the provider taken action in response to new and emerging risks, including but not limited to those posed by COVID-19?
  • What are the provider’s identified COVID-19 related risks? What measures is the provider taking to mitigate them? Are these listed on the provider’s risk register?
  • Have there been any significant events related to COVID-19, including deaths? If yes, how is learning from these being identified and shared? Have any deaths been notified to CQC?
  • Is there a protocol for testing of suspected cases and communication around the COVID-19 status of patients transferring to the hospital from acute settings?
  • Was the provider managing risk in immuno-suppressed patients?
  • Was the provider maintaining effective escalation protocols, such as NEWS2?
  • Were all patients requiring discussion at MDT discussed and decisions recorded? (Note new MDT streamlining guidance - complex patients must be discussed)

2. Staffing arrangements

2.1 Are there sufficient numbers of suitable staff to provide safe care and treatment in a dignified and respectful way?
  • Has the pandemic affected the provider’s ability to staff the service?
  • Has the provider been able to make sure that people get care and support from workers with the right knowledge and skills, including MDT input (OT, physiotherapy, speech and language therapy)?
  • On general learning disability and autism wards, have staff had suitable training to meet their needs?
  • How is the provider supporting staff to deliver services where there have been significant changes to staffing arrangements?
  • If agency/bank staff were used, how did the provider ensure the right skill mix to deliver safe care and treatment to meet a range of patients’ needs (for example restraint, learning disability, autism, older people)?
  • How is the provider making sure that new staff and any volunteers are suitably qualified?
  • Are there reasonable induction arrangements for new staff and volunteers?
  • Are staff still able to work in a way that respects and maintains people’s dignity?
  • Has the provider made changes to recruitment and training processes in response to COVID-19, in line with relevant national guidance?
2.2 Are there realistic and workable plans for managing staffing levels if the pandemic or other causes lead to shortfalls and emergencies?
  • How has the pandemic affected the provider’s ability to staff the service? 
    • What has this meant for patients who use the provider’s services?
    • What has the provider done to mitigate any impact on staffing levels?
    • Where does the provider go to seek support?
  • Has the provider been able to engage with local system arrangements to share staff where required?

3. Protection from abuse and protection of human rights

3.1 Are people using the service being protected from abuse, neglect and discrimination and loss of their human rights?
  • Has the pandemic affected the provider’s ability to protect people?
  • Are people’s human rights being recognised and respected?
  • How is the provider avoiding unnecessary restrictions, for example blanket approaches, visiting?
  • How is the provider using the Mental Capacity Act to manage restrictions that might deprive people of their liberty? (Note: not just relating to managing COVID-19)
  • Has the provider encountered any issues that may affect equality for their patients, or affect their patients’ human rights?
  • Does the provider have anyone in long-term segregation or anyone who is frequently needing to be secluded due to distressed behaviours?
  • How is the provider ensuring that patients’ and carers’ views of care and treatment are listened to during the pandemic?
  • How is the provider supporting people to stay in contact with their families and friends?
  • Were patients and carers involved, where appropriate, in decisions about service, and given opportunity to feed back on the service received?

Also consider (where relevant):

  • Does the provider have access to, and are they following, guidelines around Treatment Escalation Plans (TEPs), anticipatory care planning, Do Not Attempt Cardio-pulmonary Resuscitation (DNACPR) orders and individualised care plans?
3.2 Are the service’s safeguarding and other policies and practice, together with local systems, properly managing any concerns about abuse and protecting people’s human rights?
  • Have safeguarding arrangements and systems in the provider’s locality remained effective (for example response time to safeguarding, speak up, advocacy)?
  • Has the provider identified any risks relating to its management of safeguarding issues, for example barrier to information-sharing with relevant stakeholders such as local authority?
  • How has the provider mitigated these risks?
  • What systems are in place to identify vulnerable patients during the pandemic, for example elderly isolated patients, domestic abuse victims?

4. Assurance processes, quality monitoring and business risk management

4.1 Is the provider monitoring and protecting the health, safety and wellbeing of staff?
  • How is the provider supporting and protecting the health and safety of staff during this period?
  • Are staff being adequately risk-assessed and placed in appropriate environments to protect their health and safety, including BAME staff?
  • How is the provider managing staffing issues such as sickness and caring/childcare responsibilities?
  • What changes has the provider made to ways of working to support its staff and ensure their safety, for example remote working solutions?
  • Is debriefing being used effectively and are staff being provided with appropriate access to emotional support, for example counselling?
4.2 Does the provider have effective systems and methods for monitoring the overall quality of the service and for responding to business risks and issues as they arise?
  • Has the pandemic affected the provider’s ability to monitor the overall quality of care?
  • How is the provider keeping up to date with relevant standards and guidance relating to the delivery of care and treatment?
  • Has the provider been able to develop effective contingency plans relating to COVID-19?
  • How are ‘business as usual’ processes and systems being managed, for example seven-day follow-ups, waiting lists?
  • How are Mental Health Act safeguards being managed, for example tribunals, associate manager reviews, independent reviews?
4.3 Is the provider supporting staff and people who use the service to raise any concerns and give feedback?
  • Has the provider made any changes to the way staff are able to speak up and raise concerns?
  • Is the provider still able to have team meetings?
4.4 Is care and treatment provided to people being properly recorded?
  • Is the provider experiencing any barriers to sharing or accessing patient information with other providers, for example to support transfers?
4.5 Is the provider able to work effectively with system partners when care and treatment is being commissioned, shared or transferred?
  • Is the provider able to effectively manage discharges and ensure safe transfers of care? Is planning and partnership working effective?
  • How is the provider ensuring it is meeting the physical health needs of patients, including access to primary health care and acute hospital treatment, where required?
  • Have providers been identified for expanding capacity and brought into the local system?
  • How is information being shared where regulated activities happen across different locations? For example, where staff are working in designated hot sites in the locality and where patient record systems differ?
  • How is the provider working in the local area, and sharing information with other services and/or providers?
  • How is the provider working with external partners and/or stakeholders on service recovery plans?

Data indicators we will use to prioritise assessments

Your inspector will use their knowledge of your service and will look at some specific indicators for the data that we hold to help decide what risk you may be facing.

The information we use will evolve as the situation changes, moving from this initial focus on what we know about services from existing data, to a focus on COVID-related priorities and recovery plans.

Data indicators for independent services for people with a learning disability or autism:

  • Time since most recent rating published
  • Never been inspected
  • No registered manager in place
  • New complaints recorded in last 12 months
  • Qualified whistleblower reports received in last 12 months
  • Serious Injury notifications received in last 12 months
  • Unexpected Death notifications received in last 12 months
  • Safeguarding notifications received in last 12 months
  • Police Incident notifications received in last 12 months
  • Events that Stop Service notifications received in last 12 months
  • Abuse or Allegation notifications received in last 12 months
  • MHA Death in Detention notifications received in last 12 months
  • MHA Unauthorised Absence notifications received in last 12 months
  • Admission of a child to adult psychiatric unit notifications received in last 12 months
Last updated:
01 July 2020