132 Harley Street Limited

This service is rated as Requires improvement overall. (Previous inspection August 2013 unrated).

The key questions are rated as:

Are services safe? – Requires improvement

Are services effective? – Requires improvement

Are services caring? – Good

Are services responsive? – Good

Are services well-led? – Requires improvement

We carried out an announced comprehensive inspection at 132 Harley Street Limited as part of our inspection programme, to check whether the service was meeting the legal requirements and regulations associated with the Health and Social Care Act 2008. This was a first rated inspection for the service that was registered with the Care Quality Commission (CQC) in August 2020. During this inspection we inspected the safe, effective, caring, responsive and well-led key questions.

The service was previously inspected in August 2013, and we found it was providing care in accordance with the relevant regulations. At the time of inspecting this service in 2013, CQC did not have the statutory powers to rate the service.

This service is registered with CQC under the Health and Social Care Act 2008 in respect of some, but not all, of the services it provides. There are some exemptions from regulation by CQC which relate to particular types of regulated activities and services and these are set out in Schedule 1 and Schedule 2 of The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.

The service manager is the registered manager. A registered manager is a person who is registered with the Care Quality Commission to manage the service. Like registered providers, they are ‘registered persons’. Registered persons have legal responsibility for meeting the requirements in the Health and Social Care Act 2008 and associated Regulations about how the service is run.

Our key findings were:

• There were some internal risk assessment processes, but these did not always function well and were inconsistent in their implementation and impact.
• There was evidence some safety risks were assessed however, this was not always well-managed; the service did not have an effective system of health and safety checks. For example, there was no evidence of control measures to identify risks from exposure to Legionella.
• There were safe procedures for managing medical emergencies including access to emergency medicines and equipment.
• The service did not manage medicines appropriately. For example, prescription stationery was not always stored securely, in line with recommendations.
• Records were written and managed in a way that keep people safe. Staff helped patients to be involved in decisions about their care and treatment.
• Patients were treated with kindness, respect and compassion. Feedback from patients was positive about the way staff treat people.
• The service had a complaint policy and procedures in place. We found that complaints were dealt with in a timely manner and with openness and transparency.
• The provider had quality improvement processes in place. We saw staff had completed audits to monitor quality and improve outcomes for patients.
• Staff whose files we reviewed had not completed all essential training at an appropriate level.
• The processes for providing all staff at every level with the development they need, required improvement. Some staff had not received an annual appraisal in the last year. There was no effective system of documenting staff appraisals.
• Staff involved and treated people with compassion, kindness, dignity and respect.
• Patients could access care and treatment from the service within an appropriate timescale for their needs.
• Staff said that they felt happy to raise concerns or issues to the provider.
• The way the practice was led and managed promoted the delivery of high-quality, person-centre care. However, the governance arrangements in place were not effective, there were some areas where control measures had been put in place to manage risk, but leaders did not have oversight.

The areas where the provider must make improvements as they are in breach of regulations are:

• Ensure care and treatment is provided in a safe way to patients
• Establish effective systems and processes to ensure good governance in accordance with the fundamental standards of care.

We spoke to the provider about the concerns identified and the risk to people’s safety and wellbeing. Under Regulation 17(3)(a)(b) of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, we asked the provider to send us a report on actions they planned to take to meet the associated HSCA regulations. The impact of our concerns is minor for patients using the service, in terms of the quality and safety of clinical care. The likelihood of this occurring in the future is low once it has been put right.

We have told the provider to take action (see specific details of this action in the Requirement Notices at the end of this report).

The areas where the provider should make improvements are:

• Improve the facilities in place for people with visual and hearing impairments.
• Establish protocols for verifying the identity of patients.
• Take action to review the appraisal policy to ensure all staff have an annual appraisal.

Dr Sean O’Kelly BSc MB ChB MSc DCH FRCA

Chief Inspector of Health Care