Harley Street Healthcare - Gray's Inn Road

Harley Street Healthcare Limited is operated by Harley Street Healthcare Limited. The service was registered by CQC on 26 March 2021. The service providers dermatology treatment and day case surgical hair transplant procedures to private patients over the age of 18. There are two methods of hair transplantation: follicular unity transplant (FUE) and follicular unit extraction (FUE). The service provided only FUE. This was provided at Gray’s Inn Road, London. The service also treated dermatology conditions such as, mole removal, cyst removals and dermatological investigations. This was provided at 96 Harley Street, London. All procedures were undertaken using local anaesthesia.

We inspected this service using our comprehensive inspection methodology. We carried out an unannounced inspection on 14 and 15 September 2021. As part of the inspection, we visited 96 Harley Street, London and Gray’s Inn Road, London.

During the inspection we visited reception areas, waiting areas, treatment rooms, consultation rooms and a decontamination room. We spoke with three senior staff members, including the registered manager, two surgeons, a receptionist and two practice managers. We did not speak with any patients at the time of inspection due to low patient activity.

You can find information about how we carry out our inspections on our website: https://www.cqc.org.uk/what-we-do/how-we-do-our-job/what-we-do-inspection.

The key questions we asked during this inspection were, was it safe, effective, responsive and well-led. As a result of this inspection, we served a notice under Section 31 of the Health and Social Care Act 2008 to suspend the registration of the service provider for an initial period of four weeks in respect of the regulated activities.

We are placing the service into special measures. Services placed in special measures will be inspected again within six months. If insufficient improvements have been made such that there remains a rating of inadequate overall or for any key question or core service, we will take action in line with our enforcement procedures to begin the process of preventing the provider from operating the service. This will lead to cancelling their registration or to varying the terms of their registration within six months if they do not improve. The service will be kept under review and, if needed, could be escalated to urgent enforcement action.

We did this because we believe that a person will or may be exposed to the risk of harm if we did not take this action.

The service is registered to provide the following regulated activities:

• Surgical Procedures
• Diagnostic and screening procedures
• Treatment of disease, disorder and injury
  

Information supplied by the service showed that the following activity was completed since registration:

• Hair transplantations: 32 per month
• Mole remove: 20 per month
• Cyst removal: 19 per month
• Consultations for dermatology: 88 per month

There has been a registered manager in post since the service registered with CQC. The registered manager was also the business owner. The service employed one chief executive officer, one chief operating officer, two practice managers, three dermatologists, three hair transplant surgeons, five hair technicians, one healthcare assistant and three patient co-ordinators.

We have not previously inspected this service.

We rated it as inadequate because:

• Staff did not follow infection control principles including the use of personal protective equipment (PPE).
• The clinic manager, with responsibility for ensuring staff had a valid DBS, was unable to clearly tell us about or show how the service checks to ensure staff have current and valid DBS certificates.
• Risk assessments were not clear or fully completed as part of everyday practice. It was unclear who carried out risk assessments and the purpose of them.
• Consent was not obtained in line with the Royal College of Surgeons (RCS) Professional Standards for Cosmetic Surgery (April 2016)
• The service was unable to show us how they assessed staff performance and identified their learning needs.
• The provider could not demonstrate to us that photographs of patients were being taken in accordance with General Data Protection Rules (GDPR).
• The policy for monitoring the deteriorating patient was not service specific and did not outline what staff should do when recognising someone was becoming unwell.
• The provider was not using the World Health Organisation (WHO) safer surgery checklist.
• The service could not demonstrate that all staff had completed mandatory training.
• The provider did not show an understanding of how to protect patients from avoidable harm or abuse.