Archived: RPM Health Clinic Warwick

On this page

• Overview
• Shared direction and culture
• Capable, compassionate and inclusive leaders
• Freedom to speak up
• Workforce equality, diversity and inclusion
• Governance, management and sustainability
• Partnerships and communities
• Learning, improvement and innovation

We assessed all quality statements in the well-led key question. This is the first inspection for this provider since their registration with CQC. This key question has been rated as requires improvement.
The provider had a clear vision and business plan for the long-term development of the service. Staff and contractors shared a positive culture and felt able to speak up if they had concerns. Leaders were visible, compassionate and accountable. The service had an open learning culture and looked for innovative ways to expand and provide services to people. However, there were gaps in governance and management systems, which prevented leaders from having oversight of information about risks, performance and outcomes. This limited opportunities to identify improvements. Systems for identifying, capturing and managing organisational risks and issues were ineffective. The service had some shortfalls in governance including a lack of clinical supervision, a lack of clinical audit and a failure to comply with some national guidelines. We found that leaders were not always able to align staff skills and competence with national guidelines. There was some partnership working but information sharing was not always effective or comprehensive.
The provider was in breach of legal regulation in relation to good governance.
 

This service scored 61 (out of 100) for this area. Find out what we look at when we assess this area and How we calculate these scores.

The provider had a shared vision, strategy and culture which leaders and staff understood and supported. This was based on transparency, equity, equality and human rights, diversity and inclusion.

The provider had inclusive leaders who mostly understood the context in which they delivered care, treatment and support and embodied the culture and values of their workforce and organisation. Leaders had suitable leadership experience but did not always appreciate the breadth and depth of governance required in the independent healthcare environment to evidence that care and treatment was safe and effective. However, when we raised issues, the provider showed a willingness to review and improve their processes.
Leaders told us that as a small business they had a large administrative workload and little administrative support. They told us, this may have contributed to certain aspects of governance such as auditing clinical outcomes not being implemented. However, they had recently recruited a personal assistant and they envisaged this would reduce the non-clinical workload in future, giving leaders more time to be able to focus on areas for improvement. The provider had also recruited specialist staff to conduct independent audits.
Leaders did not carry out regular appraisals of staff and contractors, although they did review appraisals of staff done by other services they worked for e.g. locum agencies. When we raised this lack of oversight, they told us they were assessing whether the benefit of appraisals outweighed the investment of time and money to do them.
Leaders did not demonstrate thorough and robust business planning. For example, the Warwick premises was the third location the provider had opened in 2 years, but they were no longer sure that there was sufficient demand to continue providing the services. This lack of certainty over business continuity can disadvantage people if services are removed or moved to a different location after a person has started treatment.
The provider told us that several people who had been prescribed a course of a specific medicine to treat acne had not booked their final review and that this was because they did not want to pay for an extra appointment when it would not result in any treatment. This final review was important to assess the outcome of the treatment and to provide clear advice about ongoing management for people who had been taking this medicine such as reminders about an ongoing need for a pregnancy prevention plan. Although the provider was aware that people were not booking final reviews, they had not changed their policy as a result.
We found some of the information on the providers website to be unclear. The provider was advertising a medicine for the treatment of hay fever, in contravention of an ASA and MHRA enforcement notice banning the advertisement of or any reference to the “hay fever injection.” The provider also advertised a hormone replacement service on their website. Upon further investigation, it was established that this treatment was not provided by RPM Health Clinic Warwick or the provider organisation. This was not immediately obvious to potential service users, and we discussed these concerns with the provider.
 

The provider fostered a positive culture where people and staff felt they could speak up and their voice would be heard. The service had a freedom to speak up Lead and policy and staff understood their responsibilities around speaking up.

The provider valued diversity in their workforce. They worked towards an inclusive and fair culture by improving equality and equity for people who worked for them. There were policies in place regarding bullying and harassment and equality, diversity and human rights.

The provider did not have clear systems of accountability and good governance. They did not gather information about past performance to deliver high quality, sustainable care, treatment and support. They did not always act on the best information about risk, performance and outcomes, and did not always share information securely with others when appropriate.
The provider could not demonstrate regular clinical audits across their services or routine monitoring of patient outcomes. For example, in minor skin surgery, they did not track post-operative complications like infections to compare against national averages. This lack of data limited their ability to make evidence-based improvements to their practice.
The provider did not fully understand their responsibility to audit their outcomes, to ensure that staff maintained their clinical competence or to ensure there was appropriate clinical supervision. This lack of clinical governance and oversight exposed people and staff to avoidable risks that prior to our assessment had not been fully appreciated or assessed by the provider. However, when we raised these concerns with the provider, they took action to address them.
The provider had not always assessed clinical and environmental risks adequately. For example, the provider was unaware until we highlighted the issue, that the only sink in their clinical room did not meet infection prevention and control standards. Staff were transporting clinical waste in their personal cars without using a lockable, leak-proof transport container. These issues had not been identified during the provider’s infection prevention and control audit and there were no risk assessments in place.
The provider was using an artificial intelligence (AI) based ambient voice transcription software. This software provides live transcription of a consultation by listening to the conversation between the patient and the clinician and transcribing it into the patient’s medical record. As the use of AI tools is relatively new, the tools cannot be assumed to provide a completely accurate transcript and guidance from NHS Digital requires providers to conduct thorough risk assessments before, during, and after deploying such systems. The provider did not have a risk assessment for the use of this system or any policy governing the use or oversight of it.
One staff member provided the majority of medical services at the location in Warwick and was the only member of staff within the team able to provide certain treatments. A business continuity plan was in place, but it did not address how people would be managed if this staff member was unable to work for any reason. There were no other staff qualified to take over the treatment of certain people and no process for staff to follow about to how contact and refer people appropriately to continue their treatment elsewhere. We raised this with the provider and they told us they would update the policy to include this information.
 

The provider understood their duty to collaborate and work in partnership, so services work seamlessly for people. However, they did not always share information and learning with partners. We saw that where there was a specific clinical need information was shared by the provider with people’s GP in a comprehensive and timely manner. Prior to our assessment, the provider required people to forward letters intended for their GP, creating a risk that critical information might not be received. Following our assessment, the provider implemented a more robust process by sending correspondence directly to GPs, either electronically or by post.
The provider did not have agreed clinical pathways or direct access to relevant NHS services such as dermatology that they could refer people to. This was a requirement for some of the treatments they were providing. Without an effective referral process people with complex needs or severe side effects from some medicines prescribed for acne may experience delays in being referred for the appropriate management.
 

The provider developed innovative services such as providing testosterone treatment for men with naturally low levels of the hormone. The service aspired to become a leader and training hub for this kind of treatment. Leaders encouraged creative ways of delivering equality of experience, outcome and quality of life for people. We found the provider was committed to learning and improvement. They responded to concerns we raised in a prompt and timely way. Staff and leaders understood how to embed consistent improvements, although they were not always monitoring the impact of these on the outcomes for people. There were processes to ensure that learning happened when things went wrong and from examples of good practice. Leaders reflected on feedback to improve people’s experience.